February 12, 2002

BG David A. Fastabend
Commander, Northwestern Division
U.S. Army Corps of Engineers
P.O. Box 2870
Portland, OR  97208-2870

Dear General Fastabend:

The Missouri River Basin Association (MRBA) is pleased to submit the following
amendments to the Missouri River Master Water Control Manual recommendations
included in MRBA's November 19, 1999, letter to General Strock (See attached).
MRBA continues to support its November 1999 recommendations.  Where these
amendments are in conflict with those proposed in November 1999, these amendments
prevail as MRBA's official position.

MRBA's recommendations were developed with input from stakeholders throughout the
Missouri River Basin and after much discussion among representatives of the basin's
states, tribes, and federal agencies. MRBA appreciates the Corps including many of the
recommendations we offered in November 1999 in five of the six alternatives listed in its
recent Revised Draft Environmental Impact Statement (RDEIS).  MRBA recommends
the following two amendments to assist you in crafting a preferred alternative:

1. Gavins Point Demonstration Project:

MRBA believes there is a need for additional information on the benefits and impacts
of specific lower river spring rises and low summer flows before deciding to include
them in the new Master Manual.  MRBA recommends that the Corps conduct a
demonstration with the following two flow changes out of Gavins Point to help
determine the role of flow changes in species recovery.  First, MRBA recommends
that the Corps release, approximately every third year, springtime flows of up to
15,000 cfs over what is required for full navigation service.  These higher spring
flows would last up to two weeks each cycle.  Second, MRBA recommends that the
Corps reduce annual flows to minimum navigation service for up to two-and-a-half
months during the summer.  The Corps should suspend the low summer flows in
years when they may result in fall flooding in the lower river.

This proposal for the higher spring and lower summer flows is roughly equivalent to
the GP1528 alternative in the Corps' RDEIS.  MRBA would like to see the
demonstration project continue for three cycles of higher springtime flows, or
approximately ten years after which time, the federal agencies and members of a
multi-stakeholder group will determine whether to continue or modify the new
release schedule.  Linkages to the following restrictions are critical to MRBA's
support of the demonstration project:

· The demonstration project must be conducted according to the principals of
	adaptive management that were endorsed in the recent National Academy of
	Sciences study of the Science of the Missouri River.  This would include the
	establishment of a multi-stakeholder group to apply and oversee the adaptive
	management approach prior to implementation of the demonstration project.
· The Corps should work with affected state agencies, tribes, and landowners to
	plan the demonstration project before initiating it.  
· With the flow changes out of Fort Peck Reservoir and Gavins Point Dam, the
	Corps, MRBA, affected landowners, tribal representatives, river users, and
	Congress must first establish a program that would mitigate potential damages
	resulting from the flow adjustments.  
· The Corps should have the flexibility to end the demonstration if it causes undue
	harm to landowners or prevents the Corps from maintaining authorized purposes
	of the river system. 
· The demonstration project must be linked closely to continued habitat work in the
	basin and extensive monitoring.  Because monitoring is such an important
	component of adaptive management, river flows should not be adjusted until there
	is sufficient monitoring in place to evaluate the success and impacts of the
	experiments.   
· The springtime flow releases should not occur during wet periods, or when the
	additional risk of flooding or drainage problems can be reasonable anticipated.
· Impacts on other project purposes should be closely monitored and evaluated
	during the demonstration project period.  This would include impacts on
	navigation, hydropower generation, floodplain farming and drainage, water
	supply, and temperature for power plant cooling.  Appropriate mitigation of
	impacts should be implemented.
· In the event the demonstration project does not produce the intended results or is
	not adopted, MRBA reminds the Corps of MRBA's November 1999
	recommendations, including a low summer flow of 41,000 cfs at Kansas City.

2.  The Kansas River Basin Reservoir System:

During the Missouri River Master Manual Review, the Corps of Engineers has not
studied how the various alternatives will affect the operation of the Kansas River
Basin reservoirs. The Kansas River Basin reservoirs should not be used for Missouri
River navigation support, at least until such time as the impacts on the reservoirs has
been studied, and concerns resolved to the extent possible, nor should there be any
additional restrictions on flood operations.  

Conclusion:

These recommendations represent the official position of the association and are
supported by the MRBA representatives of the states of Kansas, Montana, Nebraska,
North Dakota, South Dakota, and Wyoming.  The states of Iowa and Missouri do not
support the Gavins Point demonstration project.  However, Iowa supports the restrictions
to the use of the Kansas River Basin Reservoir System and all other elements of MRBA's
November 1999 letter to General Strock.  The Mni Sose Intertribal Water Rights
Coalition abstained from voting until each Tribe has completed a thorough review of the
MRBA recommendations. 

We appreciate the difficulties associated with your rendering a decision on a new
operating plan for the Missouri River.  Again, we thank you and your staff for supporting
our efforts to reach agreement on a new plan, and we hope you find these
recommendations to be helpful.

Sincerely,



Sue Lowry
MRBA President