APPENDIX 34.-WATERSHEDS MEMORANDUM 108 REVIEW AND CLASSIFICATION OF WATERSHED PROJECTS INVOLVING CHANNELIZATION 1 PART A.-BUREAU OF SPORT FISHERIES AND WILDLIFE REPORT ON SCS WATERSHEDS MEMORANDUM 108 CLASSIFICATION HOUSE OF REPRESENTATIVES, CONSERVATION AND NATURAL RESOURCES SUBCOMMITTEE, SPENCER H. SMITH, Acting Director, Bureau of Sport Fisheries and Wildlife, Department of the Interior, Washington, D.C. DEAR MR. SMITH: Watershed memorandum 108 of the Agriculture Department's Soil Conservation Service establishes guidelines for planning and review of SCS channelization projects. It requires that SCS State conservationists-in consultation with your agency, other Federal and States agencies, and the public classify into three groups, by June 30, 1971, all authorized SCS channelization projects. Classification is determined by (1) the extent of the adverse effects on the environment of the projects, and (2) their economic benefits. The SCS has provided to us a table (a copy of which is attached) summarizing the results of their efforts. We would appreciate your response to the following questions relating thereto : 1. Please state, for each project listed in the table, the extent of consultation between the SCS State conservationist and your agency before he classified it under WM 108. 2. (a) Please list, for each project, the recommendations you made to SCS, and indicate, for each recommendation, whether it has been (1) adopted, (ii) rejected, or (iii) adopted in part (stating the part adopted). (b) For any project for which you made no recommendation to SCS, please indicate the reasons therefor. (c) Please indicate, for each project, (1) whether adoption, in whole or in part, of your recommendations resulted in SCS changing its classification of a project under WM 108, and (2) what specifically the change in categories was. 3. Do you agree with the classification given by SCS for each channelization project listed in the table? 4. For each project with whose classification you disagree, please identify the project and state: (a) Your reasons, and (b) What should be its classification. We would appreciate your early response to our request. HENRY S. REUSS, Chairman, Conservation and Natural Resources Subcommittee. HOUSE OF REPRESENTATIVES, CONSERVATION AND NATURAL RESOURCES SUBCOMMITTEE, SPENCER H. SMITH, Acting Director, Bureau of Sport Fisheries and Wildlife, Department of the Interior, Washington, D.C. DEAR MR. SMITH: On October 25, 1971, we wrote to you requesting certain information about your Bureau's review of, and recommendations to, the Soil Conservation Service concerning that agency's classification of all authorized channelization projects under SCS's watersheds memorandum 108. 1 See "Classification of Channel Improvement Projects" of the Soil Conservation Service, printed at pp. 2707-2713 of subcommittee hearings on "Stream Channelization" (p. 4). Three months have passed since then, and we still have not received this information nor any estimate of when it would be forthcoming. Your failure to respond to our request is delaying the work of the subcommittee. We request that this information be delivered to us by no later than February 2, 1972. Sincerely, HENRY S. REUSS, Chairman, Conservation and Natural Resources Subcommittee. HOUSE OF REPRESENTATIVES, CONSERVATION AND NATURAL RESOURCES SUBCOMMITTEE, Mr. NATHANIEL R. REED, Assistant Secretary, Department of the Interior, DEAR MR. REED: On October 25, 1971, we wrote to the Acting Director of the Bureau of Sport Fisheries and Wildlife, Mr. Spencer H. Smith, requesting certain information about the Bureau's review of, and recommendations to, the Soil Conservation Service concerning that agency's classification of channelization projects under watersheds memorandum 108. On January 24, 1972, we wrote another letter to Mr. Smith, in which we said: "Three months have passed since then, and we still have not received this information nor any estimate of when it would be forthcoming. Your failure to respond to our request is delaying the work of the subcommittee. "We request that this information be delivered to us by no later than February 2, 1972." The month of February is nearly over and we still have not received a report which we requested 4 months ago. Our subcommittee staff has discussed this with Mr. Gardner of your office, who has indicated that the report has been ready for several weeks now, but that it is undergoing review at the Soil Conservation Service and the Council on Environmental Quality. We are interested in learning precisely what the Bureau of Sport Fisheries and Wildlife's recommendations were as to these projects, and whether or not that Bureau agrees with the conclusions reached by the SCS. We are pleased that the Bureau has made the information available to these other agencies, but we fail to understand why our subcommittee cannot obtain this information at the same time. We again request that this report, together with the summaries, explanations, and other pertinent data, be made available to the subcommittee not later than Wednesday, March 1, 1972. If the SCS and the CEQ want to express their views on the Bureau's report, we would be glad to receive those views, but we strongly object to those agencies delaying our receipt of the report. We hope that it will not be necessary for the subcommittee to hold a hearing for the purpose of obtaining this report. Sincerely, HENRY S. REUSS, Chairman, Conservation and Natural Resources Subcommittee. U.S. DEPARTMENT OF THE INTERIOR, OFFICE OF THE SECRETARY, Washington, D.C., March 3, 1972. Hon. HENRY S. REUSS. Chairman, Conservation and Natural Resources Subcommittee, Committee on Government Operations, House of Representatives, Washington, D.C. DEAR MR. REUSS: Thank you for your letter of February 24, 1972, inquiring into the reason for our delay in supplying you with information you requested on the Bureau's review of, and recommendations to, the Soil Conservation Service concerning that agency's classification of channelization projects under watershed memorandum 108. The report as such is not yet in finalized form. We have succeeded in assembling information on over 550 soil conservation projects which contain some stream channelization. We are currently reviewing the data with SCS officials to determine the accuracy and validity of the information compiled to date. Because of the wide spread interest in this pending report, we felt it essential to be as accurate and precise as possible; hence, the delay while we confirm our facts. SCS officials have been most cooperative in helping us determine the accuracy of our data, and we hope to complete our review in the near future. We will finalize the report for transmittal to your committee as quickly as possible. In closing, let me reiterate that the Bureau has proceeded with diligence to ascertain the information you have requested, and we will be forwarding it to you in the near future. Sincerely, NATHANIEL REED, Assistant Secretary of the Interior. HOUSE OF REPRESENTATIVES, CONSERVATION AND NATURAL RESOURCES SUBCOMMITTEE, Mr. NATHANIEL R. REED, Assistant Secretary, Department of the Interior, DEAR MR. REED: Since our telephone conversation of several days ago, we have been informed that several reporters have obtained copies of the report on chaunelization projects of the Soil Conservation Service which we requested nearly 5 months ago from your Department. It is difficult to understand why the press can obtain this report and our subcommittee is told to wait until the Fish and Wildlife Service completes its drawnout series of meetings with representatives of the SCS, the Council on Environmental Quality and the Office of Management and Budget. Are we to conclude that these agencies are seeking to delay issuance of the report (and the additional material requested by our staff several weeks ago in conversations with Mr. Gardner of your staff), because the information contained therein will be embarrassing to the administration? Several reporters have told us that the aforementioned weekly meetings have resulted in substantial changes in the report, covering letter, and explanatory material, and that, as a result, significant information will not be included in the report when it is finally provided to us. We request therefore, that you now provide to us copies of each of the various drafts of the report and covering material that was provided to every one of the aforementioned agencies. Also, please advise us as to when we may expect to receive the completed report. Sincerely, HENRY S. REUSS, Chairman, Conservation and Natural Resources Subcommittee. Hon. HENRY S. REUSS. U.S. DEPARTMENT OF THE INTERIOR, OFFICE OF THE SECRETARY, Washington, D.C., April 28, 1972. Chairman, Conservation and Natural Resources Subcommittee, Committee on Government Operations, House of Representatives, Washington, D.C. DEAR MR. REUSS: I am pleased to forward herewith three copies of the report by the Bureau of Sport Fisheries and Wildlife on the review, under watersheds memorandum 108, of small watershed projects involving stream channel alteration. We apologize for the delay in completing and transmitting the report. The Bureau was particularly careful in its reporting of the facts and found it necessary to verify and confirm certain of its findings. We believe you will agree that the result is a report which describes the situation accurately and fairly. In transmitting the report to you I would like to acknowledge the excellent cooperation we received from the Soil Conservation Service in reviewing the accuracy and validity of our findings. If we can be of further service concerning this or other matters, please let us hear from you. Sincerely yours, NATHANIEL REED, Assistant Secretary of the Interior. Environmental Aspects of Watershed Work Plans of the Soil Conservation Service This report summarizes the participation by the Bureau of Sport Fisheries and Wildlife (BSFW), and in some cases by the State fish and game agencies, in the review by the Soil Conservation Service (SCS) of its watershed projects involving stream channel alteration (i.e., categorized as channelization by BSFW and channel improvement by SCS) conducted under directives and guidelines of SCS Watersheds Memorandum-108 (WS Memo-108). This report also touches briefly on the preparation and review of environmental statements prepared by SCS on its watershed work plans under provisions of the National Environmental Policy Act (NEPA; P.L. 91-190). Through WS Memo-108, SCS directed its State Conservationists to conduct a review of approved watershed work plans that include stream channel improvement not yet installed and provided guidelines for such review as well as guidelines". for developing new watershed work plans involving channel improvement." (emphasis supplied) Classification of Approved Work Plans As to Environmental Impact "The initial objective of this review under WS Memo-1087 is to classify Lusually by segments the planned channel improvement of both natural and artificial channels] ... The guidelines in WS Memo-108 set out eight salient standards for approvable channelization work and directed the classification of such work into three groups. Briefly the eight standards were: minimizing losses of fish and wildlife; proposing channel work only after land treatment and flood prohibiting channelization primarily to bring new land limiting flood protection in agricultural flood plains to permitting flood protection in non-agricultural areas against - - requiring channels to be planned and designed so as to be - encouraging adherence to existing channel alignment; and - encouraging channelization techniques that are least damaging The classification of channelization work (work plan sements, cf. above) into Groups 1, 2, and 3 was directed to be based on three criteria insofar as the classification by SCS was concerned: Effect on the environment; conformance to enumerated guidelines (the eight standards briefed above); and economic justification. It is critically important to note that BSFW's review of these projects only considered their environmental impacts. Group 1 was to include only those channel alterations that met the highest level of all three criteria, i.e., minor or no known environmental effect, clear conformance or easily modifiable to conform to the eight standards, and clearly favorable economic justification. Croup 2 was to include channel alterations meeting any or all of the moderate level criteria, i.e., some adverse environmental effects and similarly moderate (borderline) characteristics of conformance with the eight standards and of economic justification, but not falling in any of the lowest level criteria. Group 3 was to include channel alteration proposals that fell in the lowest level on any of the three criteria, i.e., serious adverse environmental effect or similarly poor conformance with the eight standards or lack of economic justification. It is notable that the guidelines of WS Memo-108 directed the State Conservationist to lean toward the more critical in their classification of stream improvement proposals (2nd paragraph, page 6): ". . . any channel improvement that is borderline between two groups should be placed in the more critical group, subject to change with more detailed analysis." This report specifically addresses the review made under the directives and guidelines of WS Memo-108. In particular it reports the results of BSFW and State fish and game agency participation in the review which SCS State Conservationists were directed by WS Memo-108 (5th paragraph, page 5) to arrange: As soon as you have completed the review, inform the state |