STATE OF GEORGIA, STATE WATER QUALITY CONTROL BOARD, Atlanta, Ga., June 24, 1971. Hon. HENRY S. REUSS, Chairman, Conservation and Natural Resources Subcommittee of the Committee on Government Operations, Rayburn House Office Building, Washington, D.C. DEAR CONGRESSMAN REUSS: Your letter of May 20, 1971, in reference to various Federal agencies responsibilities and operations in development and management of water resources projects is appreciated. We are pleased to submit the following general comments relative to projects of the Corps of Engineers, TVA, SCS, BOR, Fish and Wildlife Service, and others. Until recently these agencies or bureaus were all guilty to some significant degree of what is referred to as "tunnel vision." That is, they all promoted vigorously water resource projects directly related to their own fields with little regard for other water management concerns. Few considered enhancement of water quality, low augmentation to improve waste assimilation or protection for fisheries, recreational waters or other beneficial and legitimate uses, not directly related to a particular project. The result is that many such projects have created serious water use conflicts. Examples of conflicts between uses in Georgia are: 1. Buckhorn Lake, Carroll County, is a multiple purpose SCS project-water supply, fishing, etc. Algal blooms have produced serious taste and odor problems for the public drinking water supply of the city of Carrollton. To better serve the interest of the fishermen management does little or nothing to control the algae. 2. At Elberton, Elbert County, a rather new reservoir (filled within the past 2 months) already has serious water quality problems due to an algal bloom. 3. At Union Point and Woodbury high manganese concentrations have developed in reservoirs designed to serve as sources of drinking water. 4. Low flows in later summer and early fall, especially when peak power generation is suspended, produces critical water quality problems in the Chattahoochee and Coosa Basins below Buford Dam (Lake Lanier) and Allatoona Dam (Lake Allatoona). 5. State and Federal receiving water standards (particularly those of dissolved oxygen and temperature) have been and are repeatedly violated below impoundments of the corps and the SCS. 6. Too often the benefits of such projects appear to have been greatly exaggerated to develop a favorable benefit-to-cost ratio. 7. A serious area of conflict with the SCS and the corps involves the violation of State and Federal water quality standards by some of their structures, especially in regard to dissolved oxygen concentrations and temperature limits in the streams below impoundments. If proper amounts of oxygenated water were released to downstream reaches in times of drought to augment flows, all water uses would be improved. However, in the autumn of 1969 downstream from Lake Tobesofkee in Bibb County, there was an intermittent flow in the stream. The desirable fauna in the length of stream involved was annihilated. This incident was an example of mismanagement. 8. The projects which create the greatest environmental damage are the socalled channel improvements which are often actually destructive. Excavation of the streambed and even removal of snags can destroy or alter the habitats of fish and the invertebrate organisms on which they feed. While we recognize that these projects are sometimes needed for flood control, the SCS has sometimes seriously damaged streams unnecessarily. One of the most objectionable projects in Georgia was the "flood control" structure built on Jones Creek, a once fine trout stream near Dahlonega. The streambed was covered by silt and the migration of trout was inhibited. Channeling tributaries of lakes (e.g., Little River, a tributary of Allatoona Lake) permits the deposition of tons of particulate material in the lake and inhibits photosynthesis while the particles are suspended. 9. Proposed channeling projects include lengths of the Alcovy River. This project is highly controversial and has met with opposition from almost everyone except the landowners involved; nevertheless, the SCS seems determined to continue with a portion of the dredging. It is my belief that channeling of this stream will have an adverse effect on the water quality of Jackson Lake. Also, it has been proposed that the Alcovy River swamps be drained. Not only are swamps good natural treatment "plants," but they are also living museums for the study of nature. The Alcovy swamps are within minutes of the Atlanta area. A biologist on my staff has reported seeing a mayfly emergence of enormous proportions on a tributary destined to be altered. 10. It is our feeling that the opinion of this agency should be given great consideration when a polluted stream is to be dredged. After channel improvement the effluents from an industry or municipality do not receive the extra treatment which they would have in a natural stream-there are no boulders or debris to impede flow, create turbulence, and thus replenish the oxygen which may have been lost through microbial respiration. Furthermore, dredged organic materials may be placed alongside the stream to compound the problem. 11. Although our comments and suggestions have been solicited on corps and SCS projects, they have rarely, if ever, been incorporated into the project. It is interesting that a biologist on my staff incurred hostility from a member of the State Conservationist's staff when he attempted to ascertain the manner in which projects were grouped in accordance with SCS watersheds memorandum 108. Our suggestions for the classifications under this memorandum were neither invited nor welcome. We are grateful for the opportunity of making these comments to your subcommittee. Sincerely, HAWAII R. S. HOWARD, Jr., Executive Secretary. Hon. HENRY S. REUSS, STATE OF HAWAII, DEPARTMENT OF LAND AND NATURAL RESOURCES, Honolulu, Hawaii, May 27, 1971. Chairman, Conservation and Natural Resources Subcommittee, Congress of the United States, Rayburn Building, Washington, D.C. DEAR SIR: This is in response to your request for our views on Federal supported stream improvement projects in Hawaii. Six of the seven agencies named in your letter operate in modest ways to bring about stream improvements in Hawaii. We do not forget, in our comments and suggestions that follow, the considerable service rendered by these agencies. We would like our gratitude to be known at the outset. In the area of flood control, we have often been helped by the Corps of Engineers and the Soil Conservation Service in developing channels for floodwaters and so preventing loss of life and property. With funds and personnel available to them and operating under legal and administrative constraints, they have done admirably well. We find the rate of urbanization in Hawaii to be greater than the rate of installing necessary flood control improvements. A continuing record of flood damage attests to this. While we hold some hope in flood plain zoning, the realities of land economics in Hawaii makes us increasingly skeptical. Flood control budgets appear lean, and authorizations are often for single purpose. They exclude recreational and esthetic amenities. Spare designs often skip opportunities for special features in energy dissipators, silting and collection basins or to preserve and propagate aquatic and wetland biota. Projects can embrace more than one objective and resolve more than the problem of flood control. A reorientation of present disciplines, guidelines, procedures and institutions may be desirable. An important innovation of the past decade was the Water Resources Planning Act (Public Law 89-80). This keystone will help to join the many parts and ties of water resource management. Our contacts with the Water Resources Council, Corps of Engineers, Soil Conservation Service, Fish and Wildlife Service, Bureau of Reclamation and Bureau of Outdoor Recreation are candid, cordial and productive. They are as frequent as our means allow. Very truly yours, SUNAO KIDO, Board of Land and Natural Resources. Mr. HENRY S. REUSS, STATE OF HAWAII, DEPARTMENT OF HEALTH, Honolulu, Hawaii, June 17, 1971. Chairman, Conservation and Natural Resources Subcommittee of the Committee on Government Operations, Congress of the United States, Rayburn House Office Building, Washington, D.C. DEAR MR. REUSS: Thank you for the opportunity to comment on past and present stream improvement projects constructed or to be constructed with Federal moneys or with the aid of Federal financing. In general, the State department of health has a good working relationship with the Federal agencies charged with improvement, modification and channelization of our streams and rivers. The effectiveness of this relationship has improved since the passage of the Federal act requiring the coordination of these projects with State agencies through the use of environmental impact statements. I know of no instances in Hawaii where factors other than the prime motive of the project were not considered before the project commenced. House of Representatives, Rayburn House Office Building, Washington, D.C. DEAR REPRESENTATIVE REUSS: Your inquiry of April 26, 1971 concerning possible conflicts of interest in developing natural resource projects has been referred to my office for answer. We are aware as you are of the conflict of interest in developing Public Law 566 and other projects between the farmer and the fish and wildlife people. The farmer is concerned with his economic interests and survival and the fish and wildlife people are protecting the public interest in preserving our wildlife habitat and these differences must be resolved. We are happy to inform you that in Illinois we are presently enjoying very good cooperative relations with the fish and wildlife people. Our division is the administrative agency for the 98 soil and water conservation districts in Illinois and as such we sit as a member of the Illinois Natural Resources Development Board where all State agencies having responsibilities in the area of resource development can resolve their differences and make recommendations to the Governor accordingly. We are particularly concerned with Public Law 566 projects as the administrative agency for the soil and water conservation districts. Upon receipt of an application under Public Law 566 we hold a field investigation and review where we invite representatives of all concerned Federal and State agencies to participate in a tour and a public meeting following the tour. After this is accomplished we write a report and recommendation which is in turn reviewed and commented upon by all State agencies concerned before the final recommendations are made to the Governor. We are not a planning agency but we do have an input concerning policies adopted by the State of Illinois concerning natural resources development. We are accordingly enclosing a publication setting forth the Illinois Department of Agricultures goals in resource development. We hope this will be useful in pointing out our concerns. Please be assured that the Illinois Department of Agriculture is aware of the need to plan projects that will protect the public interest and at the same time satisfy the needs of the private landowner. We believe that by consultation and compromise satisfactory solutions can be found and we are using this approach in Illinois. Sincerely yours, Enclosure. JOSEPH BERTA III. ILLINOIS DEPARTMENT OF AGRICULTURE, DIVISION OF SOIL and Water CONSERVATION GENERAL GOALS IN DEVELOPING AND PROTECTING THE ENVIRONMENT OF The Illinois Department of Agriculture, through its division of soil and water conservation, is administratively responsible for 98 soil and water conservation districts in Illinois. It is the responsibility of the department and its 98 soil and water conservation districts to carry out the policy of the Illinois State Legislature, which reads as follows: It is the responsibility of the department and its 98 soil and water conservation districts to carry out the policy of the Illinois State Legislature, which reads as follows: "It is hereby declared to be the policy of the legislature to provide for the conservation of the soil, soil resources, water and water resources of the State, and for the control and prevention of soil erosion, and for the prevention of erosion, floodwater, and sediment damages, and thereby to preserve natural resources, control floods, prevent impairment of dams and reservoirs, assist in maintaining the navigability of rivers and harbors, preserve wildlife and forests, protect the tax base, protect public lands, and protect and promote the health, safety and general welfare of the people of this State. As amended by act approved May 22, 1961." A more recent amendment (sec. 22.07A) added August 30, 1963, broadens and makes more specific legislative policy by including air, domestic, industrial, and agricultural water supplies and recreational developments and improvements as additional objectives. As a basic element for effective work, and as a condition to receiving assistance from the United States and Illinois Departments of Agriculture, each soil and water conservation district has prepared a long-range plan, setting forth its objectives based on its problems and needs. We encourage districts to review these plans annually so that, if necessary, revisions may be made in order to keep abreast of the resource needs of an ever-changing society. The objectives of the Illinois Department of Agriculture and its 98 districts include, as applicable: Protecting land against soil deterioration, rebuilding damaged land, improving croplands, grasslands, forests, recreation areas and wildlife habitat; reducing flood water and sediment damage; stabilizing critical runoff and sediment-producing areas; developing water for agricultural, municipal, industrial, recreational, and wildlife uses; proper drainage and irrigation; abatement of wind erosion; and in general, abating the pollution of our air, water, and land resources. The objectives also include needed attention to the use of soil survey, geologic and other information in guiding sound expansion of housing, recreational and industrial developments; protecting agricultural areas against unwise and unnecessary encroachment; selective location of roads, highways, pipelines, areas suitable for the disposal of solid wastes; and improving the natural beauty of the countryside. For more detailed and further explanation of the goals of the Illinois Department of Agriculture, the primary objectives are categorized as follows: LAND TREATMENT Of first priority in the department's objectives concerning the conservation and development of our renewable natural resources is land treatment. Land treatment covers a broad scope of conservation practices and ideas concerning proper land use and involves the basic idea that the best way to prevent erosion, control floods, abate pollution, and make efficient use of moisture for crop production is to control the raindrop where it falls. It is an objective of the Illinois Department of Agriculture to protect and develop each acre of land in this State according to its capability, taking into account the economic, esthetic, and ecological needs of the people. Treatment may include conservation tillage practices, parallel tile outlet terraces, regular parallel terraces with grassed waterways as outlets, contouring, pasture improvement, reforestation or protection and development of existing forests, stabilization structures, including ponds, tile outlets, diversions, etc. Land treatment, in addition to conserving the land resource and making more efficient use of the raindrop-reduces immeasurably the accumulation of silt, herbicides, insecticides, and fertilizers in our water supply reservoirs, lakes, and streams; thereby alleviating pollution, the destruction of fish habitat, and reduction of channel and reservoir capacity. Wind erosion is also becoming a major problem that must be solved, and can be solved by use of such practices as conservation tillage, cover crops, shelter belts, spring plowing, and other means. FLOOD CONTROL It is the objective of the Illinois Department of Agriculture to alleviate flood problems, both rural and urban, wherever it is economically feasible. We are alleviating many flood problems through the Watershed and Flood Prevention Act, Public Law 566, which is an effective approach in obtaining technical and financial assistance in dealing with flood problems in watersheds of 250,000 acres or less. It is our opinion that land treatment practices which are used to make better use of the raindrop and control erosion also contribute much toward alleviating flood problems. For more effective control of floods, we recommend flood retention reservoirs and channel improvement. It is our policy, wherever possible, to locate reservoirs in the upper part of a watershed in sites which will take up a minimum of good farmland. We realize, however, that this policy cannot always be followed; especially when multiple needs demand large impoundments. Diversions, pumps, and levees are recommended wherever applicable. MUNICIPAL AND/OR INDUSTRIAL WATER SUPPLY It is the policy of the Illinois Department of Agriculture to encourage efficient use of the limited reservoir sites in this State. In the development of Public Law 566 and other resource projects, the department encourages communities to include water for municipal and/or industrial uses in flood control and other reservoir sites wherever the need is apparent and the site is feasible. The department is concerned about the limited major reservoir sites in this State, and encourages the State to either acquire outright or zone those sites still available. There are areas in the State where our underground water is in short supply and/or is not potable. It is an objective of the Illinois Department of Agriculture to encourage rural communities (population 50,000 or less), farmers and rural residents, to make use of available reservoir sites for the provision of additional water supply for households and livestock, together with filtration and delivery systems. The department strongly urges that Federal and State governments provide generous grants and low interest, long-term loans for this purpose. IRRIGATION Irrigation is being used in limited areas of the State, especially on sandy soils in river bottoms where there is unlimited ground water. There are many areas where raising of high value crops would warrant provision of additional water in surface reservoirs for irrigational uses. High seed populations and intensive use of fertilizers may one day require additional water to augment this limiting factor in the production of high crop yields. The department encourages careful consideration of the need for water for irrigation when developing reservoir sites. The Public Law 566 program cost shares for this purpose, and we also encourage financial and other assistance from the State level. FORESTRY Reforestation and the protection and development of existing forests is recognized by the department as being important as a source for Christmas tree and wood production, for providing recreational areas, for beautification and for the protection and conservation of our land and water resources. The department strongly urges individual landowners, corporations, and others who control the land to apply forestry practices where practicable. |