November 19, 1999
BG Carl A. Strock
Northwest Division
U.S. Army Corps of Engineers
P.O. Box 2870
Portland, OR 97208-2870
Dear General Strock:
The Missouri River Basin Association (MRBA) thanks you and your staff for supporting MRBA’s efforts to develop recommendations for the preferred alternative in the Revised Draft Environmental Impact Statement (RDEIS) the Corps will publish early next year. On behalf of MRBA, we are pleased to provide the following recommendations to assist in your decision.
The submission of these recommendations does not constitute a waiver of rights by any of the Missouri River Basin States or Tribes nor does it constitute a river basin compact or equitable apportionment of the waters of the Missouri River Basin among the States. They are provided for the sole purpose of assisting the Corps of Engineers in making revisions to the Master Manual.
Although it has been difficult to balance the competing uses of the river system, MRBA believes our recommended changes to the management of the Missouri River allow both economic and environmental interests to prosper. To develop these suggestions, all the basin interests have had to make some difficult decisions in the spirit of compromise and general well being of the entire basin.
MRBA will continue to encourage input from the basin’s constituents throughout the Master Manual review and update process. The Association urges the Corps and technical staff from the basin states to continue to work together to minimize adverse operational impacts in the basin.
MRBA recognizes the concerns of the Missouri River Basin Indian Tribes and supports ongoing consultations on the impacts of changes to the existing Master Manual on tribal cultural and economic resources. In addition, one basin state, Missouri, cannot support some of the recommendations in this letter. However, Missouri will continue to support the process and participate in the Missouri River Basin Association.
Flow Management Recommendations:
Water Supply:
The existing Master Water Control Manual emphasizes the importance of operating the reservoir system to provide sufficient river flows in reaches between reservoirs and in the lower river to meet water supply needs. The Corps’ preferred alternative must continue to meet these critical needs.
Navigation Support Guidelines:
The flow management recommendations provided below have been revised from the draft recommendations MRBA submitted in its August 31 letter to you. These revisions reflect concerns MRBA heard from various river users, particularly navigators, and additional follow-up modeling by the Corps. Although the revised flow recommendations fall short of meeting all the needs of all river uses, they represent our best effort based on current information to find an acceptable compromise.
MRBA believes the Corps should endeavor to keep Missouri River navigation viable during a drought like the one experienced in the 1980s by:
The MRBA also recognizes that droughts of greater intensity and duration have occurred (e.g. drought of the 1930's) and are likely to occur in the future. Further, we recognize that flow support for navigation would have to be suspended at some point (navigation preclude value) to ensure there is adequate water reserved to meet the other authorized purposes during such an extended drought.
Using data provided by your staff, we believe the following set of water control plan guidelines would achieve the results we desire.
Navigation Service Level Check:
8 Feet of Draft
(Full service minus 3,000 cfs)
March 15 less than 54.5 MAF
July 1 less than 59.0 MAF
Season Length Check:
7.1 Month Season
July 1 less than 59.0 MAF
Severe Drought Year Service Level
(Severe drought defined as a year in which there is no gain in total system storage between march 15 and July 1)
7.5 feet of draft (full service minus 6,000 cfs) July 1 to August 20 of following year
Navigation Preclude:
March 15 less than 31 MAF
Current model runs using the guidelines listed above result in a minimum System Storage level of 43 MAF during a drought similar to that experienced in the 1980's.
Evacuation of Flood Control Zone:
MRBA supports the release of excess summer and fall storage to meet the needs of
downstream uses. A flow target would be added at St. Charles, Missouri to measure possible
navigation impacts in the surrounding reaches. A maximum additional 5,000 cfs would be
released from the Missouri River mainstem system if the St. Charles target indicates that
navigation impacts will occur. The releases shall be subject to the following constraints:
Given that the Corps has generally been in an evacuation mode since 1993, MRBA recommends that the Corps presents its flood storage evacuation guidelines in the RDEIS and discusses them during the public hearings that follow release of the document.
Water Depletions:
Changes to the current level of depletions of water from the Missouri River and its tributaries may have an impact on all mainstem project purposes. The MRBA Directors commit to exploring mechanisms to determine how to fairly share these impacts on project operations. The first step of this process is to establish baseline information on the current level of depletions. MRBA urges the basin’s states, Indian tribes, the Corps, and other federal agencies to begin working on this task immediately.
Environmental Recommendations:
MRBA recognizes the need to recover the basin’s threatened and endangered species and to prevent future listings of such species. The key to MRBA’s environmental recommendations is the development of an adaptive management process to help recover the basin’s threatened and endangered fish and wildlife populations.
MRBA recommends an approach to species recovery that includes the four components listed below:
MRBA recognizes the need for the basin’s states, Indian tribes, water users, and other interested parties to be involved in discussions among federal agencies concerning the recovery of the basin’s threatened and endangered species. Other river basins facing similar issues have formed committees comprised of diverse representation from state water and fish and wildlife managers, tribal representatives, and environmental and economic interests to assist federal agencies on species recovery plans. MRBA recommends that the Corps, the U.S. Fish and Wildlife Service, and other federal agencies work with MRBA, state fish and wildlife agencies, and other water users and interests to form such a committee in the Missouri River basin. Recommendations of the committee would be subject to requirements of the National Environmental Policy Act prior to their implementation.
Unbalancing of the Upper Basin Reservoirs:
To provide benefits to sports fisheries, recreation, and endangered species in the upper three reservoirs, MRBA recommends that the Corps implement when possible, without compromising downstream flood control, an intrasystem trading of stored water (unbalanced storage) among Ft. Peck, Sakakawea, and Oahe reservoirs. MRBA acknowledges the flood control concerns of downstream interests and encourages the Corps to avoid when possible increases in the use of the Exclusive Flood Control Pool, especially in Oahe Reservoir.
Lower River Habitat Improvement and Recreation Flows:
To evacuate excess water, river flows are often significantly above full service navigation targets. To enhance wildlife and recreation in the lower river, when practical and consistent with other project purposes, the Corps should reduce releases from August 1 to September 15 to full navigation service levels (41 kcfs at Kansas City).
Fort Peck Fish Enhancement Flows:
As part of the adaptive management program, the Missouri River Basin Association recommends trial fish enhancement flows from Fort Peck Reservoir. The enhanced flows will be coordinated with the unbalancing of the upper basin reservoirs, and thus will occur approximately every third year. These higher flows will be designed to enhance the recovery of the pallid sturgeon and to provide habitat improvements for the least tern and piping plover. MRBA will also work closely with officials from the Fort Peck Indian Reservation to ensure the protection of the Tribes’ cultural resources there. The enhanced flows will adhere to the following criteria:
Flow Rates: 22,000 cfs
Timing: Begin the first week in June
Duration: Two weeks
Frequency: Every third year, to coincide with scheduled low water year for Fort Peck Reservoir in the Corps’ unbalancing of the upper basin reservoirs.
MRBA will work with state, tribal, federal, and local officials in the next few months to:
MRBA also recommends that all modifications to the existing flow patterns throughout the river system be implemented on a trial basis of approximately seven years. Throughout this period, extensive monitoring will determine the success of various approaches and the need to modify efforts to recover the basin’s threatened and endangered species. In coordination with this experimental spring rise, winter releases will be modified as an adaptive management approach to minimize impacts during ice-up.
Gavins Point Releases:
MRBA recognizes the controversial nature of adjustments to releases from Gavins Point Dam. MRBA recommends that the Recovery Committee investigate the benefits and adverse impacts of flow adjustments to the existing uses of the river system.
3. Habitat Acquisition and Enhancement:
MRBA generally supports efforts to acquire land or easements from willing sellers as a means of enhancing fish and wildlife habitat in the basin. MRBA sees a need for continued funding of and coordination between programs that buy land or easements from willing sellers, compensation of counties and levee districts for lost taxes or fees, and enhancing the wildlife habitat value of those lands. The habitat acquisition and enhancement activities generally fall under the following programs:
MRBA also recommends investigating opportunities to acquire and enhance off-channel habitat to support the basin’s threatened and endangered species. Such a program might provide incentives to floodplain landowners willing to participate in fish and wildlife habitat enhancement. Other programs that help restore the basin’s fish and wildlife habitat such as the Corps’ 1135 Program also receive the enthusiastic support of MRBA.
4. Monitoring and Research:
MRBA recommends immediate funding and implementation of a basinwide
biological and hydrologic monitoring and research program to improve overall river management and enhance the basin’s fish and wildlife habitat and species recovery. The main monitoring component is the Missouri River Environmental Assessment Program developed at MRBA’s request by the Missouri River Natural Resources Committee. The MoREAP program should be administered by the USGS-BRD office in Columbia, Missouri.
A related research activity is the National Academy of Sciences study of the Missouri River. This study will take approximately two years and has been designed to determine the status of scientific understanding of the Missouri River. The study will identify areas where additional research of the river system is needed and it will be used as a tool to focus MoREAP’s research and monitoring activities.
Tribal Recommendations:
MRBA supports the following activities and principles regarding the Missouri Basin Indian Tribes:
Other Recommendations:
MRBA refers the Corps and others to the Association’s Missouri River Planning Recommendations document published in April 1998. The document includes a variety of ideas designed to improve the basin’s overall economic and environmental conditions and was developed with input and support of constituents throughout the basin.
MRBA is currently refining those recommendations and working towards their implementation. This work will be the central focus of MRBA over the next several years, and we look forward to cooperating with the Corps, other federal agencies, and Congress in that endeavor.
MRBA also recommends exploring the development of a financial relief and/or incentive program for river interests impacted by operational changes brought on by extreme climatological conditions:
* * * *
These constitute our recommendations for the preferred alternative that the Corps will publish in its RDEIS early next year. We encourage the Corps to proceed with its planned public review process following the release of its RDEIS. We recognize that there is still much work to be done before a new Master Water Control Manual for the Missouri River system is adopted, and we thank you for giving the states and Indian tribes this opportunity to develop and express our recommendations.
Sincerely,
Bud Clinch, President
Missouri River Basin Association
