FINAL STATEMENT

PAPILLION CREEK AND TRIBUTARIES, NEBRASKA

Prepared by

U.S. ARMY ENGINEER DISTRICT, OMAHA, NEBRASKA

November 1971 Papillion Creek and Tributaries, Nebraska

( ) Draft (X) Final Environmental Statement

Responsible Office: U. S. Army Engineer District, Omaha, Nebraska

1. Name of Action: (X) Administrative ( ) Legislative

2. Description of Action: The recommended project consists of the construction of 20 lakes and the implementation of a floodplain management program, by local interests in accord with state laws, on the tributaries of the Papillion Creek basin. The structures will control drainage from 1*7/5 of the 1*02 square mile basin. The basin is located directly west and north of Metropolitan Omaha, Nebraska and is presently undergoing urbanization.

3. a. Environmental Impacts: The authorized plan would provide flood protection to all of the basin below the lakes, some 215 square miles. 1*,205 acres of lake surface would be created. 5,255 acres of land would be managed exclusively for wildlife benefits. The remaining 7,515 acres of publicly-owned project land would serve to maintain open space around project sites and for public use. Agricultural production would be lost from that portion of the 16,975 acres of project land which is arable. Forty-four stream miles of generally poor riparian wildlife habitat would be lost by lake construction and fill.

b. Adverse Environmental Effects: Approximately 1*1* miles of riparian wildlife habitat would be eliminated. The loss of agricultural land would reduce farm production in the basin since there is no land available to replace it. The increased development expected around the lakes will lend to the degradation of the impounded waters.

1*. Alternatives: Floodplain zoning, channel improvements and levees, flood proofing and diversions.

5. Comments Received:

Environmental Protection Agency City of Omaha Bureau of Sport Fisheries and Papio Watershed Board Wildlife Metropolitan Area Bureau of Outdoor Recreation Planning Agency Soil Conservation Service Nebraska Association of Soil and Nebraska Soil and Water Water Conservation Districts Conservation Commission Quality Environment Council Nebraska Game and Parks League of Women Voters Commission of Omaha Sarpy County Board of Commissioners

6. Draft statement to CEQ on 26 August 1971. Final statement to C E Q __ 2 9 NOV 1971___ . I. Project description.

The Papillion Creek and Tributaries flood control project was authorized by the Flood Control Act of 1968 (Public Law 90-U83) in accordance with the Chief of Engineers recommendations in House Document No. 3^*9» 90th Congress, 2nd Sesssion.

The recommended plan of development provides for the construction of a multiple-purpose system of 20 dams and lakes at locations throughout the Papillion Creek basin for providing flood control, recreation, fish and wildlife, and downstream water quality benefits. It is estimated that floodplain damage will be reduced approximately 87$.

The lakes would provide a storage capacity of 217,780 acre-feet principally for controlling floods in the Metropolitan Omaha area. The sediment reserve zones, totaling 1+6,560 acre-feet, would be utilized to impound multiple-purpose pools. Table 1 lists the volumes, the surface acres, and the depths of each lake. The project would create l+,205 acres of lake surface, with individual lakes varying in size from 1+0 acres to 650 acres. 5,255 acres of land would be managed exclusively for wildlife benefits. The remaining 7,515 acres of land would be used for embankment and spillway construction, maintenance and operation facilities, recreational development, and preservation of open space around project sites.

Water quality releases will be made from Sites 1, 2, 3, 10, 11, 15, 18, and 20. Releases will be sufficient to maintain 3 cubic feet per second on the Little Papillion Creek at Irvington, Nebraska, 3 cubic feet per second on Big Papillion Creek above Washington-Douglas county line, and 3 cubic feet per second on the West Branch above Papillion, Nebraska.

The combined drainage area of the project totals 186.6 square miles, approximately kl% of the basin. Drainage areas for individual sites vary in size from 2.0 square miles to 32.9 square miles. All dam embankments would be rolled earth filled structures equipped with service outlets and grassed earthen-cut emergency spillways. See plate 1 for project location.

The project is currently in the preconstruction planning stage with a revised general design memorandum completed for all sites. A specific design memorandum is being prepared for each individual site. The benefit- cost ratio of this project is currently 3.0 to 1.

II. Environmental setting without the -project.

The Papillion Creek drainage basin lies in eastern Nebraska in Washington, Douglas and Sarpy Counties. The basin is Ul miles long, averages 12 miles i.. width, and covers approximately U02 square miles. TABLE 1

INDIVIDUAL LAKE DATA FOR MULTIPURPOSE POOL

Site Vo lime Surface Acres Maximum Depth Acre-Feet Feet

1 6,000 600 26 2 5,500 1*75 29 3 5,500 650 25 1* 2,850 215 . 32 5 750 85 19 6 750 60 23 7 i*o o 1*0 2U 8 650 1*0 22 9 1*00 1*5 19 10 1,200 125 30 11 U.500 1*00 30 12 600 65 17 13 500 60 25 lU 650 70 27 15 U,220 3l*0 30 16 1 ,5 0 0 135 1*H 17 Not recommended Not recommended Not recommended 18 U . ^ O 320 1*0 19 . 1,100 115 21 20 3,650 285 31 21 900 80 33 The principal tributaries are the Big Papillion Creek, West Branch and Little Papillion Creek. The headwaters of Big Papillion Creek are approximately 1* miles northwest of Blair, Nebraska. The Little Papillion Creek Joins the Big Papillion Creek Just south of Omaha, Nebraska, to form Papillion Creek. The West Branch merges with this a short distance above Offutt Air Force Base. From there, Papillion Creek flows southeast and enters the Missouri River approximately 4 miles south of Bellevue, Nebraska.

Physiographically, this region is known as the dissected till plains section of the Central Lowlands Province. The valleys slope in a generally southerly direction. Valley widths average about 1,000 to 1,500 feet in the upper reaches, extending to one mile in some areas in the lower basin. Surface soils axe largely loess derived mollisols and highly erodible. Deep, wide gullies form in many drainageways. Sheet erosion is a serious problem on the slopes. The streams are characterized by deeply-cut streambeds with steep sides. Many of these erosion problems have been accentuated by poor land management practices.

The lower portion of the basin is in an urban setting composed of west Omaha, Ralston, Bellevue and Papillion. Intensive farming is practiced throughout the remainder of the basin. Less than 1# of the land area remains in native tree, grass and shrub cover. A significant portion of this fringes the drainageways and comprises most of the basin's wildlife habitat. Species of woody vegetation found in the basin include cottonwood, box elder, mulberry, willow, green ash, silver maple, American elm, walnut and cedar. Nettle., ragweed, chokecherry, gooseberry, honeysuckle, timothy, wild rye, brome, clover and foxtail number among the shrub and grass species found in the basin.

Game birds and animals inhabiting the basin include whitetailed deer, bobwhite quail, cottontail rabbits, fox squirrels and pheasants. Non-game species include fox, coyote, raccoon, mink, weasel, muskrat, opossum, skunk, and the common species of moles, shrews, ground squirrels, field mice, and rats. Common resident birds would include the yellow shafted flicker, downy woodpecker, bluejay, blackcapped chickadee, robin, cardinal and American goldfinch. Woody vegetation along the watershed attracts numerous species of warblers, orioles, sparrows, thrushs, hawks, and owls during spring and fall migrations. Numerous bird species such as the red-headed woodpecker, eastern phoebe, cardinal, catbird, robin, and brown thrasher would find habitat in the watershed suitable for nesting. Waterfowl are found occassionally in the basin, but rarely on any of the Papillion Creek tributaries. Although many species of birds are common to the basin, no rare, endangered or unique species of birds are known to inhabit the basin.

The huntable game populations within the basin have been decreasing the past few years, principally due to decreasing habitat. During this same period the numbers of hunters have teen increasing; resulting in very heavy hunting pressuie. Hie posting of land by private owners to prohibit hunting has helped to reduce the hunting pressure and conserve existing game populations. Below Omaha, Papillion Creek and its tributaries are quite polluted. Zero dissolved oxygen concentrations and high colifonn populations are common. The water quality of the streams in the upper reaches of the basin is degraded during periods of precipitation when waters rich in nutrients and high in turbidity, BOD and coliform populations pour into the normally low flowing streams. Studies by the Metropolitan Area Planning Agency have shown that fecal coliform populations and 5 day BOD readings in the basin tributaries vary respectively from 600,000 - 6,000,000 MF/100 ml and 39-116 mg/1 in the lower portion of the basin to 400 - 1,900,OOOMF/lOO ml and 2-13 mg/1 in the extreme northern portion of the basin. There are feedlot facilities in the basin for over 65,000 cattle which contribute to the pollution of the basin. A large portion of the land in the basin is devoted to agricultural use. This also contributes pollutants in the form of insecticides, herbicides and which accumulate in the runoff. These conditions exist through­ out the basin and have helped to reduce the fishery to a small number of carp and bullheads.

The City of Omaha has initiated a program which would considerably reduce the pollution in the lower Papillion Creek basin. The plan is scneduled for completion by the end of 1975. However, this timetable depends on the availability of State and Federal matching funds and local revenue bonds. The Soil Conservation Service is presently implementing a land improvement program which calls for 55* of the basin to come under the influence of grade stabilization structures. The first of 52 of these structures is complete and five more are planned for construction during 1971. The completion of this program would also improve the water quality in the Papillion Creek basin.

In 19^8, the State of Nebraska enacted legislation requiring all counties and towns to adopt a floodplain management program. This program has been implemented in the Papillion Creek basin and currently places restrictions on the type of development allowed within the 100-year floodplain. Although the program allows existing development to remain on this 100—year floodplain, it does place restrictions on the amount of improvements or repairs that can be made to these existing structures. Even though the program does impose restrictions on floodplain development, it is far from adequate. Primarily the inadequacy rests on the fact that floodplain management codes restrict only to the 100-year flood and no restrictions are placed on greater floods. The only totally adequate zoning would be the elimination of both existing and future development in the floodplain of the Probable Maximum Flood.

The characteristics of the basin have been changing from rural to urban since World War II. Presently, portions of five of the proposed dam and lake sites fall within the zoning limits of Omaha. By the year 2020, it is expected that all but the two most northern lakes will fall under some urban zoning authority. In 1970 an estimated 5,COO persons resided on the floodplains of the Papillion Creek basin. By the year 2020, this figure is expected to reach 25,000. Thi3 increasing urbanization has, in conjunction vith the basin's low-flow capacity streams, created a severe flood problem in the basin.

Certain improvements have already been made to alleviate the flood problem in the basin. These have been in the form of channel stabilization and improvement and are confined to the lover portion of the basin where the streams run through highly urbanized areas. These areas of improvement are downstream of the proposed sites and would not affect the proposed construction.

Flood damage in the past has been severe and it is expected to increase in the future. Since 1929, l6 major floods have been recorded in the Papillion Creek basin. The most damaging of these occurred in 196U when record discharges were recorded on Papillion, Big Papillion and West Branch Papillion Creeks. An estimated $U,9 6 2,000 in damages resulted. 87? of this damage was to urban facilities. Seven lives were lost as a result of this flood.

As a result of project authorization, the national Park Service is completing a historical and archeological evaluation of the basin and is planning extensive archeological salvage where necessary.

III. The environmental impact of the proposed project.

A. Identify impacts.

1. The proposed action would reduce the damage to property due to flooding in the Papillion Creek basin.

2. The proposed action would reduce the threat of loss of life and in g neral improve the health conditions in the basin.

3. The proposed action would place approximately 16,975 acres of land area in public ownership for the benefit of present and future generations including about 7,515 acres for recreation, open space, and operation and maintenance uses and over 5,255 acres for wildlife management and public hunting. The projects would cumulatively provide **,205 water surface acres with lakes ranging in size from Uo to 650 surface acres.

1*. The project would destroy approximately 4it stream miles of riparian stream habitat and reduce the agricultural production of the basin.

3. Beneficial aspects.

1. The proijosal would increase the amount of flood protection afforded the Papillion Creek basin. It is estimated that floodplain damage will be reduced approximately Q7%. 2. The proposed action would greatly reduce the chance for the reoccurrence of loss of life as occurred in 19&U. The proposed project would alleviate the personal hardships imparted by flooding. It would also lessen, in part, those conditions required for the propagation of mosquitoes, rats, mice, and other pests which become prevalent after flooding. The system of 20 lakes would reduce bank cutting on the highly ercdible loess soils. Downstream releases for water quality control would be made from the stored waters of eight of the larger lakes into Little Papillion, West Branch Papillion, and Big Papillion Creeks. Sediment retention would reduce downstream silt and nutrient pollution.

The project would encourage clustered urban growth adjacent to project boundaries. Interspersed open space would result. If the authorized project is not constructed, it is reasonable to assume that the basin will slowly divert from rural to an urban setting. This includes development of the floodplain to the extent permitted by the existing floodplain management regulations.

3. The proposed action would create 20 lakes with a combined total surface area of U205 acres. Present plans call for fisheries to be developed in all the lakes. This replaces the kU miles of an essentially non-existent carp and bullhead fishery. The greatly expanded fishing opportunities would be situated in a heavily populated area which is grossly lacking in places to fish. However, it is doubtful that these lakes will uniformly provide good fisheries due to water quality limitations, unless adequate land treatment measures are taken to prevent the lake waters degradation from upstream areas. Wildlife management and hunting areas would be maintained on over 5255 acres of project land. Nesting, feeding, resting and congregating areas for migratory waterfowl and shoreblrds would be created. Juxtaposition of lakes to agricultural lands would provide waste grains as a food source until such time that these lands are developed. The allocation of lands for wildlife management would provide much needed food and cover; resulting in increased game populations said more public hunting space* as well as helping control erosion and improve water quality.

The distribution of the 20 lakes, the variation of the lakes in surface area and depth, the present lack of recreation water surface and the proximity of the lakes to Metropolitan Omaha would provide opportunities for diversified and desirable recreational development. The projects too, would provide nodes for a network of open space activities such as hiking, bicycling and horseback riding and natural resource suitable for city park, high-density type use. Recreational development at Lakes 11, 15, lo and 18 will be sponsored by the City of Omaha and are an integral part of its future park and recreation development plans. C. Detrimental aspects.

1. Agricultural production of land which is presently under cultivation would be lost. However, completion of this project would only hasten the loss since urbanization of the basin's farmland is already occurring. There is expected to be a reduction of basin wildlife numbers and hunting opportunities during the construction period due to the loss of M miles of riparian stream habitat. Greatest initial losses of habitat would occur on Sites 3, 8, 9» 11, 15» l6, 18 and 20 where woody vegetation along the channels is mature, dense and offers good reproduction and escape cover.

Construction in the remaining sites would cause little or no wildlife habitat loss as the land adjacent to the channel has been cleared for agricultural production. The temporary loss of habitat is not expected to be significant and should be more than compensated by the 5»255 acres of wildlife management lands established by project completion.

2. The water quality in the lakes will ultimately be no better than the quality of the basin's streams. Potentially, the biomass in the lake water could be as much as fifteen times greater than the biomass of the stream water entering the lake. It is possible that this high production of biomass will not be realized due to some inhibiting factor such as turbidity. Should this level of productivity be attained; it is likely that it would be a major factor in determining the amount of public use realized on a lake. It would also be a major factor in determining the extent of which a sport fishery could be developed and maintained on a lake.

As lakes are completed, it is anticipated that sufficient biological data and lake experience within the basin will permit development of a model for predicting plant growth relationships. These relationships, once they are quantified, will be incorporated into design techniques and operation and maintenance procedures.

3. The filling of the multiple-purpose pool by sediment will result in continuous deterioration of some water based activities.

U. The completion of the project could result in downstream areas being more extensively developed. This would result in a reduction of the greenbelt along the downstream channel. This development would be possible because the project will reduce the amount of legal zoning requirements below the project area. D. Remedial, mitigative and protective measures.

1. Initial loss of wildlife habitat is not expected to have significant effects on wildlife populations. According to U.S. Forest Service data, there are only 300 acres of forest in the basin; most of which lie along the channels of the drainageways. The 5,255 acres of wildlife management lands would more than offset the initial habitat loss.

The wildlife lands will be planted in native trees, shrubs, and grasses. Since mature stands of vegetation will be removed in some areas, replacement plantings will be diverse as possible to help reestablish functional wildlife habitat as rapidly as possible.

2. The establishment of 1* ,205 surface acres of lakes will make the fishing potential much greater than presently exists in the Papillion streams.

3. Pesticide use during construction is not envisioned at this time. If pesticide use is indicated during operation and maintenance of the project sites, Federal guidelines have already been established to control the type used and its method of application.

U. Measures are being taken to improve the water quality in the basin from the aspects of erosion and siltation. A Watershed Work Plan for the Papillion Creek Watershed was prepared by: Sarpy Soil and Water Conservation District, Douglas Soil and Water Conservation District, Papio Soil and Water Conservation District, Douglas County Commissioners, Sarpy County Commissioners, Washington County Supervisors and Papio Watershed Board with assistance by the U.S. Department of Agriculture Soil Conservation Service, U.S. Department of Agriculture Forest Service, State of Nebraska Soil and Water Conservation Commission which provides for grade stabilization structures and land treatment measures throughout the basin. Structural works of improvement will consist of 52 grade stabilization structures to be installed over an eight year period. Site 16, for example, will have two grade stabilization structures within its drainage area, and Site 11 will have three grade stabilization structures within its drainage area. Conservation treatment will be established on 52,600 acres of cropland, 3,800 acres of pastureland, 150 acres of woodland, and 3,100 acres of other lands.

Preconstruction measures to be taken by the Corps to improve water quality in the basin include such actions as the immediate seeding of lake basin areas upon purchase and the harvesting of crops prior to closing of the dam to help remove some of the nutrients in the soil. Consideration is being given to compaction of the shoreline prior to a lake's filling to make it difficult for rooted aquatic vegetation to become established. Consideration is also being given to the establishment of marshes in the upper reaches of certain lakes; thereby utilizing some of the nutrients before they enter the lake. IV. Any adverse environmental effects vhlch cannot te avoided should the proposal be implemented.

At multiple purpose pool elevations, U,205 acres of generally mediocre habitat would be inundated by the lakes. This includes UU miles of small stream habitat. Agricultural production would be lost from that portion of the 16,975 acres of project land which is arable. Project construction would result in local changes in geomorphology; but effects on ecological systems will be small due to an inherently hilly terrain, physical and chemical uniformity of loess soil profiles, and relative ease in establishing native perennial vegetative cover for mitigation and enhancement purposes. Urban use of the lands surrounding the lakes would be accelerated. Additional water pollution sources would arise from intensifying human inhabitation of these areas.

Impoundment lakes will be eutrophic as defined by their preconstruction potential for excessive aquatic plant growth. However, excessive growth may not occur in all lakes.

In 1969, the State of Hebraska established minimum water quality standards for all bodies of water. The standards, based on use classification, are related either directly or indirectly to the problem of aquatic plant growth. Standards, based on use classification, are related either directly or indirectly to the problem of aquatic plant growth. Standards impose limits on the following water quality criteria: number of coliform organisms, concentrations of taste and odor producing substances, turbidity, concentration of toxic and deleterious substances, water temperature and temperature change, dissolved oxygen, concentration of hydrogen ion, dissolved solids and concentration of residue oil and floating substances. Flood control lakes will periodically receive high volume inflows of poor quality runoff. These inflows can cause the lake water to drop below state water quality standards. However, these conditions should occur only occasionally and should not last for any great length of time. It is also possible that state water quality standards will occasionally be breached as a result of excess aquatic plant productivity. It is not anticipated that these occasional violations would have any lasting adverse effect on project purposes.

V. Alternatives to the proposed action.

One alternative to the proposed action would be to recommend no flood control measures in the Papillion Creek basin. Under this course of action $9,605,700 per year in flood control and recreational benefits would be lost. The environmental conditions in the basin would remain in their present dynamic state. The threat to loss of human life and personal property would remain as would the miseries associated with flood evacuation and reclamation. • It is safe to assume that without the project urbanization of the basin would continue. This would result in the reduction of habitat for game and non-game species of birds and animals. It would result in the exposure of more people to the risk of flooding. It would result in urban runoff replacing agricultural and feedlot runoff as being the primary polluter of the Papillion Easin streams.

Other alternatives considered for the project included flood plain zoning, channel improvements and levees, flood proofing and diversions. Reasons for not selecting other alternatives as exclusive solutions are given below:

A. Flood Plain Zoning. Consideration was given to the possible evacuation of the floodplain; but extensive development precluded economic Justification. Zoning would control future floodplain development, but could not prevent damage to existing development and was therefore, not practical as a complete solution. The environmental consequences of flood- plain zoning would be the same as the environmental consequences of no action, depending upon the zoning regulations themselves.

B. Channel Improvements and Levees. Channel improvements and levees would offer an effective solution. However, since much of the basin requires protection, its cost was prohibitive. Channel improvements would also destroy more of the existing riparian habitat, since the woody vegetation in many areas is restricted to the proximity of the streambanks. Levees would also result in more destruction of habitat. The construction of a levee normally requires land beyond the actual streambanks. This results in additional removal of woody vegetation. When building levees, material for construction is required. This sometimes necessitates borrow areas which may be environmentally detrimental and costly to correct.

C. Flood Proofing. Consideration was given to flood proofing the existing development. At least 10 feet of flood proofing would be required to effectively protect existing development. The average annual cost of flood proofing all development in the basin would be at least five times greater than the damages that would be prevented. Although the environmental conditions would remain essentially the same, the cost of such a proposal is prohibitive.

D. Diversions. Consideration was given to diverting flood waters around existing development. This proposal was eliminated as being ineffective. The large amount of development and its diversity throughout the basin makes the effective implementation of such a proposal virtually impossible. The selected plan includes a system of 20 multipurpose reservoirs and floodplain management. Project purposes include flood control, recreation and water quality. It is assumed that zoning would eliminate future structural development within the 10-year flood limits and that zoning and flood proofing will reduce the possible future damages between the 10-year and the standard project flood limits. Implementation of floodplain management is the duty of local authorities.

Realized from project construction would be an estimated $7,556,000 in annual flood control benefits; $2,0^9,700 in annual recreation, fish and wildlife benefits; and $15,100 in annual water quality benefits. Lost would be stream miles of generally mediocre wildlife habitat. Gained would be 5,255 acres of potentially good wildlife habitat devoted exclusively to wildlife management. Created would be 20 lakes totaling U,205 surface acres whose potential water quality cannot be quantified; but appears to be questionable in some sites.

VI. The relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity.

The approximately 16,975 acres of land area would be dedicated to improving the environmental quality of man through flood protection and amenities of life. The value of these project benefits would undoubtedly increase with time. The 20 lakes would encourage dispersal of urban settlement and recreational activities in rural areas of intensive agricultural production. Locally, areas of agricultural production, interspersed with lakes and urban development, would result in an initially better environmental balance of biological quantities. These biological quanities, people, agricultural production, natural populations of terrestrial and aquatic plants and animals, are necessary for providing the amenities of life. Basin agriculture will undergo an accelerated period of adjustment in terms of farm family migration and farm consolidation. The long-term productivity of the basin would be improved through increased flood protection, soil erosion control, conservation of water resources, and vastly increased recreation and open space benefits. Stringent urban zoning regulations will be necessary to provide better and safer living conditions and responsible land use. This project would establish a living laboratory from which scientists could collect biological, sociological, and technological data which could be used to better evaluate methods of improving the environment.

VII. Any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented.

It is highly unlikely that the L.205 acres of land devoted to lakes could readily be returned to agricultural production or preproject flexibility of private use. The commitment of labor and material resources associated with construction of the project would be irretrievable. VIII. Coordination vith others.

A. Public Participation.

Two public meetings were held on this project. The first on 6. November 196U for the initiation of a flood control study. The second meeting was held on 7 July 1966 to discuss the proposed solution. News releases were issued concerning the public meetings. At the time of these public meetings environmental statements were not required and, as a result, no formal discussions were conducted concerning the environmental impacts of the proposed project.

B. Government Agencies.

The draft environmental statement was sent to the following governmental agencies requesting their views and comments. Their comments are summarized below and copies of the replies attached to the environmental statement.

1. Environmental Protection Agency.

Comment: The "project description" section should contain information pertinent to the individual reservoirs, to include surface areas, volumes and depths.

Response: The comment was considered valid and the statement has been revised to include this information.

Comment: The "Environmental Setting without the Project" should include discussion of pollution problems of agricultural wastes.

Response: The comment was considered valid and the statement was revised to include this discussion.

Comment: A discussion should be included concerning the effects of impoundment on stream water quality.

Response: Section IV, "Any adverse environmental effects which cannot be avoided should the proposal be implemented" discusses what might happen to the water quality as a result of impoundment.

Comment: A discussion should be included concerning the effects of impoundment on attempts to improve basin water quality in the future.

Response: Concur. It is anticipated that impoundment will facilitate the improvement of basin water quality by increasing the methods by which tl.:^ improvement could be made. This is discussed further in Section III. Comment: Felt that construction of the reservoirs should be preceded by an effective program designed to eliminate or minimize water quality problems from agricultural runoff, sewage, pesticides, urban runoff and erosion from construction practices.

Response: Comment was considered valid and statement was revised in Section III to include a discussion of these practices.

2. Bureau of Sport Fisheries and Wildlife.

Comment: Indicates that the draft statement in general provides adequate consideration of the environmental impacts.

Comment: Mention of the numerous non-game birds and animals found in the area would be appropriate to emphasize the non­ hunting recreational values of wildlife.

Response: Concur and the statement revised to include this information in Section II.

Comment: Expressed desire to have "shrinking habitat" mentioned as one of the more important aspects in controlling wildlife abundance.

Response: Concur and statement has been revised in Section II to include this thought.

Comment: Add to sentence 5, paragraph 1, page 6 after "limitations", "unless adequate land treatment measures to prevent erosion and siltation are taken".

Response: Concur with thought and the statement was revised in Section III to so reflect.

Comment: Page 6, paragraph 1, last sentence - change to read "...in increased game and non-game populations and more public hunting space as well -as helping control erosion and improve water quality.

Response: Concur and statement so revised.

Comment: Made three recommendations pertaining to lands set aside for wildlife management: a. Project boundaries to be surveyed, monumented, and fenced to prevent encroachment of private interests onto project lands, b. The Nebraska Game and Parks Commission be granted the authority to administer all lands, including grazing and hay lands, within the boundaries of the management areas, c. The license, provisions for fish and wildlife management purposes on Papillion Creek and Tributaries should include that the Nebraska Game and Parks Commission may plant crops, either directly or by service contract, or under sharecrop agreements with local farmers to produce food for wildlife, and may sell any excess production. The proceeds from the disposal . of any production may be used to defray other costs of administering the wildlife program. Response: Project boundaries will be surveyed and monumented. Fencing will be done, but the extent has not been decided. The Nebraska Game and Parks Commission will administer lU sites, the City of Omaha will administer 1» sites, and Sarpy County will administer the remaining two. Nebraska Game and Parks Commission will offer technical assistance to the City of Omaha and Sarpy County to aid in administering the sites under their authority. The license provisions mentioned above are already a part of our leases. District regulations require that the proceeds from the sale of excess crop production must be held in reserve to purchase wildlife food during years of poor crop yield or crop failure. Other administrative costs are the responsibility of the leasee.

3 . Bureau of Outdoor Recreation.

Comment: Consider rewording of Section D, "Remedial, mitigative and protective measures" to reflect the continued need for floodplain management and zoning to afford protection from floods of greater severity than the project is capable of handling.

Response: The comment was considered valid but cannot be included under Remedial, mitigative and protective measures section because the Corps of Engineers cannot offer assurance that this problem will be alleviated.

U. Soil Conservation Service.

Comment: Concurred with the comprehensive coverage of the Environmental Statement.

5 . Nebraska Soil and Water Conservation Commission.

Comment: Felt that references to fishing potential were too vague.

Response: We concur, but due to the limited information available, we felt that we should not be more specific.

Comment: Suggested we mention sources of water quality degradation and the possibility for future mitigation of anticipated water quality problems.

Response: Refer to comment number 1.

6 . Nebraska Game and Parks Commission.

Comment: Suggested that reference to birds in the basin be more specific. Response: The comment was considered valid and the statement was revised in Section II to include this information.

Comment: The impact of hunting on the watershed's wildlife carrying capacity is relatively minor. Habitat is the overriding aspect controlling wildlife abundance in Washington, Douglas and Sarpy Counties.

Response: Concur, but referenced paragraph intends to point out only that hunting pressure has been increasing in the basin.

Comment: We question the extent of which the project will actually aid in the preservation of open space.

Response: The comment was considered valid; however, assurance of open space between project sites is outside the framework of the project authority. Open space will; however, be maintained at each project site. In time most of the open space between sites will be developed to some extent. Although this could result in an environmental imbalance, it is anticipated that this imbalance would be less with the completion of the project. Completion of the project should serve to maintain open space that might otherwise be developed.

Comment: Compensation for the wildlife habitat to be destroyed can only be accomplished by improving the diversity and inter- ‘spersion of remaining habitat or by creating new habitat.

Response: We concur, 5,255 acres of land would be managed exclusively for wildlife benefits. These lands would more than offset the initial habitat loss.

7. Sarpy County Board of Commissioners.

Comment: The Sarpy County Board endorses the environmental statement.

8. City of Omaha.

Comment: Concur with the environmental statement.

C. Citizen Groups.

The draft environmental statement was sent to the following citizen groups requesting their views and comments. Their comments are summarized below and copies of the replies attached to the environmental statement.

1. Papio Watershed Board.

Comment: Expressed concern that the statement does not mention that the acreage lost to agricultural production does not take into consideration roads, farmsteads, unfarmable creeks and banks, and odd shaped parcels that are uneconomical for agricultural production. Response: The concern is valid and the statement was revised to include this thought.

Comment: Express the view that the buffer strip around project sites, along vith proper sewage disposal and developmental controls, could give adequate protection of all water areas.

Response; Concur, but the Corps has no control of land outside of project areas. SCS has an active program in the basin concerning watershed improvements. The State of Nebraska has a law concerning treatment of domestic waste and feedlot runoff. The above should help maintain the environment of the area.

Comment: It might be advisable to enlarge the last sentence of paragraph 1 on page 3 to indicate that many of these erosion problems have been accentuated by poor land management practices and earlier drainage and stream realignment projects.

Response: The Environmental Statement says that "many of these erosion problems have been accentuated by poor land management practices". Stream realignment projects have been accomplished, for the most part, within the city limits of Omaha and have actually reduced the erosion problem.

Comment: Millard is now a part of Omaha.

Response: We concur and the word has been deleted from the Environmental Statement.

Comment: It should be pointed out that all of the area within the Papillion Creek basin is currently zoned by some governmental agency. Therefore, zoning authorities are exercised throughout the entire basin and will be from the onset of the project. In the same paragraph there is a projected population increase from 5*000 to 25,000 persons in the floodplain of the Papio Creek. With proper zoning and subdivision regulations, this population increase should be of such a nature that it would be suceptible to only flooding from very rare occurrences.

Response: Concur. The entire basin is under some type of zoning authority. The referenced paragraph refers to urban zoning other than county or floodplain zoning.

Comment: Indicated that recommended floodplain management program as discussed in Section V would not be in accord with existing floodplain management programs already established in the basin. Response: Concur. The 10-year flooding is technically not the Selected Floodway. However, it does approximate the selected floodway and as such gives more meaning to the average reader.

Comment: Thought the phrase "although it is doubtful that these reservoirs will ever provide quality fishing" was rather pessimistic in view of the fishing presently available in eastern Nebraska.

Response: Concur. Statement has been revised to reflect the possibility that the lakes will produce fisheries of a good quality.

2. Metropolitan Area Planning Agency.

Comment: In general, we find the statement quite honest and factual, and compliment the Corps on its preparation.

Comment: Did not agree that thehmtable game populations within the basin have been decreasing over the past few years.

Response: The Nebraska Game and Parks Commission indicates that habitat is the principal factor in determining game abundance in Washington, Douglas and Sarpy Counties. Since urbanization has been taking place in the basin and will no doubt continue; and since urbanization reduces habitat, we believe our statement is correct.

Comment: Do not agree that B.O.D. and fecal coliform counts have a direct effect on fish populations.

Response: Under natural stream conditions, B.O.D. and fecal coliform counts are not significant in relation to the fish population; but under polluted conditions, B.O.D. and fecal coliforms become more important to the fish population. Since the Papillion Creeks are polluted, this has a significant effect on existing fish populations.

Comment: We question the statement that the project will benefit water quality.

Response: One of the features of this project will be water releases to maintain a minimum flow. The benefit from this is that the water will flow continuously and help to overcome some of the problems of stagnating water.

Comment: We do not believe that any beneficial aspects can be assigned to downstream nutrient control as a result of the project.

Response: Concur that the benefit may be small, but a lake tends to trap nutrients due to the growth of aquatic plants. This reduces the amount of nutrients released downstream. 3• Nebraska Association of Soil and Water Districts.

^3iment2_ Concurred in the general content of the statement.

U. Quality Environment Council.

Comment: Expressed concern over the value of recreational benefits due to questionable vater quality.

Response: This fact had been taken into consideration since recreational benefits were based primarily on non contact water recreation.

Comment: Expressed concern about urban dispersion as a quality of the project and the possible resultant pollution problems from urban sprawl.

Response: Concur in this possibility. However, the Metropolitan Area Planning Agency and the Papio Watershed Advisory Board have master plans which should go a long way in establishing environmentally sound urban development around project sites.

Comment: These dams should not be built. There should be good floodplain zoning.

Response: Floodplain zoning does not help or protect the people already settled on the floodplain.

Comment: Expressed concern over the loss of agricultural production in time of a population boom.

Response: The concern is considered valid; but flood protection must be afforded people, and recreational areas must also be provided for these people.

Comment: The Papio Watershed Dams as now planned are another part of a massive hoax that has been perpetrated upon the American public by those believing that a dam will solve sill of ones problems.

Response: The Environmental Impact Statement was sent to 23 agencies for review and comment. Public meetings have been held on the proposed project to elicit public opinion. The Environmental Impact Statement has also been made available to the general public for review and comment. It would seem that if the American public were interested in opposing the proposed project, their opposition would have been voiced by now. Certainly ample opportunity has been afforded.

5. League of Women Voters of Omaha.

Comment: How many governmental bodies are there in the Papillion basin who have the authority to establish floodplain zoning, and how many of them have committed themselves to establishing good floodplain management? Response: The counties of Douglas, Sarpy and Washington and any incorporated village or town in the basin have the authority to establish floodplain zoning regulations. The Papio Watershed Advisory Board says that "zoning authorities are exercised throughout the entire basin."

Comment : What cooperation will there be between the independent projects?

Response: There is some uncertainty as to what is meant by this question. Within the project boundaries there will be coordination between the individual sites. The lands, outside project boundaries, between project sites is outside the authority of the Corps.

Comment: What coordination has been worked out with the various governmental agencies?

Response: Consultation has been made with the Metropolitan Area Planning Agency, the Papio Watershed Advisory Board, the City of Omaha, and the counties involved. The Metropolitan Area Planning Agency says that "this project is not a duplication of effort nor Federal expenditure within the Omaha-Council Bluffs Metropolitan Area".

Comment: Is this plan for the Papillion Basin consistent with the State Water Plan?

Response: Warren D. Fairchild, Executive Secretary of the State of Nebraska Soil and Water Conservation Commission, states "the proposed plan of improvement for this area has been endorsed as a part of the State Water Plan."

Comment: What measures can be taken to supervise construction in the vicinity of the proposed lakes, prior to government procurement, so that new building will be in harmony with the purposes and guidelines of this project?

Response: The above mentioned zoning authorities, which are in effect, are expected to keep new building within the guidelines and purposes of the project.

Comment: What measures will be, or could be taken to prevent speculators from buying up cheap floodplain land and making great capital gains when publicly-financed dams greatly increase the value of that land?

Response: It is outside the authority of tbeCorps of Engineers to control such speculation. The courts must decide what the fair market value is. Comment: Will there be ordinances to limit building around the lakes to the extent that sevage facilities can adequately handle the load?

Response: Sanitary facilities, on the project lands, will conform with the requirements of the State of Kebraska Department of Health. Outside of project lands, the Corps has no authority but State lavs will control the pollution from adjacent lands.

Comment: Will water rights downstream from the reservoirs be affected, vith the change in flow?

Response: Water rights downstream from the project should not be affected. Water releases have been calculated to account for evaporation and to sustain water flow during dry times.

Comment: What is the estimated streamflov depletion due to this project?

Response: The total depletion is based upon the amount of evaporation and infiltration from the lakes as opposed to that from the existing streams. Although the exact figures are not known, it is expected that there will be significant stream flow depletion after project completion.

Comment: What effect will the elimination of flooding have on natural ecological systems?

Response: The effect should be insignificant since we are not dealing with a natural ecological system. We are dealing with an altered ecological system, altered by man's encroachment upon a floodplain (urbanization). If the question were to allow for man's presence on the floodplain, then the effect would be to render the floodplain more hospitable to man and his endeavors.

Comment: Is there thought of using any of the water stored in the reservoirs for municipal and industrial requirements?

Response: At the present time, there are no plans for using stored water for municipal or industrial requirements.

Comment: What assurance is there that the wildlife areas will be kept inviolate?

Response: State and local bodies will administer project land and water areas for recreation and fi3h and wildlife enhancement in accordance with the provisions of Public Law 89-72, which establishes permanently these lands for wildlife benefits. Comment: We question the emphasis on public hunting.

Response: Concur in part. Public hunting will be allowed only at some sites. Individual circumstances for each site will help determine where hunting will be allowed. Public safety will be the primary control in operating hunting areas.

Comment: What measures will be taken to control soil erosion above each of the lakes?

Response: A Watershed Work Plan for the Papillion Creek Watershed was prepared by: Sarpy Soil and Water Conservation District, Douglas Soil and Water Conservation District, Papio Soil and Water Conservation District, Douglas County Commissioners, Sarpy County Commissioners, Washington County Supervisors and Papio Watershed Board with assistance by the U. S. Department of Agriculture, Soil Conservation Service; U. S. Department of Agriculture, Forest Service; State of Nebraska Soil and Water Conservation Commission which provides grade stabilization structures and land treatment measures. Structural works of improvement will consist of 52 grade stabilization structures to be installed over an eight-year period. Conservation treatment will be established on 52,600 acres of cropland; 3,800 acres of pastureland; 3,100 acres of other land and 150 acres of woodland.

Comment: Are an/ measures planned, or possible, to decrease the loss of soil from the total Papillion Creek basin, as the waters run into the Missouri River?

Response: See previous response.

Comment: How long are the lakes expected to last, considering other factors than possibly filling with sediment?

Response: For the purposes of flood control, the structures could l-st indefinitely. The economic life is calculated to be 100 years. For the purpose of recreation, the life is virtually unknown, since this is dependent on the water quality which for any extended period of time is unpredictable.

Comment: Will the quality of water make fishing feasible in all the lakes?

Response: Fishing of some type will be available in all the lakes initially. The quality of fishing, including types of available fish, will depend upon the quality of the impounded water. Obviously all of the lakes will not have identical water quality. Therefore, it is possible that certain lakes will develop water quality which would preclude their use for fishing. Comment: What will be done to guarantee that the lake waters will be kept clean enough for water-contact sports?

Response; At the present time, water-contact sports is planned only at sites 1, 2, 3, 11, 15* and 18. There is no guarantee that the aforementioned sites will be kept clean enough for water-contact sports, but one can be assured all possible measures will be done to maintain these sites with human health in mind.

Comment: What will be done to control feedlot pollution from running into the lakes?

Response: Federal law requires feedlots of 1,000 head and over which contribute runoff from rain and snow melt to install waste treatment facilities. State laws are being formulated, but the extent of their control has not been established.

Comment: Concern about Tranquility Park was expressed.

Response: Tranquility Park is over one half mile from the closest lake and is situated downstream end should not be effected.

Comment: What was learned from the Salt Valley Watershed reservoirs which will be of benefit to this project?

Response: The most important aspect of planning reservoirs that will be of benefit to the Papillion project is that recreation has to be included in the original planning and not added later. The Salt Valley Lakes were not planned with recreational benefits in mind.

Comment: How can eutrophication be avoided in the Papillion lakes?

Response: Eutrophication, simply defined as the aging of a lake, is a natural process, occurring with or without the presence of man and his livestock. The problems start when man's effluent and his animals' effluent are added to a lake in the form of nutrients. These "extra” nutrients serve to accelerate eutrophication. At the present time, methods are being studied which will sidetrack and utilize these nutrients before they can cause trouble in a lake.

Comment: Typing error on page 2.

Response: Concur. It was corrected.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 911 WALNUT STREET. ROOM 702 KANSAS CITY, MISSOURI 64106

Ort-nKor 1 ”2 1071

Colonel Billy P. Pendergrass, Jr. District Engineer Department of the Army Omaha District, Corps of Engineers 7410 U.S. Post Office and Court House Omaha, Nebraska 68102

Dear Colonel Pendergrass:

Reference is made to the letter from your office dated August 27, 1971 asking for comments on the draft Environ­ mental Impact Statement for the Papillion Creek and Tributaries Project.

The plan of development provides for the construc­ tion of a multi-purpose system of 21 dams and lakes at locations throughout the Papillion Creek basin for providing flood control, recreation, fish and wildlife, and downstream water quality benefits.

The following comments, in our opinion, should be incorporated into the final Environmental Impact State­ ment to enable the reviewer to adequately assess the environmental impact of the proposed action.

I . Project Description

This section should contain information pertinent to the individual reservoirs, to include surface areas, volumes and depths.

I I • Environmental Setting Without the Project

We feel that this section should expand its discussion of pollution problems, particularly, agricultural wastes.

Ill. Environmental Impact of the Proposed Project

Pesticide use during the construction, operation, and maintenance of this project should be described and discussed. I V . Adverse Effects

Presently the overall water quality of the basin is poor. In light of this, we feel that this section should discuss the effects of impounding the water on (a) the present water quality, and (b) attempts to improve water quality in the future.

In order to minimize some of the water quality problems that may be associated with these impoundments, we feel that the construction of the 21 reservoirs should be preceded by an effective program designed to eliminate or minimize water quality problems from agricultural runoff, sewage, pesticides, urban runoff, and erosion from construction practices.

Please furnish us with a copy of your final Environmental Impact Statement with agency review comments as submitted to the Council on Environmental Quality.

Very truly yours, United States Department of the Interior FISH AND WILDLIFE SERVICE BUREAU OF SPORT FISHERIES AND WILDLIFE Federal Building, Fort Snelling Twin Cities, Minnesota SSI 11 October 21, 1971

Colonel E. P. Pendergrass District Engineer Corps of Engineers 7^10 U. S. Post Office Ctoaha, Nebraska 68102

Dear Colonel Pendergrass:

This is in response to Mr. Burnett's letter of August 27, 1971, requesting our views and comments on a draft of the five-point environmental statement for the Papillion Creek and Tributaries project in Nebraska.

Our review indicates your draft statement in general provides adequate consideration of the impact this project will have on the environment. However, we do have several comments which are listed below:

Page 3, paragraph 3. Since non-hunting recreational values of wildlife are rapidly increasing, especially near metropolitan areas, the importance of this aspect of wildlife and resource management should be emphasized in this paragraph. Mention of the numerous non-game birds and animals found in the area would be appropriate.

Page 3t paragraph 4 . The contents of this paragraph should indicate that adverse environmental factors, principally shrinking habitat, are the aspects controlling wildlife abundance and not solely the number of hunters applying hunting pressure.

Page 6, paragraph 1. Add to sentence 5 after "limitations", "unless adequate land treatment measures to prevent erosion and siltation are taken". The best method for controlling siltation and erosion is by establishing proper land use adjacent and upstream from a body of water.

Page 6, paragraph 1, last sentence. Change to read ". . .in increased game and non-game populations and more public hunting space as well as helping control erosion and improve water quality."

Page 7, firattparagraph. The statement is made that the 4,700 acres of wildlife management lands would more than compensate for habitat losses. This is not entirely true. The wildlife areas must be developed and managed, likely involving substantial expenditures, to provide habitat conditions necessary to compensate for project-caused losses. To insure that the proper development and management can take place, the following measures should be Included as part of the project plan. It would be appropriate to list them as part of the plan.

a. Project boundaries to be surveyed, monumented, and fenced to prevent encroachment of private interests onto project lands.

b. The Nebraska Game and Parks Commission be granted the authority to administer all lands, including grazing and hay lands, within the boundaries of the wildlife management areas.

c. The license provisions for fish and wildlife management purposes on Papillion Creek and Tributaries should include that the Nebraska Game and Parks Commission may plant crops, either directly or by service contract, or under sharecrop agreements with local fanners to produce food for wildlife, and m y sell any excess production. The proceeds from the disposal of any production may be used to defray other costs of administering the wildlife program.

7 t paragraph U, D.l. Again the measures emphasized immediately above would apply to the third sentence of this paragraph to offset project- related habitat losses. We suggest insertion in the 5th line after "lands" fully developed and intensively managed". *

We appreciate the opportunity to review and comment on the environmental aspects of the project. We consider the draft to be generally very well written.

Sincerely, United States Department of the Interior BUREAU OF OUTDOOR RECREATION MID-CONTINENT REGION BUILDING 41, DENVER FEDERAL CENTER DENVER, C O L O R A D O 80225

SEP 2 7 1971

Mr. R. G. Burnett Chief, Engineering Division Department of the Army Omaha District Corps of Engineers 7410 U.S, Post Office & Court House Omaha, Nebraska 68102

Dear Mr. Burnett:

We have completed our review of your Environmental Statement for the authorized Papillion Creek and Tributaries Project, Nebraska, as requested in your letter of August 21, 1971.

We feel that the statement adequately covers potential impacts the project would involve and have only one comment to offer. You may wish to consider rewording Part D on page 7 to reflect protective as well as mitigative measures. Mention might be made of the continued need for flood plain management and zoning to afford protection against the remaining 13 percent of damage that could result from floods of greater severity than the project is capable of handling. Although flood plain management and zoning are covered elsewhere in the statement, it may be well to re­ emphasize such a need in this section.

Thank you for giving us an opportunity to comment.

Sincerely yours, UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE . South 12th. Rm 6oU. Lincoln. Nebr. 68S08

September 10, 1971

Mr. R. G. Burnett Chief, Engineering Division Department of the Army Omaha District, Corps of Engineers 7^10 U. S. Post Office and Court House Omaha, Nebraska 68102

Dear Mr. Burnett:

We are pleased to have the opportunity to review and comment on your draft Environmental Statement for Papillion Creek and Tributaries. The statement is very comprehensive and seems to cover all of the environmental effects of the project.

Considering the overall aspects of your proposed project, I do not believe your project will have an adverse effect on the environment. Therefore, I concur in your Environmental Statement.

Sincerely, 5tcte o f "Nebraska

»*5; ; * Soil an

October 14, 1971

Mr. R. G. Burnett Chief, Engineering Division U. S. Army Corps of Engineers 6012 U. S. Post Office & Court House 215 North 17th Street Omaha, Nebraska 68102

Dear Mr. Burnett:

As the coordinating agency for state review of water development projects, the Commission has requested comments on the draft of the environmental statement on the Papillion Creek and Tributaries Project sent to this office on August 27, 1971. The comments received have generally been favor­ able, but it was felt that the references to fishing poten­ tial on page 6 are too vague, and on page 7 there seems to-be some question concerning the water quality; but nothing is said about the sources of water quality degrada­ tion or the possibility for future mitigation of the antici­ pated problems.

We appreciate this opportunity to review and comment on this phase of the project proposal.

Very truly yours. NEBRASKA GAME AND PARKS COMMISSION - , ST A TE C A PITOL , L INC OLN , N E BR A SK A 6 8 5 0 9

October 8, 1971

Mr. R. G. Burnett, Chief Engineering Division Omaha District, Corps of Engineers 7410 U.S. Post Office and Court House Omaha, Nebraska 68102

Dear Mr. Burnett:

Following are our comments on the draft Environmental Statement for the authorized Papillion Creek and Tributaries Project provided with your letter of August 27, 1971.

1. Page 3, paragraph 3: The importance of the non-hunting recreational values of wildlife should be emphasized in this largely urban watershed since the value and public appreciation of this aspect of wildlife and resource management is increas­ ing rapidly. We suggest that the following be substituted for the 3rd sentence, beginning with "Birds common to . . Common resident birds would include the yellow shafted flicker, downy woodpecker, bluejay, black-capped chickadee, robin, cardinal and American goldfinch. Woody vegetation along the watershed attracts numerous species of warblers, orioles, sparrows, thrushs, hawks and owls during spring and fall migrations. Numerous bird species such as the red-headed woodpecker, eastern phoebe, cardinal, catbird, robin and brown thrasher would find habitat in the watershed suitable for nesting.

2. Page 3, paragraph 4: The contents of the paragraph are inaccurate and misleading. The impact of hunting on the watersheds wildlife carrying capacity is relatively minor. Environmental factors, principally habitat, are the overriding aspects con­ trolling wildlife abundance in Washington, Douglas and Sarpy Counties.

3. Page 5, B. Beneficial Aspects, 2nd paragraph under #2: We question the extent to which the project will actually aid in the preser­ vation of open space. It is our understanding that the 100 year flood plain will be reduced to essentially the stream channels by plan implementation. In addition, it is our understanding that the area now subject to flooding is substantially larger than the area that will be acquired for installation of project features. Most of this area now subject to serious flooding is being used for agricultural production and a significant portion of it lies within the urban area and constitutes desirable open space. It would therefore appear appropriate to include a statement disclosing the potential for encroach- ment on these important urban open space lands that may result directly or indirectly from plan implementation. An alternative to avoid or lessen this potential adverse impact would be public acquisition and dedication to public recreation and open space uses.

4. Page 7, 1st paragraph, 2nd sentence: Compensation for the wildlife habitat to be destroyed can only be accomplished by improving the diversity and interspersion of remaining habitat or by creating new habitat.

In summary, we recommend that the close liaison established between agencies in­ volved in planning in the Papillion Creek Basin be maintained during the advanced planning and construction phases of the project. It appears especially important that existing and potential major sources of pollution (including plant nutrients, toxicants, coliforms and turbidity) above the planned reservoir sites be identi­ fied and appropriately considered if the full potential of the Corps sites is to be realized.

Very truly yours,

NEBRASKA GAME AND PARKS COMMISSION Board of County Commissioners

Sarpy County Humm IIM M a PAPILLION, NEBRASKA 68046

September 20, 1971

Mr. R. 0. Burnett Chief, Engineering Division Omaha Distriot Corps of Engineers, 71*10 U.S. Post Office and Courthouse Omaha, Nebraska 68102

Dear Sir: This is to inform you that the Sarpy County Board of Comm­ issioners has thoroughly reviewed the Environmental Draft Statement of the Papillion Creek and tributaries, Nebraska, as prepared by the U.S. Army Engineer, Distriot, Omaha, Nebraska. The Sarpy County Board endorses the report as prepared, and believe that, overall wild life, recreation and the general environmental conditions will be much improved by the con­ struction of the 21 lakes and the implementation of a flood plan management program.

S i n c e r e l y ,

The Sarpy County Beard of Commissioners c f O m aha, jVehta&ha

PUBLIC WORKS DEPARTMENT • C I T Y H A L L

October 12, 1971

Mr. R. G. Burnett Chief, Engineering Division Omaha D is t r ic t , Corps o f Engineers 7410 U.S. Post O ffice and Court House Omaha, Nebraska 68102

Re: Environmental Impact Statement, Papi11ion Creek and T rib u ta rie s, Nebr.

Dear Mr. Burnett:

In response to your le t t e r o f August 27, 1971, Mayor Leahy asked that a ll Directors and Division Chiefs review your draft copy of the Environmental Statement and return th e ir comments to you through my o ffic e .

I am enclosing comments from Mr. Charles Geisler, Sanitation Engineer, and Mr. Clarence Shafer, Director of Parks, Recreation and Public Property.

The Pub lic Works Department concurs with the Environmental Statement, and pledges its and the City's cooperation in the improvement of the Papi11 ion Creek system.

S in cerely _ INTER-OFFICE COMMUNICATION September 21, 1971

TQ. Gene E. Jordan. Director Public Works

FROM:— Charles A. Geisler, City Sanitation Enoineer

S U B J E C T * ™ 'ronmenta Statement - Pap i 11 ion Creek Tributaries Nebraska Project dated Sept., T97T, by U.S. Army E ngineer District

I believe the envi ronmer.tal statement as proposed sums ud quite adequately what may transpire as a Result of thl proposed dams on the Papillion Creek. tne

Eutrophication wil1 occur in the smaller and shallower lakes °ff fa™ ,ands increase nitres and phosphates, providing the nutriants required.

measurements o f the stream flow bears out the fact that ihtch dissolved oxygen following a storm, artera fte ? wnich recovery Of follows in a few days.

^ 1 h_ 1 of bypassed waste water, there is no reason whv the Papio Creek couldn't carry a dissolved oxygen the year ^ around, with exception of periods following these storms.

As indicated, only time will tell if these lakes will provide realized!6 features* 1 doubt 'f water contact sports will be

oenericialbenef?cia? * to ’ i-h#»brthe Greater !■ ' C^e t Metro|le e nptol[l®i tanProject Omaha is area. worth The while and sJanUaTh! m aterially be changed or altered sub- stantiaIly to create any great concern. INTER-OFFICE COMMUNICATION

September 29, 1971

JO.______Burt Whedon, Operations Engineer

PROM:______Clarence E. Shafer, Director

SUBJECT:_____Environmental Statement___

The Parks, Recreation and Public Property Department completely agrees with the Environmental Statement as submitted by Public Works Director, Gene Jordan, in regard to the Papillion Creek Tributaries on October 22, 1970.

We are looking forward to the completion of the flood control system and the vast amount of recreation areas that will be developed as a by-product of this flood control system. Paavo- Watestilted feoatol

September 7 , 1971

Colonel B. P. Pendergrass District Engineer Corps of Engineers 7**10 U. S. Post Office and Court House Omaha, Nebraska 68102

Dear Colonel Pendergrass:

I wish to acknowledge receipt of the draft environmental statement for the Papillion Creek and Tributaries, Nebraska project which you forwarded to our office on August 27, 1971 for review. We are very happy to have an opportunity to comment on your environmental statement relating to the Papillion Creek project and would offer the following comments for your consideration. These comments can be considered as a supplement to our letter of October 9, 1970 which contained comments on your earlier draft environmental statement.

The future acceptance of the project by all segments of the population will depend upon total consideration of not only the flood control aspects but also the environmental situation. The people of the Papio basin are very much in­ terested in the recreational future of the project, especially those people who are not in a flood hazard area. Water based recreation will be one of the major benefits of this project to the entire population.

The following comments deal with specific items in the statement which you transmitted.

In Paragraph 3.a, Page 1, it mentions that agricultural production would be lost from 16*630 acres. We feel that you could mention that the entire area of 16,630 acres is not currently being used for agricultural production since a por­ tion of it is utilized for such items as roads, farmsteads, un- farmable creeks and banks, and odd shaped parcels that are un­ economical for agricultural production.

In Paragraph 3.d, Page 1, it is mentioned that the Increased development expected around the lakes will lend to the degrada­ tion of the impounded waters. It seems to us that if there were proper controls on the areas surrounding the Impoundments during development there should be very H ttle If any degradation of Impounded waters. The minimum buffer strip required by the present land acquisition policy by the government along with proper sewage disposal and developmental controls could give adequate protection of all water areas.

On Page 3, Paragraph 1, it might be advisable to enlarge the last sentence to Indicate that many of these erosion pro­ blems have been accentuated by poor land management practices and earlier drainage and stream realignment projects.

On Page 3» Paragraph 2, it mentions that Hillard Is a separate city. Millard is now a part of Omaha so that word- could be deleted.

On Page h, Paragraph 3 refers to zoning In the PapiUIon- Creek basin. It should be pointed out that all of the area within the Paplllion Creek basin is currently zoned by the appropriate governmental agency. Therefore, zoning authorities are exercised throughout the entire basin and will be from the onset of the project. In the same paragraph there 1s a pro­ jected population increase from 5,000 to 25,000 persons In the flood plain of the Papio Creek. With proper zoning and subdi­ vision regulations, this population Increase should be of such a nature that 1t would be susceptible to only flooding from very rare occurrences.

Njf On Page 9, Paragraph 3, a statement is made that the flood plain management program recommended would be to eliminate structural development in the ten year flood plain and to restrict development from the ten year flood plain to the standard pro-, ject flood. A recommendation of this type would not be in accord with current flood plain management principles which are being implemented throughout the basin. Presently, development is per­ mitted In areas which are termed as flood plain areas with re­ strictions on fill elevation, etc. All new construction has a minimum protection level of the 100 year flood. Those areas which are required as a floodway are maintained in open space and not used.

The Bureau of Sport, Fish e rie s, and Wildlife In their comments on Page 11 requested that the phrase "although It Is doubtful that these reservoirs will ever provide quality fishing" be Included in the statement. This seems to be a rather pessismlstic statement in view of the many reports from fishermen in the eastern part of the State of excellent fishing in numerous impounded waters.

The opportunity to comment upon your environmental statement is appreciated. If you have any questions regarding our comments, please feel free to contact us.

Very truly yours^ OMAHA • COUNCIL BLUFFS • METROPOLITAN AREA PLANNING AGENCY

October 12, 1971

Mr. R.G. Burnett, Chief Engineering Division Omaha District Corps of Engineers 7410 U.S. Post Office Omaha, Nebraska 68102

RE: MAPA CASE NO. 7172-021 Papio Environmental Impact Statement

Dear Mr. Burnett:

We are enclosing a copy of the action taken by the MAPA Board of Directors in regard to the Papio Creek Flood Control Project Environmental Impact Statement.

Should you have any questions concerning the Board's action, please contact the MAPA office.

Sincerely, OMAHA COUNCIL BLUFFS METROPOLITAN AREA PLANNING AGENCY

RESOLUTION NUMBER 1971-180'

WHEREAS the members of the Omaha-Council Bluffs Metropolitan

Area Planning Agency have been formally designated by their respec­ tive legislative bodies to act as their official representative in planning matters of mutual concern; and

WHEREAS the Corps of Engineers Environmental Impact Statement concerning the Papio Flood Control Project has been reviewed, and

WHEREAS the Planning Agency has given due consideration to said statement, Therefore be it

RESOLVED, That the Omaha-Council Bluffs Metropolitan Area

Planning Agency submits the attached comments regarding the Envir­ onmental Impact Statement to the Corps of Engineers; and be it

RESOLVED further, That the Planning Agency recommends said comments be forwarded to the appropriate Federal Agency with the

Environmental Impact Statement.

PASSED this V " day of , • ,* , 1971. ~ f COMMENTS AND RECOMMENDATIONS OF STATE, METROPOLITAN OR REGIONAL PLANNING AGENCIES

DATE Sent. 30. 1971 Res. No. 1971-180

Planning Agency:

Name Omaha-Council Bluffs Metropolitan Area Planning Acercy Address 7000 West Center Road, Omaha, Nebraska 68106___

Source of Authority for Establishment of Z.gency Sections_____ 23-2201 thru 23-2207 Nebraska Statutes (1965 Supplement) as____

amended and Chapter 83, Section One (1) thru fourteen (14)_____

Laws of the 61st General Assembly of Iowa

Grant Applicant:

Name U.S. Army Corps of Engineers, Omaha District__

Address 7410 Post Office Bldg. Omaha, Nebraska 68102___

Project Description:

Environmental Impact Statement Papio Creek and Tributaries Flood Control Project

The project described above does (< ) does not ( ) conform with the comprehensive plan developed for the metropolitan area in which it is located.

Comments and Recommendations:

The above project has been reviewed by this Agency and was found to be within the guidelines established for the Metro­ politan Comprehensive Plan. This project will be included as an implemented part of the completed Comprehensive Plan.

This project is not a duplication of effort nor Federal ex­ penditure within the Omaha-Council Bluffs Metropolitan Area. The Board of Directors of this Agency recommends this request be approved by the appropriate Federal Agency. The Agency's additional comments^on the Environmental Impact Statement are attached. September 30, 1971

The Omaha-Council Bluffs Metropolitan Area Planning Agency submits the following comments on the Draft Environmental Impact Statement by the U.S. Army Engineer District concerning the Papillion Creek and Tributaries Flood Control Project.

1. In general, we find the statement quite honest and factual, and complement the Corps on its preparation.

2. Our review of the statement produces the following specific comments:

a. Part II Environmental Setting without the Project.

Page 3 - We do not believe the statement that huntable game populations within the basin have been decreasing over the past few years is en­ tirely accurate. Our staff biologist believes this point will be quantified be the Nebraska Game Commission.

Page 4 - Regarding the comment that fisheries have been reduced, our staff biologist notes that BOD and fecal coliform counts have no direct effect on fish population and the up­ stream areas presently contain sufficient levels of dissolved O2 to support carp, bullhead and other species of fish.

b. Part III The Environmental Impact of the Proposed Project, Section B Beneficial Aspects.

Page 5 - We question the statement that the ■project will benefit water quality. Ou^ staff biologist does not believe there will be suf­ ficient water available to make releases during low flow periods which might have a significant impact upon downstream water quality. During high flow conditions, when water quality is at its lowest, water will be retained for flood control.

We also do not believe that any beneficial aspects can be assigned to downstream nutrient control as a result of the project.

Statement prepared by Larry C« Holcomb , Chairman, Quality Environment Council,_ Associate Professor of Biology, Creighton, U.

Environmental Impact on the Papllllon Creek Watershed, Nebraska

Submitted to Colonel B. P. Pendergrass, Army Corp of Engineers, O m a h a , Nebr., Sept.171

The developments in the Fapio Creek Watershed were made, knowing full well the risks involved in their building. Why must all the people now pay the price for the benefits provided for a few individuals who persist against the odds.?

Water quality in the impounded lakes is highly questionable.

Thus, the recreation potential, a"^" stated worth of 81,000,000 per year, is far too high.

If contact water recreation is so doubtful, and it is doubtful that the reservoirs will ever provide quality fishing, how can there be 81,000,000 cf recreational benefits^ This 81 million statement is completely out of line.

The statement talks about urban dispersion as a quality of the project. I question this unless there are comprehensive urban and rural zoning ordinances previous to the time when the projects are constructed. The trend is to concentrate in a cluster area with housing and shopping facilities and jobs within walking or very short driving or urban transit distance of one another. If this is the type of urban dispersion the Corp. is referring to, it will take a great deal of advance planning. To only disperse the urban population by spreading out will only crate more land waste, more transportatio problems and the resultant air and water pollution problems that are ever present with the transportation difficulties.

We must face the issue head-on; these dams are going to pro- vide no real recreational value. ^ a ^ g that the Army Corp of Engineers says will be used for hunting will be highly limited if there are homes built close by. The Corp has no control over the building codes in the area and thus if in fact the "urban dispersion" takes place, the hunting and fish­ ing benefits will go down. The dams should not be built. There should be good flood

.plain, zoning.

Let me make one final point. Population is booming. World­

wide estimates of total population are 4 billion and is scheduled to double

in about 35 years. Where are people going to live? Surely not in the reser­

voir site. These projects will remove 16,630 acres of land from agricultural

production. This is land that produces good crops; even without irrigation.

How much in terms of calories of food do they produce each year2 I am confid­

ent that it exceeds one person for each acre represented for a total of at

least 16,630 persons fed every year.

I realize that tie U.S. has several acr«e that are unused for

agricultural production each year. However, much of this is already marginal

agricultural land. The land we are discussing is good soil and produces

good crops. If, in fact, U.S. citizens are going to provide for the best

possible land use and the best possible use of our tax dollars, the majority

of the impoundment programs would not be implemented.

The Papio Watershed Dams as now planned are another part of

a massive hoax that has been perpetrated upon the American public by those

believing that a dam will solve all of ones problems. LEAGUE OF WOMEN VOTERS OF OMAHA

224 South 41st Street Phone 556-3919

Omaha, Nebraska 68131

October 13, 1971

Mr. R. G. Burnett Chief, Engineering Division Department of the Army Omaha District, Corps of Engineers 7VlO U.S. Post Office and Court House Omaha, Nebraska 68102

Re: Environmental Statement - Papillion Creek and Tributaries, Nebraska Project

Dear Mr. Burnett:

Thank you for the opportunity to comment on the Environmental Statement for the authorized Papillion Creek and Tributaries Project. We regard citizen participation in water resource decisions as very important.

As you probably know, the League of Women Voters of the United States has been studying water resources since 1956. In 1970 the League also undertook a study of environmental quality.

The League of Women Voters is concerned about improved coordination be­ tween agencies and departments. The middle paragraph on page 9 says that "Implementation of flood plain management would be the duty of local authori­ ties." This could result in a variety of regulations, or the lack of them in some areas. How many governmental bodies are there in the Papillion Basin who have the authority to establish flood plain zoning, and how many of them have committed themselves to establishing good flood plain management? What cooperation will there be between the independent projects?

What coordination has been worked out with the various governmental agencies, so that they will not duplicate each other's efforts, or work at cross purposes?

Is this plan for the Papillion Basin consistent with the State Water Plan?

What measures can be taken to supervise construction in the vicinity of the proposed lakes, prior to government procurement, so that new building will be in harmony with the purposes and guidelines of this project?

What measures will be, or could be taken to prevent speculators from buy­ ing up cheap flood-plain land, and making great capital gains when publicly- financed dams greatly increase the value of that land? Papillion Creek Statement - 2

Will there be ordinances to limit building around the lakes to the extent that sewage facilities can adequately handle the load?

Will water rights downstream from the reservoirs be affected, with the change in flow? What is the estimated streamflow depletion due to this project? There will surely be increased evaporation loses from the lakes.

What affect will the elimination of flooding have on natural ecological systems?

Is there thought of using any of the water stored in the reservoirs for municipal and industrial requirements?

What assurance is there that the wildlife areas will be kept inviolate?

Hunting - We question the emphasis on public hunting around the lakes, where it is expected that the public will make extensive use ox the recreational facilities other than hunting, and in areas which are expected to be built up.

Soil Erosion - As the statement points out, soil erosion is prevalent in this basin. What measures will be taken to control soil erosion above each of the lakes, not only for the sake of the land involved, but also to lessen the lakes filling with sediment? The Enironmental Statement does not give an estimate of the life of the lakes, based upon the possibility of their being filled with sediment.

Are any measures planned, or possible, to decrease the loss of soil from the total Papillion Creek basin, as the waters run into the Missouri River?

Life of Lakes - How long are the lakes expected to last, considering other factors than possibly filling with sediment?

Water Quality - It is stated that fishing will be developed in all the lakes. Will the quality of the water make this feasible in all the lakes?

'What will be done to guarantee that the lake waters will be kept clean enough for water-contact sports?

What will be done to control feedlot pollution from running into the lakes? There is considerable livestock feeding around Omaha.

How close will Tranquility Park be to any of the lakes? 'What affect will this landfill have on the ground water and streams flowing into the lakes? In turn, will the lakes raise the ground water level so that there will be excessive soil moisture in this 12-foot deep landfill? The Papillion project has been compared with the Salt Valley Watershed reservoirs near Lincoln, Nebraska, which were also built by the Corps of Engineers. What was learned from that project which will be of benefit to this project? How can the eutrophication which occurs in the Salt Valley lakes be avoided in the Papillion lakes?

We do notice what is probably a typing error on page 2, where it is stated that the drainage areas range in size from 1.7 square miles. The map accom­ panying the statement lists the smallest drainage area as 2.0 square miles.

Again, thank you for the opportunity to raise these questions.

Sincerely, LEAGUE OF WOMEJJ VOTERS OF OMAHA