which benefits were claimed. The Federal share for channel construction costs was estimated at $51 per acre. Land in this watershed was valued at an average of $72 per acre in 1957 when the project was planned. Are these high expenditures for structural measures justified in view of the few people that receive benefits? Upstream landowners on many watershed projects resent paying special tax assessments to support watershed projects from which they receive no benefits. This feeling, along with objections to donating or paying for land rights and easements for structural measures, has resulted in the termination of Federal assistance to the east and west forks of Clarks River watershed projects in west Kentucky. One former, now retired, Soil Conservation Service conservationist who worked for years on small watershed projects in west Kentucky has expressed his opposition to channelization (see attached exhibit A).

Historic perspective of privious private drainage efforts in many west Kentucky streams, shows that drainage ditches were not maintained because of high costs. They eventually filled-in and now local landowners are calling for Government aid to rechannel these streams. The Humphrey-Clanton watershed in Ballard County is an example of the failure of previous drainage efforts. Portions of Clanton Creek were channelized during 1918-19 by private enterprise. Landowners below the lower end of this channel suffered floodwater damage and the channel soon filled up with silt. Clanton Creek was again channelized during 1965 with Public Law 566 funds, terminating approximately 41⁄2 miles above its Ohio River outlet. The wind deposited loess soils of this area are highly erodable. The lower portion of Clanton Creek Channel shows this clearly with slumping banks and silt deposits in the channel (see photo and letter marked exhibit B). Lack of maintenance by the watershed conservancy district has allowed small silt islands to form and willow trees to sprout within the channel. Because of upstream silt, debris and a restricted natural channel below the termination of Clanton Creek ditch, the State's Ballard waterfowl area has suffered some flood damage to agricultural fields growing crops for waterfowl. A private landowner across the channel from the waterfowl area is also receiving silt and scour damage to his land. As a result, the only alternative is to extend the channelization another 7,600 feet throught the waterfowl area in order to alleviate the flood damage. Not only are surplus crops and Federal expenditures to control them increased by these drainage and flood control projects, but other inconsistencies are evident. Acquisition of important and fast disappearing northern waterfowl breeding wetlands are financed by Federal duck stamp funds and the recent Waterbank Act (Public Law 91-559) seeks to compensate landowners for preserving certain classes of wetlands. Of what benefit is saving waterfowl breeding areas if federally subsidized Corps of Engineers and Soil Conservation Service watershed projects are destroying resting and feeding areas used by migrating waterfowl in the Mississippi flyway?

In the lower Mississippi Valley, a shift from forest to cropland is underway mostly for soybean production. Approximately 1,500,000 acres of Mississippi Delta timberlands have been cleared between 1960-69 in Arkansas alone (3). Many farmers are clearing bottom land hardwoods for soybean production in hopes of receiving large quotas should soybeans be brought under a Federal acreage control program. One northern land development company has already cleared 31,500 acres in Arkansas, 14,000 acres on the Sunflower River in Mississippi and 47,000 acres in Louisiana for soybean production (4). In many of these areas, Federal drainage projects speed the destruction of bottom land timber for soybean production. As Federal flood control creeps into the delta, water tables drop and tree root zones dry out. This has not only destroyed valuable timbered wildlife habitat, but some commercial forest products companies have been forced to clearcut their dying or slow growing timber and turn to soybean production. (4) The soil, dried out by channeling, is no longer capable of growing commercially valuable bottom land timber which requires high water tables and periodic flooding. The recent completion of a West Virginia Pulp and Paper Co. mill in west Kentucky has opened up a new and continuing market for bottom land hardwoods. This industry is concerned that channelization will accelerate clearing of wetland timber for crop production and destroy what could be a sustained supply of pulpwood. The 1970 Kentucky Soil and Water Conservation Needs Inventory states, "the annual harvest of 13.8 billion cubic feet of timber is projected for 1980, approximately 35 percent more than was harvested in 1962" (5). This publication further states, Areas devoted primarily to recreation and wildlife uses are expected to expand from an estimated 62 million acres in 1959 to $1 million acres by 1980. This 19 million acre increase is expected to consist of 6 million acres of forest land and 13 million acres of nonforest land." Demand for our wildlife, wet lands and timber resources is increasing, while cropland acreage is in oversupply.

Drainage and channelization of tributary streams leads to a domino effect of downstream drainage and flood control projects. All five of the Public Law 566 projects mentioned previously are complimented by Corps of Engineers channelization surveys of drainage proposals on the main streams serving as outlets for the watershed channels. These projects serve to push the sediment and water load into the Mississippi River, increasing dredging costs for maintaining navigational channels and raising flood levels. Despite expenditures of billions of dollars for structural flood control measures since 1936, the yearly costs of destruction by floods has continued to increase (6). Man's engineering mentality has attempted to overwhelm and dominate nature's use of bottomlands as natural floodplains by constructing dams, dikes, and channels. The natural use of many of our wetlands by man is the wisest choice in the long run. Instead of attempting to accelerate water velocity through channelization, why not funnel the excess water into natural marshes and timbered wetlands? Present funds allocated to channel construction could be used to purchase such areas in fee title and managed for recreation and fish and wildlife production. Wetlands serve to spread out and retard floodwaters, remove silt, recharge ground water supplies, trap excess nutrients and regulate streamflows. A 10-acre marsh will hold 3 million gallons of water in a 1-foot rise. Nature provides these areas free of charge, but man must recognize their multiple uses. In the report of the President's Council on Recreation and Natural Beauty it states, "Natural waterways that are used by floodwaters have in effect an easement placed upon them by nature for intermittent use. Man's encroachment into the flood plain violates the natural easement and often adversely affects the vested public interest" (8).

Since structural measures have failed to stem the tide of flood damages, use of more nonstructural measures should be explored and increased. Forestry, recreation and fish and wildlife uses might constitute adequate returns from many bottomlands without the expenditures of public funds for flood control. The Federal Council for Science and Technology Committee on Water Resources in 1966, recommended a fivefold increase in research on nonstructural alternatives to flood control. The latest Soil and Water Conservation Needs Inventory (1970) stated that the "dominant problem in Kentucky is the susceptibility to erosion in each region for land suitable for cultivation” (5). A 1966 study of Kentucky streambank habitat showed that 41 percent of the 226 miles of stream margins surveyed had been altered (7). Agricultural clearing was responsible for a majority of the streambank habitat destruction. Accelerated bank erosion, warming water temperatures, destruction of aquatic life through siltation and lower water quality are the result of such streambank clearing. The majority of flooding of agricultural and timbered bottomlands in Kentucky's tributary streams is caused by lowered stream capacity due to silt deposition. This is due to degradation of the watershed by poor agricultural practices, clearing of streamside cover strip mining, logging, and highway construction. The Public Law 566 moneys presently spent on stream channelization could be more effectively diverted to the use of developing and implementing more efficient vegetative and cultural methods to stabilize soil conditions on the upper watersheds. Stream channelization funds should also be used to supplement cost-share rates for vegetative and cultural practices that control sediment and water runoff on individual farms in a watershed project area through going ASCS programs. The retention of soil and water on the upper watershed would have enduring benefits for more people downstream than the construction of channels to speed the water and silt downstream.

While much attention has been paid to stabilizing upstream sediment sources, watershed project funds have not been spent on streambank erosion control in Kentucky. The present Watershed Handbook (paragraph 104.0411) states that streambank stabilization by vegetative and minor structural means is authorized under the present Watershed Act. Instead of stabilizing natural or man-caused streambank sediment sources, the practice is to destroy a stream and replace it with a ditch. More effort should be made to minimize disturbance to natural stream channels and banks and improving in bank flow capacity by removing silt and obstructions and controlling erosion by vegetative and minor structural means. Mechanical methods for removing silt and debris from stream channels without having to destroy vegetation for 100 feet on each side of a stream should surely be available in today's advanced technology.

At times, channelization is substituted for upstream retention structures because of the inability of local sponsors to acquire the necessary high-cost land rights. This substitution prevailed in the planning of the Highland Creek watershed project in Henderson, Union, and Webster Counties, Ky. The original

Soil Conservation Service watershed work plan includes nine floodwater retention structures and 14.8 miles of stream channelization. Local interests were unable to purchase land rights for the necessary flood retarding structures. Instead of informing the local sponsors that this was the best proposal with the least detrimental environmental impact, the SCS submitted a revised plan. This second work plan included no flood retarding structures and 43 miles of stream channelization. The elimination of the upstream flood retarding structures and substitution of extensive channelization to satisfy local demands, does not conform with the true concept of wise water conservation. Fortunately, this plan was later withdrawn by the SCS. However, the Corps of Engineers has now initiated a survey to study the advisability of providing improvements for flood control. The mitigation of fish and wildlife damages caused by watershed channels has not been satisfactorily resolved in our State. At best, it is impossible to replace rapidly vanishing and important wildlife wetlands, even through replacement in kind. Unless fish and wildlife mitigation costs are paid 100 percent by Public Law 566 funds, local sponsors seldom accept their share of these costs. The Watershed Act allows sponsors to accept or reject their share of fish and wildlife mitigation costs. Furthermore, it must be clearly demonstrated that the structural measures are causing significant damage to fish and wildlife resources. If channelization enables private landowners to clear and drain wetlands, this is not considered as a direct effect (damage) due to the structural measures (channel), but an independent action of an individual. How can fish and wildlife damages be clearly demonstrated under these circumstances? Mitigation in SCS terms is to leave some streamside vegetation where feasible, or cut off a bend to form an oxbow lake. Under the present Watershed Act, it is impossible to satisfactorily mitigate channel-caused fish and wildlife damages. The only acceptable reimbursement for fish and wildlife damages would be to replace in kind the lost habitat. This would probably raise the cost side of the benefit-cost criteria to an unacceptable level. We would prefer that all channelization be stopped until a more satisfactory solution is found. There are alternatives to the present watershed program.

1. Recognize flood plains as natural areas that spread out floodwaters at little or no public expense. This should be part of all legislation dealing with the expenditure of funds for the control of soil erosion, flood control, and drainage. 2. Institute flood plain zoning on a national level. Institute grants or matching funds to States for flood plain zoning and planning.

3. Strengthen and expand legislation such as the Waterbank Act to retire flood-prone wetlands that are now marginal for agricultural production. Recognize recreation, fish, and wildlife uses as acceptable in any land retirement programs. Pay for flood routing of water through natural wetlands on watershed projects by purchase of easements or through a land retirement program.

4. Direct present expenditures for channelization into research for better vegetative and cultural methods to control and stabilize soil and water. Sediment is still the number one agricultural problem. Also, put more emphasis and moneys into vegetative and cultural practices on individual farms within watershed project areas through present Agricultural Stabilization and Conservation Service and Soil Conservation Service programs. These funds should be earmarked for watershed use only.

5. Amend the Watershed Protection and Flood Prevention Act to require at least 75 percent of lands above water and silt retention structures be included in proper farm plans or soil conservation measures.

6. Put more emphasis and funding into going programs of the ASCS and SCS for stabilizing and maintaining streambanks through vegetative and minor structural measures.

7. Recognize ecological and fish and wildlife losses caused by structural measures and include replacement in kind as part of watershed project costs. This could include diverting and holding water on natural wetlands which would be purchased as a part of project costs and turned over to an appropriate natural resource agency for management.

8. Call a moratorium on watershed channelization until new and less environmentally damaging water control methods are developed.

9. Amend the Watershed Act to give State fish and wildlife agencies more voice in reviewing watershed work plans.

10. Make fish and wildlife mitigation measures, including replacement of habitat in kind, an integral part of watershed work plans that must be accepted as a package by local watershed sponsors.

REFERENCES

1. The First Annual Report of the Council on Environmental Quality. Environmental Quality. 1970. U.S. Government Printing Office, Washington, D.C. 326 pages.

2. Goldstein, J. H., 1967. An economic analysis of the wetlands problem in Minnesota. University of Minnesota, unpublished thesis. 115 pages.

3. Holder, Trusten, 1969. The destruction of our most valuable wildlife habitat. Twenty-third annual conference of the Southeastern Association of Game and Fish Commissioners, Mobile, Ala. 11 pages.

4. Potlatch Farmer in the Delta. The Potlatch Story, April 1969.

5. Kentucky Soil and Water Conservation Needs Inventory. 1970. Soil Conservation Service. U.S. Department of Agriculture. Lexington, Ky. 256 pages.

6. National Academy of Sciences. 1970. Land use and wildlife resources. Committee on Agricultural Land Use and Wildlife Resources. National Research Council. National Academy of Sciences, Washington, D.C. 262 pages.

7. Russell, Dan M., 1966. A survey of streambank wildlife habitat. Southeastern Association of Game and Fish Commissioners, 20th Annual Proc. 5 pages. 8. President's Council on Recreation and Natural Beauty. 1968. From sea to shining sea. A report on the American environment. U.S. Government Printing Office, Washington, D.C. 304 pages.

Submitted for the record are the following exhibits:

Exhibit A: Letter from former SCS conservationist expressing opposition to watershed channelization.

Exhibit B: Letter from farmer with land along the lower end of Clanton Creek Watershed channel dug in 1965. (Ballard County, Ky.). Three photographs showing channel siltation and bank slumping due to highly erodable loess soils and a lack of maintenance of the channel. Descriptions are on reverse side of photographs.

EXHIBIT "A"

Congressman HENRY REUSS,

FULTON, KY., May 10, 1971.

Chairman, Conservation and Natural Resources Subcommittee,
Committee on Government Operations,

Rayburn House Office Building, Washington, D.C.

DEAR CONGRESSMAN REUSs: The following letter is a copy of one that I sent to Mr. Joe Bruna, game biologist of the Kentucky Department of Fish and Wildlife Resources on January 11, 1971. It expresses my feelings on the use of channelization under the Small Watershed and Flood Protection Act. I would like to have this statement entered in the record of your hearings on channelization.

"I appreciated your comments in the Courier-Journal of January 10, 1971, about the channeling problem. I worked as a Soil Conservation Service conservationist in the Jackson Purchase for many years on the small watershed program. I can agree with the small, upstream water and silt retain program, but have been opposed to the engineers channelizing. The improvements have always been minor, and of benefit to a few. I hope it can be slowed down."

Very truly yours,

NORMAN TERRY.

(SUBCOMMITTEE NOTE.-The letter referred to is in the subcommittee files.)

Congressman HENRY REUSS,

EXHIBIT "B"

LA CENTER, KY.

Chairman, Conservation and Natural Resources Subcommittee,

Committee on Government Operations,

Rayburn House Office Building, Washington, D.C.

DEAR CONGRESSMAN REUSS: I own a farm on the lower end of Clanton Creek, which was channelized in 1965 as part of the Humphrey-Clanton watershed project, located in Ballard County, Ky. I feel that this ditch has helped drain my bottomlands, but it is filling in with silt and trees. The watershed district has failed to maintain it properly and the channel below the end of the Clanton Creek

ditch is not large enough to take care of the water and silt. As a result, the silt is being deposited in the lower end of Clanton Creek ditch which is on my farm. The banks along my portion of the ditch are eroding and eating into my fields. About 1918-19, Clanton Creek was dredged but not maintained, and it filled up again. I'm afraid that this same thing will happen unless the ditch is cleaned out and properly maintained.

I would like this letter entered as a statement in your hearings on channelization. Respectfully yours,

ARMON LOWERY.

Clanton Creek channel on the Humphrey-Clanton watershed project in Ballard County, Ky. Channel completed in 1965. Picture taken December 1970. Shows lack of maintenance. Channel banks have fallen in and willows have started to grow. Despite the heavy fescue sod on the channel banks, this type of loess (wind deposited) soil is subject to severe erosion.