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Mr. BOB TRUETT,

U.S. DEPARTMENT OF AGRICULTURE,
SOIL CONSERVATION SERVICE,
Auburn, Ala., June 23, 1971.

Zoo Director, Birmingham's Jimmy Morgan Zoo,
Birmingham, Ala.

DEAR MR. TRUETT: We appreciate your continued interest in the small watershed program, as indicated in your letter of June 18, 1971.

As stated to you in my letter of June 16, we were not able to send you the information and documents you requested. As of this date, we are still not able to furnish you with the specific information you asked for. The reasons for this are as follows:

1. Environmental impact statements as called for in section 102 of the National Environmental Policy Act of 1969 have not been prepared for projects that were planned prior to January 1, 1970. Requirements relating to these projects planned prior to that date are that they will be handled on an individual basis.

2. Environmental impact statements will be available in our office for review. We are not required to send copies to individuals on request. Copies of course are sent to the Council on Environmental Quality and the other appropriate agencies. 3. Public participation in the studies being conducted under watersheds memorandum 108 is being done through Federal and State game and fish agencies. In Alabama, representatives of the Alabama Department of Conservation and the Decatur office of the Bureau of Sport Fisheries and Wildlife have been fully involved in making the required studies. In other words, the Alabama Department of Conservation in this State is acting in behalf of Alabama citizens and organizations in making the review. The report required in watersheds memorandum 108 will be forwarded to our national office in the very near future. The memorandum does not specifically require, nor should it require, that copies of these reports be made available to the general public until reviewed and approved by the agencies mentioned above and by the Administrator of the Soil Conservation Service. These reports will be available at the Washington office of the Service.

I assure you that we in the Soil Conservation Service in Alabama are complying fully with both the spirit and the letter of recently enacted laws dealing with environmental quality and also with the provisions of memorandum 108. As stated to you before, we will welcome an opportunity to discuss matters of mutual interest here in our office and to have you review our procedures and working papers regarding this entire matter. In addition, you may wish to visit one or more projects in the State to see and become fully acquainted with this type project, and particularly the role of local sponsors. Sincerely,

Mr. RUSSELL E. TRAIN,

W. B. LINGLE, Acting State Conservationist.

LOUISIANA WILDLIFE FEDERATION, INC.,
Alexandria, La., February 45, 1972.

Chairman, Council on Environmental Quality,
Washington, D.C.

DEAR MR. TRAIN: This is in reply to Mr. Stephen F. Sloan's letter of February 10.

I would like to point out to you that neither the National Environmental Policy Act nor the guidelines established by your agency in regard to this act, imply in any way that SCS memorandum 108 can be substituted for the required section 102 environmental impact statement.

If your agency believes memorandum 108 reviews can be used in lieu of section 102 statements, I suggest that you revise the guidelines issued by your agency and that you have Congress reword the National Environmental Policy Act.

Mr. Sloan stated in his letter, "We firmly believe that the projects of the Soil Conservation Service will be adequately discussed under either the environmental impact statement process or the memorandum 108 review."

This is utterly absurd. Memorandum 108 is an intragency copout, subject to no public participation and no authority other than that of the agency which has devised the projects being reviewed.

In the West Fork of Bayou Lacassine watershed project in Louisiana, for example, the Soil Conservation Service has refused to discuss or consider any mitigation of the damages that have resulted from the dredging of channel W-1. This channel has drained an 870-acre cypress tupelo swamp and is the principal cause of environmental damage in this project. Requests from the Louisiana Wildlife and Fisheries Commission that weirs be placed on the spoil on the east bank of W-1 to halt drainage on that side of the swamp have been ignored in the memorandum 108 review.

I am deeply disappointed if this is your agency's concept of adequate discussion and if memo 108 is your agency's idea of compliance with NEPA.

It is my understanding that the Soil Conservation Service has over 300 authorized, but not completed watershed projects for which it is now refusing to file the required environmental impact statements. Is it the intention of your agency to require private citizens to finance legal action to force the SCS to obey the law in all 300 cases (while private citizens are also financing Justice Department defense of the SCS)?

If it is, then I have no recourse but to conclude that the Council on Environmental Quality, rather than being a court of appeal for rational land use, is simply a rubber stamp for the Soil Conservation Service, Corps of Engineers, et al.

Sincerely,

cc: Hon. Ben B. Blackburn

Hon. Henry Reuss

Hon. John Sherman Cooper

Hon. James Buckley

Hon. John Dingell

RICHARD W. BRYAN, Jr.,

Chairman, Water Control Projects Committee.

RESOLUTION ADOPTED AT MEETING OF LOUISIANA WILD LIFE AND FISHERIES COMMISSION-NEW ORLEANS, LA., MAY 23, 1972

Now therefore be it:

Resolved, That the Louisiana Wild Life and Fisheries Commission does hereby authorize the director to forward the following letter to the State Conservationist for the United States Soil Conservation Service in Alexandria, recommending that they file environmental impact statements on watershed projects.

Mr. J. B. EARLE,
State Conservationist.

Alexandria, La.

ALEXANDRIA, LA., May 23, 1973.

DEAR MR. EARLE. This regards your letters of May 12 and 17, 1972, acknowledg ing our previous assistance and requesting our future help in resolving watershed project problems.

As a result of the cooperation we have shown and our action in agreeing to your reclassification of projects placed in group II under watershed memo 108, we have been subjected to severe criticism from another quarter. Conservation groups are as quick to tell us that our actions are too passive in the face of environmental damages, as watershed sponsors are to tell us that our evaluations have been too high. It has been called to our attention that our interagency review of these projects completely eliminates the general public from the review process. We are reminded that this evades the intent of the National Environmental Policy Act. It also appears to circumvent the intent of your agency's watershed advisory 12. In order to share the responsibility of decisionmaking on these public projects, I feel that you should prepare an environmental statement along the guidelines published by the Council of Environmental Quality for each of these remaining projects.

As time permits we propose to continue to work with you in identifying damaging project features and to assist you in finding ways to eliminate, reduce or mitigate damages. We will also provide whatever information we have that may be useful to you in preparing these statements.

I greatly appreciate your recognition of the considerable amount of work my staff has performed in these reviews.

Sincerely yours,

CLARK M. HOFFPAUER,

Director.

APPENDIX 35.-BUREAU OF OUTDOOR RECREATION PILOT STUDY RE IMPACT OF WATERSHED PROJECTS ON RECREATION VALUES

Memorandum to: Director.

U.S. DEPARTMENT OF THE INTERIOR,
BUREAU OF OUTDOOR RECREATION,

SOUTHEAST REGIONAL OFFICE,
Atlanta, Ga., September 2, 1971.

From: Regional Director, Southeast Region.
Subject: Pilot study-SCS watershed projects.

This responds to Assistant Director Dent's memorandum of July 7, 1971, concerning the subject study.

Our pilot study of small watershed projects has reaffirmed our position concerning the impact that this program is having on recreation and esthetic values associated with resources in small watersheds.

Some knowledge of the history of the soil conservation movement, small watershed program, rural South's economy, and morphological forms present in the Southeast is pertinent to an understanding of the situation which has developed in the southeast region. The effectiveness of any future plan of action is enhanced if formulated upon a thorough understanding of these items and their interplay. In many parts of the Southeast, small watershed projects have enhanced recreation values contained in watersheds because the major component of the work plan has been the installation of a system of small reservoirs. However, for a variety of reasons, small structures did not evolve as the primary component of small watershed work plans in the flatlands of Florida, Louisiana, and Arkansas. Here the terrain was not conducive to small reservoir construction. Reservoirs either would not function satisfactorily as flood control devices or in some instances unstable soils often precluded their construction.

In other parts of the region, reservoir sites are often located in forested headwaters some distance from the beneficiaries of flood protection. In this situation, channelization is a more immediate and satisfactory solution to the problem. Farm income in the South is, on the average, below that in the rest of the Nation. This has tended to foster the least expensive means of flood protection to achieve short-term goals. For these and other reasons, channelization became a major feature of the small watershed program in the Southeast. Its effects on the recreational resources and natural environment have reached disastrous proportions. Basic to the success of the small watershed program in the Southeast, as in other parts of the Nation, is the skill with which the Soil Conservation Service sells its program.

The work plans which were studied did not consider the values inherent in natural free-flowing streams nor the values of the lands and forests as recreation resources associated with the streams. The benefit-cost ratios upon which the work plans were justified do not, in these four instances, represent a true evaluation of cost and benefits. Costs of the projects did not include benefits foregone through the destruction of streams and stream-associated resources.

Procedures employed in preparing small watershed work plans have fostered the steady destruction of streams and associated lands vital to natural life systems and recreation values. Fragmented localism that characterizes small watershed planning frustrates the attainment of recreation goals and environmental objectives. Part of the reason for this situation stems from the limited vision of sponsors when planning the recreation and environmental functions of the watershed plans. Sponsors are not equipped, generally, to measure the local, regional, or national importance of scenic areas or recreation potentials. Another force causing this situation is the dependency of local people on the economic productivity of a watershed's resources for their living. Resource uses that best serve the long-term broad public interest must often confront powerful local short-term economic interests. Sponsors are unwilling to yield powers long vested in there to outside individuals or agencies. A third factor

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which magnifies the problem of the small watershed program is the rapidly changing character of the region. Once it was true that if one swamp were drained, one more stream channelized, it mattered little since there were others. This is no longer the case. Today we are dealing with the few remaining unaltered streams and swamps. The time has long since passed for single purpose local planning which is oblivious to the regional situation. The frontiers are gone but the frontier mentality lingers on to the detriment of our national heritage and the overall public welfare.

Channelization has produced a tumultuous clamor among the knowledgeable and concerned public. This outcry has as yet produced no discernible effect on the current watershed work plan but has at least stirred the Soil Conservation Service to react superficially.

SCS memorandum 108 has been ineffective, at least within the scope of our awareness of its application, primarily because the Soil Conservation Service cannot accept the fact that anything the Soil Conservation Service does could be regarded as detrimental to the natural environment. Channelization is still considered stream improvement.

When confronted with irrefutable evidence of environmental degradation the responsibilities for the plan are laid at the feet of the sponsor. Sponsors, on the other hand, have not been conditioned to accept the more expensive measures nor a lesser degree of protection for the sake of a greater public good.

In devising our proposed program, we have tried to remain sensitive to the strengths of the small watershed approach. The majority of decisions taken during formulation of a watershed work plan is indisputably local in nature and should remain subject to local direction. Our proposals seek to avoid disturbing present arrangements regarding local decisions expressed in the formulation of watershed work plans. However, we have a duty to define and attend to those recreational and environmental issues which are inherently regional or statewide. The long-term broad public interest must be represented in any plan formulated with respect to the natural environment. We believe protecting the diminishing natural recreation and scenic areas in the small watershed must be a priority concern of this Bureau. The decisionmaking process, developed under Public Law 83-566, places priority upon flood control and drainage. Recreation and associated value are not project purposes of equal significance-a situation which appears to be a matter of interpretation rather than a deficiency in the act. The interdisciplinary approach to planning, which is required by the National Environmental Policy Act of 1969, appears to be one of the most critical deficiencies of the small watershed program. The interdisciplinary approach to plan formulation can best be achieved in the authorization studies by the combined efforts of agencies concerned with the planning and development of natural resources. Agencies representing other areas of needs satisfaction should assist in the reinterpretation of Public Law 83-566 and in the reorientation of the program toward a broader spectrum of public need. A major objective of this approach must be the comprehensive plan for the development of the watershed, which is based on a consideration of all the resources and the full complement of resource use.

The small watershed work plan which is then developed should conform to and be consistent with the comprehensive plan.

There are presently 296 active watershed work plans in the 10 States within the southeast region. As indicated in our letter dated May 20, 1971, it is estimated that with an additional five professionals and $140,400 in direct funding, the region could hope to study in detail approximately 30 projects annually. Perhaps an additional 10 percent could be reviewed more or less superficially and meaningful comments supplied [see report on Big Creek watershed] in an effort comparable to that of the Bureau of Sport Fisheries and Wildlife.

It is assumed that fully 80 percent of the active small watershed projects would be either unworthy of our involvement or beyond any expected capability which the region might hope to achieve.

Although cooperation with Soil Conservation Service personnel has been excellent, the effectiveness of our reviewing functions would be improved greatly by an appropriate memorandum of understanding between the Soil Conservation Service and the Bureau of Outdoor Recreation. At present, neither agency knows exactly what function BOR is attempting to perform.

The memorandum should establish the Bureau's role as the public advocate in all matters pertaining to recreation and associated needs. The Bureau should, in this role, do the following:

1. Provide an inventory of recreational resources within the watershed with and without the proposed work plan.

2. Establish the significance of these resources through an analysis of the demand, supply, and needs within the watershed zone of influence and by relating the resources within the watershed to those within the region, State, and Nation, and to the approved statewide comprehensive outdoor recreation plan and/or other comprehensive plans.

3. Determine the effects of the proposed work plans on the recreation potentials and associated values existing in the watershed.

4. Provide conceptual plans for the development and protection of the recreation resources within the watershed assuming the implementation of the plan. 5. Provide a recreation appendix to the authorizing document for the watershed work plan.

During the next 2 years, assuming our present manpower and funding, we visualize our involvement in the small watershed program as one in which we would review selected work plans to (1) ensure conformance with sound recreation practices and principles, and (2) determine the effects a proposed project would have on resources containing recreation or aesthetic values.

It should be noted that comments on the environmental impact statement to be meaningful require nearly as much study as that required for the authorization report. Fortunately or not, as the point of view may indicate, we have received very few environmental statements on small watershed plans to date.

In summary, we have concluded that the small watershed program in the southeast region is of such proportions and its impact on the recreation and associated values of such serious consequences that the Bureau of Outdoor Recreation's participation in the program has become essential.

ROY K. WOOD.

U.S. DEPARTMENT OF THE INTERIOR,
BUREAU OF OUTDOOR RECREATION,
Washington, D.C., January 18, 1972.

Memorandum to: Director, Bureau of Outdoor Recreation.
From: Assistant Director for Federal Programs.
Subject: Bureau involvement in Soil Conservation Service small watershed

program.

We have reviewed Regional Director Roy Wood's September 2, 1971, memorandum, copy enclosed, summarizing his pilot study. The study appraised the recreation and related environmental values of four watersheds for which the Soil Conservation Service is providing planning assistance under the provisions of the Watershed Protection and Flood Prevention Act (Public Law 83-566) as amended.

The field study approach was to examine each watershed in the context of recreation demands, exclusive of fishing and hunting, projected for the people in the surrounding area, the natural resource base, and the potential future land uses. An analysis was made to determine the capability of the watershed to provide recreation opportunities without the proposed work plan measures and to estimate the effects of work plan measures on recreation and related environmental values within the watershed.

The analysis was accomplished by preparation of a conceptual plan for singlepurpose recreation development which would provide a baseline for the utilization of the resources of the watershed to their theoretical capacity for affording recreation opportunities. The recreation capacity of the watershed with the work plan measures considered in place was compared with the conceptual recreation plan to determine the magnitude of impacts. The conceptual recreation plan provides insight into the environmental values as well as alternatives available to the local interests in the development of the resources of the watershed to meet all the needs of the people.

The North Concordia watershed, Louisiana; Talladega Creek watershed, Alabama: Big Creek watershed, Georgia; and Whitesand-Greens Creeks watershed, Mississippi, were selected for the study because they exhibited a wide range of ecological conditions and water and land use problems. A summary of the findings of each watershed is presented below.

NORTH CONCORDIA WATERSHED, LOUISIANA

The North Concordia watershed encompasses about 225,000 acres, including 214.800 acres in the northern half of Concordia Parish, 8,750 acres in eastern Catahoula Parish, and 1,450 acres in southeastern Tensas Parish. The area is

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