March 1971
ft'm L Environmental Statement
West Tennessee Tributaries Feature
Mississippi River and Tributaries Project
(Obion and Forked Deer Rivers)
Prepared By
U. S. Army Engineer District, Memphis, Tennessee WEST TENNESSEE TRIBUTARIES
(Obion and Forked Deer Rivera)
Environmental Statement
1. Project Description. The West Tennessee Tributaries project is designed to provide flood control and drainage benefits to the agricul tural lands and the small urban centers adjacent to the Obion and Forked Deer Rivers and their major tributaries in We3t Tennessee. The project was authorized by the Flood Control Act of 1948, based on studies con tained in House Document 627, 80th Congress, 2d Session, and was last reviewed in House Document 308, 88th Congress, 2d Session. As of the last review, the authorized project consisted of enlargement and realign ment of 110 miles of main stem and major tributary channels in the Obion River system and similar work on 106 miles of the Forked Deer system. Approximately 59 miles .of construction have been completed on the main stem and North, South and Rutherford Forks of the Obion River and approxi mately 10 miles along the main stem and South Fork of the Forked Deer River. The authorized work in the combined watersheds is about 32 per cent complete.
A field report now under review proposes to modify the project to provide fish and wildlife mitigation measures which will achieve a better balance in man's use of his environment in the Obion and Forked Deer Rivers basin than'provided for by the original project. The modifications recom mended for inclusion in the project consist of acquisition of about 14,400 acres of floodplain lands; development of these lands for.management for fish and wildlife purposes; development of the Tennessee Game and Fish Com mission's Tigrett Wildlife Management Area and the undeveloped portion of Gooch Wildlife Management Area; and ninor modification of the project, such as provision of smaller channels in certain reaches, and beautification measures at highway crossings consisting of dressing, fertilizing and seeding of the spoil banks and berms. The location of the areas to be acquired and the extent of the development for fish and wildlife purposes would be based on mutually agreeable plans developed jointly by the Corps of Engineers, the Department of Interior, and the Tennessee Game and Fish Commission prior to the time the work is accomplished. Modification of the authorized project to include channel changes, beautification measures, and development of approximately 7,800 acres of publicly-owned lands for fish and wildlife use can be accomplished under existing authorities without awaiting further Congressional action. Development might typically include low weirs in channels adjacent to these areas to form permanent pools for water supply, and pumping sta- tions, low levee3, and culverts with controlled outlets to manipulate water levels for management purposes.
Based on information provided by the Department of Interior, the bottomlands of the Obion and Forked Deer Rivers are considered an important link in the Mississippi waterfowl flyway, since they comprise a significant habitat necessary to sustain the waterfpwl population. Preservation of a portion of this habitat, developed to sustain the present wildfowl population, is in the national interest; therefore, acquisition and development at Federal expense to mitigate project- induced losses appears appropriate. In accordance with Section 3 of the Fish and Wildlife Coordination Act of 1958, acquisition of the 14,400 acres of floodplain lands at Federal expense will require specific author! zation by the Congress. Plans for development of these areas would be similar to those for existing publicly-owned lands.
The location of the project, the extent cf presently authorized work and its status of completion, and the proposed modifications are shown on the attached nap. In formulation of the project, only tangible benefits have been evaluated for comparisons with tangible costs. The resulting benefit-cost ratio of the project, modified to include proposed mitigation measures, is 1.3. The Corp3 recognizes that the project will result in intangible benefits and damages which are impossible to quantify in monetary terms. However, consideration has geen given to these values in the formulation of recommendations.
2. Environmental Setting Without the Project. The Obion and Forked Deer Rivers basin (also referred to as the West Tennessee Tributaries) is a tributary to the Mississippi River, encompassing all or part of fourteen counties in northwestern Tennessee and a small part of two counties in western Kentucky. The drainage area of about 4,500 square miles is almost equally divided between the Obion ar.d the Forked Deer watersheds, as shown on the attached rap. The two river3 and their major tributaries flow through narrow, relatively flat valleys which gradually broaden toward the west. The linear flatness of the valleys gives a bayou effect to the streams. The adjacent uplands are gently rolling. Both streams emerge from the hills into the alluvial valley of the Mississippi through
2 which the Obion River flows for about 31 miles (improved mileage) and the Forked Deer River about 13 miles (improved mileage).* The Forked Deer enters the Obion 3 miles above its mouth.
Water in the streams is turbid, flows are sluggish, and overbank flooding is frequent. The associated woodland, occupying the lower zone of the floodplain, is composed of such bottomland types as cypress, tupelo gum, overcup oak, bitter pecan, hackberry, elm, ash, sweetgum,' water oak, and others. This wetland ecosystem is especially favorable for waterfowl and the basin draws hunters from generally throughout the state, particularly from the large urban centers of Memphis and Nashville. The Department of Interior considers the area to be of significant value in maintaining Mississippi flyway waterfowl populations by providing rest ing and wintering habitat. It is also a wood duck production area. No known rare or endangered species of botanical and zoological origin are kno\ra to exist in the project area. A natural heron rookery is known to exist on the north side of the South Fork of Obion River just west of the Weakley County line. The state’s largest cypress tree is located on the right bank of Middle Fork of Obion River immediately upstream from its confluence with South Fork. The channel improvement is being designed to preserve the tree.
Mineral resources in the basin consist of sand, clay and gravel. There are no known historical or archeological sites in the area that would be endangered by the proposed project.
Prior to the start of construction of the project, the maximum flood- plain consisted of 180,600 acres of bottomland forest and 155,400 acres of agricultural land. The channels of all the major tributaries and many of the minor tributaries have been replaced by straightened artificial ditches constructed by the local people for drainage purposes in the 1920*s and 1930*s. With the decline of agricultural land values and crop prices during the "Great Depression" of the 1930's, the local people were unable to properly maintain these ditches and as a result they have largely reverted to a clogged condition. The open lands occupy the higher edge of the_alluvial plains and typically are used as family farming operations. Flooding has iri_the past deterred use of low lands for crop pro- ___ duction. However, since”the advent of soybeans in the early 1960’s as a high return cash crop which cen mature during the short growing season remaining after the high water in the river bottoms subsides, the influ ence of flooding on land clearing is not as controlling as it once was. The landowners, as a result, are clearing bottomland timber in large blocks for soybean production, evon above the limits of any authorized work.
3 Income of basin inhabitants is derived primarily from agriculture. There are also nurse reus small manufacturing and processing plants. .Market ing of forest products is dono primarily for supplementing the agricultural income of individual landownera. Other minor income is attributable to the bottomlands in the fora of selling or leasing hunting rights on private lands. Disruption of normal living conditions by flooding of homes, busi nesses, roads, and farmlands affects about 17-,000 farm families and. a segment of the urban population of Dyarsburg, Tennessee,•and other rural communities at the edga of the floodplain.
3 * Identify The Environmental Impacts of the Proposed Action. The construc tion of the project will contribute to the improvement of the day to day economic and social well-being of the people of this economically deprived region. A comparison of the median incomes of families in the Tennessee counties which are wholly or partially in.the basin with the median family income for the nation shows that tho overage income of basin families is 45 percent of that of the typical American family. Therefore, providing the basic essentials of life, including a desirable standard of living for their families ar.d an adequate educational opportunity for their children, is a primary desire of basin inhabitants. The project will enhance the ■ human environment through increased crop yields, increased agricultural production, enhancement of land values and, as currently recommended for modification, assure the preservation of quality fishing and hunting oppor tunities. Greater yields and production will result In additional net income for tho individual farmer and for the businessmen in the rural communities who are dependent on expenditures by farm families and the pro cessing of farm products for their livelihood. Enhancement of land values will provide county governments with a higher tax base from which to draw the income needed to provide an improved level of service to the people of tho basin.
Mitigation measures proposed for inclusion in the project emphasize the preservation and development of wetland habitat, since this type of environment is the most adversely affected by the flood control and drainage improvements. Certain of those measures may proceed and are recommended for adoption within existing authorities, regardless of whether Congress authorizes the acquisition of additional lands. Fisheries and waterfowl will suffer the greatest loss of the faunal resource, and the potential for human utilization of these cpocie3 will essentially be re placed by the proposed mitigation measures. Losses to other wildlife species, which, with the exception of fur bearers, are less dependent on wetland or aquatic habitat, will not be totally replaced. However, the conversion of mitigation land to public ownership will, overall, maintain the basin's realizable potential for human utilization and enjoyment of the remaining bottomland envircnmsnt and the fish and wildlifs resources which will be preserved.
4 Thus, the project in time will result in an upgrading of both the standard of living and the appearance of farmsteads and basin communl-* ties, and assure continued public enjoyment of the basin's recreational- resources . Adverse impacts of the project on the existing environment which will occur are discussed in the following sections.
4 - Identify Any Adverse Environmental Effects Which Cannot be Avoided Should the Proposal be Implemented. The major alterations of the river's alignment and dimensions required by this project and the attendant reduction in duration and frequency of overbank flooding include adverse effects on the existing ecosystem. Some of these adverse impacts can be successfully mitigated or minimized by the Incorporation of appropriate remedial measures as are proposed for inclusion in this project. Other impacts remain, however, which cannot be successfully mitigated or minimized.
The project will cause a localized reduction in soil moisture (ground* water) in the upper few feet of the floodplain soils in the area immediately adjacent to the channel. This will cause some reduction in the growth rate of the bottomland hardwoods in that zone. Because overflow will continue to occur in the winter and early spring months, the growth rate of the re maining hardwoods in the floodplain is not expected to be affected.
Other unavoidable impacts will result from the disruption of the natural frequency and duration of overbank flooding throughout the present floodplain. Clearing of tlmberlands for agricultural uses will be signif icantly accelerated and magnified beyond the limits presently imposed by annual flooding. Aquatic habitat and remaining woodlands will suffer a reduction in productivity of many biological elements of the ecosystem. Lands proposed for acquisition and development as mitigation for lost hunt ing and fishing potential will preserve and, in many instances, enhance biological productivity in these areas. However, the forest-water regimen of the remainder of the floodplain will be permanently altered by the proj ect . Wood duck production associated with water and woodland losses will be only partimlly replaced on mitigation lands. Aesthetics associated with shaded, meandering bayous, potholes, and pools will be lessened by the ditch- like appearance of the new channels and the mounding of spoil. The appearance of an artificial channel immediately after construction is displeasing, how ever, with the first growing season after spoil deposition, natural revegeta- tion of the spoil bank and berms will begin to progress through ecological succession to a climax vegetative cover much like other parts of the flood- plain. Channelization may adversely affect the water quality during con struction and until the channel becomes stabilized. It is anticipated that the time required for stabilization will be relatively short-term. t
5 5. Identify Alternatives to the Proposed Action. Various alternatives were considered in formulation of the project described in paragraph 1 of this environmental statement. Other alternatives given thorough con sideration were complete or partial abandonment of the project, substitu tion of channel clearing and snagging for authorized channel enlargement, acquisition of lands in excess of 14,400 acres both with and without development, and types of land control other than acquisition.
All or part of the remaining 68 percent of the authorized work which has not been constructed could be abandoned or simply not constructed. To completely stop construction at this point would result in the continued loss of income which the residents of the basin badly need if they are to continue to raise their standard of living which is far below the national average. The daily lives of the farmers and the residents of the urban areas upstream would continue to be disrupted by periodic inundation of their lands, homes and businesses. Conversely, abandonment at the present status of construction would tend to discourage the otherwise project- induced clearing of an estimated 35,000 acres of bottomland hardwoods and to preserve 86,600 annual man-days of hunting and fishing use of the lands for basin and Vest Tennessee residents. This does not resolve the problem of the fish and wildlife values lost as a result of the construction to date. Full development of the state-owned Gooch and Tigrett Wildlife Man agement Areas, in conjunction with total project abandonment, would not replace the losses to fish and wildlife use caused by the project to date. A unilateral decision by the Federal Government to abandon the remainder of the project would constitute a breach in faith with local sponsors and citizens of the area who have made substantial investments and commitments based upon construction of the project. Therefore, to insure the preserva tion of hunting and fishing opportunities, as well as provide the economic benefits for which the project was originally authorized, complete abandon ment of the remainder of the authorized improvement is not considered to be either a reasonable or a desirable alternative.
In addition to complete abandonment, consideration was also given to the effects of the abandonment of all or parts of major segments of the project, both on the fish and wildlife resources and on flood control. The analysis showed that the flood control benefits to the people of the basin from these segments far exceeded the fish and wildlife benefits which would be foregone. No major reduction in damage to wildlife resources could be achieved by abandonment of channel construction through any one or two of the segments considered. This alternative, again, does not address the problem of mitigating fish and wildlife losses resulting from the com pleted portion of the project. Other problems arise with the consideration of partial abandonment. The project has been designed as a continuous entity.
6 Any significant modification or reduction in channel capacity in inter mittent segments disrupts the hydraulic ability of the project to function as designed. The capacity of the channel upstream of the abandoned seg ment to carry flows is restricted causing increased flooding of adjacent and upstream lands. Disruption of the channel grade through abandoned segments results in severe bank erosion and bottom degradation in places where an abandoned stream segment transitions back.into the improved i channel. In view of the technical and physical problems encountered with partial abandonment of any one or combination of segments of the author ized project, and in view of the economic benefits foregone, this is not considered to be a feasible alternative.
Modification of the project to substitute channel clearing and snagging for channel enlargement was considered in project reformulation and sub stitution of approximately 25 miles of clearing and snagging for enlargement are recommended in the extreme upper reaches. This is adequate in these reaches where the drainage area contributing run off and the required channels are relatively small. However, in the lower reaches the channels are clogged with debris and sediment to the extent that they are almost non-existent. Clearing and snagging of these reaches would be a major and costly operation and no material savings in construction cost would be realized by tne substitution. In addition, based on our observations of this and other basins in the district, it is believed that substituting clearing and snagging for enlargement would not significantly affect the amount of woodland converted to agricultural use. Therefore, it was con cluded that the flood control benefits foregone would be much greater than the savings in cost, and, as a result, a reduction in the degree of flood protection to be provided in the lower reaches is not feasible.
Another alternative would be to acquire additional lands in excess of the approximately 14,400 acres proposed and to develop the lands for extensive management and intensive public use. Developments would consist of some type of water supply, dikes, and diversion and water level control structures. This alternative would preserve a larger portion of woodland habitat, which is very desirable from a fish and wildlife standpoint. How ever, in terms of replacing realizable hunting and fishing opportunities as a part of this project, it exceeds the replacement of project-induced losses and measures attendant to their mlclgatl*on. "There* *ar*e additional unquantifiable environmental losses .for which it could be argued that additional acquisitions should be made. However, acquisitions beyond the 14,400 acres now proposed involves an exercise of judgment. Con sideration must also be given to the detrimental effect upon the local economy that would result from additional loss of tax base presently used to provide governmental services and further decrease of potential agricultural productivity and associated income for the inhabitants of this economically depressed area.
Consideration was also given to acquisition of lands in excess of the approximately 14,400 acres proposed, with a reduced level of development. This proposal affords the major advantage of making increased lands avail able for preservation and public use. However, without development for
7 intensive management, neither full potential for wildlife populations nor full potential for public usage can be realized. Accordingly, reasonable mitigation of losses in terms of man's enjoyment of wildlife- oriented recreation cannot thus be achieved, and the alternative is thus not compatible with Federal interests.
Consideration was also given to both voluntary preservation of private lands as fish and wildlife habitat and preservation through some type of lease or easement. Such arrangements could help to lessen the Impacts of the project on future fish and wildlife values but is not considered a fully feasible alternative to the proposed mitigation plan. In formu lation of the project, it was assumed that a portion of the existing woodlands will remain after construction of channel improvement. The anticipated amount which will remain was based on the evidence of cur rent conditions adjacent to the completed portion of the project. It is considered reasonable to assume that the landowners in the upstream reaches will react to the channel improvement in a similar manner and land clearing will be comparable to that being experienced downstream. A major aspect of the proposed mitigation plan is intensive development and management of lands to significantly increase public utilization of the areas for hunting and fishing. In order to properly develop and effectively manage a wildlife area, an adequate block of land is required which can be controlled under a single management program. There is the possibility that some individual landowners will donate or sell some type of easement on their lands for fish and wildlife purpose, but no assur ances of this happening on a large enough scale to be effective have been offered to date. Therefore, it is not considered feasible to base a miti gation proposal on this type arrangement. Following Congressional authorization of land acquisition, a thorough evaluation of real estate requirements will be undertaken. At this time, consideration will be given to these and other proposals, which might be made by Individual landowners, to determine their feasibility.
6. Identify the Relationship Between Local Short-Term Uses of Man's Environment and the Maintenance and Enhancement of Long-Term Productivity. The Obion and Forked Deer Rivers basin has been and continues to be pre dominantly an agricultural area. Its forest lands have historically pro duced forest products and at the same time served to satisfy the demand for
8 hunting and fishing opportunities from West Tennessee residents, both in and out of the basin. Previous to project construction, the agricultural lands primarily comprised the higher elevations with the forest lands limited largely to the lower wetlands. Productivity of both areas is long-term in nature. The introduction of soybeans as a short-season,high- return cash crop and the partial completion of the West Tennessee Trib utaries project have combined, in recent years, to accelerate the rate of forest clearing. The flood control and drainage benefits from the partially completed channeling project have resulted and will continue to result in the expansion and enhancement of agricultural development in the higher elevations of the floodplain and to encourage encroachment into the lower areas. One local short-term use of the environment at the expense of long-term productivity could possibly be the project-induced conversion of the marginal lowlands immediately adjacent to the channels from timber to agriculture. This could amount to a relatively short-term use at the expense of hardwood timber production and fish and wildlife resources associated with the existing forest-wetland ecosystem. The result would be a loss in the long-term productivity of the areas to provide hunting, fishing and recreational opportunities required to meet future demands of the general public. Most elements of the existing environment are renewable; consequently, implementation of the project will not comprise an irrevocable commitment oi these resources. A balanced program of agri cultural development, combined with bottomland forest resource preservation and management,together with adequate preservation of recreational oppor tunities, would contribute to both short— and long-term needs for the basin's economic stability and growth as well as a quality human environment.
7• Identify Any Irreversible and Irretrievable Commitments of Resources Which Would Be Involved in the Proposed Action Should It Be Implemented. Bottomland forest, natural stream channels and water quality, which are damaged or displaced es a result of the project, are relatively long-term commitments of renewable resources. However, the nature of channel improve ment on this project will not impose physically irreversible or irretrievable losses of these resources. Upper reaches of the Obion and Forked Deer Rivers contain striking examples of early channeling projects developed by local people which, over the years, deteriorated through lack of proper maintenance, causing them to become constricted with debris and sediment. Subsequently, the floodplains regained a close similarity to the prechanneled condition. Historical evidence of this nature confirms that the process of ecological succession will eventually restore a natural floodplain environment if an improved channel is not maintained. This process could be greatly accelerated by vegetative seeding or planting, systematic plugging of the improved channel and opening of old bendways in the original channel. Fish and wildlife resources associated with the floodplain would eventually return naturally to approximately their original composition and numbers.
9 The West Tennessee Tributaries project is not dependent upon clearing of the marginal lands immediately adjacent to the channels for its justification. Therefore, the retention of these lands in timber or their reversion to their natural vegetative cover, after a few years in cultivation, would affect neither the need for the project nor its economic justification.
S. Special Commentary. Mitigation measures which are not contingent upon Congressional authorization can be accomplished within the existing authority of the Chief of Engineers. These features will be incorporated in future channel improvement, which for the immediate future, will be limited to completing work on the North Fork of the Forked Deer River, consisting of about 4.5 miles of improvement entitled "Middle City Item" at Dyersburg.
9. Coordination. A public meeting was held in Dyersburg, Tennessee, on 10 February 1971 to present the proposed mitigation plan. Approximately 277 persons attended including representatives of Federal, State, and municipal governments and agricultural and fish and wildlife interest. The majority of statements presented expressed opposition to the proposed plan. Agricultural interests expressed opposition from the standpoint that they urgently need the flood-control benefits and accomplishment of mitigation measures at Federal expense will divert construction funds from the flood-control project. In addition, most of those who felt that their lands might be acquired expressed an unwillingness to sell their lands. Fish and wildlife interests and conservationist groups expressed opposition from the standpoint that mitigation measures did not go far enough. In general, the conservationist groups' opposition was directed primarily to the flood-control project instead of the proposed mitigation measures. A small minority of the people at the meeting recognized the existence of conflicting resource needs in the basin, and the need to modify the flood- control project to include mitigation measures and provide a balance in the use of the basin's natural resources. The following are some of the comments, by various interests represented at the meeting;
10 Comment: Timber in the floodplain is being killed by permanent Inundation.
Response: Considerable timber deadening is occurring as a result of prolonged flooding of woodlands along reaches of unimproved channels which are full of sediment and other debris to the extent that the channel is essentially nonexistent. Due to the limited flow capacity of these channels, constant flooding and poor drainage is killing prime hardwood timber. The authorized channel improvement will reduce the severity and duration of flooding and provide better drainage, thereby reducing the amount of timber being killed due to prolonged flooding. Adequate open ings in the spoil banks of the improved channels will be provided to pre vent permanent impoundment of water on woodlands.
Comment: Opposed to acquisition of private hunting clubs and farm lands for fish and wildlife use.
Response: The plan for acquiring approximately 14,400 acres of land at Federal expense for fish and wildlife purposes is preliminary. The actual locations and acreage boundaries will be based on additional de tailed data obtained at a later stage in our planning process. The final fish and wildlife mitigation plan, including acquisition areas and develop ment, will be jointly approved by the Corps of Engineers, Department of Interior, and Tennessee Game and Fish Commission. Extensive considerations will be given to selecting areas that can best be utilized for achieving a balance in the use of the basin's natural resources. Each area will be developed in accordance with a plan formulated to achieve the most useful operation for fish and wildlife purposes. In order to effectively operate such an area, the lands need to be continuous and encompass enough habitat acreage for proper management. Such block acquisition may Include small acreages belonging to private hunting clubs and/or individuals who wish to preserve the existing fish and wildlife habitat. Acquisition of private hunting club lands offers the advantage of making attractive and partially- developed lands Immediately available to the public-at-large for recreation; additionally, because tbese lands are not now threatened by further clearing and drainage for agricultural development purposes, acquisition of these lands can be deferred depending on the rate of funding, thus affording a highly desirable flexibility to the acquisition program.
11 Comment: Unaltered streams in West Tennessee provide good fishing and channelization ruins this resource.
Response: The fisher;' resources in unimproved reaches of the Obion and Forked Deer Rivers are of relatively poor quality as a result of heavy silt suspension in the water, and sediment deposition and accumula tion of debris which has completely eliminated long reaches of any defined stream channel. The fishery is predominantly comprised of rough species which are generally incompatible with quality sport fishing. The Corps' analysis recognizes that channeling will have significantly adverse effects upon the existing fishery. Mitigation proposals include reservoir development which will more than offset overall fishery losses..
Comment: Recreation values used in the Corps' evaluation of losses and mitigation requirements are minimal.
Response: See response to Tennessee Game and Fish Commission's comment.
Comment: Proposed mitigation plan is Inadequate and does not consider intangible values.
Response: See response to Tennessee Game and Fish Commission's comment.
Comment: Proposed voluntary preservation of private lands for fish and wildlife habitat or on a lease basis.
Response: This comment is adequately covered in paragraph 5.
On 19 February 1971 a conference was held with representatives of the Bureau of Sport Fisheries and Wildlife and the Tennessee Game and Fish Commission to discuss study results in more detail and to seek reconcilia tion on certain points. A representative of the Tennessee Game and Fish Commission stated that the Commission is naturally opposed to drainage,* that their report is reasonable; that the 44,425 acres recommended for acquisition and development are reasonable, and the very minimum required to mitigate the fish and wildlife losses. In addition, it was stated that their technical staff feels that the total project (flood control and fish and wildlife mitigation) should progress together. They also objected to putting a dollar value on fish and wildlife usage. A representative of the
12 Bureau of Sport Fisheries and Wildlife stated.that it was the Bureau's position that the state is justified in their stand.-and they agreed with the state’s desire to achieve core fish and wildlife developments. The difference in our evaluation and their3 was discussed and the reasons for the proposed mitigation plan as opposed to their reconmenda— tion were explained. It was pointed out that the Corps’ analysis was based on realizable potential in terms of recreational man-day3 usage, and that damages occasioned by the flood control and drainage improvements will be replaced by the proposed mitigation plan. The.plan recommended by the Tennessee Game and Fish Commission would preserve significantly more floodplain woodlands,• and is desirable from the view'point of fishery, wildlife and various aesthetic or other intangible considerations. This plan would, however, preserve considerable more habitat than the amount necessary to replace realizable public utilization of existing fish and wildlife resources, which occur almost totally on privately-owned lands. Therefore, their plan includes benefits in excess of the replacement of fish and wildlife values for which aitigative measures should reasonably be provided as part of the Federal flood protection project. The a c quisition of substantially more additional lands and any developments thereon, in order to serve fish and wildlife purposes beyond those mitigating project effects, may be justifiable but should be a separate project, planned, administered, and funded by appropriate fish and wildlife agencies. Local proponents support and strongly urge expeditious development of the authorized flood control improvements on the basis of the human welfare gains associated with the reduction in water damages to personal property and crops, alleviation of human hardships and suffering caused by flooding and increased agricultural productivity from protected crop land. On 23 February 1971 a conference was held with a representative of the West Tennessee Tributaries Association, an agricultural group, to discuss the mitigation proposal in more detail. This group was concerned that fish and wildlife developments will restrict upstream runoff and drainage from adjacent agricultural areas which will be cut off from the river. It was explained that provisions will be included in design of the project to minimize these effects.
The draft environmental statement wa3 coordinated with Federal and state agencies. Their summarized comments are as follows:
Tennessee Department of Highways
No comments on the environmental impact of the project.
13 Tennessee Game and Fish Commiesion
Comment: They maintain that the Corps' estimates of flood damages which were made in 1948, 1965 and 1970 show increases which are partly the result of attempted agricultural operations in the floodplain, and that benefits have been increased to reflect the prevention of damage to these lands.
Response: The estimates of flood damages have increased with each analysis and this is to be expected. Over the years, since 1948, there have been continued changes in crop patterns, yields and acreages which have come about as a result of economic, social and technological changes not directly related to the project. Therefore, each reanalysis of the project must, by necessity, account for those changes which have taken place since the previous analysis or it would not present a true picture of the conditions which existed at the time it was made.
Comment: They are of the opinion that conversion of floodplain wood- lands to agricultural uses are primarily a result of the project, and that woodland losses attributableto the project are much greater than the Corps has projected.
Response: The Corps' projections of the effects of the project in inducing the conversion of floodplain woodlands to agricultural use were based not only on observations of the clearing that has and is taking place in the Obion and Forked Deer Rivers basin but, also, on observa tions and data from other similar river basins in the Memphis District. Therefore, we believe the projections are reasonable.
Comment: They state that the Corps* evaluation does not attribute values to any aspect of the wetland-woodland ecosystem beyond the harvest of game animals and fish, and general outdoor recreational visits which are limited to existing public areas. They state, also, that assigned fish and wildlife values are minimized.
Response: In evaluating damages to fish and wildlife resources result ing from Corps projects, the Corps, as stated policy (ER 1165-2-104), expresses such damages, to the extent practicable, in monetary terms. Tangible damages are expressed as person-days of recreation which will be lost as a result of the project. Intangible damages are to be described in sufficient detail to permit judgement decisions to be made as to whether or not they justify national expenditures required to prevent or offset them. Thus, the Corps' evaluation of resource losses resulting from this project is based on both tangible and intangible damages, with
14 the former assigned monetary value, and the latter described in narrative terms. The determination of person-days of wildlife and fishery-oriented recreation was based on estimates of realizable potential of areas affected by the project to provide hunting, fish ing, and other recreational opportunity. Nearly all of this land is privately owned; therefore, potential public utilization is significantly less than it is on public lands, and is probably well below the threshold of physical or biological capability of these lands to provide recrea tional uses. General recreational opportunity on private lands was judged to be nil. Indices used in calculating realizable potential were taken from both the Tennessee Game and Fish Commission report of July 1970 and the Department of Interior report of 1959, depending on which were judged to most nearly reflect realizable potential. In no case were lower index factors used in estimating hunting or fishing use of any particular species than were used in the Department of Interior's 1959 report. Monetary values of person-days of hunting and fishing are the maximum allowable within guidelines established in Supplement No. 1 to Senate Document 97. Strict interpretation of evaluation criteria in Supplement No. 1 would support a judgement decision to use lower monetary values for utilization of most species in the basin.
Comment: They state that the Corps' estimates of fish and wildlife recreational use and value is approximately the same as used by the Department of Interior in their 1959 report which evaluated project Impacts. Thus, a large portion of our values are based on old data, whereas, our evaluation of flood damages, agricultural values, project benefits, etc., are updated to current levels.
Response: The Corps’ estimates of fish and wildlife recreational trips are equal to or greater for individual resource items than those used by the Department of Interior in their 1959 report. Monetary values assigned to these trips are the maximum allowable, as explained above. The indices derived from the Department of Interior 1959 report are those which reflect estimates of future average annual person-days of hunting and fishing provided by each acre of habitat. With all other factors equal over a period of time, biological productivity will remain relatively stable. In this sense, hunting and fishing potential has not changed significantly since the Department of Interior's 1959 evaluation was made. Wherever applicable, it is true that project values or benefits have been updated to reflect current market levels. This has been applied to person-days of hunting and fishing (at maximum levels per mitted by Supplement No. 1 to Senate Document 97), as well as to agri cultural, flood control and other quantifiable aspects of the project.
15 Comment: They state that our analysis includes no qualitative or quantitative evaluation of wetland significance to the national flyway, wood duck production, nor migration and wintering habitat for all species.
Response: Comments dealing with wetland significance to the national flyway are essentially answered above. It is presently impossible to quantify this value; thus, it is considered an intangible value to which appropriate weight must be given in the decision-making process. Im portance of migration and wintering habitat is, in essence, inseparable from flyway significance. Wood duck production values were not included, since the species is inseparable from other waterfowl in estimating total person-days of waterfowl hunting activity which the wetlands will provide. To attempt to put a separate value on wood duck production would be equivalent to evaluating the flyway population in terms of the production value of northern breeding gounds; it would inevitably lead to the double counting of resource values. Wood duck production, as an intangible value, is acknowledged in the statement.
Comment: They state that the 14,400 acres proposed for mitigation is unreasonable in view of project-induced loss of 84,000 acres of woodland, and that the money recommended for development features would better serve long-range public interests if it were used to acquire additional lands.
Response: The acquisition of sufficient woodland habitat, without develop ment, required to replace total days of recreational opportunity lost to the project would result in a much greater imbalance in the availability of individual resource items than would the proposed acquisition and in tensive development of 14,400 acres. A basic objective of mitigation in the Corps' view is to restore or replace, to the extent practicable, the utilization (in terms of person-days of recreation) of individual resource items in kind. Of even greater impact to fish and wildlife resources than the estimated project-induced loss of woodlands will be the affect upon stream characteristics and the change in frequency, height, and duration of floodplain overflow. Fisheries and waterfowl habitat will be parti cularly adversely affected by the change in stream and overflow charac- acteristlcs. Purchase of additional woodlands will not significantly contribute to replacement of fish and waterfowl losses, unless measures are taken to restore water via artificial flooding of floodplain wood lands. This can only be done with developments which will provide a supply and control of water on these areas. Without this development, and without the development of auxiliary facilities such as access roads and other facilities to enhance public utilization of the lands, reasonable mitigation of all losses occasioned to man's wildlife-oriented recreation cannot be achieved.
16 Comment: The Commission does not agree that median Income of basin families will be significantly increased by the project, but rather that primary recipients of project benefits will be approximately 1,200 families whose lands are directly affected by flood control or drainage.
Response: Primary recipients of project benefits are the rural families whose lands lie adjacent to the project and the urban families whose homes and businesses are provided some measure of flood relief. It is also true that when these families have additional income to spend that the entire community benefits, though in widely varying degrees. It should be noted that the urban area of Dyersburg alone contains a population of 14,523, and some 15 percent of this area alone is affected by flooding. If the basin as a whole is considered, benefits attributable to only 1,200 families are patently understated.
Comment: They do not concur that proposed mltiation measures will assure preservation of quality fishing and hunting opportunities, nor that these measures will replace previously existing fisheries and water- fowl resources.
Response: The statement does not purpose that mitigation measures will replace previously existing fisheries and waterfowl values. In tangible values associated with these resources, including the national flyway significance, are not quantified; however, they are recognized. The mitigation proposal is based on the restoration, to the greatest practicable extent, of potential hunting and fishing use of each resource item in kind. Inevitable remaining losses encompassing the broad spec trum of the total wetland ecosystem are unquantifiable, and thus must be considered intangible values which are weighed by judgment in the decision-making process. It cannot be agreed that proposed mitigation measures will not preserve quality hunting and fishing opportunity. These are objectives of areas presently owned and developed by the Tennessee Game and Fish Commission. Fishing quality will undoubtedly be enhanced, in reservoirs developed for that purpose, as a result of improved water quality and controllable water levels.
Comment: They state that the project will not only adversely affect the existing ecosystem but will eliminate the existing wetland environ mental community.
Response: It is recognized in the statement that the project will have significant impacts upon the existing ecosystem. It cannot be con cluded that the existing wetland environmental community will be elimi nated. The degree of flood protection afforded by the project does not preclude the possibility of frequent overbank flooding, which in itself is a constraint on the clearing of some of the lower, wetter areas of the floodplain. Furthermore, a number of landowners will choose to keep their lands in timber production, or will not elect to take the risks inherent in reducing marginal wooded lands to agricultural use.
17 Comment: They point out that the Tennessee Department of Public Health has stated that channelization will degrade water quality to the extent of violating state water quality standards established for the Obion basin.
Response: See response to Tennessee Department of Public Health's comment.
Comment: They question that mitigation proposals will enhance overall biological productivity.
Response: The statement does not contend that overall biological pro ductivity will be enhanced with proposed mitigation. Lands specifically acquired and developed for mitigation purposes will, however, be biolog ically enhanced with respect to waterfowl and sport fishing. Any signifi cant mitigation of project-induced hunting and fishing losses is dependent on the combination of biological enhancement and public availability of these lands.
Comment: They state that the two alternatives considered by the Corps utilize information based on minimized adverse aspects of the project and do not adequately test other alternatives.
Response: Alternatives described in the statement were evaluated on the basis of a common set of values. It is disagreement on the range of these values which is a basic issue in the Corps* recommended mitigation plan as opposed to measures for mitigation proposed by the Tennessee Game and Fish Commission.
Comment: They state that an alternative should have been evaluated which would have included mitigation of losses attributable to completed portions of the project, with modification of remaining authorized works to include only the minimum channel alteration necessary to maintain stream flow.
Response: This comment is adequately covered in paragraph 5.
Comment: They reiterate that the Corps discussion of the investments of local interests substantiates their contention that woodland clearing is more directly related to the project than to soybean production.
Response: The commitments and investments as used in the context of the statement are those represented by the assurances of local cooperation for the project, not those made in converting woodlands to croplands 4
18 Comment: They question whether channeling represents good flood control practice, especially considering future conditions when there will be little more than crop residue to retard runoff.
Response: It is anticipated that some woodlands will remain in the basin after project construction. In addition, the individual farmer has the responsibility for on-farm drainage and land treatment measures to preserve the productivity of his land for agricultural purposes.
Comment: They disagree that acquisition and development of lands in excess of 14,400 acres will exceed project-induced losses.
Response: According to the Corps' estimate of project-induced losses to realizable potential hunting and fishing opportunity, the acquisition and development of 14,400 acres is adequate to essentially restore the loss of this potential, though not entirely in kind. There are physical and biological limitations to the amount of hunting and fishing in kind which can be replaced in areas of appreciable less magnitude than the original acreage. However, the diversity of habitat provided with proposed development addresses itself to this problem to the fullest practicable extent. Thus, total potential person-days of hunting and fishing are essentially replaced with the proposed acquisition and development, and any significant increase in fish and wildlife project features would exceed the opportunities foregone. This is not to say that losses to various intangible values in excess of hunting and fishing will not be incurred.
Comment: They believe the best long-term use of the floodplain ("c" Zone) is for timber and wildlife oriented recreation; that the Corps' mitigation plan is inadequate for short-term needs, and is completely out of line with regard to long-term needs in view of declining wetland resources and increasing demand.
Response: The authorized project with the proposed modification will provide a reasonable balance of long-term uses of the basin's resources, i.e., uses or combinationrof uses which will best serve both national and local interests.
Comment: They recommend that project justification be limited to benefits above the one-in-three year flood zone as compared to project construction costs and reasonable estimates of the value of all natural resources which will be lost.
Response: All the analyses of the project to date, including the one Just finished, whow the justification for the project on the basis of benefits received above the one-in-three year flood zone.
19 Comment: They state that continuation of the project will result in further loss of wetlands unless mitigation is given equal priority in funding and scheduling.
Response: The mitigation report, presently being finalized for sub mission to higher authority, recognizes the impact of the project on the floodplain lands and the need for positive action to implement the pro posed mitigation plan.
Comment: They state that the investment of public funds for project construction can only be protected by channel maintenance; that this has not been adequate on completed portions of the project, and sufficient monies have not been made available for this purpose. They further state that questions related to this matter should be answered prior to further construction.
Response: Our records of the results of the annual inspection by the Corps show that over the years the maintenance of the completed portion of the project has been satisfactory. We have no reason to expect the performance of the needed maintenance to change in the future.
Bureau of Sport Fisheries and Wildlife
Comment: The agency is hopeful that a fish and wildlife mitigation plan, somewhat greater in scope than the presently proposed plan, will eventually be included as a part of the authorized project.
Response: Several meetings between the Bureau of Sport Fisheries and Wildlife and Corps officials have been held, since the Bureau's comments were received, in attempts to resolve differences in the acreages which should be acquired for mitigation purposes. To date, there has been no agreement to terms upon which mutually acceptable modification of the proposed plan can be based. The Bureau of Sport Fisheries and Wildlife’s attitudes are oriented toward the acreage of lands devoted to public use. The Corps' attitudes are oriented toward the public usage potential of Federally-acquired lands.
Comment: The agency contends that any mitigation plan will serve only to lessen severity of project impacts and cannot completely restore losses. In this respect, the Corps' proposed plan is unsatisfactory, and they ask that it be expanded to provide a more equitable degree of mitigation.
Response: The Corps has explicitly stated that the proposed mitigation plan will not restore all fish and wildlife losses. It attempts, to the fullest extent practicable, to replace estimated losses to realizable hunt ing and fishing potential. All known intangible values, which cannot be quantified, have been listed in the statement so that a decision can be made as to whether, or to what degree or cost, the Nation is justified in pre serving them or offsetting their loss.
20 Comment: The agency contends that quality (meaning quality outdoor experience) can seldom be maintained with mitigation, since space is an important component of aesthetic experience, and i9 reduced in virtually!- all cases.
Response: The Corps cannot refute the adverse effects of the project on space. However, in comparing the estimated annual man-days of recrea tion which the Corps’plan will provide, as compared to the Tennessee Game and Fish Commission plan, there is a difference of only two man-days per acre; 23 annual man-days per acre in the Corps plan, and 21 annual man- days per acre in the Tennessee Game and Fish Commission plan.
Comment: The agency takes the view, regarding alternatives, that different means of achieving project purposes should be emphasized, and/or project purposes might be modified to encourage economic pursuits more in line with maintaining the existing bottomland condition.
Response: In the formulation of the project and in the restudy to give additional consideration to environmental values, many alternatives both structural and non-structural, were explored. They are discussed in paragraph 5 of this statement.
Comment: The agency asks what the Corps’ prediction is as to the likelihood of fish and wildlife habitat reverting toward former condi tions as a result of lack of project maintenance on the Obion and Forked Deer Rivers.
Response: The section of the statement dealing with commitments of resources states only that they are not irreversibly or irretrievably committed as a result of channeling. Paragraph 4 states "... the remain ing forest-water regimen will, for all practical purposes, be permanently altered by the project." Therefore, fish and wildlife habitat will not revert as long as the channel is maintained, and there is no indication that this will not be done indefinitely. However, if at some future time it is determined that fish and wildlife habitat will best serve national and local interests, at the expense of project benefits foregone, then these values can be restored by permitting the streams to return to their original state.
21 Tennessee Department of Conservation
Comment: The department states that possible problems stemming from the lowering of the watertable may also be detrimental to public as well as private water supplies.
Response: Public and private water supplies are drawn from water bearing strata located well below the bottom of the channel. Thus, the project will have no identifiable impact on the level of the water in these strata or on their ability to be recharged. This is confirmed by informal discussions with personnel of the Department of Conservation's Division of Water.
Comment: They state that further benefits can be derived if Corps of Engineers will advise local interests of proper floodplain management practices.
Response: The Corps of Engineers has an active floodplain informa tion program in West Tennessee, in cooperation with the Tennessee Planning Commission, which includes assistance in developing and implementing regulations and plans for wise use of flood prone areas. While the pro gram operates largely in the urban areas, information is also made avail able to individuals, groups, and agencies in the rural areas upon request.
Comment: The department contends that the cost of clearing and the timber lost should be included in the project cost. An additional project cost should be included for the potential loss to primary and secondary wood-using industry.
Response: The benefits to the project from conversion of woodland to crop production are based on the net increase in income resulting from the conversion* therefore, these costs are fully accounted for in the analysis. The losses in commercial products, including timber, are expressed in our analysis in monetary terms using the market value of the products, net of associated production, and marketing costs. Thus, timber values lost to the project are included in our analysis of project cost. It should be noted that economic incentives may, in the future, result in a reversion of agricultural clearing to industrial timber management.
Comment: The department's other comments relating to environmental impacts of the project are similar to those of the Tennessee Game and Fish Commission.
Response: These comments are adequately covered in response to comments of the Tennessee Game and Fish Commission, or within the statement.
22 U.S. Forest Service.
Comment: The Forest Service states that the area would serve the Mississippi flyway population much better without channelization.
Response: The area might well serve the Mississippi flyway better without the flood control project; however, the value of the area to the flyway is not the only question involved. A better question would appear to be: What use or combination of uses would best serve the interests of the nation and of the people in the people in the basin? We believe our proposal represents the most reasonable balance of existing basin and national uses.
Comment: The agency recommended changing words ” ... could be similar” in paragraph 1, and "natural" in paragraph 2.
Response: These changes have been incorporated into the statement.
Comment: They suggested that comparing median family incomes in the basin to national incomes is misleading unless the cost of living is also given.
Response: The use of median family incomes as used is considered proper.
Comment: They contend that channelization practically eliminates fishing and that it is difficult to imagine assuring the preservation of quality fishing with a drainage project.
Response: This comment is adequately covered in response to comments presented at the public meeting.
Comment: The agency contends that mitigation measures attempt to make fish and wildlife losses less severe, rather than "preserve and develop wetland habitat"; therefore, losses would not normally be re placed by mitigation measures.
Response: This comment is adequately covered in response to comments of Tennessee Game and Fish Commission.
Comment: They contend that the alternatives are not discussed thoroughly.
23 Response: The alternative portion of the environmental statement has been expanded to include a discussion of clearing and snagging as an alternative. While land treatment would aid in retarding runoff and reducing sediment, it is a supplement to, rather than an effective alternative to the project. Floodplain management would serve to prevent damage to future development but would not eliminate the need for the project to reduce the damages to present urban development and to lands currently in agricultural production.
Comment: The agency contends that forests were considered largely as they affect fish and wildlife with little consideration given to the economic loss of bottomland hardwoods.
Response: This comment is adequately covered in response to comments of Tennessee Department of Conservation.
Comment: They state that the statement does not mention rare and endangered species of plants or animals.
Response: This omission has been corrected and an appropriate comment has been incorporated into the statement.
Tennessee Department of Public Health
Comment: The department discussed the water quality criteria and classification of Tennessee streams, and stated that "channelization, if allowed to proceed, will cause violations of these standards."
Response: The Corps recognizes that dredging operations on a stream will introduce solids, floating materials and some deposits as the total sediment transport capacity of the stream is exceeded. The additional solids and floating materials caused by dredging will be temporary; how ever, the transport load will be higher than normal until the stream and its side channels become stabilized. The time required for this stabiliza tion to occur is not known. Additional turbidity will be added to the stream during the dredging operations and also while the channel is seeking a stabilized level. The exact amount of turbidity units added while channelization is in progress and while instability exists has never been determined. It is likely that channelization may create conditions that will violate Tennessee Stream Pollution Standards for an undetermined but reasonably acceptable period of time. The United States Geological Survey maintains a temperature and discharge station on the North Fork of the Obion River near Union City, Tennessee. This portion of the river was channelized by the Corps in 1966 and temperature data is available both
24 before and after dredging. Analysis of the data indicates that there has been no significant change in the water temperature after the dredg ing operations. This indicates that channelization has no measurable effect on the water temperature of the stream; however, more extensive studies would be required to substantiate any definitive conclusions.
Comment: The department contends that the project will render over 200 miles of stream practically sterile and cause irreplaceable loss to the fish, wildlife, and wetland resources of the area.
Response: This comment is adequately covered in response to the Tennessee Game and Fish Commission's comment.
Comments and Responses Regarding Supplemental Letter dated 5 March 1971
Comment: The Tennessee Department of Public Health states that any reduction in flood height and frequency will reduce the present public health problems concerning private water supplies and sewage disposal, and the department further states that drainage of certain areas will reduce the mosquito production in those areas.
Response: The Corps recognizes the beneficial effects on vector problems and considers the benefits to be part of the intangible values to which monetary terms have not been applied.
Comment: The department restated that from the stream pollution standpoint the channeling will cause adverse effects on the fish and aquatic life of the streams.
Response: This comment is adequately covered in response to the Tennessee Game and Fish Commission's comment.
Environmental Protection Agency
Comment: The agency stated that the possible damage to water quality should be recognized.
Response: This comment has been recognized in paragraph 4 and adequately covered in response to Tennessee Department of Public Health's comment.
25 Comment: They cautioned that care should be exercised in relocation of petroleum product pipelines, handling and storage of petroleum, herbicides and pesticides to prevent accidental spillages.
Response: All Corps of Engineers specifications contain a section stating that the contractor shall not pollute lakes, ditches, and reservoirs with fuels, oils, bitumens, calcium chloride, insecticides, herbicides or other similar materials harmful to fish, shellfish, and wildlife. The contractor is responsible to comply with all laws pertaining to pollution of rivers and streams.
Comment: The agency called to our attention the guidelines for pro viding and operating sanitary facilities to treat and dispose of domestic wastes in conformance with state and Federal water pollution control regulations.
Response: Provision and operation of sanitary facilities as set forth in district regulations require adequate toilet facilities to be installed and maintained and the sewage disposed of in accordance with local, state and Federal sanitary regulations. These provisions are applied to all work under the jurisdiction of the Corps.
Comment: They recommend that excavation and construction operations be scheduled and performed in such manner as to keep turbidity and siltation at the lowest level practicable.
Response: Turbidity and siltation will be kept to a minimum by proceeding from downstream to upstream with the construction and exca vating during low water as much as possible.
Comment and Response Regarding Supplemental Letter dated 15 March 1971
Comment: The Environmental Protection Agency states that the Corps should consider the comments offered by the Tennessee Public Health Department.
Response: The Tennessee Health Department's comments have been covered in the preceding section which contain responses to their comments.
26 Bureau of Outdoor Recreation
Comment: It is the Bureau's opinion that the statement shows full cognizance of the project's effect upon natural resources and environment, and that such a view is basic to remedial action. They believe that the proposed mitigation measures are.worthwhile and feasible, although they consider them to be inadequate, primarily because of the discrepancy in acreages proposed by the Corps and the Tennessee Game and Fish Commission for acquisition.
Response: This comment has been thoroughly addressed in the Corps previous response to similar views by the Tennessee Game and Fish Commission and the Bureau of Sport Fisheries and Wildlife.
Comment: The Bureau states that the Corps statement does not consider possible alternatives of rlood plain zoning, flood insurance, or possible utilization of Public Law 91-559, the Water Bank Act.
Response: Regarding flood plain zoning, the program whereby information is provided by the Corps to local interests has been mentioned in an earlier response to a comment of the Tennessee Department of Conservation. The project benefits are largely based upon a reduction of flood damages on lands in their present agricultural or improved use and not upon the conversion of woodland to such other use. Flood plain zone restrictions to be imposed upon lands other than woodland would deprive their private owners of all or a substantial part of their present livelihood and thus create greater social problems in an economically deprived area. Flood insurance is voluntary and requires application by the local entity to HUD, subject to meeting required conditions. However, insurance pays for damage by spreading the loss, and is considered only a supplement to more effective measures of reducing the flood losses to individuals. Whether financial losses due to flooding damage are incurred by private citizens or insurers, they are nevertheless losses to the overall national economy. The Water Bank Act is administered by the Department of Agriculture, and it is understood that the program has not been made available within Tennessee. Consequently, there is no basis at this time to con sider action under the Water Bank Act as a valid alternative.
Comment: The agency recommends that channelization be deferred until necessary acquisition is authorized as a part of the project.
Response: A field report recommending land acquisitioning at Federal expense for fish and wildlife mitigation has been prepared and is being reviewed by higher authority prior to submission to the Congress for authorization. The report points out the desirability of adequate funding to permit concurrent implementation of mitigation measures and construction of flood control features.
Tennessee Stream Pollution Control Board
Comment: The Tennessee Stream Pollution Control Board states that their comments were included in the Tennessee Department of Public Health letter of 9 February 1971 and repeated these comments.
2 7 Response: These comments have been covered in the responses to the comments of Tennessee Department of Public Health.
Comment: The Stream Pollution Control Board states that, because of the many interests involved in the streams in the Obion and Forked Deer Rivers basin, there will have to be a compromise worked out to serve the best interests of the area, and the Board further states their willingness to work with the Corps and other interested parties to seek a solution.
Response: A field report, which recommends modifying the authorized project to include measures for achieving a better balance in the use of the basin's natural resources, has been prepared and is being reviewed by higher authorities. Coordination will be maintained with Tennessee Stream Pollution Control Board and other concerned agencies in the later stages of our planning process to develop the desired solution.
28
18 January 1971
Ur. Robert £dthf Director Tenaacsee Dapcrlcsnt of Rijpawya 817 Highsay Building Haahvillc, 37219
Dear Mr. Ssltht A review of the Vest Tteaaaecee Tributaries project tea been to deteraiat the extent of codification naodad to cahteve a balance in the use of the baaia*s natural resources In eceerdcnsa with tha Flah end M idlife Oocrdlasllea Act of 1998, Malta Lear 89-624, cad tha raocstly created Tsrlgtr-rvital Boltay Act of 1969, Public l a 91-190. Our esalyals chose that cd iftcatica ef tha cuthericsd project to lnaluda door eternal afarjra, bssatlftaatlca csssuroo, developssat of the existing Qeeah end Ticxctt M id life h—* Arose, end eaqutaltloa end davwlcpasat cf c^prcxientaly U ,400 csree cf eddl- tiosel lends will 1 m tha cSverse e ffe c ts ef tha flood ocntxol i^aofensa* end cffeatlvely d tlcsts the projsat-lcdusad lesssa of fiCh end wildlife rcssawes la tha Ohio end lharhad Deer Rivera Basin. These ensnares osa he esss^ildsd endsr the cdotteg cutheritles ef the Chief cf Csjterrra with the ensspt lea ef lend •oquldtica, rhtah retiree Cesyr,rsicr>1 enthsaicstlcn. Xnalesad la oepy ef draft restart, entitled •Fixh end M idlife m igo- tla Plcn, Cast Tributaries Rntoa, IScslcdppi River end Tributaries Projsat,* which lealudn car cstiestas cf the paojsat- inftissd leases te flch end wildlife re n a tu end —'-t —t w ill affectively dtlcsts these losnss. The dtfcstlca featuzoe eatlisad la the sc^sart cse hsssd cn psslidnnry lefcrcstlcn cbtainsd during pate eesd estio with V. 0. Pieh cd Midlife Cnrvtae end Tcssssee Ossa cad 91eh Onndcstaa. fin a l d etails cad dssScm of d tlg s tlc a features will esnstat ef pleas c^roecJ Jointly ty the Cops of Xhgtassrs, fc p a tn ia t c f S aterlcr, end teas end Plch Oea- dcslca. Va ds cst hsllsea that tha cdagtlca cf tha plea la tha repeat will pies cay rlltim l tardm cn tha El£=sy Depsrtssal US3D-PF IB January 1971 Mr. Robert Saith, Director as the local sponsor for tha Vest Tesaacsaa Tributaries project. The Vanessas Ossa cod Fish Cocaicaloa Is aspeeted to ba the spoDsor fear the citlgattcn work cad, as such, will ba responsible far tie operation cad olrtcacnoe coats. Also inalocad is a prelininary draft of our fire-point csrironcsotal statessat prepared in response to the spirit and intent of Section 102(2)(C) of tbs national Kcnrlroassntal Policy Act of 1960 (PL 91-190, 63 Stet. 352-356). This cactlca requires that parlor to "wiring cay detailed ststesaxt, the responsible Federal official shall consult with cad obtain tbs consents of cay Federal, state, or local agency which has Jurisdiction by lcar or special expertise with respect to any cavirosasatal lepaat Involved. Copies of such stetesents toad operants cad vicars of the cpproporlate Federal, state, cad local agencies which are authorised to develop cad enforce envircnaental stcadsrds shall be Bade available to tbs President, tin Council an tovircncsntsl Quality, cad to tbs public, and sh all accocpcny the propoeal through the existing cgcacy review procecsae. Ve would very uch appreciate receiving your agency^ views and con- Bsnts oa the draft report ad prelizdnnry cavirosasatal statement, separately, by 20 February 1971. Separate replies will fsollitste our processing of t hese doeucaats. Tour vicars cad cosaante w ill be fully coesidsred in our final report cad five-point steteaent end w ill be included as attesfasaats to thea in our final subedsaien to the Chief of Eaglsssrs. Sincerely,
2 tool JOBS T. PARIS!, JR. As statsd L t. C ol., Corps of Engineers District tegiraer u c s d -p f 21 January 1971
***■• F w d W. Stanberry, Director Tennessee Game and Fish Commission Ellington Agricultural Canter Past Office Box M O O Nashville, Tennessee 37220
Dear Mr. Stanberry:
A review of the Vest Tennessee Tributaries project has been nade to deter mine the extent of aodlflcatlon needed to achieve a balance In the use of the basin's natural resources In accordance with the Fish and Wildlife Coordination Act of 1998, Public Lav 85-624, and the recently enacted Environmental Bailey Act of 1969, Public Lav 91-190.
Our analysis shove that Modification of the authorised project to Include ■lnor channel chances, beautification asesuies, development of the Gooch and Tlgrett Wildlife Management areas, and acquisition and development of approximately 14,400 acres of additional lands will lessen the adverse effects of the flood control Improvement and mitigate the project-induced losses of fish and wildlife resources In the Obion and Forked Deer Rivers basin. These meesures can be accomplished under the existing authorities of the Chief of Engineers with the exception of land acquisition, vhlcb requires Congressional authorisation.
Inclosed are three copies of draft report entitled "Fish and Wildlife Mitiga tion Plan, West Tennessee Tributaries fWatnre, Mississippi River and Tributaries Project , which Includes our estimates of project-induced losses to fish and wildlife resources and measures which will effectively mitigate these • The mitigation features outlined la ths report are baaed on pre liminary Information obtained during prior coordlmtIon, Including that from your agency. Final details and designs of mitigation feature will consist of plans approved Jointly by the Corps of Engineers, Department of Interior and Tennessee Game and Fish Commission. Be anticipate tint your agency would assume responsibility for the operation and maintenance of any miti gation measures that night result from approval of this plan. u & 3 > - v r 21 January 1*71 ISr. Fred V. Itubarrjr
Alao lacloeed In • pallalaury draft «f our five-point twrliaaantal atatr* ■ant prepared la raaponaa tb*>tha aplrtt aad latest of fiactlaa 102(2) (C) of the Batlaaal Pirlrann aatal Bailey Act of 1*0* (O. »1-180, 83 ttat. I S M M ) . This aactlaa m a l m that prior to anting any dotal lad atatanaat , the raapenalbla M o r a l official ahall eonault with aad obtain tho eocaanta of nay M oral, etate, or local agon ay which haa Jnrladlctiee by law or apodal azpartiaa with roapact to any oadromaatal lcpact Involved. Ooplaa of aoch atatanoota and oaoaanta aad d e w e of tho approprlato Federal, atato, and loci a g e a d e e which aro aitthorlcod to develop aad oaforoo endroanestal ataadarda ahall ha aada avallablo to tho Preeldent, tho Council on fiavlroaanntal dual ity, and to tho public and ahall aceanpaay tba pnopoaal through tba a d d i n g aponcy rowlow proceeoee.
«o would vary n o d approclato receiving your agency*a vlowa and coaawsta on tho draft report aad prollnlnary ondronnantal atatonant, ooparatoly, by 20 February 1*71. Separata roplloe d l l f a d lit a to oar preaeaelng of thoaa docunanta. Four wlawa and cocsanta d l l bo fully coaaldorad la our final report and flwo-polat atatanaat aad d l l bo Included aa at tact mint a to than la our final aubalaalen to the Chief of Xngiaoora.
*0 aro alao far d ablag coploa of the two lncloourao to tho U.8. Flab and VI Id 11 fa fiardeo.
Sincerely,
2 ia d (trip) jo a v. Msxca, ja. Aa a tat ad Lt. Col., Oarpa of bflanra Dletrlct engineer
2 uaua>-pr 21 January 16/1
Mr. Edward C. Carlson, Regional Director Bureau of Sport Fisheries sad Wildlife Southeast Region Peachtree-Seventh Building Atlanta, Georgia 30223
Dear Mr. Carlson:
A review of the heat Tennessee Tributaries Project has been unde to determine the extent of modification needed to achieve a balance la the use of the basin's natural resources In accordance with the Pish and tl Id life Coordination Act of 1958, Public Law 85-824, and tho recently enacted Environmental Policy Act of i960. Public Law 91-190.
Our analysis shows that acidification of the authorised project to Include alnor channel changes, beautification measures, development of the Oooch sad Tlgrstt Wildlife Ms nag— at arena, and acquisition and development of approximately 14,400 acres of additional loads will lessen the adverse effects of the flood control Improvement sad altlgst# the project-Induced losses of fish and wildlife resources In the Obion and Forked Deer Rivers basin. These measures can be accomplished under the existing authorltlos of the Chief of Engineers with the exception of land acquisition, which requires Coagrsssioosl authorisation.
Inclosed are three copies of draft report entitled ,*Fiah and Wildlife Mitigation Plan, West Tennessee Tributaries Feature, Mississippi River sad Tributaries Project”, which Includes our estimates of project-induced losses to fish and wildlife resources sad measures which will effectively mitigate these leases. The mitigation features outlined in the report are based an preliminary information obtained during prior coordination, Including that from your agency. Final details sad designs of mitlgutloa feature will consist of plans approved Jolatly by the Corps of Engineers, Department of Interior nad Tennessee Gene and Fish Commission. U S O a H P r 31 January 1971 Mr. Edward C. Carlson
Also lncloaod la a preliminary draft of our fivw-point environmental state ment prepared in response to the spirit and Intent of Section 102(2)(C) of the Rational Environmental Fa 1icy Act of 1969 (VL 91-190, S3 Stat. 852-856). This section requires that prior to making any detailed statement, the responsible M o r a l official shall consult with and obtain the comments of any federal agency which has Jurisdiction by lav or special expertise with respect to any environmental impact Involved. Copies of such statements and ooamenta and views of the appropriate federal, state, and local agencies which are authorised to develop and enforce environmental standards shall be made available to the President, the Council on Environmental Quality, and to the public and shall accompany the proposal through the existing agency review processes.
Ve would very mud) appreciate receiving your agency's views and comments on the draft report and preliminary environmental statement, separately, by 20 February 1971. Separate replies will facilitate our processing of these documents, Vbur views and comments will be fully considered in our final report and five-point statement and will be included as attachments to them in our final submission to the Chief of Engineers.
Ve are also furnishing a copy of the inclosures to the Tennessee Game and fish Commission.
Sincerely,
2 lad (trip) JOHN V. PAMUH, JS. As stated Lt. Col., Corps of Engineers District Engineer
Copy furnished] Mr. Richard S. Klchhors, field Supervisor Bureau of Sport fisheries and Vildllfe 31S Fseples-Xewman Building Vicksburg, Mississippi 39180 w lncl
2 21 JUauary 1071
Br. 9. Boyd Garrett, CUalailMor Tennessee Departasat of COnservatlea 3611 Boot lad Avenue Mashrllle. Tesneeeee S7S33
Door Mr. Garretti
A review of the Boot Towneesoo Tributaries project bos boos oodo to deter- ■loo tho extent of oodiflcotioo ooodod to achieve o bolonoo la tbo oao of tho boals's sotoral resources la oeoordoaoo vltb tbo fish asd Wildlife Coord last loa Act of 19 £3, Public Lav IS-IM, asd tbo recently ococtod Snvlreaaeutal Volley Act of 1993, Public Lav 91-190.
Oar analysis sboos that oodlfloatloa of tbo authorised project to Include nlaor channel changes, boavtlfloatloa aoasuros, dovelopaent of tbo Gooch and Tlgrott Vildllfo ftinurim t Areas, a d acquisition and dovelopaent of apprexlnately 14,400 acres of additional lands d l l looses the adverse effects of tbo flood control lnprevoeent sad effectively altlgate tbo project-Induced losses of flsb and wildlife resources la tbo O M o a sad Verted Door Klvors basin.
Inclosed Is a pxollalcary draft of our five-point oavlroaaoatal lcpicO state- aont prepared la rsspanss to tbo spirit asd latent of Section 103(1) (C) of tbo Mat Iona 1 tewlrocaoatal tellcy Act of 1999 (PL 91-190, 93 Ctat. 983-993). This section requires that prior to caking say detailed staterrant, tbei.'Tospos sible Vedoral official shall assault d t h and obtain tbo consents of any Federal, state or local agrocy white has Jurladlctlon by lav or apodal expertise with respect to any eavlracaeatal Icgact Involved. GapUa of such statonosts and eoeaanto and d o e s of the appropriate Vedoral, state, and local agencies white are authorised to develop sad oaf ores cavirocnsatal standards shall bo cads available to tbo President , tbo Council on Enrlroa- nestal Quality, and to tbo public sad shall acconpaay tho proposal threegb tbo ox Is tiny s e m e y review processes. fir. B. Boptf C a m tt 11 J*“ “ ry 1971
***** u •«*»>«» t » etas?* i p a m t i p t o f nsi—inf fvoa o t l w r M m l , "tat* *c3 Im I i b c i m Im . On m u m ; cocb antdatc
“ T ° * r r t » - »m ■» f lly « M U m d thru, m m t t a . 'f f L*****3” * »"» ««=»«• »m to fenutM rttk tte state-
W ortatUo ablto ^ b , M i t e t e l * U l. a x p t o l t u j
i x*fx * » v- maicH, jb. ** ****** Ctol., Cbrps of Casino*rs District Eag Inner SI January 1171
Director, HnrtkMatoni Ares State and Private forestry U. 3. Poraat Sarrlea 6816 Market Straat Uppar Darby, Pennsylvania 16031
Daar Sir:
A rarlaw of the Vast Tennessee Tributaries project haa baas nade to deter- ■Ina tha eatent of Modification noadad to achieve a balaaea la tha uaa of tha baaln'a natural raaourcaa la aooardaaea with tha Pish and VI Id life Coordination Act of 1638, Public Lata C3-634, cad tha recently enacted Knviroaeantal Policy Act of 1SC9, Public Lee 11-160.
Our analyala shews that aodlflcaUoa of tha authorised project to include alaor chcnaal changes, beautification aeaauree, develcpacat of tha Oooch and Tlgrett Vlldlifa Ernsgsasat Arana, sad acquisition and develepacat of approKlaataly 14,400 aeraa of additional leads will lessen tha adverse affects of tha flood central leproveaent and effectively Mitigate tha project-induced ^OM#i °* cad vlldlifa resources in tha Obion and Porfcad Daar Alvars basin.
Inclosed la a prelldnary draft of our five-point anviramcntal lnpeet stato- nant prepared in response to tha spirit and latent of SocUon 103(3) (C) of tha Rational Envlrocacatal Policy Act of I M S (PL 11-160, IS 8tat. 803-856). This section requires that prior to asking any detailed statenent, tha responsible Padaral official shall consult vlth and obtain tha ceeaaats of any Padaral, state or local agency which haa Jurisdiction by law or special expertise with respect to any euvlreaneatal lcpect involved. Copies of such stateoents and ooeaeata and views of the appropriate federal, state, and local agendas chick ape authorised to develop and enforce eavlreaaental standards shall be aade available to the President, the Council on Kaviroa- Moatel Quality, a d to the public cad shall aaaccpany tha proposal through the edstlag agsaby review preoesecs. TfeAa pwUrlroy la ad jaet to rTir~~i « a r—islnt of nr n if t n otter Tadaaal, atoto ad loaal cscadca. Ba oeald vcrTnte associate ocsaaata ca tU i draft atatcssat ca cr tefero S3 Vateaarf X971. Tver vtarn d U te fally ocaddard dcrlas crcaoratlea of tte flaal atatcaaat ad ^ oasaata dU te faJ«dd d tS ^ ltd L
a«w r a i4itie2liais 7laaftaeae2autlaLa,S o d2d ej”me cay lrriairitdialr/ t1e*®lp*f*u- l *l•a f* flnatraly, i ,a* _ *=» M aa,n . Aa stated Lt. Cal., COrpa of I jlm n District frjlinaar U 3 D -fP 21 Jauuary 1971 Mr. b s m V. I M t U a , M.D., Om t u i - w Dq»rtwRt fit M ilo EMltk 603 Cordoll Ball Del Idles RMbvill*, hO M M 37219 Door Mr. Peolaklo: A n fU v of tin Woat Toaaoasoo Tributaries Projoot tea boon aado to dotoxalao tho u tM t of aedlflootlea ir i«d to aohlom a balaaoo la the u m of the b u l l 's Batumi maouro»a &• aooordaaoo olth tho Viah aad Wildlife Coordlmtica Act of 1993, P te lle Lao 99-C34, aad the recently eaaotod Kwrimeamtal Policy Aat of 19C3, Pvblio Lao 91-190. Our analysis shoos tMat aodlfleatlea of the authorised project to laolude slaor ehaaael obugu, beautl flaatlca m a au , demlcpaoat of tte Ooeoh oaf Tlgrott Wildlife n n g-in t areas, ad u ydcltUa aad d u iltp n t of apprauiaatelp 16,403 aoroo of additicsal loads w ill looeoa tMo adverse offoota of tho flood oostrol laprovenaat oof effectively aitlcate tho projoot-ladoood looaoa of fish acd wildlife mooaroaa la tho Qhlca aad Posted Door U v ir a ha ala, laoloood la a prollalaary draft of oar flvo-point eavlrecaeatal lapaet atatoaaat prepared!* recpsase to «h» spirit ssd latoat of Oeotlca 1C3<2)(C) of tho Katloaal lovlrosmittal Policy dot of 10S3 b g l m l Director Federal Watar Quality Adalaletratloa 1402 21a 8tract, 3rd floor Dallaa, Texaa 78203 Dear Sir: A review of the treat Teaseacoe Tributaries Project tea beea aade to deteralae the exteat of aodlf loatlea weeded to achieve a bala ano la tie uae of the beala'a aotural resources la aooordaaoe vita tie flea aad Wildlife Coordlaatlea Act of 1888, Public Lav 88-824, aad tba reoeatly eaactod Xavlroaaeatsl Policy Act of 1888, Public Lao 81*180. Our analysis above taat aodlfloatloo of tba aathorlasd project to lasluda nlaor cbaaael ebaasea, beautlfloatloa ace a urea, development of tbo Oooch aad Tlsrett Wildlife Kaaasemoat areas, aad aoqulaltloa aad dovelcyneat of approxlaately 14,400 acres of additional leads d l l losses tAe adverse affects of tao flood eoatrol laprovaaent aad effectively aitlcato tas p r o j e c t - laducod looses of flea aad wildlife resources la tae Obloa and forked Doer fivers basis. Inclosed is a prsllalasry draft of our flvo-polat oadrscaeatal lapact state- seat prepared la retjwass to tao spirit sad latoat of Soetloa 103(2) (C) of tae Rational Furl rnrsmitnl Policy Act of 18C8 (PL 81-180, 83 8tat. 882-888). TAla soetloa rood roe tAst prior to aaklas any detailed stataaoat, tAo roppceslblo POdoral offlolal aball oooault d t a aad obtala tba i rrnsta of aay federal, state or local acoaof wAlcA Aas Jurlsdlotloo by lav or cpoelal expert la# with respect to aay • a r i r c a w d l lapact lavolved. Copies of ouch atatcaoata aad n m u at a aad d o v e of tbo appropriate Podaral, atato, aad local agendas vbieb era autharlaad to dovelep asd ooforoa oadrosaoatal ataadasda shall ba aada available to tbo Presided, tbs Ceuaoll oa fiavlroo- neatal Qmlity. aad to tba pcblis aad aball acocagaay tba prep seal tbrougb tbo oxlstlas agency review presessss. 21 Jaauary 1971 Ur. BiQsaa V. O.D., 3.P.B., ComlMiMnr This m llaieiiy draft is otbjoct to okusa 1 9 M rooslpt «f o o h m U f r a •tbsr M in i, ititi sad U n i (^d k Ih , Vo w o ld ssry msofc apprsolato rooslvlas your acM of'i oon n U oa this draft statoaoat os or boforo 20 rsbrusry 1971. Tsar visas w ill ho fully oaasldsrod darts® prnpamtlaa of ths fissl rt ■ taw at sad your n nan ■ at a a l l l ho foraardsd with tho stato- ■oat to ths Chlsf of b jlM in , Vs will hs plsaaod to furnish M9 furthor srsllsbls Information ahloh you aay osasldsr hslpful la sxpsdltl^t prop*- ration of your esaosats. Slaooroly, 1 lm al jobs v. pausa; a . As atmt od It, Col,, Corps of laslnosrs Dietriot Kaglassr S I J iB ifliy X971 Bcatlaeal Plnottr, M m l Cater Qeallty A 6 ici«tiiU « Vhte pnilBtfiuy draft is ed jN t te chocs* q m rooolpt cf ntniila frca other federal, state mod local oecaoloo. « • ooold tory each atprcelate raaolrlsg four apaqr'a nr n a f a «Mt draft statcasot oa or tefcro £9 Vtecaiy 1071, Tear doss will ho felly nrnilfiiod dsr» i«3 tetewratloa of tho flaal otetcaoot a d yoor nnunin otn ho fer- ^ tfc* dataasat to tho Chiof of Esglaoors. Co d l l ho slosssd to faralsh coy farthar svallahlo lafcrcatlca chleh yoa aay rn tlricr hai»fal la sspsdltUg praeaaatloa of year ocaaaots. •laoorsly, 1 Ia#1 J0=l T. VdUCI, A . Aa stated It. Col., Corea of taglBsors District rrjlaaai 21 January 1871 Ur. l«jr X. Wood, Btslcsal Dlrwctor Bureau of Outdoor Enervation Southeast Xoglooal Offloo •10 Moo Walton Bui Idles Atlanta, Georgia 30303 Dear Mr. Wood: A w U i of the Vest Tease see* Tributaries Project has boon sade to determine the extent of aediflcatlon seeded to achieve a |t the use of the basin’s natural reeouroea in aooordanoe with the Fish and Wildlife Coerdlaatloa Act of 1M9, K U l e Lao E8-C34, and the recently enacted larlroeasntal Policy Act of 190, Public Lav 81-180. Our analyala shove that notification of the authorised project to include ulnar channel changes, beautification neasures, development of the Gooch and Ylgrett Wildlife Caeagcaent arena, and aoqulaltlca and dsvelcgaent of approxlnately 14,400 aeroa of additicaal lands vlll la seen the adverse effects of the fined ocatrel laprevcneat and effectively nitlgate the project-induced leases of fish end wildlife re sources in the Obion and Ported Deer Elvers basin. Inclosed is a preliminary draft of ear five-point environmental Impact state- neat prepared in recpoaae to the spirit and intent of Beetles 103(3) (C) of the fictional fiavlresaeatal Policy Act of 1SC3 (PL 81-180, 83 Btat. 888-tSd). This section requires that prior to asking nay detailed statement, the responsible Federal official shall ocasult with and cbtain the ccnaeats of any Federal, state or leoal agency which has JurlsdicUen by lav or special expertise with respect to any environmental inpact involved. Copies cf . euch statements and oesamnts and views cf the appropriate Federal, state, and leoal agencies which are anthcrissd to develop and enforce environmental standards shall be node available to the President, the Council an finvlrom- nental Quality, and to the pehlie and shall — y the preponal through the existing agency revise processes. Cr. E>j X. tM n * » » J i»n Thla prollnlcary draft is mbjoet to riatp apsa local* of eeeaete frca #th w •*•*• ted tool scsactca. Oa aoald w y cad appraelata nM slvles jwer acaey'a nrarata ea tkia 4 n !t otatocant «ai or bafM * 83 M raiy 19T1. bar view oill ba faliy nwldwad teles papntiM of tbo final atatesat aad ymer me=xA m will b* («m iM with tbs atttr- aanad to tbo Cblof of Csjleeete. 6a w ill bo pltaaod to fav d d may furtbor avallablo iB teB tia d id yw cay oesaidor bolpfbl la oxpodltlas paopaia- JNM6SP M S S S S 3 0 t# o t t a o m ly t 1 1181 joss v. mica, xt. do atmt od Lt. Oal., Oarp a of Eaglaoors D iatrlot JCaglaow 12230-83 24 Utii t i i y 1971 Kr. Roy K« Chad, D ticatcr Bureau of Outdoor G screatla Ssutheest Rraional Office 810 Car Calt ca Culldicg At la ta , Qscrgla 30303 Osar Or. Cosdi This la 1b re f tia e to ear latter of 21 Jrrxrcry 1971 etdeb reyrrstod year esasy’e ceaasste a tbs Cat Hrr—“ja Tributaries csrirca- ental l^i»t ctsteaal. 2a car repeat, a iahj fer your ceaaata by 20 fttw ay 1971 a tbsy could b lesarporotcd la tb flsal state* e a t ad a la bo feresrfad with tb» etatceat to tbs Chief of a bars baa digested to complete tbs o to taat a esa aa possible) beaver, yar cssrate, chlch ers a crrrntlal part, bare eot yst baa received. b caul c^saalcte raalrley peer rless at tbs earliest psattcafrls data a tbst tbay cay bs eeasldarcd la prepare* tla ef tbs fl&sl cabalala. D laaraly , J t o T. MBXC3, JX. Oslnesl, Oerps c f fcytearra Xttotrlet Essiasr DATE TELEPHONE OR VERBAL CONVERSATION RECORD For uto of this form, too AR 340*15; fhe proponent agency U The Adjutant General** Office. 1 March 1971 Request for Comments on West Tennessee Tributaries Environmental Impact Statement OUTOOINO CAUL PW ION CALLING o r n c e PHONE NUMICA AND EXTENSION Andrew V. Grosso Environmental Resources Sec 534-3857 PERSON CALLED ADDRESS PHONE NUMVKn AND EXTENSION Bureau of Outdoor Recreation Chuck Schuler 404 526-6377 Atlanta Office S U M M A R Y OF CONVERSATION 1. Mr. Schuler is handling the impact statements for Director Roy K. Wood of the Bureau of Outdoor Recreation. 2. Mr. Schuler stated that his office had not intended to make an impact statement at this time. In view of the pending litigation, his office was under the impression that all information on the project would be handled at department level. 3. On the morning of 1 March 1971, Mr. Schuler met with Mr. Dean Fields of the Bureau of Sport Fisheries and Wildlife and had an informal discussion on that bureau's fish and wildlife impact statement. lie said he was in general agreement with the Bureau of Sport Fisheries and Wildlife's statement and would probably concur with it rather than completely rewrite one for the Bureau of Outdoor Recreation. Mr. Schuler said he would try to get something to this office by Friday, 5 March 1971. U S S H V >1 Jhauary 1871 hr. 9. Leary Jocag, D l m t a r TtinrtffTT ItrMB M l K t l « Control 630 Cordell Cull Buildlag MfhvllU, H i w n M 37319 Dear Ur. Joansi A rarlew of the Vast Tm h u m Tributaries Frojeet D u boos aede to 6atonalao U « extent of Bonification aaoda6 to achieve a balance la the uao of the basin's aataral raaooroaa la aeoardaaoa with tho flah aad Wild Ilf a Coordlaatloa Aet of IMS, Public Law 96-C34, aad tha raoaatly aaaotad Barlroneatal Policy Aot of 19CP, Public Law 91-190. Oar aaalyala ahoao that aedlfloatlon of tha authorised projeat to Include ohaaaal chaages, hoaotlfloatloa aaaauraa, derelcgaeat of tha Ooooh aad Tlgntt Wildlife Baaetawt arena, aad aoqulaltloa aad derelepaent of a p r a d M t a l y 14,400 aosoa of addltloaal laada will laaaaa tho advoraa affaota of tha flood oaotrol Irprareaont aad affaotloaly altlcate tho proJect- induced laaaaa of fish asd wlldllfa roaaatroaa la the Ohloa aad Farted Door El ware haala. Xaoloaod la a proUalcary draft of oar flve-palnt earlrosaeetal lspect state- aoat praparod la rirjmt" to tho spirit aad lateat of Saotloo 100(3) This p e l i o i m y draft ia w ltjM t to eftarga « p a n e t l p o f ccssssta frea other M m l, otato aed local acaadea* Ca coold vary atii appreciate reealrlcg year agsacy'a a sssta ca this draft atatesaat ca cr before 20 hbm ry 1071. Toor vices will bo felly eeraldarod darirg p tp n tiN of tbo flcal atatesaat cad year nr.Tnta d l l be fercarded vltb tbo state- aaat to tbo Chief of CaglMora. Ci will bo pin —d to fernich aay farther available infe rotica chlcb yea cay cccaldor helpful ia expadltics pare pa ra- Olaoerely, i xaci «s=i v. raaira, n . Aa atatod L t. C a l., Carps o f Eagl— era District Biglaoor UC3D-FR 24 February 1971 Sr. S. Leery Jeaea, Diroetor fcrrseese Strcaa Pollution Central i20 Cordell Hull Building tocbrille, 7r—.tm :> 77219 )o«r Ur. Jcaest foia is la ic fte aao to our latter of 21 Jcaiery 1971 which requested rour e c sa y ’e nc---- rU cn tha test Trlbuteriea csrlrossantal lepeot statessat. In our request, wa cstod for jour ecmsnta by K} FTbruexy 1971 eo they oould be laeorpeaated la tbs flasl stats* sat cad also be forwarded with the wtatcesat to the Chief of Engineers. to here bees dlrostcd to ecrpleta the statesat as coca es pocaibla; toowrwr, your corssnta, tfcleh ere ca essential pert, haws sot yet teea received. Ce csuld c^reeiate reeolwlsy your Tiers at the Mrllest prestleebla data eo that they cay be ocaaldared la prepera- -ioa of the flaal cubnlralcn. Sleeerely, J0K3 7 . MKZSB, JB. Oolessl, Corps of fggtceer e Dlstriot Engineer OATC TELEPHONE OR VERBAL CONVERSATION RECORD F o r woo of th is form, A R 340-15; the proponent agency I t The A4|utont General*• Office- 26 Feb 71 SUBJECT O r CONVCROAT 1 OH Request for Comments on West Tennessee Tributaries Environmental Impact Statement OUTGOINO CALL PERSON CALLING OFFICE PHONE NUMtEH ANO EXTENSION Kent Carmain Planning 5 Reports 534-3460 RKRIONCALLED ADORES* RHONE NUMBER ANO EXTENSION Tenn. Stream Pollution Control S. Leary Jones 620 Cordell Hull Bldg. 81 615 741-2275 __Nashvi T le~ Tenn.__ 3 7 2 1 9 SUMMARY OR CONVERSATION 1. Mr. Jones was called at 1430, he was in conference and the woman answering the phone said that he would call us when he got out of conference. 2. 0830 Monday, 1 Mar 71, Mr. Jones was talking long distance. I told the woman that answered the phone who I was and asked her to have Mr. Jones call me. 3. 0845 Tuesday, 2 Mar 71, Mr. Jones was talking long distance. Miss Melnick said she would relay the message to Mrs. Rodgers (Mr. Jones' secretary) to ask Mr. Jones to call us. STATE OF TENNESSEE DEPARTMENT OP HIGHWAYS NASHVILLE 37219 February 18, 1971 WINFIELD DUNN. GOVERNOR R O B ER T F. SMITH. COMMISSIONER Lt. Col. John V. Parish, Jr. Corps of Engineers, Contracting Officer District Engineer Memphis, Tennessee 381G3 Dear Colonel Parish: Reference is made to the preliminary Environ mental Statement for the Mitigation Plan (West Tennessee Tributaries) transmitted with your letter dated January 18, 1971. We have reviewed this statement and have no comments to offer since it appears it will have no effect on our highway operation. Very truly yours, Robert F. Smith Commissioner Comments of Tennessee Game & Fish Commission on Corps of Engineers Environmental Statement The following are comments in relation to the Corps recent project review, environmental statement, including evaluation of fish and wildlife resources, mitigation proposals and current environmental statement. General (Items 1 and 2): Originally the project was primarily justified on the basis of drainage improvement of two upper zones (A & B), and minor flood relief on T,B” Zone. Now benefits are applied to all zones and flood control is given special significance. The estimated annual flood damages have increased as follows: review of 1948 = $55,000.00, 1965 = $757,150.00 and 1970 = over $2,000,000. It is our opinion that the greatly increased flood damages are partially the result of attempted agricultural operations in the lower floodplain. Thus, substantiating our opinion that such operation: are open to serious question from the standpoint of sound conservation land use practices. We also feel that the use of channels for flood control is questionable. Attempted clearing of the floodplain lands is not of recent origin. Evidence of same can be determined by field observation or study of old aerial photographs. As noted by the SCS (MRT) such has occurred periodically with improved market conditions and optimism caused by several consequentive dry years. In the present situation, we are firmly of the opinion that land conversion of Zone "C” woodlands and some of the areas in Zone "B" are the result of the authorized project. Thus, woodland losses will be much greater than projected. Sections of the Corps statement dealing with increased flood losses, large capital investments, etc., confirm this position. Clearing in backwater sections (even more frequently flooded than headwater) is causing the demand for more protection. Conversion in areas not yet reached by the canal is occurring in contemplation of drainage benefits. Some of these areas have not been farmed after clearing (too wet). Contact with farmers who are above the project will reveal that they think they will gain some drainage improvement from the project and believe that a new project will someday reach them. The large flood damages noted in the above paragraph indicate that farming in the lower bottoms is "rather" risky and dependent upon project completion. Future without project estimates of clearing do not seem to account for areas reverting back to woody growth. In essence, we are saying that habitat losses are the results of the project - not the soybean market. Fish and wildlife values are minimized and restricted primarily only to species of game animals and fish harvested. Thus, values are basically not assigned to the general wetland-woodland ecosystem or the related plant communities and populations of non-game fish and wildlife. The only values provided for these components are those general outdoor recreational visits, which are projected to occur only on existing public owned areas. Thus, the remainder of the habitat has no importance from this standpoint in their evaluation. - 2 - Although approached via slightly different methods, the estimates of fish and wildlife recreational trips and values seem to be approximately the same as those reported in 1959 (data of mid-fifties) by the USDI (considering difference in habitat acres and resources used or not used). Therefore, at least a large portion of the values are based on information which is over ten years old. This is in direct opposition tt> other phases of the project review (flood damages, agricultural values, benefits, etc.) which were updated to current levels. The Corps has acknowledged that the wetlands have national significance generally and specifically for waterfowl. However, no.monetary values have been applied to these national aspects, except as related to local waterfowl hunting. No values have been assigned to wood duck production and/or migra tion and wintering habitat for all species. In essence, these things may have been considered, but they have not been weighed qualitatively and ' quantitatively. Thus, they are not really included in the evaluation. The proposed mitigation is not considered adequate (note Tenn. Game & Fish Commission Statement of Feb. 10, 1971; and preliminary report of . July, 1970). The amount of mitigation has been developed On the basis of use of minimal "without project" natural resource values - thus, said proposals are extremely .low. Fishing, waterfowl hunting and general out door recreation (primarily fishing and general) are being substituted for the overall recreational potential of the broad natural resources of the basin. Considering project induced loss of at least 84,000 acres of wood land (Corps estimates), the 14,400 acre acquisition proposal seems unreason able. This opinion is further substantiated by adding related loss factors involving elimination of wetlands via drainage, reduced productivity and probable greater conversion of woodland/wetland area. Over $5,000,000.00 is recommended for development features. It is our opinion that the long range interest of the general public could be better served by using such funds for further acquisition of lands. We do not approve the proposed acquisition of 2,400 acres of land adjacent to the Gooch WMA. These lands are primarily of importance only for waterfowl management. Thus, we feel that this portion of the acquisi tion fund could be spent on better quality, all purpose habitat. Based upon land values used by the Corps, the money required to purchase this 2,400 acre unit would buy 7,200 acres of woodland. Based upon the Fish and Wildlife Coordination Act of 1948, Subsection 2 (c) (later 16 U.S.C. 662 (c)) we do not approve the use of monetary (B/C analysis) justification of means and measures to prevent loss of and damage to fish and wildlife resources. Further, that such means and measures should be presented only in nonmonetary terms because of the basically intangible nature of fish and game values. The recommended smaller channels in certain reaches cannot be evaluated without additional information on actual specifications of such work. An example of "snagging and dragging" can be seen in the upper section of the South Fork, Obion River. It is pure and simply a typical "improved" and enlarged canal. - 3 - Beautification measures at road crossings are fine. However, such cannot be considered as adequate measures for handling erosion of tributary outlets, bank stabilization or other related soil management problems in the total project system. Impact Statement (3): a. We question the premise that the median income of families in the basin will be significantly affected by the project. We feel it is more likely that the small number (1220± : 354,000 acres * ave. farm size of 290 acres) of bottomland farm owners will be the primary recipients of the $23,000,000.00 outlay of public funds. Questions regarding the^mitigation proposals are noted above in another section. Briefly, we do not concur that the proposed mitigation will "assure the preservation of quality fishing and hunting opportunities", or that such mitigation will "replace" previously existing fisheries and waterfowl resources. b. We agree that the project will adversely effect the existing ecosystem. Plain and simply, it will eliminate the existing wetland environ mental community.. It is our opinion that the soil moisture and timber production will be affected over a wider area than just that immediately adjacent to the channel. We agree that aquatic and woodland habitat will suffer a reduction in pro ductivity. However, we feel that almost total elimination of aquatic area and substantial reduction in woodland area are more important factors to be considered. We question that the mitigation proposals will enhance overall biological productivity. No means are known for making the new channel and spoil as "aesthetically pleasing" as the previously existing natural stream segments (which are now gone I). According to new state law (based upon National Water Quality Laws) the waters of the Obion basin have been classified for "Fish and Aquatic Life". • A statement presented by the Tennessee Department of Public Health at the public hearing on Feb. 10, 1971, indicated that channelization would be in violation of said laws (due to detrimental affect of the new channel). c. The Corps statement lists two alternatives. The analysis behind both of these alternatives primarily utilizes only minimized, dated, fish creel or game bagged, minimum habitat conversion information and no actual consideration of the overall wetland resource. Thus, we question the actual tests of alternatives. Such alternatives should have included one which would include mitigation of existing losses (55% of the fish and wildlife values within the authorized project lost via 32% completionof works - Corps estimate) and minimal channel works necessary to maintain stream flow. - 4 - We think clearing of woodlands in the larger, more frequently inundated section of the floodplain should be discouraged. The statement involving local interests and their large investments (based upon project construction) substantiated our contention that clearing is related primarily to the project rather than the soybean market. (Thus our position that project induced land conversion is too low.) The discussion of the alternatives emphasizes flood control, Again. we wonder if such ditch systems represent good flood control measures, especially considering future conditions whereby there will be little except annual crop residue to retard runoff. In considering the alternative of acquiring lands in excess of 14,400 acres it is again indicated that their proposal' (acquisition and development) will ’’exceed” the project-induced losses. As previously noted, this is not practical when considering all of the components of the natural environment or reasonable evaluation of those resources measured. d. As noted above, we think the best long term usage of the ”C” Zone is for timber and wildlife oriented recreation. Such will be (not could be) detrimentally affected by the project for short term attempts of agricultural gain, at extremely high cost to the farmer (clearing, farm drainage, etc.) and the public. Elements of the existing environment are perhaps renewable, but what are the costs and time involved for such to occur. If the project must proceed, the program designed by the Corps for preservation of the forest resource and recreational opportunities is inadequate for short term needs and would be completely out of line in regard to future long term needs (considering declining resources and increasing demand). e. We cannot say that irreversible or irretrievable fosses of natural resources may not occur. Changes in water quality and quantity, heavy applications of pesticides and herbicides, soil conditions (moisture, temp., composition), increased rates and changed patterns of sedimentation, etc., may, over a long period, basically affect natural succession of this area. The Corps has indicated that other floodplains have reverted, after ditching has not been maintained, to their previous state. The history of the channeled portions of the Obion-Forked Deer seem to refute this opinion. Shrub and wooded swamps have evolved in large areas rather than the previously dominant hardwood type. Modification of water patterns, especially opening bendways in original stream channels, may be essential for recovery of the previously existing natural state. Irregardless, the time and economics involved (natural resource losses, funds required in construction and maintenance, funds involved ii land conversion, etc.) are the primary factors to be considered. Time in this case is certainly not a "few years” as noted in the statement. We would recommend that justification of the project be based on benefits to upper zones (like original plans) as related to total construc tion costs and estimatedreasonable potential values of all natural resources (hardwoods, swamps, game, fish,-general fauna and flora, etc., etc.). - 5 - Special Commentary: The continuance of the project (Middle Cities and especially Sidonia Items) without initiation of mitigation will simply mean further loss of a depleted wetland system. Example - some improvement of drainage has occurred in the Sidonia Item (due to adjacent new channel). As expected, clearing and plans for same have been started and a fine cypress swamp (and heronry site) is being drained. Thus it is essential that if the project is to be continued, mitigation must be given equal priority in funding and scheduling of same. The foundation upon which the expenditure of over $22,000,000.00 of public funds will ultimately rest is maintenance. Such has not been adequately carried out on the completed sections and sufficient monies for same have not been made available. It would seem reasonable that questions, related to this all important matter should be answered prior to considering further construction. STATEMENT OBION-FORKED DEER RIVERS PROJECT U. S. CORPS OF ENGINEERS PUBLIC HEARING FEBRUARY 10, 1971 by Dr. Greer Rlcketson, Chairman Tennessee Game and Fish Commission I am Dr. Greer Ricketson, and It is my privilege to represent the Tennessee Game and Fish Commission as Chairman in presenting this statement. The Commission is made up of nine members appointed to represent the hunters and fishermen of Tennessee. In addition to concern for the hunters and fishermen, the Commission is charged by statutes, as follows: "It shall be the duty of the Commission to protect, propagate, increase and preserve the game, fish, fur-bearing animals and wildlife of the state." We are, therefore, responsible for the fish and wildlife species and since they are dependent upon suitable habitat, any habitat changes of a detrimental nature are of concern to the Commission. On February 17, 1970, after noting what was happening to bottomland habitat as a result of the Corps of Engineers' project on the Obion and Forked-Deer Rivers, a resolution was adopted asking that a total restudy be made of the project by the Corps. It was felt that, as a result of the restudy, fish and wildlife resources and general environ mental factors could be more adequately considered. In addition to the resolution, our position and Interest has been affirmed by the completion 4 of our own Investigation of the impact of the channelization project on fish and wildlife. This report has been submitted to the Corps for consideration. We are pleased that the Corps has initiated a restudy of this project and provided a report for our review. However, because of the short period of time available for our complete analysis of the data, we thus reserve the right of providing specific and detailed comments for a later time. The following are a few major aspects which I would like to discuss briefly. The recreational values upon which the proposals are based seem to be minimal. The wetland habitat Is noted by the Corps as having national significance; yet, little consideration In terms of dollar values has been assigned to this significance. The minimal values do not seem in line with the rapidly Increasing demand for outdoor oriented recreation— especially hunting and fishing. We think it Is only reasonable for the Corps to consider mitigation via land acquisition and development. This principle has been followed In other Corps projects and In programs of other federal agencies. We do not think the proposals for acquiring and developing 14,000 acres and development of 10,000 acres of already existing state-owned lend Is adequate when it Is considered that 140,000 acres of high-quality wetlands are projected to be lost. We also do not concur with the selection of one of the acquisition units, as we feel very strongly that all acquired areas should be those which best provide typical units of the woodland-swamp wetland type. In summation, the Corps report and proposals, in our present judgment, do not go far enough towards measuring recreational values, providing adequate mitigation, or considering values of the total wetland ecosystem. Thus, we do not feel that hunters and fishermen and future generations have received full consideration in regard to having a balanced healthy environment. In closing, I would like to reiterate that the Tennessee Game and Fish Commission Is reserving the right to provide specific and detailed comments until a later time. United States Department of the Interior FISH AND WILDLIFE SERVICE BUREAU OF SPORT FISHERIES AND WILDLIFE PEACHTREE-SEVENTH BUILDING ATLANTA. GEORGIA 30323 February 19} 1971 District Engineer U.S. Army, Corps of Engineers 668 Federal Office Building Memphis, Tennessee 38103 Dear Sir: This is in response to your letter of January 21, 1971; LMMED-PF, requesting our comments on your draft environmental statement for the West Tennessee Tributaries project (Obion and Forked Deer Rivers). You prepared this statement in response to Section 102(2)(c) of the National Environmental Policy Act of 1969; Public Law 91-190, 83 Stat. 852-856. The proposed draft statement treats the Fish and Wildlife Mitigation Plan as drafted in January 1971 as though it were a part of the authorized project. Except for development of existing State-owned lands, mitigation proposals could not be accomplished without further congressional action. We are hopeful that a fish and wildlife miti gation plan, somewhat greater in scope, will eventually be included as a part of the authorized project, but we believe it inappropriate to assume the present plan is a project feature at this time. In considering any mitigation measures for fish and wildlife, short of reversing the trend of land development to other uses, it should be realized that there will remain a net loss to these resources. Fish and wildlife project features are mitigating— a lessening of the severity of project impacts— not a complete restoration of losses. In this respect, the draft fish and wildlife mitigation plan of January 1971 is considerably less than we consider satisfactory, and an expansion of this plan will be asked so that a more equitable degree of mitigation can be achieved. It should also be recognized that very seldom can quality be maintained. Space is an important component of the esthetic experience and is reduced in virtually all cases. Regarding alternatives, we take a somewhat different view in that it appears alternatives to achieving project purposes should be given emphasis. In this respect, would it he proper to evaluate other techniques such as flood plain zoning, flood proofing, and reloca tion of facilities? Project objectives; i.e., improving the econoc^r and thereby improving human well-being, might be met by encouraging economic pursuits such as timber production and recreation rather than adding further to an agricultural economy. In discussing the possibility of reversing loss of fish and wildlife habitat, there is much said of projects lacking maintenance and reverting toward former conditions. What would be your prediction as to the likelihood of this occurring on the Obion and Forked Deer Rivers? The opportunity to offer these comments is appreciated. We will be glad to work with you in further consideration of the project's impact on the environment. Sincerely yours, C. Edward Carlson Regional Director TENNESSEE DEPARTMENT OF CONSERVATION STATEMENT REGARDING THE ENVIRONMENTAL PROPOSAL BY THE CORPS OF ENGINEERS ON THE WEST TENNESSEE TRIBUTARIES (OBION AND FORKED DEER RIVERS) Dyersburg Tennessee February 10, 1971 The Tennessee Department of Conservation is designated as the State agency responsible for providing for the wisest use of our natural resources, and therefore feels the necessity to comment on and emphasis the adverse affects, a continued channel improvement project will have on the West Tennessee tributaries and the surrounding locale. The most obvious affect resulting from the channelization of the Obion and Forked Deer Rivers, will be to the environment, contributing to the inevitable destruction of the flood plain ecosystem; a point fully realized by the Corps of Engineers in their "recent environmental proposal." A cursury examination of an undisturbed flood plain ecosystem is one of annual flooding, large trees, smaller pole size trees, shrubs, and other plant life providing the habitat for deer, squirrels, rabbits, raccons, beavers, various birds and other wildlife. Smaller animals and plants interact with all the other forms of life to create a rich sustaining natural balance. The most permanently distructive and disruptive factor of the flood- plain ecosystem would be the cessation or radical change in the annual flooding, causing a substantial decrease in the productive capacity of the ecosystem, and resulting in a noticable reduction in timber productivity. If the channel improvements are made then we can expect nearly a 50 percent loss in forest productivity. According to C. J. Barstow in a preliminary report entitled "Fish and Wildlife Resources— Obion and Forked Deer River Basin, Tennessee" the annual timber loss will be approximately $1,774,560. This timber loss should be included in the cost analysis of the project. Another result to a radical change in the annual flooding, is the destruction of existing floodplain habitat due to an inability to retain surface and ground waters. Possible problems steming from the lowering of the water- table may also be detrimental to public as well as private water supplies. Obviously annual flooding is the key to a productive floodplain left in a natural state. Reducing the annual floods will conversely reduce the productive capacity of the flood-plain ecosystem. The objective of the channel improvements is to remove water fast enough so as to prevent flooding. The Corps of Engineers admits that the planned channels can only accommodate the floods which occur once every 1.1 years. Therefore those floods that occur once every 2, 3, 4, 5 or 10 years will still result. Further benefits can be derived if the Corps of Engineers will advise local landowners, communities and interested persons in proper flood plain management including zoning against high loss structures; proper location of roads, bridges and other developments that have to be placed on the flood plain. As stated the landowners, as a result of anticipated channel improvement are clearing bottomland timber in large blocks for soybean production, even above the limits of any authorized work. Land clearing for agricultural crops is strictly a short term use of man's environment when one considers that the channel improvements are designed to carry flows, within banks, from a flood with a frequency of occurence of once in 1.1 years. In other words the larger floods that occur once every 2, 3, 4 or 5 years will be slightly reduced but not to the point where the landowner has no potential loss. Thus the farmer or landowner who converts his productive forest land to cropland can expect a loss approximately every other year. It has been estimated by the Tennessee Office of Emergency Planning that the June 1970 floods caused $12,500,000.00 income loss on 181,600 acres. Double the acreage because of land clearing and the next flood which can very likely occur next spring, or the next or the next would undoubtedly double the estimated income loss. The land clearing which will occur because of the feeling of security created by the channelization project will not be as beneficial to the landowner as they are led to believe. If one of the benefits attributed to the project is increased use of flood plain forest land for agricultural purposes the cost of clearing and the timber lost by such activities should be inlcuded in the cost. An additional cost should be placed against the project for the potential loss of primary and secondary wood using industries. Further study should be conducted by the Corps of Engineers, to determine the loss that will occur because of increased erosion of the agricultural land by faster moving water. When this has been determined the increased cost of fertilization to maintain a high level of soil fertility and conser vation measures to prevent further soil erosion should be added to the cost of the project. The loss, to future generations, of the opportunity to see a balanced but dynamic flood-plain ecosystem in action should be considered as a cost to the project. This is nebulous and will be difficult to determine but to future generations it will be a definite loss. The Corps of Engineers field report now under review proposes to modify the project to provide fish and wildlife mitigation measures which will achieve a better balance of man’s environment in the Obion and Forked Deer Rivers basin. The modification recommends the inclusion of abour 14,400 acres of floodplain lands as additions to the Tennessee Game and Fish Commission's Gooch Wildlife Management Area, and the Tigrett Wildlife Management Area. This is of little reconcilation for the long-term losses resulting from a continuation of channel alteration; a proposal that does not accommodate the claims asserted by the Game and Fish Commission and U. S. Bureau of Sport Fisheries and Wildlife for the destruction of Tennessee's prime waterfowl area. The question that arises, is whether it is the resident farmers who will be financially enhanced or the land-owners who may or may not reside within the basin. The Department cannot support a project detrimental to the concepts of good "conservation.” The completion of some remaining 68% of channel improvement will have an adverse and long-term effect on the existing ecosystem, a reduction of valuable forest lands, fish and wildlife, as well as recreational losses; all of which are required to meet the future demands of the general public. A loss of this magnitude in an area of the state that has fallen short of meeting these needs, cannot be supported. A balanced program of agricultureal development, combined with bottomland forest resource preservation and management, together with provisions for adequate recreation opportunities should be established. Further time and study is needed to come up with a solution beneficial to all, and until such time no further construction should be undertaken. Max d. Young Chief of Planning U n it ed S tates D e p ar t m en t o f A g r ic u l t u r e FOREST SERVICE Southaaitarn Area, Stat* and Privata Forestry Atlanta, Gaorgia 30300 March 3, 1971 Lt. Col. John V. Parish, Jr. District Engineer, COE 668 Federal Building Memphis, Tennessee 38103 Dear Colonel ftirish: The letter to the Director, Northeastern Area, S&FF, on the review of West Tennessee Tributaries was forwarded to this office for reply. Please address future correspondence on Corps projects in Kentucky, Tennessee and Virginia and all states south to: Director, Southeastern Area, S&FF, Room 713, 1720 Peachtree Road, NW, Atlanta, Georgia 30309. The USDA is now in the process of making a Type IV Basin Study of the area covered by your West Tennessee Tributaries project. In the course of the study, environmental impact studies will be made of all proposed project alternatives, with due consideration given to the projects proposed in your study. Our comments on the Draft, Environmental Statement are: In many cases there is not sufficient information in the Draft on which to base an opinion as to the effect of a practice or procedure on the environment. Last paragraph, page 2. Sounds like an execellent reason for no channelization. The area would serve waterfowl using the Mississippi flyway much better if left in its present condition. Page 3, Line 7. ". . could be similar . .", raises a question to exactly how the lands will be managed. Page 4, Last line. Delete "natural". It is not natural for stream channels to be clogged. This is usually caused by poor land use practices in the drainage area upstream. 2 Page 6. Using median family income as a basis for comparison is apt to be misleading unless cost of living is also given. A rural family- may have a much lower total income than the median, but because of the much lower outgo, may be as well off financially as a city dweller with a much higher income and much higher living costs. Line 9. It is difficult to imagine assuring the preservation of quality fishing with a drainage project. Normally, channelization practically eliminates fishing. Last paragraph. Mitigation measures do not usually "preserve and develop wetland habitat." They only attempt to make the loss less severe. Therefore, the fisheries and waterfowl losses would not normally be replaced by mitigation measures. Page 8, Line 9. After Aesthetics add "and productivity for wildlife". Line 11. "ditch-like" is a misnomer, the new channels are ditches. c. alternatives. Alternatives not discussed are cleaning and snagging the present channel, land treatment measures to retard runoff and reduce sediment, floodplain zoning and flood proofing, and relocation of facilities out’of the flood prone areas. Throughout this statement, forests have been considered largely as they affect wildlife. The economic loss of bottomland hardwoods, which are already in short supply, has largely been passed over. Also, the other ecological and environmental effects of the forest stands should be written up in an environmental statement. No where in this statement are rare or endangered species of plants or animals mentioned. Are there none in the area? We appreciate the opportunity to review these environmental statements and hope that our comments have been constructive. Carter P. Quails Assistant Area Director W infield D unn STATE OF TENNESSEE G o v e r n o r DEPARTMENT OF PUBLIC HEALTH N A S H V IL L E 3721S Eugene W. Fowinkle, M.D., M.P H. Commissioner February 9, 1971 Llautanant Colonel John V. Parrish, Jr. District Engineer, Memphis District U. S. Army Corps of Engineers 668 Federal Building Memphis, Tennessee 38103 Ret West Tennessee Tributaries Project LMMED-PF Dear Colonel Parrisht Thank you for your letter of January 21, 1971. He appreciate being asked to present our attitude toward the West Tennessee Tributaries Project. Since this is essentially a watar oriented matter, I have asked the Division of Stream Pollution Control for their comments on your letter and the Corps' Environmental Statement. In accordance with the Hater Quality Act of 1965, the Tennessee Stream Pollution Control Board has adopted criteria defining the permissible pollution conditions of waters for ssven dlffsrent stream uses. This criteria is contained in the document "General Hater Quality Criteria for the Definition and Control of Pollution in the Haters of Tennessee" as adopted on May 26, 1967, and amended on November 17, 1967. With the exception of temperature standards, this criteria has been accepted and approved by the Federal Government. Also, in accordance with the 1965 Hater Quality Act and Section 70-304 of the Tennessee Strecm Pollution Control Law, the Board has held and is in the process of holding public hearings for the purpose of classifying streams for various stream uses. These hearings are held after legal public notice is given so that lntarestad partlea nay voice their opinions as to the uses for which the streams may ba claasifled. A public hearing for the classification of the interstate waters in the Obion River Basin was held on March 21, 1967. A hearing for the intrastate or remaining waters in this basin was held at Martin, Tennessee, on June 2, 1970. Those classifications suggested at the Martin hearing have been approved by the Board and, in accordance with Tennessee Code Annotated Section 70-302, paragraph d, filed with the Secretary of State. On February 8, 1971, these daaslficatlona became legally effective and, thus, all the waters in the Obion River Basin have legally defined limits of allow able pollution. A hearing for the classification of those waters in the Forked Deer River Basin will be held in May or June of 1971. Lieutenant Colonel John V. Parrish, Jr. Page 2 February 9, 1971 All the waters of the Obion Basin were classified for the designated use of "Fish and Aquatic Life". Section c of those standards of quality for protecting fish and aquatic life reads: Solids, Floating Materials and Deposits - There shall be no distinctly visible solids, scum, foam, oily sleek, or the formation of slimes, bottom deposits or sludge banks of such size or character that may be detrimental to fish and aquatic life. Section d reads: Turbidity or Color - There shall be no turbidity or color added in such amounts or of such character that will materially affect fish and aquatic life. There is no doubt that channelization, if allowed to proceed, will cause violations of these standards. Violations of these standards are, according to Tennessee Code Annotated 70-316, violations of the Tennessee Stream Pollution Control Law and may be prosecuted as such. We have a situation in which one agency of the Federal Government has required that certain standards of quality be adopted and another agency is pursuing a project which will violate these standards. On January 20 and 21, 1971, a representative of the Division of Stream Pollution Control attended a meeting, called by the Environmental Protection Agency, of those states bordering on the Mississippi River for the purpose of discussing temperature standards for the Mississippi River. Although this meeting was concerned with the Mississippi River, it was stated by Mr. Murray Stein, Chief of the Enforcement Branch for the Environmental Protection Agency, that the pattern for adopting temperature standards for the Mississippi River would extend to the other streams of the country. If the proposed pattern for setting stream temperature standards is adopted by the State of Tennessee and applied to the Obion and Forked Deer River Basins, it is probable that channelization will create conditions which will cause violations of stream temperature standards. We have again a contradictory situation. Finally, our review of your Environmental Statement has failed to offer any substantial reasons for considering the West Tennessee Tributaries Project justifiable. The Corps' proposals for minimizing the environmental damage of the project are appreciated. The Tennessee Department of Public Health has a responsibility to consider the overall welfare of the people of the State, The Department has not and will not oppose any action or project which it considers to be in the best interests of both our present and future citizens. In the light of the responsibilities of this Department and of the Tennessee Stream Pollution Control Board and having considered those documents submitted by the Corps of Engineers, we can see no justification for the loss of at least 100,000 acres of wetlands which this project will induce and the rendering practically sterile of over 200 miles of streams. We feel that this project Lieutenant Colonel John V. Parrish, Jr. Page 3 , February 9, 1971 can cause irreplaceable losses to the fish, wildlife, and wetland resources of the area and to the vital migratory bird route known as the Mississippi Flyway. For these and the previously mentioned reasons, we must go on record as being opposed to the continuance of the West Tennessee Tributaries Project. Sincerely-yours, Eugene W. Fowinkle, M.D., M.P.H., Commissioner Tennessee Department of Public Health EWF/SU/WWB/jw CC: The Honorable Winfield Dunn CC: Office of Urban and Federal Affairs CC: Environmental Protection Agency Atlanta, Georgia CC: Tennessee Game and Fish Commission ENVIRONMENTAL PROTECTION AGENCY WATER QUALITY OFFICE 1402 Elm Street, Third Floor Dallas, Texas 75202 March 1, 1971 Your Reference: LMMED-PR District Engineer U.S. Army Engineer District, Memphis 668 Federal Office Building Memphis, Tennessee 38103 Dear Sir: We have reviewed the environmental impact statement prepared by your office for the West Tennessee Tributaries Project. This project when completed will provide flood control and drainage benefits to the agricultural lands and small towns adjacent to the Obion and Forked Deer Rivers and their major tributaries in West Tennessee. The project was authorized in 1948 and is about 32 percent complete. A field report now under review proposed to modify the project to provide fish and wildlife mitigation measures intended to achieve a better balance in man's use of the environment in the Obion and Forked Deer River Basins than provided by the original project. The modifications recommended for inclusion will provide 14,400 acres of floodplain lands to be managed for fish and wildlife purposes, additional development of existing state wildlife areas, and minor modification of project channel design. The impact of the project on water quality, including modifications, probably will be minimal. Possible damage to water quality indicated in first sentence cf section (e) should be specified in section (a) of the statement. The planned modifications, which considers the Bureau of Sport Fisheries and Wildlife objec tions to the authorized plan, will further minimize the adverse effects of the project on water quality. To protect water quality during construction and to soften the adverse effects engendered by operation and maintenance of the project, the following guidelines should be considered: 1. Exercise care in the relocation of any petroleum product pipelines and take precautions in the handling and storage of hazardous materials such as petroleum, herbicides, and pesticides, to prevent accidental spillages that could result in water pollution. 2. Provide and operate sanitary facilities to treat and dispose of domestic wastes in conformance with State and Federal water pollution control regulations. 3. Schedule and perform excavation and construction operations to keep turbidity and siltation at the lowest level practicable. Our Agency considers your field level request for review and comment on the draft environmental statement to be a request for consultation and technical assistance. Our response to requests for comments at field level is informal and unofficial. EPA's official or formal comments on environmental statements prepared by other agencies will be made at the Washington level. Sincerely yours, KENTON KIRKPATRICK Director, Office of Planning cc: Messrs. MacFarland, Northington, & Davis-EPA W infield D u n n STATE OF T E N N E S S E E G o v ern o r DEPARTMENT OF PUBLIC HEALTH N A SH V IL L E 372 I 9 Eugene W, Fowinkle, M.D., M.P H. Commissioner March 5, 1971 Colonel John V. Parish, Jr. District Engineer, Memphis District U. S. Army Corps of Engineers 668 Federal Building Memphis, Tennessee 38103 Re: West Tennessee Tributaries Project LMMED - PF Dear Colonel Parish: Please refer to my letter to you of February 9, 1971, concerning this project in reply to your letter of January 21, 1971. My letter of February 9, 1971, was written to you primarily based on informa tion furnished by the Stream Pollution Control Board staff investigations. I should have signed that letter as Chairman of the Stream Pollution Control Board. Since that letter was written it has been called to my attention that other factors directly related to public health in that area were not included. I, therefore, wish to supplement that letter and place in your record the in formation that we have. We appreciate your problem in arriving at a conclusion for your final solution because of the conflicting views and interests in the stream sections of the Project. From the stream pollution standpoint the channeling will cause adverse effect on the fish and aquatic life of the streams. During construction and until the banks are completely stabilized there will be an increase in the turbidity of the water. Unstable bottom conditions will occur in the channel bottom which will adversely affect aquatic life. It has been called to my attention, however, that the flooding of the area does cause a public health problem both as to private water supplies and sewage dis posal. Any reduction in flood height and frequency will reduce the present hazard to the public health. The drainage of certain of the areas will reduce the mosquito production in those areas. Colonel John V. Parish, Jr. Page No. 2 March 5, 1971 This Department will be glad to work with you in any way that we can to reach a suitable and best solution for this project. Sincerely v q k a Eugene w. Fowinkle, M. D. Commissioner EWF/SLJ/mpr cc: The Honorable Winfield Dunn cc: Office of Urban & Federal Affairs cc: Environmental Protection Agency, Atlanta cc: Tenn. Game and Fish Commission cc: Regional Office STATE OF TENNESSEE STREAM POLLUTION CONTROL BOARD CORDELL HULL BUILDING NASHVILLE 37219 March 5, 1971 Colonel John V. Parish, Jr. District Engineer Memphis District, Corps of Engineers Department of the Army 668 Federal Building Memphis, Tennessee 38103 Re: West Tennessee Tributaries Project LMMED - PR Dear Colonel Parish: This will acknowledge your letter of February 24, 1971, with reference to your previous letter of January 21, 1971, requesting our comments on the West Tennessee Tributaries environmental impact statement. You received a letter dated February 9, 1971, on the above subject signed by Dr. Eugene W. Fowinkle, Commissioner, Tennessee Department of Public Health. Dr. Fowinkle is Chairman of the Tennessee Stream Pollution Control Board. His letter included the comments on this subject that we had pre pared and routed to him to be transmitted. Since the transmittal of Dr. Fowinkle’s letter of February 9, 1971, we have received objections to the stream classifications established for the Obion River Basin by the Tennessee Stream Pollution Control Board following its hearing of June 2, 1970. This objection will be referred to the Board members when the Board meets on April 1, 1971. The public hearing for the classification of the interstate waters of the Obion River Basin was held at Jackson on March 21, 1967. The stream classifications and standards were adopted for these interstate waters on May 26, 1967. The General Criteria also were adopted on that same date. These were approved by the U. S. Department of Interior with the exception of temperature. A public hearing was held on June 2, 1970, at Martin to consider classification and standards for the intrastate waters of the Obion River Basin. These were approved by the Board, filed with the Secretary of State, and became effective on February 8, 1971. Colonel John V. Parish, Jr. Page No. 2 March 5, 1971 A H of the waters of the Obion River Basin were classified for the designated use of "Fish and Aquatic Life." Section "c" of these Criteria as applied to this classification for protecting fish and aquatic life reads: "Solids, Floating Materials and Deposits - There shall be no distinctly visible solids, scum, foam, oily sleek, or the formation of slimes, bot tom deposits or sludge banks of such size or character that may be detri mental to fish and aquatic life." Section d of the Criteria for protection of fish and aquatic life reads: "Turbidity or Color - There shall be no turbidity or color added in such amounts or of such character that will materially affect fish and aquatic life." The channelization will cause violation of the above standard and will cause a detrimental effect on the fish and aquatic life in the river. The streams in the Obion River Basin have been classified for fish and aquatic life use. It has also been called to our attention that of the 127 miles of main stem and major tributary channels in the Obion River system that 59 miles of construc tion has been completed. It will, of course, be impossible to return these miles of stream to their natural condition. Also to stop all work and leave the re maining miles of streams unchanged will, I believe, complicate the flood conditions in that area, however, I do not have sufficient facts to evaluate that problem. Because of the many interests in this stream there will have to be a compromise worked out to serve the best interest of the area. We will be glad to work with you and the other interested parties to seek a solution. Sincerely yours, S. Leary Uo n e ^ Executive Secretary Tenn. Stream Pollution Control Board SLJ/mpr cc: Tenn. Game & Fish Commission cc: Environmental Protection Agency cc: Office of Urban & Federal Affairs ENVIRONMENTAL PROTECTION AGENCY WATER QUALITY OFFICE 1402 Elm Street, Third: Floor Ha 1 1 a c Tflvoe 7 R O O March 15, 1971 District Engineer U.S. Army Engineer District, Memphis 668 Federal Office Building Memphis, Tennessee 38103 Dear Sir: On March 1, 1971, we reviewed the preliminary draft of the Environmental Impact Statement on the West Tennessee Tribu taries Project, prepared by your office. In that review we pointed out that adequate measures to protect water quality during construction and operation of the project must be taken. We have recently received a copy of a letter to you from the Tennessee Department of Public Health pointing out that the project would violate Tennessee Water Quality Standards on the Obion and Forked Deer Rivers. This very significant adverse effect should be discussed in your statement and satisfactory alternatives formulated to prevent violation of the Tennessee Water Quality Standards. Sincerely yours, KENTON KIRKPATRICK Director, Office of Planning cc : Water Hygiene Rep. United States Department of the Interior BUREAU OF OUTDOOR RECREATION SOUTHEAST REOIONAL OFFICE 810 New Walton Building Atlanta, Georgia 30303 District Engineer U.S. Army Engineer District, Memphis 668 Federal Office Building Memphis, Tennessee 38103 Dear Sir: This is in response to your January 21, 1971 letter, inviting our comments on your draft environmental statement for the West Tennessee Tributaries Project (Obion and Forked Deer Rivers). I appreciate the opportunity to provide the following comments and earnestly request their serious consideration. The Bureau of Outdoor Recreation's interest here stems from concern over recreation related to affected fish and wildlife resources and to growing alarm over wetland timbered area clearing incident to drainage operations--a significant environmental degradation. Your analysis of the Obion-Forked Deer situation shows full cognizance of the project's effect upon natural resources and environment to date and its probable continuing deleterious impact. An honest and thorough analysis of a project's adverse effects is certainly basic to remedial action, and your statement records this. The mitigation actions your statement proposes are most worthy and are certainly of the type needed. It is tragic that what is now proposed could not have been initiated incident to the project's inception. It is doubly tragic that these very actions were proposed in reports and conferences between concerned Federal and State officials prior to the project's initiation. Although your proposed mitigation measures are worthwhile and feasible, I believe they are inadequate as I will explain in the following paragraphs. * It is noted that you propose acquisition of 14,400 acres of flood plain lapds at Federal expense. I believe that the Tennessee Game and Fish Commission has suggested something over 40,000 acres as a necessary conversion to public ownership to protect game and fish resources in the face of planned drainage operations. There is such a vast discrepancy between 14,400 and something over 40,000 acres that more discussion on this point to arrive at a proper figure seems in order. It is noted that you propose no acquisition at all on the South Fork of the Forked Deer. It is also noted that some of the lands proposed for acquisition are already managed by private interests for fish and wildlife purposes. I might further point out that unless mitigation in the form of acquisition proceeds first, it will be ineffective. In your identification of "alternatives to the proposed action" no mention was made of the possible alternatives of flood plain zoning, flood insurance or possible utilization of Public Law 91-559, the Water Bank Act. I believe it highly desirable to explore and discuss these alternatives. Most importantly I note the authorized project does not presently include the acreage proposed for acquisition at Federal expense. In your analysis of possible alternative courses' effect you point out the deleterious results to stopping the project at its present stage. However, considering all resources— agriculture, fish and wildlife, outdoor recreation, timber and environmental, I suggest the advisability of delaying further channelization until necessary action can be taken to include mitigation measures beyond those presently possible within the project's authorized framework. There is little that can be done after channelization proceeds and the landowners clear the land right down to the channel's bank as they have done where channelization has been completed to date. It is a hollow thing to propose buying the land after it has been almost totally ruined from a natural environmental and fish, wildlife and timber resources point of view. Therefore, I repeat my recommendation that channelization be deferred until necessary acquisition can be authorized as a part of the project. Your statement very completely describes the perhaps unforeseen results of the channelization and you use the phrase "project-induced conversion of the marginal lowlands immediately adjacent to the channels from timber to agriculture" most effectively. This is what your mitigation measures must guard against if they are to be effective and they can only be effective if accomplished prior to the channelization. This is amply illustrated where the project has been completed up until this date, particularly on the Obion River. The only place where the land has not been cleared is where it was converted to public ownership in advance by the Tennessee Game and Fish Commission. 2 It is noted that the West Tennessee Tributaries Project justification *is not dependent upon clearing the lands immediately adjacent to the channel. Such areas are commonly referred to as "first bottoms." The "second bottoms" are somewhat more elevated lands needing drainage for proper agriculture usage. A perfect picture from all resources' point of view would be timbered first bottoms with appropriate water management controls and second bottoms converted to agriculture. While it is somewhat out of this office's technical scope, it is believed worthy of consideration to observe that timbered lowlands with their moisture absorbent qualities are, themselves, a flood control element. A significant statement under your Special Commentary section is that these features can be developed concurrently with the continuation of channel improvement. Presumably, this means channel improvement through existing Tennessee Game and Fish Commission areas. Unfortunately, they cannot really be said to be mitigation features because these areas are already, until they are affected by channelization, excellent fish and wildlife areas. It is necessary to go back to my basic premise that public acquisition must precede channelization if mitigation measures are to be effective. SinpAtely yours, Roy K. Wold Regional Director