I must indicate that in the past 10 years a rather large percentage of Corps of Engineers stream channeling projects have been conducted with little or no consideration for fish and wildlife. In some instances this has resulted in significant losses of important habitat, recreational opportunity, and caused an unnecessary reduction in valuable fish and wildlife resources. Expedient methods were used where the purpose of the project could have been accomplished with slight modifications to protect the resources. Two specific instances that come to mind are flood control channelization in the Israel River in Lancaster and the Mohawk River in Colebrook. As a matter of interest, the former project was not successful in accomplishing the project purpose. We have made every effort to work with the corps on such projects, but, as I have indicated, our counsel has not been sought or has been ignored, resulting in the loss of valuable fish and wildlife resources. I appreciate the opportunity to express my feelings in this matter. I would hope that the Congress could develop guidelines for such Federal projects which would require acceptance of State stipulations designed to protect fish and wildlife habitat. Sincerely yours, BERNARD W. CORSON, Director. THE STATE OF NEW HAMPSHIRE, WATER SUPPLY AND POLLUTION CONTROL COMMISSION, Hon. HENRY S. REUSS, I do hope this meets with your approval, as we would like to be as cooperative and helpful as possible. Most sincerely, R. E. TOWNE, Biologist. NEW JERSEY Mr. HENRY S. REUSS, STATE OF NEW JERSEY, DEPARTMENT OF AGRICULTURE, Trenton, N.J., May 19, 1971. Chairman, Conservation and Natural Resources Subcommittee, Congress of the United States, Rayburn Office Building, Washington, D.C. DEAR MR. REUSS: Your inquiry regarding stream improvement projects is welcome in view of the apparent controversy over the long range benefits of such projects. This department has been closely involved with several such projects which are administered by the U.S. Soil Conservation Service under the Watershed Protection and Flood Prevention Act of 1954. Through the State Soil Conservation Committee and our local soil conservation districts, the resources of this department have been made available to assist local sponsors with their project responsibilities and the necessary protective upstream land treatment has been accelerated to assure overall watershed protection. Channel improvement work has been performed with Soil Conservation Service assistance in five projects to date. Two more projects are under construction and three are in planning stages. We feel that project results have been highly favorable. In only one case has a fishery resource been affected and local fishermen report better fishing than before. Channel modification apparently permits sportsmen to better utilize this put and take trout stream. Of the two under construction, one is sponsored by the New Jersey Division of Fish, Game, and Shell Fisheries. The other involves drainage of a wetland area which has received the attention of environmental groups. In this case, special project measures were designed by the Soil Conservation Service to provide for retention of the key wetland resource. In the three projects in the planning stage, a coordinated review has been conducted by all concerned conservation agencies to be sure that all environmental factors are considered. Any potential damages will be mitigated to the greatest possible extent. If it is determined that potential damages are still too great local project sponsors will be encouraged to modify the project proposals. This department is actively involved in the planning and development of channel improvement when this method is determined to be the only feasible method of solving water management problems. A significant percentage of staff time of the State Soil Conservation Committee is devoted to watershed project development through coordination and assistance to local project sponsors. It is the evaluation of this department that the advantage of the above-mentioned channel improvement projects far outweigh any related adverse effects. We certainly approve of all efforts to maintain high coordination between all environmental interests and will do our utmost to be sure that this is done. Sincerely yours, STATE OF NEW MEXICO, DEPARTMENT OF GAME AND FISH, Santa Fe, May 14, 1971. Re: Channelization of Streams and Rivers. DEAR REPRESENTATIVE REUSS: We have your letter of April 26, 1971, asking for our suggestions and recommendations for changes or improvements in the present program for modification and channelization of streams and rivers. Our letter, to you, of April 23 on essentially the same subject, no doubt, crossed in the mails. The primary target for channelization in our State has been the Rio Grande, our major river that transverses the State from the north boundary to the south boundary. Flood control projects have been carried out along much of the length of the river and water salvage operations have been conducted by channelization to confine the flow of the river and to narrow channels. This has resulted in great loss of habitat for waterfowl and other wildlife in our State. In recent years we have been able to enter into the planning stage of this work through the Bureau of Sport Fisheries and Wildlife. The plans of the Bureau of Reclamation must be concurred in, or reviewed by the Bureau of Sport Fisheries and Wildlife. They in turn call in our department to review these plans. We have been quite adamant that proper provision for protection and enhancement of wildlife habitat be included in the plan. We feel that it should be incombent on the action agency to demonstrate and document, through proper research, that the work they intend to do will not be destructive to wildlife habitat or, if it is, to plan into their projects adequate mitigation to overcome these losses. Also we believe that the cost-benefit ratio of these projects should be very closely scrutinized to make sure that no less than a dollar return will be realized for each dollar spent. Another problem in our State is that the water salvaged from these federally funded operations is assigned to the benefit of a few landowners holding valid water rights. The public in general receives little or no benefit from the federally funded projects. Here again, we feel that enhancement programs should be carried on that will be beneficial to the public, as well as to the limited number of water users. If our comments raise specific questions, we will be happyto discuss the situation you in greater detail. We appreciate the opportunity to comment. with Very truly yours, LADD S. GORDON, Director. STATE OF NEW MEXICO, HEALTH AND SOCIAL SERVICES DEPARTMENT, Hon. HENRY S. REUSS, Chairman, Conservation and Natural Resources Subcommittee, DEAR REPRESENTATIVE REUSS: Your letter of inquiry dated 20 May 1971 addressed to Mr. John R. Wright, Chief, Water Quality Section, Office of Environmental Services, P.O. Box 2348, Santa Fe, N. Mex., 87501, has been referred for response. At the present time, major stream improvement projects in New Mexico that are constructed, under construction and planned to be constructed by the Federal Government or with the aid of Federal financing that have been referred to this office for comment, are limited to Corps of Engineers projects. Referrals have been in compliance with section 102(2) (c) of the National Environmental Policy Act of 1969. Projects by this agency that are complete or that are under construction are regarded as beneficial. Two proposed projects by the Bureau of Reclamation have not been submitted for comment. However, comments will be offered on both. Although this department employs competent engineers and technicians, there has been no invitation to participate in the planning and development of projects. The opportunity to participate in the planning and development would be welcome. For your future guidance, it is requested that any further communication or inquiry be addressed to: The Director, Environmental Improvement Agency, P.O. Box 2348, Santa Fe, New Mexico 87501. The opportunity to comment in response to your inquiry is appreciated. RUFUS H. CARTER, Jr., Hon. HENRY S. REUSS, NEW YORK STATE OF NEW YORK, Albany, June 11, 1971. DEPARTMENT OF ENVIRONMENTAL CONSERVATION, Chairman, Conservation and Natural Resources Subcommittee, DEAR MR. REUSS: Thank you for your letter requesting our views on stream improvement projects in New York State which have been or are planned to be constructed by the Federal Government or with the aid of Federal financing. New York has been involved with three Federal agencies in the following activities over the past years and, as presently foreseen, will continue cooperation and coordination with these agencies in the future: 1. Corps of Engineers: These projects have involved clearing and snagging operations, emergency flood damage repairs, and channelization of certain streams to prevent future flood damage. In general, cooperation has been good, sufficient time has been allowed for planning and our State's recommendations for preservation of the natural stream qualities have been well received. In the past, emergency flood repairs have been quickly planned and executed, with little attempt to touch back with this department for recommendations to lessen habitat damage before or during the project work. In our opinion, this has resulted in unnecessary stream habitat damage because most of the work involves dredging, bulldozing and clearing of debris without regard to esthetic and fishery habitat values on a long-range basis. Recently there has been a marked improvement in communicating our respective concerns and applying them to project requirements. 2. Soil Conservation Service: We have participated in several small watershed projects under Public Law 566 and provided technical advice on stream channelization to assure preservation of fisheries and habitat. However, there have been certain instances where flood control is given prime consideration with limited emphasis on fisheries and esthetic values. This has been mainly in the form of stream channel realinement, tree removal, and increased channel size to accommodate floods. Cooperation in planning and development has varied from reasonably good to excellent. Currently we are receiving the full cooperation of the Soil Conservation Service. 3. Fish and Wildlife Service: We have been involved in several development projects on streams over the years to provide better trout habitat by stream improvement methods. Cooperation in planning and development of these projects has been excellent due to a mutual understanding of objectives and goals. Our department has the capacity to review all such projects, determine the environmental impact and make recommendations to preserve the natural qualities of streams affected by such projects. We have noticed a marked increase in cooperation with these Federal agencies in the past few years and a sincere attempt on their part to understand that improvement, modification, and channelization involve more than flood control concepts. Our suggestions for continuing stream improvement with the aid of these agencies are dependent on mutual appreciation for each other's objectives and an understanding of problems from both the environmental and engineering points of view. It is attitude, not technology, which is responsible for the few unjudicious projects undertaken by these agencies. It is our contention that environmentally unsound projects can be eliminated by a strong liaison at all levels of planned or emergency project development. As an agency we are committed to review and modification or veto of projects deleterious to the environment. Unless full cooperation and understanding are achieved among all agencies concerned, the numerous adverse effects cited in your letter will continue to be a source for complaint. I hope our comments will be helpful in your investigation. 'Sincerely, HENRY L. DIAMOND, Commissioner. NORTH CAROLINA STATE OF NORTH CAROLINA, Raleigh, N.C., May 18, 1971. Hon. HENRY S. REUSS, Chairman, Conservation and Natural Resources Subcommittee, DEAR MR. REUSS: The North Carolina Wildlife Resources Commission sincerely appreciates this opportunity to present its views on the stream improvement projects in this State which have been made possible by Federal financing. We are intimately acquainted with the details of the projects carried out by the Soil Conservation Service and the Corps of Engineers. Our Commission has competent biologists whose specific assignment is to cooperate with these agencies in the planning and development of their projects. Detailed agreements with both agencies lay the groundwork for timely participation. Because our agency is charged with the responsibility of fish and game management, it is from the viewpoint of their welfare that we consider the benefits of stream improvement projects. To a greater or lesser extent, most projects are destructive of wildlife habitat and, at least to that extent, produce negative benefits. The positive benefits are appealing, and are well stated by the project sponsors. These conflicting values should be balanced by the "cost-benefit ratio", and that ratio, if negative, should provide an automatic veto to the project. Unfortunately, that is not the case. Positive benefits easily can be reduced to reasonably accurate dollar values. Negative benefits, rarely susceptible to monetary evaluation, are presented by the conservation agencies as "costs". Lacking dollar values, the negative benefits do not fit the cost-benefit ratio, and they are largely ignored. For example, consider the typical hardwood-swamp drainage project. Farmers around the swamp keep extending their fields into it by clearing more woodland. Their fields flood more frequently. They apply for drainage assistance (frequently at the suggestion of representatives of the agencies which must continue to have projects to maintain their payrolls). Since the money is "Free" (Federal), only the conservation agencies complain. The ditches are dug. more Positive benefits are short term and of definite value. Each land-owner can cut the trees from his property and sell them for a foreseeable price. The swamp, now cleaned, will grow a certain number of dollars worth of soybeans with little danger of flooding. These are definite and positive benefits which, in dollars, need only exceed the cost of digging the drainage channel. Negative benefits usually are of intangible value and of long term. The deep pools of the swamp stream provided bass and bream and jack for the fisherman, but often channelization (the big ditch) is suitable habitat for only a few minnows. The swamp hardwoods are cut and sent to the furniture manufacturers. There will be no more. The swamp habitat is gone. What is the real loss of irreplaceable habitat? The bear and the deer and the turkeys that lived in the swamp have been lost to predation. The ducks have lost their winter habitat and will not return. What is their dollar value now, or 20 years from now? How can definite values be assigned? Perhaps most important of all is the speed with which the water is hurried off the land. The swamp served as a retention area, where the water might lie and slowly percolate down to replenish the water table. The long-term result of drainage is a falling water table which will force an irrigation program on the farmers and, eventually, a desperate deepening of wells for drinking water. Commonsense dictates that this project should not have been carried out, yet the cost-benefit ratio proved it to be desirable. A new basis for decision must be devised. For every one of the positive benefits stated for any of the "stream improvement" projects, a similar list of negative benefits can be compiled with only the details varying with the particular project site. We attach several papers, which have been prepared by our staff, on negative benefits. The most recent, "Evaluation of the Effects of Channelization on Fish Populations in North Carolina's Coastal Plain Streams," is as scientifically accurate a study as we can devise. Also, if it is desired, we will be glad to present to your committee a series of slides showing pictorically most of the negative benefits resulting from stream improvement. (SUBCOMMITTEE NOTE.-The papers referred to are in the subcommittee files.) These negative benefits cannot be entered in the cost-benefit ratio. Either a method must be designed to give them a practical dollar value, or the ratio must be discarded as a guide to the validity of each project. Some method must be found, and quickly, by which the intangible benefits can be assigned an evaluation to measure against a like evaluation of the positive benefits. There must be a method by which the negative values will acquire veto power over the positive benefits when the destruction of our Nation's resources hangs in the balance. I hope your committee can find that method. Thank you for permitting us to comment on this most serious problem. CLYDE P. PATTON, Executive Director. STATE OF NORTH CAROLINA, DEPARTMENT OF WATER AND AIR RESOURCES, Raleigh, N.C., May 26, 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 SIR: This is in response to your letter of May 20, 1971, concerning Federal agency practices in stream channel modification. Our agency is responsible for overall State water planning and generally for coordination of State water plans. In specific reference to small watershed projects of the Soil Conservation Service our board must approve the work plans. The basis for the board to reject these plans is legally quite limited, but the review process facilitates discussion of questions and the Soil Conservation Service has been amenable to board suggestions. In respect to TVA activities and U.S. Army Corps of Engineers projects a formal board action has not been required in a manner paralleling the Public Law 566 procedure. Using the Upper French Board project as the model, we can say that TVA very assiduously considered all points of view and held frequent discussions, both locally and with the State government agencies, particularly the Wildlife Resources Commission. In our coordinating responsibility for water projects we canvass interested State agencies for their views and establish a unified response to the corps, TVA, and SCS, or seek to referee the differences. In the case of channelization this led us to sponsor in conjunction with the Water Resources Research Institute a workshop on channelization wherein knowledgeable interests in the State got together to exchange views. |