Mr. KENNETH E. FRICK, ENVIRONMENTAL PROTECTION AGENCY, Administrator, Agricultural Stabilization and Conservation Service, Department of Agriculture, Washington, D.C. DEAR MR. FRICK: The Environmental Protection Agency has reviewed the draft environmental impact statement for the Department of Agriculture water bank program. We believe the water bank program as described in the draft environmental statement is a positive measure in the conservation of our natural resources, and would like to offer several suggestions for your consideration in strengthening the final impact statement. Under the discussion of alternatives, the final impact statement should outline the reasons for excluding salt water estuarine areas from the program. These may be equally or more important than fresh water areas in meeting the goal of conserving fish and wildlife habitats. This section should also include a discussion of the estimated cost-effectiveness of the water bank program as compared to outright purchase of the lands by the Department of the Interior or other agencies as a means of meeting program goals. The statement should also include a discussion of specific environmentally protective measures included in the wetland conservation and development plans. We suggest that consideration be given to controlling the use of pesticides in the vicinity of wetlands included in the program. Such controls would be valuable in meeting the conservation objectives of the program. We appreciate the opportunity to review the statement. If we can be of further assistance, please contact us. Sincerely yours, : SHELDON MEYERS, Director, Office of Federal Activities. EXECUTIVE OFFICE OF THE PRESIDENT, Memorandum for Mr. Kenneth E. Frick, Administrator, Agricultural Stabilization and Conservation Service, U.S. Department of Agriculture. Subject: USDA draft environmental impact statement on the water bank program. We have reviewed your draft impact statement on the water bank program and have a number of suggestions for your consideration in preparing the final statement. DESCRIPTION Provide a map showing location and acreage of the selected wetlands with high potential for migratory waterfowl nesting and breeding to be recommended to the Advisory Board. Identify the migratory waterfowl species (or subspecies) for which this program is being directed. Include a map showing the location of their nesting and breeding areas, the estimated population trends of the species (or subspecies), and the proportion of its total production that occurs in the United States. Identify those migratory waterfowl that are on the endangered species list and provide a map showing the location of those species and the corresponding acreage of wetlands eligible under the water bank program. ALTERNATIVES TO THE PROPOSED ACTION Identification of the location and acreage of wetlands presently under easement (or eligible for easement) by the Department of the Interior that are also eligible for inclusion in the water bank program. ALVIN L. ALM, APPENDIX 33.-SCS WATERSHEDS MEMORANDUMS RE ENVIRONMENTAL IMPACT STATEMENTS, AND RELATED CORRESPONDENCE U.S. DEPARTMENT OF AGRICULTURE, SOIL CONSERVATION SERVICE, Subject: WS-PL-566.-Cypress Creek watershed, Alabama and Tennessee. W. B. LINGLE, State Conservationist, SCS, Auburn, Ala. We have read the draft environmental statement for Cypress Creek watershed with considerable interest and concern. Our concern stems from several facts described in the statement. 1. There are 11 vertebrate species that are suspected to be in Cypress Creek watershed that are classified as "rare" or "status undermined." 2. The proposed works of improvement include 50.3 miles of channel improvement of which 43.4 miles have perennial flow. Approximately 20 miles of these channels are moderate to high valued habitat. The proposed channels will have bottom widths which vary from 4 feet to 103 feet with a maximum top width of about 140 feet. The present channels occupy an area of 252 acres. It is estimated that channel improvement will require 1,358 acres of which 871 acres are woodland. This with the channel area totals 1,123 acres, most of which has relatively high ecological value. 3. The basis for plan formulation seems to be to contain the 0.8 year frequency storm within channel banks throughout the channel length and to provide an 80 percent reduction in floodwater damages. This is a reasonably low level of protection hydrologically. However, the proposed project not only provides the desired level of economic protection but also is expected to result in benefits from land use adjustments which amount to $177,185. This indicates a relatively high level of protection to land not now in crop production. In comments transmitted with our memorandum of May 28, 1970, we requested that flood routings be made of the proposed project with and without channel improvement. In your response of June 29, 1970, you stated that this was not done because experience has shown that floodwater-retarding structures alone will not provide an acceptable level of flood protection. In view of the expected impact of this proposal on ecological values, this judgment analysis does not provide an adequate basis to support a decision to go ahead. Before we can take further action on this project proposal the following factual information must be provided. 1. The area and depth of flooding by flood plain evaluation reaches for 1-, 2-, and 10-year frequency storms with the 19 floodwater-retarding structures and no channel improvement. This should be shown by existing cropland, pastureland, and woodland acres. 2. The same type analysis with the 19 floodwater-retarding structures and the proposed channel improvement. 3. The same type analysis with the 19 structures and removal of critical channel blocks, but no extensive channel modification. 4. The same type analysis with the 22 floodwater-retarding structures and no channel improvement. We recognize that making these analyses will require additional time and expenditures. However, basically they are the analyses suggested in our comment of May 28, 1970. Regardless, the criteria under which we currently are planning require that we give more careful attention to alternatives, their economic and environmental impacts, and their balance between economic and environmental considerations. These alternatives need to be discussed more fully in the alternative section of the statement. We will hold the draft statement until we hear from you on the additional routings. Then we will be able to advise you regarding additional actions. These actions could involve either going ahead with the project as now proposed or reformulation based on some modified objectives which are more consistent with our current planning procedures. KENNETH E. GRANT, Administrator. U.S. DEPARTMENT OF AGRICULTURE, Subject: WS-PL-566-Draft work plan and environmental statement-Diamond-Traphole Brooks watershed, Massachusetts. Dr. BENJAMIN ISGUE, State Conservationist, SCS, Amherst, Mass. This contains our comments on the draft work plan and environmental statement transmitted with your memorandum of March 29, 1971, and January 27, 1972. The plan provides an unusually high level of flood protection on Diamond Brook. Structural measures are not feasible on Traphole Brook and a floodplain management program will be promoted to alleviate future flood damages. The plan does not give convincing evidence that the cost of achieving the high level of protection is warranted or that a lower level of protection would not be adequate. There is no question that a lower level of protection would be more comparable to the level provided in other watershed projects. Floods will be prevented on Diamond Brook by retardation in a multiplepurpose reservoir, controlling the runoff from one-half the drainage area, and a floodwater conduit and outlet channel. The conduit and channel constitute 62 percent of the flood prevention costs of the project. If it could be eliminated or reduced, the savings would be substantial, and the plan might not require approval by congressional committees, a critical consideration. Before completing this plan, costs, benefits, levels of protection, and other pertinent information for various alternative solutions should be reexamined to determine whether a plan providing a lower level of protection acceptable to the Service and the sponsors can be developed. The plan provides for using floodplain management in areas where the level of protection provided by the works of improvement is not adequate. This is highly desirable and should be used and encouraged wherever it is practical. This watershed appears to offer a golden opportunity to use the "carrot" of Federal assistance to secure much greater flood damage alleviation than the works of improvement alone will provide. Floodplain management, including assistance for preparing a floodplain management plan needs to be included in the work plan with the same degree of certainty that it will be carried out as structural works of improvement. Suggestions to improve the plan in this regard are contained in the detailed comments. Subject to the foregoing, you are authorized to complete the work plan and draft environmental statement substantially in accordance with the drafts, and take the actions specified for congressionally approved plans in chapter 13 of the Watershed Protection Handbook. Comments are attached for your use in preparing the final plan and draft environmental statement. Since the Upper Darby K&WP unit provided you with its comments on April 27, 1971, they will not be repeated. The above average quality of the draft plan and environmental statement reflect the care and consideration to detail your staff gave these documents. We commend them for it. N. A. BERG, Acting (For Kenneth E. Grant, Administrator). DIAMOND-TRAPHOLE BROOKS WATERSHED, MASSACHUSETTS Comments on the Draft Work Plan: Floodplain Management Reference throughout the plan make it The plan should show in broad form what floodplain management would consist of, i.e., limitations on buildings within certain flood hazard zones, flood proofing, land filling, removal of constrictions, etc. A floodplain management plan will probably be desirable and the plan could make provisions for providing assistance for this purpose and financing it from Public Law 83-566 funds. It appears that such costs would be handled as engineering costs. Flood prevention benefits would accrue and these should be evaluated, If positive means of including floodplain management as a nonstructural 3. 4. The plan should be carefully edited to make it clear that the Public Law 83-566 funds will be used to achieve the objectives of this watershed project, i. e., watershed protection, flood prevention, and improvement of fish and wildlife resources and that this will make a major contribution to maintaining and improving the environmental quality of the watershed. Agreement The agreement should be modified to incorporate the provisions of Watershed Memorandum-110 as indicated 1. Dr. Isgur's memorandum of July 26, 1971. It should also contain the following statement inserted immediately ahead of the signature block for the Administrator: "Appropriate and careful consideration has been given to the Page 3 The last two paragraphs appear to be out of place in the summary and should be deleted. 5. Page 4 The responsibility for maintaining land treatment measures rests with the Norfolk Conservation District even though land owners will do the work. Page 6, Econonic Date This section should show information on land Pages 7 and 8, General This appears to give the status of land treat- Page 10, Diamond Brook - How often do floods occur or what size (frequency) of floods cause damage? What is the frequency of the '55 flood? Would a description of the '68 flood provide a better understanding of flood problems? Page 13 It is suggested that the primary objective in formulation could be deleted. |