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agriculture on our eastern shore is dependent upon adequate drainage. At the same time, Maryland is blessed with several types of wetlands which are important to the survival of many fish and wildlife species.

The principal Federal agency participating in channel work in Maryland is the Soil Conservation Service under its Public Law 566 program. The benefits that are claimed for these projects are increased crop production and better farm operation. It is claimed that drainage permits the operation of heavy equipment in the critical periods of the spring and fall when the land is either being tilled or the crops are being harvested. Public Law 566 projects do not claim new land being brought into production as a benefit. Some conservationists have claimed that such projects have destroyed valuable wetlands.

This department is currently supporting the planning of Public Law 566 projects with an annual contribution of $30,000 per year. Our department is a member of the overall department of natural resources which includes the Maryland Fish and Wildlife Administration. The department of natural resources and its member agencies are currently working with the Soil Conservation Service in the planning of these projects in order that we may find compromise solutions for the benefit of all concerned.

In Maryland, at least, the Soil Conservation Service has demonstrated a willingness to cooperate with us in seeking an equitable solution to problems. By the time the work plan is completed and an environmental impact statement is prepared all of the various problems have been resolved.

One of the problems with the Public Law 566 program and similar Corps of Engineers' programs is that they are structurally oriented programs, that is, if the Soil Conservation Service finds that a dam cannot be built or a ditch cannot be dug economically that is the end of their participation. These are requirements that are imposed by Congress. Our recommendation is that the Public Law 566 program be expanded to the extend that it can solve broad resource problems. When a work plan is prepared, it should include nonstructural measures for solving problems as well as structural solutions. For example, why couldn't the work plan include the delineation of a floodplain and provision for local government adopting land use controls to prevent food damage?

hope that your committee finds these comments helpful. If we can be of any further assistance, please contact us. Yery truly yours,

Paul W. McKEE,

Director.

STATE OF MARYLAND
Fish AND WILDLIFE ADMINISTRATION,

Annapolis, Md., June 7, 1971.
Hon. HENRY S. Reuss,
Chairman, Conservation and Natural Resources Subcommittee,
Rayburn House Office Building, Washington, D.C.

DEAR CONGRESSMAN Reuss: Thank you for your letter to Mr. Manning of April 26, 1971, inviting comments on the various agencies handling responsibilities and operations concerning the improvement, modification, and channelization of streams and rivers. I am sorry that we have not been able to answer your letter sooner, but appreciate being able to comment.

We have a very strong interest in this area of activity in Maryland because of our many tidal estuaries ending in low lands which have been and are being channelized by the Soil Conservation Service. Much of this activity we feel is extremely detrimental to many of our natural resources and is destroying habitat for various fish and game species. This habitat once destroyed is almost irreplaceable. I am attaching a brief report prepared by two of our biologists that have been directly concerned in this matter, and are authorities in this particular field.

Again, I am sorry this has been delayed but as this has been an extremely busy period for us we could not prepare a suitable report sooner. Thank you again for the opportunity to comment. Sincerely,

FRED W. SIELING,

Assistant Director.

River AND STREAM CHANNELIZATION PROJECTS: CONSERVATION AND

NATURAL RESOURCES SUBCOMMITTEE During the past 25 years, agricultural drainage projects under the supervision or guidance of the Soil Conservation Service, including, but not limited to Public Law 566 projects, and ASCS drainage practices have resulted in the loss of 11,960 acres of Maryland marshes and swamp of 5 or more acres in size. Unfortunately, we have no acreage figures for marshes and swamps which are less than 5 acres in size. Wetland types: 1

Loss in acres 2- Inland fresh meadow.

675 3—Inland shallow fresh marsh.

483 7-Wooded swamp.

10, 791 12— Coastal shallow fresh swamp

9 16-Coastal salt meadow.

2

11, 960

Total.--1 Types according to Department of Interior, U.S. Fish and Wildlife Service “Circular 39, Wetlands of the United States.'

It may be noted that Federal cost sharing programs administered under ASCS prohibit the use of Federal funds to drain certain types of wetlands: “Cost-sharing or technical assistance shall not be authorized for draining land described as wetland type 3, 4, or 5.'' 2

It is doubtful that there is any agricultural drainage ditch dug in Maryland which does not receive some Federal cost-sharing or technical assistance.

The above figures show that during the last 25 years, Maryland has lost 483 acres or 65 percent of all type 3 inland shallow fresh marshes of 5 acres or larger in size. How many hundreds or thousands of acres of type 3 wetlands less than 5 acres in size which have been lost is impossible to determine.

Just as Maryland expects other States and countries to provide waterfowl for the excellent recreational opportunities we have on Chesapeake Bay, it is Maryland's duty to supply a fair share of certain species of waterfowl to other States. Many of these waterfowl species, in particular the black duck, wood duck, mallard, gadwall, and blue-winged teal, nest and raise their young in the marshes and swamps of Maryland.

As an example, wood ducks produced in Maryland are harvested and observed in all the States in the Southeast, black ducks raised in Maryland have been harvested northward into Canada, westward into Ohio and southward into North Carolina; and blue-winged teal travel to South America. Every acre of wet land lost in Maryland means a corresponding drop in waterfowl populations in Maryland, other States and other countries.

Hunters today have received much criticism for decimating, among other things, waterfowl. It is time much of the blame was placed in the proper perspective.

Estimates of wetlands drained for primarily agriculture and flood control have been calculated to be approximately 50 million acres in the United States. If each of these destroyed wetland acres produced one duck we would have 50 million additional ducks per year which is 40 to 100 percent of the annual duck harvest during the past 15 years. Also, canvasback and redhead ducks would not be at such critically low levels and some of the other duck populations would not be at such low levels as they are today.

Additional wetland destruction for any purpose will only aggravate these already serious problems and may well lead to the extinction of several species of waterfowl. It would be a shame to see the canvasback duck pass into oblivion just to produce additional surplus agricultural crops or to protect industries and homes in food plains where they should not be in the first place.

Benefits of channelization projects to upland wildlife is questionable. Most wildlife can stand seasonal, periodic flooding within their niche. Once an intermittent wetland area is channelized, clearing of the now dry woodlands soon follows with complete obliteration of any wildlife habitat in order to make way for cropland. One only has to review the present habitat along the recently drained Long Marsh Ditch on the Queen Anne's-Caroline County line in order to determine the irreplaceable damage done to wildlife resources in the area.

Channelizing increases erosion, speeds runoff and greatly decreases the filtering qualities of the adjacent habitat. The results are sedimentation and further de

2 "National Agricultural Conservation Program for 1968 and Subsequent Years", Federal Register of August 1, 1967 (32 F.R. 11117).

struction of wetlands and waters downstream. Flooding occurs in the lower reaches of the channelized stream during heavy runoff. Pesticides and pollutants are concentrated downstream.

According to a recent conservation needs inventory conducted by the Soil Conservation Service in Maryland, every major stream system on the Eastern Shore of Chesapeake Bay has a favorable cost-benefit ratio for a Public Law 566 drainage channel. Maryland's Eastern Shore contains more than 80 percent of the State's wet lands. If these drainage projects are carried out, significant waterfowl nesting, migrating and wintering areas will be lost, not to mention the losses to fisheries, furbearers, and other wildlife dependent on specific wetland habitats.

It is these same systems that provide Chesapeake Bay with the most productive finfishery on the Atlantic Coast. Some 50 or more species of fish utilize Maryland tidal and near tidal streams for a part or all of their lives. Most important of these are shad, herring, and striped bass. A significant proportion of the Atlantic striped bass stock are produced in the tributaries of Chesapeake Bay. Herring, produced in the Chesapeake Bay, make up an important part of the herring fishery as evidenced by recent tag returns from Russian trawlers working the North Atlantic.

These fish are produced in the same streams in which channeling is proposed. Enough studies have been conducted to date to show that when a stream is channeled it ceases to produce fish.

The main question before us is whether or not channelization should continue with resulting losses to important fisheries and wildlife resources of Chesapeake Bay and the Atlantic Coast. Should such costly destructive practices be allowed in order to produce questionable benefits to an agricultural community that is already producing surplus crops?

Prepared by: J. R. Goldsberry, V. D. Stotts, May 1971.

STATE OF MARYLAND,
DEPARTMENT OF NATURAL RESOURCES,

Annapolis, Md., June 9, 1971.
Hon. HENRY S. REUSS,
Chairman, Conservation and Natural Resources Subcommittee, Congress of the

United States, Rayburn House Office Building, Washington, D.C. DEAR CONGRESSMAN Reuss: Thank you for your invitation to submit a statement for consideration by your subcommittee on various agency's programs related to the improvement, modification, and channelization of streams and rivers. During the course of the hearings you will probably receive testimony from governmental agencies such as the Corps of Engineers and the Soil Conservation Service, stating their policies and procedures for considering the environmental effects of their programs and procedures and, on the other hand, statements from "conservation' associations charging adverse environmental impacts from various agencies' projects. My Department has enjoyed generally cooperative relationships with such Federal agencies during the planning and implementation of their programs and projects. However, I wish to comment on one Federal assistance program which is of particular concern to the State of Maryland: the agricultural drainage program administered by the Soil Conservation Service.

Drainage of wetlands has been pursued as a program of significant national benefit for many years; with technical and financial assistance from the Soil Conservation Service in recent decades. The program goal is to minimize the adverse effects of excess water on agricultural lands; thus providing agricultural landowners a more certain annual income. The Soil Conservation Service's efforts have been highly successful. However, in recent years, two major policy changes have occurred. First, the Congress, reflecting recent public awareness of the value of wetlands, passed the Water Bank Act of 1970 which provides for reimbursement to landowners who agree to refrain from drainage activities. Second, public programs have been developed to retire or divert cropland from agricultural production as the Nation's ability to produce has exceeded the market demand for food. There seems to be a conflict in policies when we as a Nation subsidize the construction of agricultural drainage channels which significantly adversely affect wetland environments and increase food production, while at the same time, offer payments to encourage the protection of wetlands and to reduce cropland production.

Certainly there is reason to doubt any drainage project if the stated objective is to increase the national supply of food. It is widely recognized that nutritional deficiencies, where they are found in this Nation, are not faults of the productive capacity of American agriculture. In fact, the land retirement programs make Federal payments annually to prevent production on more than 50 million acres, and the Federal Government purchases large quantities of agricultural commodities at the legal support prices. Therefore, it is quite obvious that the drainage program can no longer be justified on the basis that the national supply of food is increased. Further, if national increases in food production are desired, they could be more efficiently achieved by application of a variety of agricultural science and technologies to existing well-drained lands-usually with less adverse environmental impacts than channelization projects.

Reduction of consumer food expenditures is, similarly a questionable objective of the agricultural drainage program-questionable in light of agricultural price support policies and other public programs designed to artificially maintain the price of agricultural products, thereby increasing the income of agricultural producers. Although agricultural drainage projects produce minimal national benefits, benefits to individual landowners, in terms of increased productivity per acre, do represent increases in income. The income increases resulting from reduced probability of crop losses, provide a definite incentive to channelize. I recommend that this incentive be eliminated.

My department recognizes the problem that uncertainty creates for the farmer. We do not wish to see Maryland farms abandoned because natural conditions are so uncertain that profitable returns cannot be insured, since maintaining a viable agricultural sector is an objective of the State of Maryland. At present, the Soil Conservation Service administered program is the only available federal method for reducing the uncertainty of flood damaged crop losses. I would suggest that your subcommittee include within the scope of its investigation alternative means of reducing the uncertainty of farmers whose crops are periodically affected by flood waters. A national crop insurance program similar to the flood insurance program could be successful in relieving uncertainties. Alternatively, an expansion of funds for the Water Bank Act would allow farms to increase the acreage of land held as "wetlands” while maintaining an overall income.

We often receive petitions from farmers who claim they need a drainage project if they are to survive as farmers. The federal government does not presently offer agricultural landowners effective alternative means of obtaining the security of annual incomes. A federally subsidized crop insurance plan could provide such an alternative. To eliminate apparent conflicting public policy, to reduce the environmental loss from agricultural drainage projects, while at the same time providing farmers with the certainty they need to remain in agriculture, I suggest your subcommittee consider amending Federal law (Public Law 83-566) to eliminate Federal subsidies to agricultural drainage projects and examine several programs, including a publicly subsidized crop insurance program, to reduce the uncertainty due to natural conditions, and seek to initiate the most feasible program as national policy. While the States can strive to reduce any adverse environmental impacts of agricultural drainage projects, the Congress has the opportunity to remove the Federal incentive for such projects while instituting effective alternative programs to maintain or enhance the status of agricultural land owners. Sincerely yours,

J. Millard Tawes, Secretary.

MASSACHUSETTS
THE COMMONWEALTH OF MassaCHUSETTS,
DIVISION OF FISHERIES AND GAME,

Boston, Mass., June 1, 1971.
Hon. HENRY S. REUSS,
Chairman, Conservation and Natural Resources Subcommittee,
Congress of the United States, House of Representatives,
Rayburn House Office Building, Washington, D.C.

DEAR CONGRESSMAN Reuss: This letter extends our comments relative to your request for information pertaining to the effects of completed or planned stream improvement projects in Massachusetts that are conducted by Federal agencies or involve Federal financing.

Massachusetts is perhaps fortunate in that the general topography lends itself toward the construction of flood storage structures rather than stream improvement measures for flood prevention. The two agencies most frequently involved with flood control projects in the Commonwealth are the Soil Conservation Service's Public Law 566 program and the Army Corps of Engineers.

To date, the Soil Conservation Service has not undertaken any channel improvement work, except for small reaches below the outlets of principal skillways at retarding structures. Currently, there are nine Soil Conservation Service projects, either in preliminary or advance stages, that include some channel work. These planned channel improvement measures will supplement programs of land limited to very short reaches to remove local constrictions with little actual disturbance to the environment. However, one of the aforementioned projects would involve approximately 242 miles of channel improvement on the Upper Quaboag River Watershed. The Division anticipates that this project would be highly detrimental to the associated fish and wildlife resources and has so informed the Soil Conservation Service. It is now my understanding that a supplemental work plan is presently being prepared which would delete this channelization and substitute two additional flood prevention structures.

The stream improvement measures constructed and planned by the Army Corps of Engineers again are usually supplemental to programs of land treatment and food storage structures. However, one ongoing project, the New England Water Supply Study, being conducted by the corps, plans for considerable manipulations of major river systems. The Division of Fisheries and Game in cooperation with the Bureau of Sport Fisheries and Wildlife is presently evaluating the proposals and advising the corps on those features to which we have some objection. To date, most of our recommendations have been included into the corps' preliminary work plan.

The Corps of Engineers has just recently demonstrated a significant departure from their standard policies and procedures within Massachusetts. The corps is recommending that 8,500 acres of Charles River marshes be procured through easements or acquisition to be preserved in its natural state in order to prevent future flooding problems that might arise as the area becomes more urbanized. In principle, this is very definitely a trend in the right direction; nevertheless, it is difficult to evaluate the actual benefits to fish and wildlife since no works of improvement can be constructed. If ese areas are not managed then natural plant succession will proceed resulting in the loss of wildlife habitat as well as the wetlands capacity to hold food waters. Therefore, the Division recommends that if this preserving of natural storage areas becomes national policy, the respective States or Federal fish and wildlife agencies should have first option of leasing said lands in order that they may be properly managed.

Although Massachusetts has had limited channel improvement work performed by Federal agencies for flood prevention, we are facing problems with the use of Federal funds for channelization in conjunction with the construction of public highways. The Massachusetts Department of Public Works has for some time been using Federal aid for the relocation of rivers or the partial filling of ponds when the road bisects the same. In most instances, these stream relocations are small, without much consequence to fish and wildlife. However, one recent project, still in the preliminary stage, involves the extension of Route 25 through the northern section of the Hockomock Swamp, the largest uninterrupted inland wetland in New England. The Hockomock is a highly productive fish and wildlife area, particularly for waterfowl. The present plans for the extension of Route 25 is to relocate over a half-mile reach of the Canoe River which leads out of the Hockomock. A straight, dug out ditch will replace the natural meanders of the Canoe River. The Division anticipates that this stream improvement measure may rapidly drain

portions of the Swamp right at the time when water is needed for waterfowl production. Furthermore, this relocation will probably have adverse effects upon the cold water fisheries downstream of the Canoe River. Therefore, the Division recommends that an amendment be made to the Federal Bureau of Public Roads Instructional Memorandum 21-5-63 that whenever a relocation of a stream is deemed necessary, the new channel shall approximate the existing channel as closely as possible.

The Division of Fisheries and Game wishes to be recorded in support of the recommendations as set forth by Mr. Charles D. Kelley, chairman, Water Resources Committee, International Association of Game, Fish and Conservation Commissioners in his letter to you dated April 23, 1971.

We hope that this has been of some assistance to you. If, however, you have any further questions or additional information needed, please do not hesitate to contact this office. Sincerely yours,

JAMES M. SHEPARD, Director.

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