Good evening, my name is Dan Engemann and I serve as Executive Director of the Coalition to Protect the Missouri River (Coalition). The Coalition is made up of a variety of interests and supports the congressionally authorized purposes of flood control, navigation, water quality and water supply. We also support endangered species recovery.
We appreciate the opportunity to comment on the Draft Environmental Impact Statement (DEIS) of which several of our members and I have been heavily involved in as part of the MRRIC process.
Of the six alternatives presented to us for review and comment, the Coalition supports mechanical sandbar habitat construction contained in each of the alternatives. However, we cannot support various flow modifications common to alternatives two, four, five and six. Low summer flow provisions in alternative two will cause great harm to the navigation industry by creating a split season on the Missouri River and adversely affecting navigation flows on the middle Mississippi River. It has the potential to negatively impact water and sewer treatment plants, as well as power plants; creating problems with intakes and increasing the risk of failure to comply with the conditions of discharge permits. Alternatives four and five create unacceptable amounts of flooding risk in the spring and fall, increasing downstream flood control constraints and doubling releases from Gavins Point for 35 days. Regarding alternative six, our members do not support the implementation of a full bi-modal release because of the risks to flood control and impacts to interior drainage.
We believe the Corps’ preferred alternative three strikes a better balance between human interests and species recovery. However, our members are concerned about the potential for flooding and impacts to interior drainage as part of a one-time flow test included in this alternative.
The Coalition supports eliminating the current bimodal spring rise from the preferred alternative because no science has been developed to prove its value. We applaud the Corps for their commitment to study the linkage between tributary flows and pallid sturgeon recovery. However, we question how the Corps can keep such an option “on the shelf” for nine to ten years in the future as part of this alternative, knowing that river conditions can change during this time, making human consideration effects difficult to monitor. We are concerned that this one-time flow test could be part of a permanent flow regime.
Flow rises in other alternatives raise questions about implementation, as those actions require amending the Master Manual. We oppose such revision because of the time involved, the risk to the species and the potential for litigation during which time the species could decline even further. Should the Corps choose something other than alternative three, the process for creating flow changes needs to be clear to stakeholders and be aligned with the Master Manual.
For the same reasons, any adaptive management actions could cause concern. Whenever new actions are proposed or existing actions are modified, including those outside of the Record of Decision, they must be subject to thorough review, including public comment and EIS impact assessments and be in compliance with the Master Manual.
The Coalition to Protect the Missouri River will be offering comprehensive comments in advance of the extended comment period deadline. Thank you for traveling the basin to hear stakeholders’ thoughts and concerns on this important matter.