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MICHIGAN

STATE OF MichiGAN,
DEPARTMENT OF NATURAL RESOURCES,

Lansing, Mich., May 6, 1971.
Hon. HENRY S. REUSS,
Chairman, Conservation and Natural Resources Subcommittee, House of Representa-

tives, Rayburn House Office Building, Washington, D.C. DEAR MR. Reuss: We appreciate having this opportunity to respond to your letter of April 27, 1971, advising us of your subcommittee's investigation of various Federal agency activities and their responsibilities and operations concerning works of improvement involving the streams and rivers of our country:

We are pleased to be able to advise you that the department of natural resources has enjoyed an unusually strong and well established line of communication and cooperation with both the U.S. Corps of Engineers and the Soil Conservation Service in their activities here in Michigan.

Through the years my staff has had the opportunity to effectively and openly involve themselves in very careful and critical reviews during planning phases of these two agencies' projects. This has brought about a further unusually strong relationship and results in annual meetings of the staffs of these two agencies to discuss new phases of their programs and responsibilities. Sincerely,

Ralph A. MacMullan, Director.

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STATE OF MICHIGAN,
DEPARTMENT OF NATURAL RESOURCES,

Lansing, Mich., May 14, 1971.
Hon. HENRY S. Reuss,
Chairman, Conservation and Natural Resources Subcommittee, Committee on Govern-

ment Operations, U.S. House of Representatives, Washington, D.C. DEAR Mr. Reuss: Your letter of April 27 requesting comments on changes or improvements in programs of certain Federal agencies concerned with modification and channelization of streams and rivers has been received.

Your letter emphasizes that benefits in the form of flood control, improved navigation, erosion control, etc., also result in numerous adverse effects on fishery resources, destruction of wildlife habitat, greater eutrophication and destruction of esthetic values.

You request our views on water resource improvement projects in Michigan which have been constructed or are planned to be constructed by the Federal Government or with the aid of Federal financing.

In order to avoid a lengthy letter detailing our problems, complaints, and accomplishments, we will restrict our response to philosophy and discuss the program being followed in Michigan.

A reorganization of State agencies in Michigan has consolidated water resource responsibilities in the department of natural resources. This has strengthened the State efforts and provided for better compliance with concepts of recent Federal statutes.

The Michigan Department of Natural Resources is strongly of the opinion that there must be a close Federal-State partnership in planning efforts, as well as implementation, if successful programs are to result.

Local and State governments have viewpoints on how they want to see the water resources used as they must live with the results. In the past, State agencies were sometimes bypassed concerning local sponsored projects through Federal agencies who dealt directly with the Congress. Fortunately, this is changing.

With the requirements now specified under the various cost-sharing programs, both in the planning field, such as Public Law 89-90 funds, and in cost sharing of construction funds, as in Public Law 566 and other Federal-State and local programs, partnerships are absolutely necessary to resolve water resource management problems.

It is our position that some fault and some past criticisms are due to inadequate efforts of State agencies in being a full-fledged partner. We believe opportunities are available under existing statutes and policy memorandums of Federal agencies to protect our water resources, providing we are given a chance to review them. The directive for filing “environmental statements” for each project receiving Federal assistance is a giant step in the right direction to bring the facts before the public and Congress as to adverse effects previously known only to a few conservationists. The new procedure now provides for checks and counterchecks in appraising each project in regard to all public benefits, the disadvantages and possible alternatives.

A major problem, as we see it at present, is funds to employ qualified personnel at both the Federal and State level to adequately appraise proposed projects and prepare objective statements which adequately portray unbiased positions. Making full use of the National Environmental Policy Act, Public Law 91-190, and complying with directives issued under its authority presents a real problem in the funding of required State efforts.

This same problem exists for a number of long-term studies carried out under the Water Resources Planning Act-the Great Lakes Basin study is an example where we have some 90 people contributing their efforts, and a number of other water resource studies assigned to the Corps of Engineers. A Federal project provides funds to the various Federal agencies involved, but none of the moneys, except in a few special studies, are made available to the State to fund or help fund its effort in the same project. As a result, we frequently find ourselves lacking in manpower and supporting services to provide the efforts or input expected from the State. Recommendations we offer are:

1. Make the fullest use of the National Environmental Policy Act.

2. Provide Federal assistance in funding State resource agency personnel to facilitate compliance with provisions of the act.

3. Authorize a portion of the allotted funds for Federal project studies to cost sharing for State personnel contributions in specific studies. You also inquire as to what extent this agency participates in the planning and development of such water-oriented projects.

While Michigan is not lacking in problems, we wish you to know that the planning process is working quite smoothly as a result of the efforts by both State and Federal agencies to communicate and cooperate. The Michigan Department of Natural Resources has been fortunate to enjoy a very close working relationship with the U.S. Army Corps of Engineers; the Soil Conservation Service, the U.S. Forest Service; and various bureaus of the Department of the Interior.

Judging from news media and from contacts with resource agencies in other States, such relationships do not always exist. We are strongly of the opinion that a "will" to work together on many complex activities inherent to water management project planning is necessary if a truly effective program is to result. Certainly, you can understand that "attitude" is most difficult to express in procedures, planning guidance, or in legislation. It is our opinion that personnel with proper "attitude" is a key factor in maintaining cooperative working relationships.

In regard to specific legislation, we wish to take this opportunity to inform you that we support H.R. 200 which would amend the Fish and Wildlife Coordination Act and repeal section 12 of the Watershed Protection and Flood Prevention Act. The objectives of the proposed legislation are to give greater voice to those speaking for the preservation of our natural waterways and fish and wildlife habitat in the planning of projects under Federal assistance. The proposed amendments should result in better projects with public interests more adequately protected. At the same time, they should increase the opportunities for achieving a balance of the various environmental considerations inherent in water management projects. Thank you for providing the opportunity to offer comments. Sincerely,

CHARLES D. HARRIS, Deputy Director, Resources Management.

STATE OF MICHIGAN,
DEPARTMENT OF NATURAL RESOURCES,

Lansing, Mich., June 22, 1971.
Hon. HENRY S. Reuss,
Chairman, Conservation and Natural Resources Subcommittee, Committee on Gov-

ernment Operations, Rayburn House Office Building, Washington, D.C. DEAR MR. REUSS: Thank you for your letter of May 20, 1971, and the opportunity to comment upon the effectiveness of water resource management and improvement projects being undertaken in Michigan by various Federal agencies.

As you may know, one of the most serious problems now facing this State along these lines is that of erosion along the Great Lakes shorelands during this current period of high water levels. Numerous studies are now underway, both at State and Federal levels, to alleviate damage to property resulting from this erosion problem.

We have been working closely on many studies of this nature with the Corps of Engineers and other Federal agencies and have been pleased with the cooperation and coordination extended by those agencies in these projects.

I would not like to leave you with the impression that we are not aware of the environmental implications of some stream improvement and erosion projects. We know that fish and wildlife habitats can be destroyed, that some dredging can hold potential pollution problems, and streamflows may be affected. We are also certain, however, that with proper planning and design, these problems can be held to a minimum, and in some cases enhanced, while providing flood control, agricultural water management, and harbor maintenance.

Overall, the assistance of certain Federal agencies on some projects in this State
has been most beneficial, and we would like to continue the working relationship
as has been successful in the past.
Thank you for the opportunity to submit our comments.
Very truly yours,

WATER RESOURCES COMMISSION,
RALPH W. PURDY,

Executive Secretary.

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MISSISSIPPI

STATE OF MISSISSIPPI,
GAME AND Fish COMMISSION,

Jackson, Miss., May 11, 1971.
Hon. HENRY S. Reuss,
Chairman, Conservation and Natural Resources Subcommittee, House of Representa-

tives, Rayburn House Office Building, Washington, D.C.
DEAR Sır: Reference is made to your letter of April 27, 1971, requesting our
comments on the projects of various Federal agencies.

We feel that the works of the Corps of Engineers and the Soil Conservation Service have had a detrimental effect on the fish and wildlife of Mississippi. Our commission has adopted a resolution opposing channelization of our streams because of the problems we have encountered.

In the Delta section of Mississippi the corps has installed flood control projects that have permitted the clearing of thousands of acres of wildlife habitat. These projects have consisted of channelization of all of the streams in this section of the State. When this happened, we lost our fish habitat.

The clearing of this land for agricultural use has increased the amount of pesticides used to where in some areas we have lost all of our largemouth bass and crappie because of these chemicals. In some lakes the levels of DDT exceed the allowable limits set by FDA regulations.

In one SCS project (Tippah River) fish population studies were done before the stream was channelized. It was found that this stream was carrying 242 pounds of fish per acre of all sizes and species of fish. Approximately 2 years after it was channelized we found that it had only 4.8 pounds of fish per acre of which four pounds were minnows.

At the mouth of this same stream approximately 1,500 acres of timber have been killed by silt from this project.

One excellent natural waterfowl area was also drained by the channel.
In other areas silt from the project has killed as much as 1,000 acres of timber.

We could show you mitigation measures on paper that cannot be found on the ground in project after project.

The gradual pecking away at our stream system by the corps and SCS has hurt our fish and wildlife resources tremendously.

In reply to your question on the extent we participate in the planning, we would have to say “None" until the last couple of years. Some projects were not even sent to us for review. In many others the local landowners had been given such a “hard sell” by the SCS or corps personnel that by the time we saw the project there was no way of convincing these people that it was not the best thing that could happen to them.

Within the last year we have been consulted a little more on projects, but with the limited funds and personnel we have we cannot compete with the planning and development set forth by the Federal agencies. They have local representatives selling their story constantly while we have one or two men trying to cover the entire State.

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A harder look should be given to cost benefits. It seems foolish to spend $363.29 per benefited acre when the SCS valued this land at only $200 per acre. If they went in and bought the land in this project, they could save the taxpayer $163.29 per acre, or a total of $1,099,758.

More detail should be given to water retardation rather than moving it off as fast as possible.

The maintenance and operation of mitigation measures should be as rigid as the maintenance and operation of the structures. Now it is left up to the local landowner to do as he pleases. A greentree reservoir built for mitigation in one project is cleared and growing excellent soybeans.

Little consideration, if any, is given to the loss of wildlife, fish, and esthetic values when benefit ratios are computed.

We appreciate the opportunity to present in a small way some of our objections to the work of these two Federal agencies. Very truly yours,

Billy JOE CROSS,

Executive Director.

MISSOURI

MISSOURI WATER POLLUTION BOARD,
DEPARTMENT OF PUBLIC HEALTH AND WELFARE,

Jefferson City, Mo., June 3, 1971.
Mr. HENRY S. REUSS,
Chairman, Conservation and Natural Resources Subcommittee of the Committee on

Government Operations, Rayburn House Office Building, Washington, D.C. DEAR MR. Reuss:

This is in reply to your letter of May 20, 1971. We do participate in the review of Federally financed projects such as for dams, flood control and so forth. It is true the changes created by dams are not always beneficial. There have been water pollution problems which occur below impoundments due to temperature changes and low oxygen. These problems have been brought to the attention of the Corps of Engineers who operate the facilities. We believe that more consideration should be given to the design of intake structures for power generators to further protect water quality. I have no suggestion or recommendations for changes or improvements in the present program. Yours truly,

Jack K. SMITH,
Executive Secretary.

MONTANA

STATE OF Montana,
DEPARTMENT OF FISH AND GAME,

Helena, Mont., May 27, 1971.
Congressman HENRY S. REUSS,
Chairman, Conservation and Natural Resources Subcommittee of the Committee on

Government Operations, House of Representatives, Congress of the United States,

Washington, D.C. DEAR CONGRESSMAN Reuss: In response to your letter of April 27 requesting information concerning the channelization of streams and rivers by Federal agencies, I solicited information from each of our seven Fish and Game Districts in the State of Montana. Unfortunately, the response in regard to specific projects experiencing environmental degradation was too voluminous to include in a single correspondence with your committee. As a result I have elected to point out what we feel are typical problems experienced in the relationship between Federal agencies and our aquatic environment. If specific examples are required, we will prepare a discussion on specifics at your request.

Emergency flood control.—Each spring Montana's streams are subjected to a variety of emergency flood control problems. Not too many years ago, our agency had to stand helplessly by and observe channelization and riprap projects that considered little other than transporting water in the fastest possible means, Today, much of this has changed, and there is a greater degree of cooperation and less physical stream abuse than in the past. However, the basic concept of emergency food control, which we believe to be a false concept, has gone unchallenged.

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The problems treated are seldom, if ever, an emergency. Each spring the rivers rise. They always have and always will. However, problems of local stream bank erosion weakening bridge abutments which are ignored throughout the year are suddenly declared emergencies because flood waters are due to come.

The Corps of Engineers generally responds by attacking a local specific problem, and seldom, if ever, considers the total watershed and floodplain problems that are actually contributing to flood damage.

In our opinion, this program that does nothing but spend money attacking symptoms of problems while carefully ignoring their causes, solves nothing. However, Congress has given spending authority to conduct this program while denying funds to the comprehensive drainage problems that will continue indefinitely.

While a greater environmental awareness has lessened the physical damage done by the federal government on these projects, there still appears to be no effort to scrap this rather shallow program on a national level and devote the federal resources to describing and solving the real problems.

Cost-benefit efficiency.--All Federal agencies in Montana that conduct programs in and around this State's water resources are committed to producing favorable cost-benefit ratios. It is equally apparent that in many cases, preserving this nation's environment is not going to be an efficient thing to do on a short-term repayment period. However, most agencies are still required to produce these favorable ratios if they are to have an authorized project. There is no provision for an environmental subsidy comparable to the flood control subsidy that is available on Federal water resource development projects. This provision should be made.

Attitude. While the recent environmental interest and new laws such as the Environmental Policy Act of 1969 have changed many of the basic ground rules, it has been our experience that the attitude of many of the agencies does not reflect a total commitment to environmental preservation. Many groups still view the Environmental Policy Act as a necessary evil or a document that requires redescribing old methods with new terminology. There appears to be a hesitancy to make a substantial commitment toward restoring and repairing the envirorment.

While much of this is undoubtedly related to cost-benefit problems posed by environmental concessions, I believe individual attitudes also make a contribution. For example, some Federal agencies have been committed to a lifetime of improving agricultural efficiency. In Montana, this frequently means less and less for wildlife on private land. In some cases it means less flows committed to streams, and in other cases it means actually circumventing the intent of the Environmental Policy Act. Unfortunately we have no solutions to some of these problems.

Another good example of this is the attitude of Federal planners preparing to embark on the Western United States Water Plan. As always their basic premise is, the population must expand, demands must multiply, the land must satiate the demands. It is obvious the time has come to determine what the land can yield in perpetuity and to adjust our demands accordingly. You can be assured the Federal bureaucracy is standing firm against that basic environmental attitude. Sincerely,

FRANK H. DUNKLE,
State Fish and Game Director.

NEBRASKA

NEBRASKA GAME AND PARKS COMMISSION,

Lincoln, Nebr., May 28, 1971. Congressman HENRY S. REUSS, Chairman, Conservation and Natural Resources Subcommittee, House of Representa

tives, Rayburn House Office Building, Washington, D.C. DEAR CONGRESSMAN Reuss: We are in receipt of your letter of April 27, 1971, in which you called our attention to your subcommittee's investigation of the various Federal agencies' participation in stream and river improvement, modification and channelization. In answer to your specific request for our views relative to the impact of federally supported stream improvement projects, both constructed and planned, we will preface our remarks with a few comments on the ecology of our State.

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