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Colorado
Wildlife Federation
Conservation Federation of Missouri
Iowa Wildlife Federation
Kansas Wildlife Federation
Montana Wildlife Federation
National Wildlife Federation
Nebraska Wildlife Federation
North Dakota Wildlife Federation
South Dakota Wildlife Federation
February 28, 2002
Brig. General David Fastabend, Commander
U.S. Army Corps of Engineers, Northwestern Division
12565 West Center Road
Omaha, NE 68144-3869
RE: Revised Draft Environmental Impact Statement (RDEIS)
for the Missouri River Master Water Control Manual (August
2001).
Dear General Fastabend:
The National Wildlife Federation (NWF), and its state
affiliates in the Missouri River basin (Colorado Wildlife
Federation (CWF), Conservation Federation of Missouri
(CFM), Iowa Wildlife Federation (IWF), Kansas Wildlife
Federation (KWF), Montana Wildlife Federation (MWF),
Nebraska Wildlife Federation (NEWF), North Dakota Wildlife
Federation (NDWF), and South Dakota Wildlife Federation
(SDWF)) submit these comments to the U.S. Army Corps
of Engineers (Corps) on the Revised Draft Environmental
Impact Statement (RDEIS) for the Missouri River Master
Water Control Manual (Master Manual) (August 2001).
Our wildlife organizations urge the Corps to select
the alternative that provides maximum benefits to fish
and wildlife resources as the preferred alternative
in the Final Environmental Impact Statement. For the
reasons discussed below, the Corps should revise the
Master Manual to implement the flexible flow alternative,
GP2021, which would provide the widest range of higher
spring flows and lower summer flows below the Gavins
Point Dam among the alternatives presented.
NWF is the nation’s largest conservation education
organization, with over 4.2 million members and supporters,
and affiliates in 47 states and territories. CWF is
the oldest conservation organization in Colorado, and
its 5,000 members are united in their desire to protect
wildlife habitat, to support sound principles of wildlife
management, to enhance outdoor resources, and to cherish
the natural beauty that the world associates with Colorado.
CFM is the largest and most representative conservation
group in the state of Missouri and has 70 clubs and
30,000 members. IWF is a statewide organization that
is dedicated to promoting the interests of natural resources
conservation in Iowa. One of the oldest state-wide conservation
organizations in Nebraska, NEWF supports common sense
conservation solutions to natural resource issues. KWF
represents 2,000 members and works to inspire and empower
individuals and organizations to take action to conserve
natural resources, and to nourish an ethic of stewardship
and enjoyment of our natural world. Founded in 1935
by conservationists, landowners, hunters, and anglers,
MWF is Montana’s oldest, largest and most effective
conservation organization. NDWF represents more than
1,000 members and works to preserve the wildlife in
North Dakota and in North America. Finally, SDWF has
nearly 4,000 members and represents the interests of
all South Dakotans in wildlife, outdoor recreation,
natural resources and a quality environment.
As documented by the National Academy of Sciences National
Research Council’s January 2002 report, The
Missouri River Ecosystem: Exploring the Prospects for
Recovery (Missouri River Ecosystem), the Missouri
River was a dynamic system that sustained incredibly
rich biological diversity and production before the
human activity of the twentieth century changed it.
Efforts to improve navigation and protect against floods
have significantly degraded the Missouri River as a
resource for fish and wildlife. In its recent report,
Troubled Waters, NWF together with Taxpayers
for Common Sense, identified Missouri River navigation
as among the most financially wasteful and environmentally
damaging water resource projects in the nation. The
Corps must modify the way the Missouri River is managed
in order to restore and protect the river’s ecosystem.
The resources at stake are of critical importance to
many members of our wildlife organizations, who live
near, use and enjoy the Missouri River’s resources.
1. Introduction
Revisions to the Master Manual and the Corps’
management and operation of the six mainstem dams ought
to be the first steps in an effort to recover the lost
biological diversity in the overall Missouri River system.
The Missouri River, which served as the major thoroughfare
for the eastern half of Lewis and Clark’s Expedition,
has played an incredibly significant role in America’s
development. It supports critical forest and aquatic
habitat for hundreds of different species of fish and
wildlife. The Missouri River is also one of America’s
most highly engineered river systems. Areas that fish
and wildlife need to feed, reproduce and conserve energy
have been eliminated. Stable flows from March through
November have replaced the river’s natural pattern
of high flows in the spring and low flows in the summer.
Findings and conclusions in the National Academy of
Sciences’ Missouri River Ecosystem report
provides significant evidence that returning the Missouri
River to a more natural state can put the river on a
path of ecosystem restoration. In addition, significant
questions remain about whether the Missouri River should
continue to be managed to provide for commercial navigation.
Any further delays to revising the Master Manual would
be a mistake. Sufficient data exists to support the
selection of a preferred alternative that involves changes
to the Gavins Point Dam releases. Changing the mainstem
dam operations to include a spring rise and low summer
flows will substantially reduce the adverse impacts
of the current operations on native fish and wildlife,
and their habitat. While the GP2021 option is not the
best alternative for native fish and wildlife and their
habitat, it represents a compromise with other river
interests that provides the maximum benefits for fish
and wildlife as compared with any of the other alternatives
identified in the RDEIS. In the Final Environmental
Impact Statement, however, the Corps must identify an
alternative that truly represents the best alternative
for fish and wildlife, and their ecosystem. Failure
to do so would make the GP2021 option appear as a position
from where compromise begins. The truth is, GP2021 is
where the compromises must end. Our wildlife organizations
support GP2021 because we do not wish to see the current
process prolonged unnecessarily, but urge the Corps
to identify an alternative that would maximize benefits
to native fish and wildlife, and their habitat.
The Corps must also look beyond the current Master
Manual revisions and continue to monitor and evaluate
the health of the Missouri River ecosystem through adaptive
management. The Corps must work with the U.S. Fish and
Wildlife Service to implement the Missouri River Biological
Opinion, as well as a recovery action plan, like the
one described by the National Academy of Sciences (NAS,
Missouri River Ecosystem at 109-118). We urge
the Corps not only to proceed with updating the Master
Manual to provide maximum benefits to fish and wildlife
and to implement beneficial actions immediately, but
also to proceed with a comprehensive review of the entire
river system that would include completing ongoing studies,
identifying additional information needs, and monitoring
fish and wildlife habitat and their responses to new
conditions.
II. The Corps Must Adopt the GP2021 Option
as the Preferred Alternative
Over the past century, the Corps has engineered the
Missouri River and controlled the Mainstem Reservoir
System to serve multiple purposes, including navigation,
flood control, hydropower, water supply and irrigation,
water quality, recreation, and fish and wildlife habitat
– but only to the extent fish and wildlife do
not interfere with the other purposes. (NAS, Missouri
River Ecosystem at 34). Fish and wildlife habitat
have been relegated to the lowest priority in terms
of the system’s management and operation. As the
National Academy of Sciences notes, as a result of regulating
the Missouri:
the production and the diversity of the ecosystem
have both markedly declined. . . . The habitat through
a typical cross-section of the post-regulation Missouri
(in the non-submerged portions) has been greatly simplified.
Side channels and backwater areas have been greatly
reduced, thereby eliminating important habitat for
many species of fishes, birds and game. The water,
sediment, and nutrients previously spread across the
floodplain by overbank flows and the meandering river
are now primarily restricted to the main channel or
contained in the system’s reservoirs. These
changes, combined with other human activities in floodplain
areas, have produced an ecologically impoverished
ecosystem. (NAS, Missouri River
Ecosystem at 55 (emphasis added) (internal citations
omitted)).
The symptoms of this sick system include three species
native to the Missouri River that are on their way
to extinction because their habitat is disappearing.
The Corps must firmly and aggressively address the
needs of the interior least tern, piping plover and
pallid sturgeon, and adopt a preferred alternative
that will give these species the best chance of recovery,
and that will maximize benefits to other native fish
and wildlife and their habitat. A conservative approach
to species recovery is not acceptable because underestimating
the real needs of the least tern, piping plover and
pallid sturgeon could be an error the Corps cannot
reverse. Providing these species the best chance of
recovery will lay a solid foundation for addressing
many of the river’s other ailments. The Corps
must adopt the GP2021 option because: (1) it gives
the federally listed species the best hope for recovery
over any other identified alternative, and is the
best option identified for other native fish and wildlife,
and the ecosystem upon which they depend, and (2)
it no longer makes sense to manage the river to benefit
other purposes at the expense of fish and wildlife.
In addition, the Corps must revise the Final Environmental
Impact Statement to identify an alternative that provides
maximum fish and wildlife benefits and clarify its
analysis of the selected alternatives.
A. The GP2021 Option Provides the Best Hope
for Recovering Federally Listed Species, and Is the
Best Option Available for Other Native Fish and Wildlife
and the Ecosystem Upon Which They Depend.
Among the alternatives presented and discussed in
the RDEIS, GP2021 represents the best option for native
fish and wildlife, and the ecosystem upon which they
depend, and should be selected as the preferred alternative
in the Final Environmental Impact Statement.
1. USFWS Reasonable and Prudent Alternative
Requires Modifying Operation of the Gavins Point
Dam to Provide a Spring Rise and Split Low Summer
Flows.
As part of the Endangered Species Act (ESA) Section
7 consultation process, the U.S. Fish and Wildlife
Service (USFWS) completed an ecosystem-based Biological
Opinion (BiOp) regarding the Corps’ Missouri
River projects, which includes operation of the
Missouri River Mainstem Reservoir System. The USFWS
concluded that if the Corps continues current operations
of the Mainstem Reservoir System, the continued
existence of the interior least tern, piping plover,
and pallid sturgeon will be in jeopardy. Our wildlife
organizations agree with the USFWS that “the
Corps should make conservation of federally listed
endangered and threatened species, and the ecosystem
upon which they depend, a priority objective
in future operations.” (USFWS BiOp at 230
(emphasis added)).
The BiOp describes a “reasonable and prudent
alternative” (RPA) that the Corps could implement
consistent with the project purposes to avoid jeopardizing
the continued existence of the least tern, piping
plover and pallid sturgeon. (USFWS BiOp at 234).
The key elements of the USFWS RPA are: (1) adopting
an adaptive management framework that allows the
Corps to monitor and evaluate the actual results
of changes to system operations and to adapt system
operation as new information becomes available;
(2) implementing unbalanced intrasystem regulation
of the reservoirs, which would enhance the creation
and availability of nesting and foraging habitats
for the least tern and piping plover, and also enhances
habitat for the pallid sturgeon; (3) creating, restoring
and acquiring habitat for wildlife; and (4) modifying
flow releases at the Fort Peck and Gavins Point
Dams to provide an ecologically improved hydrograph
in the lower Missouri River.
Other than the no action alternative, which would
maintain the status quo, each of the alternatives
presented by the Corps in the RDEIS incorporates
an adaptive management strategy, unbalanced intrasystem
regulation, and modified releases at Fort Peck Dam.
While habitat creation, restoration and acquisition
are outside the scope of the Master Manual, it is
important to emphasize that habitat creation would
be a by-product of unbalanced intrasystem regulation
and modifying the flow releases. The Corps should
address the need to create, restore and acquire
habitat as part of a comprehensive approach to the
Missouri River ecosystem and must consider the additional
habitat benefits of modifying the Gavins Point Dam
flow releases. As a result, the most critical element
to discuss regarding the Corps’ selection
of a preferred alternative for the Master Manual
revisions is the spring rise and low summer flow
releases at Gavins Point Dam.
2. GP2021 Most Closely Resembles the USFWS
RPA.
The RDEIS presents six alternatives for revising
the Missouri River Master Manual. Two of the options
do not include any changes to the Gavins Point Dam
releases and therefore, lack key elements of the
USFWS RPA to avoid jeopardizing the federally listed
species. These two alternatives are (1) the no action
alternative, which would continue the current Water
Control Plan (CWCP), and (2) the modified conservation
plan (MCP), which would alter the CWCP by incorporating
unbalanced storage among the upper and largest lakes
in the Mainstem Reservoir System, increased drought
conservation, and a spring rise approximately every
three years from the Fort Peck Dam, but no spring
rise from the Gavins Point Dam.
The other four options are referred to as the “GP
options” because, in addition to the elements
contained in the MCP alternative, these alternatives
include increased spring releases and lower summer
flows from the Gavins Point Dam. The RDEIS distinguishes
among the GP options by referring to the number
thousand cubic feet per second (cfs) above the amount
normally required for full service navigation in
the spring and summer. The RDEIS presents the following
GP alternatives: (1) GP1528, which includes a 15,000
cfs spring rise followed by a minimum flat release
of 28,500 cfs that ends on September 1; (2) GP2021,
which includes a 20,000 cfs spring rise, followed
by a 25,000 cfs release to mid-July and then a 21,000
cfs release until mid-August when the 25,000 cfs
resume until September 1; (3) GP1521, which includes
a 15,000 cfs spring rise, followed by a 25,000 cfs
release to mid-July and then a 21,000 cfs release
until mid-August when the 25,000 cfs resume until
September 1; and (4) GP2028, which includes a 20,000
cfs spring rise, followed by a minimum flat release
of 28,500 cfs that ends on September 1. (RDEIS at
7-1).
While the four GP options seem to comply with the
USFWS RPA because they modify the Gavins Point Dam
releases, only one most closely resembles the scenario
identified in the USFWS BiOp as the starting point
for implementing the revised releases. The USFWS
RPA describes a scenario that would implement an
initial spring rise of 17,500 cfs above the full
service navigation level up to 20,000 cfs. The summer
flows would target 25,000 cfs between late June
and mid-July, followed by 21,000 cfs until mid-August,
with a return to 25,000 cfs until September 1. (USFWS
BiOp at 242-243). This is the GP2021 option.
The endangered interior least tern and threatened
piping plover are directly affected by changes in
water level. The least tern and piping plover depend
on a dynamic river with certain water level changes
to create the necessary habitat for feeding and
nesting. The GP2021 option includes a 20,000 cfs
spring rise every three years on average and a spilt
summer release of 25,000/21,000 cfs each year from
Gavins Point Dam. The high flows in the spring scour
the channels and carry sediment to form unvegetated
sandbars and islands that the birds need for nesting.
In addition, shallow water habitats, which are formed
by periodic flooding, are necessary to capture small
fish that the birds feed upon. (USFWS BiOp at 82-84,
91-931). An additional 20,000 cfs in the spring
would provide the maximum habitat for the least
tern and piping plover in all four river reaches,
as compared with the other alternatives. (RDEIS
at 7-45). Although the USFWS RPA indicates that
a range of spring flows between 15,000 to 20,000
cfs may be acceptable, there is marked improvement
at the upper end of that range versus the lower.
(RDEIS at 7-45 to 7-46). Similarly, the split summer
release is critical to restoring and maintaining
the exposed sandbars and shallow water areas that
serve has nesting and foraging habitat for the least
tern and piping plover. (USFWS BiOp at 241-242).
The split summer season is the most critical element
to providing the habitat needed by the native species.
The USFWS RPA does not include a flat summer release
like those proposed in the GP1528 and GP2028 options.
Like the listed birds, the endangered pallid sturgeon
and other native fish require a dynamic river system
to provide habitat. The pallid sturgeon also rely
upon higher flows in the spring to provide critically
important spawning cues for reproduction. (USFWS
BiOp at 103). Native fish require overbank flooding
in the spring for habitat. The pallid sturgeon also
depend on overflow areas that create habitat for
the young and facilitate organic matter accumulations,
which is important to increasing macroinvertebrate
production that serve as a source of food. (USFWS
BiOp 101-116). GP2021 is the alternative presented
with the highest spring flow on an average of every
three years, and is likely to provide substantial
benefits to the pallid sturgeon’s reproductive
cycle. It is not necessary for the Corps to know
with certainty the exact number of cfs needed to
provide adequate spawning cues. There is no denying
the fact that the pallid sturgeon evolved and once
thrived in the Missouri River. Over the years, as
their habitat has been eliminated and the river’s
natural hydrology has been replaced with steady
flows, this species has suffered. In 1993, 1995
and 1997, the Missouri River experienced high flows,
despite the Corps’ attempt to control the
river. Following those years, in 1998 and 1999,
the USFWS collected evidence of successful pallid
sturgeon reproduction in the lower Missouri River
(USFWS BiOp at 106). There is sufficient scientific
data to support the USFWS’ recommendation
that an additional 15,000 to 20,000 cfs would provide
substantial reproductive benefits to the pallid
sturgeon. An extra 30,000 cfs could provide additional
benefits to the fish habitat. (RDEIS at 7-57). Any
uncertainty regarding the spawning cue needs of
the pallid sturgeon must be addressed through adaptive
management. For these reasons, the Corps must start
at the upper end of the range recommended by the
USFWS, 20,000 cfs, and determine whether additional
flows are needed through adaptive management. In
sum, GP2021, which provides the largest range of
flows between the spring and summer months, is the
alternative presented in the RDEIS that produces
the greatest benefits to federally listed species,
other native fish and wildlife, and the ecosystem
generally.
The Corps identifies the GP1528 option as the potential
starting point because “it has the smallest
changes of the four options from the releases”
of current operations in the spring and summer,
which is currently a 34,500 cfs flat release. (See,
e.g., RDEIS at 7-1). There is no evidence to
support that changes in the current operations should
be kept to a minimum. It may be politically attractive
to attempt to minimize the changes in the flow releases,
but it bears no relationship to what is best for
the Missouri River ecosystem or the federally listed
species. To the contrary, the need to change current
operations is dire. The list of species in danger
of extinction is growing – 82 species along
the Missouri River are listed as rare, threatened,
or endangered by the seven states bordering the
river in their state endangered species programs.
(NAS, Missouri River Ecosystem at 65).
GP1528 starts with an incorrect premise of minimizing
changes from current operations. While our wildlife
organizations support the concept of flexibility
to allow the Corps to alter the Gavins Point Dam
releases based on actual experience without requiring
lengthy procedures, the Corps needs to start with
the option that is best for the native fish and
wildlife and the ecosystem upon which they depend.
Rather than trying to minimize the changes to current
operations, the Corps ought to be striving to return
the Missouri to as close to its natural state as
possible. In the few areas where the Missouri River
retains a free-flowing nature, such as in Montana,
upstream of the mainstem dams, “the moderately
regulated reaches have retained their essential
pre-regulation state including overbank flooding,
adequate sediment supply to prevent channel degradation,
scattered populations of cottonwood forests similar
to those observed by Lewis and Clark, and productive
native fisheries.” (NAS, Missouri River
Ecosystem at 59 (internal citations omitted)).
3. Alternatives That Fail to Avoid Jeopardizing
the Threatened and Endangered Species Must Be Rejected.
The RDEIS recognizes that the non-GP options risk
a “jeopardy finding” by the USFWS because
they do not meet the standards of the USFWS RPA,
and suggests ways by which the Corps can avoid the
requirements of the ESA. (RDEIS at 6-6). The Corps
should not consider these alternatives viable. The
Corps must reject attempting to avoid the ESA for
two reasons. First, any attempt to seek an exemption
from Section 7 of the ESA will impose yet another
lengthy process on this undertaking to finally revise
and update the Master Manual. Second, and most importantly,
the ESA requires the Corps to consult with the USFWS
about the future existence of federally listed species
for a very good reason – to avoid sending
the piping plover, least tern and pallid sturgeon
into extinction. Without addressing the merits of
an exemption request, attempting to avoid the law
in this case would be a severe disservice to future
generations that would be denied the benefits of
these species. The Corps must reject any alternative
that would involve seeking an exemption from the
ESA.
B. It Does Not Make Sense to Continue to
Manage the Missouri River System to Benefit Navigation,
Flood Control, Irrigation and Hydropower at the Expense
of Fish and Wildlife.
The Missouri River mainstem reservoir system serves
multiple purposes, including: (1) navigation, (2)
flood control, (3) water supply and irrigation, (4)
hydropower, (5) fish and wildlife, and (6) recreation.
The Master Manual requires that “. . . the reservoirs
will be operated for maximum benefit to recreation,
fish and wildlife” to the extent possible, without
interference with other purposes. (NAS, Missouri
River Ecosystem at 40-41). As a result, the fish
and wildlife have suffered woefully. Since the Missouri
River reservoir system was constructed, “there
has been a shift in emphasis in the United States
from the development of water resources to better
management of water resources in highly developed,
mature systems like the Missouri River, and specifically
to explore the prospects for restoring some level
of ecosystem benefits that have often been diminished
with river regulation.” (NAS, Missouri River
Ecosystem at 45). It simply does not make sense
to make these other project purposes a priority over
the needs of the fish and wildlife, and the ecosystem
upon which they depend.
The cost of giving the least tern, piping plover
and pallid sturgeon the best chance of recovery under
the Master Manual plan alternatives presented is about
one half of a percent of the total
average annual national economic development (NED)
benefits of the Missouri River mainstem reservoir
system. (RDEIS at 7-179). The RDEIS reports the total
average annual NED benefits under current conditions
to be approximately $1,853.6 million. Under the best
option for fish and wildlife presented, the GP2021
option, average annual NED benefits increase by $5
to almost $9 million, depending on whether navigation
would continue before and after the split flows in
the summer. The GP2021 NED benefits, however, are
calculated to be $7-11 million less than the NED benefits
under the GP1528 option, depending on whether navigation
would continue before and after the split flows in
the summer. That $7-11 million is just 0.4 to 0.6
percent of the total NED project benefits. (RDEIS
at 7-179).
The largest economic drivers in the NED calculation
are hydropower, water supply/irrigation and flood
control (in that order). Navigation – which
the Corps describes as “a primary concern regarding
changes in a Water Control Plan for the Missouri River
Mainstem Reservoir System” – has, by far,
the smallest impact on the NED benefits. (RDEIS at
7-196). Recreation accounts for 12 times the amount
of the annual average NED benefits as navigation under
current operations. (RDEIS at 7-179).
1. Navigation Accounts For Less Than 0.4
Percent of the Average Annual NED Benefits.
Navigation on the Missouri is far less than projections
from 50 years ago and should no longer be a “primary
concern.” The Missouri River navigation channel
extends 735 miles from St. Louis to Sioux City,
Iowa. Commercial navigation on the lower basin has
dropped considerably over the past 40 years –
falling well below the Corps’ projections
in 1950. Commercial traffic peaked in 1977 at 3.3
million tons, and by 1997, the traffic had dropped
to 1.6 million tons. In the last decade, commercial
traffic leveled off at an annual average of 1.5
million tons. (NAS, Missouri River Ecosystem
at 74-75). Using the Missouri River to transport
agricultural grain, food and food products proved
to be unfavorable because these products tend to
be bound for export markets and the Missouri is
not well positioned to reach export markets. Instead,
to the extent the Missouri River is used for commercial
navigation, it is dominated by sand and gravel traffic.
Sand and gravel, along with the material needed
to construct and maintain the navigation channel
account for almost 80% of the total waterway tonnage.
(NAS, Missouri River Ecosystem at 75-76).
Navigation benefits currently account for less
than 0.4 percent of the average annual total NED
benefits. (RDEIS at 7-179). The RDEIS reports average
annual total navigation benefits to be approximately
$7 million under the current operations, with the
total average annual NED reservoir system benefits
at about $1,853.6 million. (RDEIS at 7-171, 7-179).
Taking into account the cost of operation and maintenance
results in net benefits of less than $3 million
per year at full-service flow levels. When flows
fall below full service levels, the benefits drop
rapidly and actually reach zero at about 30,000
cfs. (NAS, Missouri River Ecosystem at
75-76 (citing USACE, 1998)). Moreover, the calculation
of navigation benefits ignores the opportunity cost
of ecosystem restoration services and recreation
benefits, which could easily make net navigation
benefits a negative number.
Commercial navigation traffic is not significant
on the Missouri River, but the effect of trying
to maintain navigation services is having a tremendous
impact on the ecosystem. The total amount of commercial
navigation traffic that will be affected by the
change in operating conditions under GP2021 is small
and will not significantly impact the total NED
benefits. The RDEIS dedicates a separate section
(7.15.4) to navigation efficiencies and shows a
loss of approximately $7.39 million in navigation
efficiency costs due to the low water volume in
the summer. The only chart presented on this subject
shows this “loss” – even though
the Corps’ final conclusion is that “additional
flows in the fall months are coincident with extreme
low stages on the Mississippi River and provided
sufficient savings to offset the summer losses.”
(RDEIS at 7-196). As a result, from a national perspective,
economic benefits from navigation increase under
the GP2021 option.
2. Hydropower Benefits Increase with GP2021.
More than 40% of the average annual total NED benefits
are derived from hydropower production under current
operating conditions. Under all of the proposed
alternatives, including each of the GP options,
hydropower production benefits increase. GP2021
would provide an additional $13 (plus) million to
the average annual hydropower benefits. (RDEIS at
7-143). While GP2021 does not provide the maximum
hydropower benefits, hydropower is an ancillary
purpose to the project, and therefore should not
be the determining factor used by the Corps in selecting
an alternative.
Hydropower was never intended to be the primary
purpose of the mainstem dams. In the early 1900s,
Congress gave the Federal Power Commission (now
known as the Federal Energy Regulatory Commission)
primary responsibility for approving nonfederal
hydropower dams on navigable waters. Congress decided
that rather than having the federal government coordinate
hydropower development, hydropower should generally
be developed by the private industry subject to
federal government regulation. (NAS, Missouri
River Ecosystem at 22). The Corps may include
hydropower as a project purpose, but only as ancillary
to flood control or navigation.
There is only a marginal difference between the
hydropower production benefits under GP1528, as
compared with GP2021. (RDEIS at 7-143, 7-152). The
increase in benefits is, in part, due to the higher
spring flows that would come with the GP options.
Summer and winter, however, are when power demands
tend to be at the highest, which is generally due
to increased heating and air conditioning use. The
amount of energy generated at a hydropower dam is
directly related to the amount of flows in the river.
Because the GP2021 option would provide lower flows
than GP1528 from Gavins Point Dam during the peak
summer months, the dam’s capacity to produce
hydropower in those months will be less under GP2021,
as compared with GP1528. The differences among the
GP options in general, however, are small and should
not be a barrier to selecting the GP2021 option.
In addition, the RDEIS presents insufficient information
regarding the impact of changing the dam operations
on Western Area Power Administration’s (WAPA)
customers. WAPA markets the capacity and energy
generated at the mainstem dams on the Corps’
behalf. The RDEIS describes who some of WAPA’s
customers are, but does not provide adequate information
about how those customers will be affected. (RDEIS
at 7-144 to 7-145). Because the effects are stated
as a percentage increase in purchased power costs,
it is impossible to analyze how many dollars, megawatts
and people are affected. WAPA’s customers
should not experience a substantial increase in
their electricity costs as a result of the changes
in the mainstem dam operations. For example, if
the value of energy, but not capacity, was considered
in determining lost revenue, the Corps has undervalued
the GP2021 option. In addition, there is a myriad
of hedging instruments WAPA could use to protect
its customers from increased power costs. But without
more information, it is not possible to understand
the predicted effects on purchased power and whether
those predicted effects should be passed on to the
end-users.
3. Flood Control and Water Supply Benefits
Cannot Outweigh the Needs of Fish and Wildlife.
The remaining elements of the NED benefits are
flood control, water supply and irrigation, and
recreation. Here again, the differences in economic
benefits among the alternatives for each category
are relatively small. The GP2021 option would provide
$1.6 million less in water supply benefits than
the current operations and $2.6 million less than
the GP1528 option. (RDEIS at 7-138). Flood damage
reduction benefits decrease by $2.6 million under
the GP2021 option compared to current conditions,
but are $1.9 million higher than the GP1528 option.
(RDEIS at 7-88). Finally, recreation benefits increase
under the GP options as compared with the current
operations. Regional economies, particularly riverside
communities that support opportunities for boating,
fishing, hiking, camping and birding, will benefit
as fish and wildlife resources increase. While more
could be said about each of these topics, the most
important point is that balancing the mainstem dam
operations involves trade-offs. Sometimes there
is a positive economic effect and sometimes there
is a negative economic effect. The National Academy
of Sciences makes this pointed conclusion:
The Master Manual is the key document for distributing
the benefits of the river and its reservoir operations.
However, the procedures in the Master Manual used
to produce the current suite of benefits largely
reflect social values from the mid-twentieth century.
As a result, the Master Manual may not adequately
be meeting contemporary social demands, which
place a greater emphasis on ecosystem benefits,
water- and nature-based recreational pursuits,
preservation of endangered species, the enhancement
and conservation of biodiversity, and maintenance
of the river corridor’s cultural heritage.
. . . On the Missouri River, there
is a distinct prospect that a reversal of tradeoffs
that would favor ecosystem restoration may be
justifiable solely on the grounds that it represents
an economic improvement on current mainstem dam
operations. (NAS, Missouri River
Ecosystem at 87 (emphasis added)).
As the Corps prepares to plan its operation and
maintenance of the Missouri River mainstem reservoir
system for the twenty-first century, the Corps must
recognize that protecting and restoring the ecosystem
can and should outweigh other interests.
III.The Corps Must Improve Its Analysis of
Alternatives To Fully Present the Environmental Impacts
of Each Alternative.
For more than a decade, the Corps and other state and
federal agencies have collected a great deal of data
about the Missouri River and the issues that concern
many of the stakeholders. While there is still more
information to obtain about how the proposed changes
will impact the Missouri River’s ecosystem, our
wildlife organizations believe that the RDEIS contains
sufficient information for the Corps to present a preferred
alternative. Our wildlife organizations encourage the
Corps to move swiftly to implement modified flows below
Gavins Point Dam. The Corps, however, failed to identify
the best alternative for fish and wildlife, and the
information is not presented in a clear way that is
easily understood by the public. In revising the RDEIS,
our wildlife organizations urge the Corps to clarify
its analyses in the Final Environmental Impact Statement
and address the following:
- Identify the alternative that provides maximum benefits
for fish and wildlife, and the ecosystem upon which
they depend, and explain the effects of such an alternative
as a point of comparison to analyze other selected
alternatives.
- Provide a more complete explanation of how the Corps
intends to implement adaptive management with each
of the identified alternatives. As currently drafted,
the RDEIS provides a broad description of what adaptive
management is, but does not describe what specifically
would be done to implement it for each of the alternatives.
- Discuss the benefits the GP options would provide
to other native fish and wildlife and the Missouri
River ecosystem generally, rather than limiting the
benefits to the federally listed species. While the
least tern, piping plover and pallid sturgeon are
of most immediate concern, it is wrong to present
the material in a way that ignores the other fish
and wildlife benefits, which may include avoiding
future federal endangered species listings.
- Provide summary tables for all data sets. In various
sections of the RDEIS there are charts that present
certain data, but not others. Many times the text
describes a conclusion that is different from what
one would expect based on the charts and figures that
are presented. Pictures speak more loudly than words
and it is important that the Corps present such tables
and charts for all critical data.
- Evaluate the positive and negative impacts to waterfowl
management, hunting and other uses on the Kansas River
system as a result of continuing to use water from
the Tuttle Creek Reservoir, Milford and Perry Reservoirs
in Kansas to provide navigation support. The Corps
should eliminate releases from the Kansas River system
to support navigation in the Missouri River, and at
a minimum, make no further releases for those purposes
until a complete and thorough evaluation of the benefits
and impacts has been completed.
IV. Conclusion
The current Master Manual for the Corps’ management
and operation of the six mainstem dams along the Missouri
River is in dire need of revision. Since 1979, changing
economic and social conditions in the United States
have caused the Manual’s focus on navigation and
flood control to be far less desirable in the face of
other ecological considerations. The fact that these
dams were built before the enactment of many of our
nation’s most important environmental laws, such
as the Endangered Species Act, further necessitates
a management plan that decreases their negative impact
on native fish and wildlife, and the ecosystem upon
which they depend. Revising the Master Manual to implement
the GP2021 option would be a significant first step
in helping the federally listed species to recover and
restoring the Missouri River to a more natural state.
The Corps should implement GP2021 as soon as possible
and continue to work with the USFWS to implement the
entire BiOp.
Our wildlife organizations appreciate the opportunity
to provide these comments to the Corps and look forward
to continuing to work with the Corps on this and many
other issues. If you have any questions about these
comments, please contact Tom France at 406-721-6705.
Sincerely,
Jamie Rappaport Clark, Senior Vice President for Conservation
Programs
National Wildlife Federation
Suzanne O’Neill, Board Chair
Colorado Wildlife Federation
Denny Ballard, Executive Director
Conservation Federation of Missouri
Joe Wilkinson, President
Iowa Wildlife Federation
Tommie Berger, President
Kansas Wildlife Federation
Craig Sharpe, Executive Director
Montana Wildlife Federation
Duane Hovorka, Executive Director
Nebraska Wildlife Federation
Mike Donahue, Board Member
North Dakota Wildlife Federation
Chris Hesla, Executive Director
South Dakota Wildlife Federation
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