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<br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />otoi21~ <br /> <br />estimate did not account for these additional costs despite the fact that application <br />of the ISDEA was mandated in the 1988 Settlement Act and the Tribes made it <br />very clear in the negotiations over the 2000 Amendments that application of the <br />ISDEA was part of the total settlement. Additionally, the lack of a cost ceiling for <br />ALP has caused confusion and made it more difficult to determine the true impact <br />of the ISDEA on the project.8 While the 2003 PCE includes a $43 million <br />estimate because of the application of the ISDEA, the true costs could be less. <br /> <br />F. Organization and Procedures within Reclamation Associated with <br />Management of the Project <br /> <br />The review looked at factors within Reclamation's organization and application of <br />its procedures from January 1999 to July 2003 during completion of National <br />Environmental Policy Act compliance, Project authorization, and initial <br />construction activities on the Project. The intent was to determine whether the <br />necessary procedures were in place and followed in development and review of <br />cost estimates. <br /> <br />In the early 1990's, Reclamation was reorganized to give Area Offices greater <br />autonomy to perform design work and manage construction. In addition, all <br />Reclamation Instructions, including those related to design and construction, were <br />sunset and new guidance developed on a case-by-case basis. Additional guidance <br />in the Reclamation Manual for performing design and construction activities was <br />released in February and September 2000, respectively. <br /> <br />In the case of the Project, WCAO's Durango Field Office had greater <br />responsibility for project design, eliminating much of the TSC's oversight role. <br />Prior to the reorganization, the Denver Office had a much stronger role in <br />oversight of design and construction management. Today, the TSC provides <br />services to Reclamation's field offices at their request. <br /> <br />The Durango Field Office did request a TSC review of the 1999 PCE prepared by <br />the Ute Mountain Ute Tribe contractor in November 1999. The TSC indicated the <br />1999 PCE lacked sufficient detail to complete a full review. This comment also <br />was provided by Durango Field Office staff to the team preparing the DSEIS. <br />However, evidence of follow up by Reclamation staff beyond that point was not <br />found during this review, and the cost estimate subsequently finalized by the <br />Tribes contractor was included in Appendix E of Reclamation' s 2000 FSEIS. The <br />Project Management Team and Project Construction Committee established by <br />Reclamation in 2001 were intended to provide a way to assure that necessary <br />internal and external coordination and management of the Project occurred <br />respectively during construction. <br /> <br />8 Most Departmental construction projects have a congressionally authorized cost ceiling. Having <br />a ceiling helps maintain project costs by providing a clear delineation on the total amount that may <br />be spent on the project. <br /> <br />11 <br />