FINAL ENVIRONMENTAL STATEMENT
31 AUGUST 1972
LOWER COLUMBIA RIVER BANK PROTECTION PROJECT,
OREGON AND WASHINGTON
U. S. ARMY ENGINEER DISTRICT PORTLANL,OREGON STATEMENT OF FINDINGS LOWER COLUMBIA RIVER BANK PROTECTION PROJECT
1. I have reviewed and evaluated the data and information pertaining to the Lower Columbia River Bank Protection Project. The principle elements considered in this review include: engineering feasibility; socio-economic factors; and environmental impacts, all of which have been evaluated in
light of the project purpose.
2. The purpose of the Lower Columbia River Bank Protection Project is I primarily to prevent breaching of the many levees which protect valuable \ agriculture, industrial, and residential areas in the flood plain of Lowerl Columbia River. Filled or other valuable unleveed lands also may require I bank protection. Authority for the project is provided by Public Law 516.
3. I find that the proposed action is based on thorough analysis and -- evaluation of various practicable alternative courses of action for \ achieving the above objectives. It is anticipated that most bank \ protection works will consist of stone revetment. Alternatives include \ pile dikes, deposition of dredged sand, and set-back levees. The several, available alternatives will be fully considered at each site where bank protection appears to be needed. Continuing efforts will be made to minimize adverse effects of the proposed actions. I find that the proposed action is consonant with national policy, statutes, and administrative directives; and that on balance the total public interest should best be served by the implementation of the proposed action. X have reviewed the Statement or Facts and concur with the recommendations of the District Engineer.
DIVISION ENGINEER. / DATE
DIRECTOR OF CIVIL WORKS DATE FINAL
ENVIRONMENTAL STATEMENT
LOWER COLUMBIA RIVER BANK PROTECTION PROJECT
Prepared by U.S. ARMY ENGINEER DISTRICT, PORTLAND, OREGON Lower Columbia River Bank Protection Project, Oregon and Washington
( ) Draft ( X ) Final Environmental Statement
Responsible Office; U.S. Army Engineer District, Portland, Oregon
1. Name of Action; (X) Administrative ( ) Legislative
2. Description of Action; Construct bank protection works along channels in the flood plain of the Columbia River. Most of the works to be construct ed under project authorization will be revetments of dumped stone protecting leveed areas. Revetment locations to be constructed in FY 1972 and FY 1973 include Lower Fisher, Burke Slough, Santosh, Hudson-Rowell, Honeyman, Reasoner, Riggs, and Lawton Creek locations. The areas protected by these proposed works include lands used for livestock husbandry and row crops, as well as industrial sites, rural residences, and a portion of one city.
,3. a. Environmental Impacts; Destruction of small sections of natural shoreline providing fish and wildlife habitat and scenic values in an area which has already been extensively altered by man; potential effects on land use in protected areas; excavation of fill materials; protection of valuable agricultural lands, industrial sites, and residences from flood damages resulting from breaching of levees; prevention of land loss through bank erosion.
b. Adverse environmental effects; Loss of shoreline habitat for fish and wildlife; loss of scenic values of vegetated shoreline.
4. Alternatives: Vegetative bank protection; pile dikes; dumping of dredged spoils along the eroding banks; construction of new levees inland from eroding banks; no action.
5. Comments received:
Federal Environmental Protection Agency Department of Transportation Department of the Interior Department of Agriculture Department of Commerce
State Washington Department of Ecology Washington Parks and Recreation Washington Department of Fisheries Commission Washington Department of Game State of Oregon Office of the Governor Washington Department of Highways Oregon Highway Division Local Cowlitz-Wahkiakum Regional Planning City of Washougal, Washington Commission Port of Portland, Oregon Cowlitz County, Washington Board of Commissioners Clark County, Washington, Department of Public Works
Other Oregon Environmental Council hr. Howard M. Rondthaler 1. Project description (Description of the proposed action). The Lower Columbia River Bank Protection Project provides protective works to stabilize eroding banks along lower Columbia River. The primary objective of the project is to prevent breaching of the many levees which protect valuable agricultural, industrial, and residential areas in the flood plain of lower Columbia River. Filled or other valuable unleveed lands also may require bank protection. Bank erosion along this reach results principally from waves induced by wind and water craft, from rapid currents, or from tidal action. The area covered by the Lcwer Columbia River Bank Protection Project consists of the flood plain of the Columbia River along the last 125 miles before it enters the ocean at Astoria, Oregon. The flood plain is divided into two narrow strips, one in Oregon and one in Washington, and extends upstream along the tribu taries to the upper limit of backwater effect from the Columbia River.
The proposed action is the construction of revetments and other bank protection works along channels in the flood plain of the Columbia River. Construction of new levees and raising of existing levees are not authorized objectives of the project. Construction of approximately 123,800 linear feet of bank protection works at 66 locations along both banks of the Columbia River downstream from Washougal, Washington, about river mile 125, was recommended in 1950 in House Document 531, 81st Congress, Second Session. Protection of those 66 areas was later authorized by the Flood Control Act approved 17 May 1950 (Public Law 516, 81st Congress, Second Session). Funding for the Project began in FY 1958. Subsequent investiga tions made in 1958 revealed a change to 96 active erosion areas; of that total 61, a total length of 133,680 linear feet, were deemed critical and protective works were believed to be economically justifiable in view of the damages which would result from a levee failure caused by erosion of the levee foundation. To provide for the changing needs as erosion areas become critical during the life of the Project, detailed investigations are made, plans developed, and justifications determined for bank protection works for each leveed area or for each location where bank stabilization is needed. Appropriations for the Project have averaged $402,090 per year since initial construction funds were allotted in FY 1961, These appropriations have permitted the Corps to proceed with the authorized protective works in a manner consistent with the capability of the Portland District, the relatively short construction season, the availability of local sponsorship, and the availability of local contractors experienced in bank protection work. Through FY 1971, appropriations totaling $4,423,463 have been made for the project, and 81,705 linear feet of dumped-stone revetments and 651 linear feet of pile dikes have been constructed at 42 locations at an average cost of about $54 per linear foot. The land areas occupied by revetments already constructed under the lower Columbia bank protection project amount to approximately 75 acres. Approximately 100 more acres will be used during the remaining project. Thus, the total land covered by revetments already constructed or proposed for construction under pro ject authorization would be about 175 acres, or 0.1 percent of the total project area. These protective works prevent the breaching of levees of 14 drainage districts, diking districts, and diking improvement districts, and the erosion of two land areas on which are located highly developed industrial facilities. The total leveed area protected by revetments is 46,348 acres. Existing levees will provide flood protection to this area only if some form of bank protection is provided, since breaching of a levee at a single point may eliminate all the flood protection whf.ch that levee had provided.
The existing levees, which were constructed many years ago by private interests, have been raised and improved by the Federal Government under the authority of the Flood Control Act approved 22 June 1936. Under that levee improvement authorization, a total of 37.3 miles of hand-placed and dumped-stone revetments have been placed, mostly during the period from 1938-1944. These revetments were placed along the river banks and levees to protect the levees from erosion and eventual breaching. Most of these revetments are still providing the protection for which they were designed. Areas revetted under the Flood Control Acts on lower Columbia River thus total approximately 60 miles, or very roughly ten percent of the total shoreline. Bank protection works completed in FY 72 were: Gnat Creek location (2,080 linear feet) in Clatsop County Diking District No. 7, Oregon; and Gilson location (1,565 linear feet) in Cowlitz County Consolidated Diking Improvement District No. 2, VJashington. In FY 1973 it is planned to con struct Burke Slough location (5,550 linear feet) in Cowlitz County Consolidated Diking Improvement District No. 2, Washington; Lower Fisher location (3,500 linear feet) in Cowlitz County Consolidated Diking Improve ment District No. 15, Washington; Lawton Creek location (300 linear feet) in Washougal area, Washington; and Santosh location (1,597 linear feet) and Hudson-Rowell location (4,001 linear feet) in Scappoose Drainage District, Oregon. Protective works planned for construction in FY 1974 or thereafter include Honeyman (2,800 linear feet) and Reasoner (1,600 linear feet) locations in Scappoose Drainage District; and Riggs Location (400 linear feet) in the Washougal area. The Lower Fisher, Burk Slough, Santosh, Hudson-Rowell, Honeyman, Reasoner, Riggs, and Lawton Creek loca tions are designated as locations one to eight, respectively, on the inclosed map. Existing conditions at several of these locations are indicated in Photos 1 through 8.
The Hudson-Rowell, Honeyman, and Reasoner locations are on Multnomah Channel at approximately river mile 92, where increasing boat and barge traffic in the channel is causing bank erosion. The Burke Slough location is near river mile 82. Here the bank is being eroded by small-boat traffic and by currents from the Columbia which enter the slough during freshets. Lower Fisher location is on Fisher Island Channel at approximately river mile 60, where river currents have steepened the underwater bank, causing sloughing of the berm riverward of the levee. Santosh location is on Santosh Slough, which enters Multnomah Channel at approximately river mile 91. Barges moving to and from a gravel excavation further up the slough cause waves which have eroded the bank at this location. Other revetment locations are on the ship channel where swift currents and waves caused by many large ships have eroded the bank to great depth, requiring heavy riprap stone and underwater protective blankets. In the wide estuary at the mouth, pile dikes and armour stone revetments have been required to protect the banks against swift tidal currents and storm vsves. Based on experience gained during the first ten years of the construc tion phase of the Project, more than 90 percent of the remaining authorized revetments will be constructed of dumped stone and will be located to pro vide protection of leveed areas. Tansy Point location, where pile dikes were constructed, is the only site where bank protection other than dumped- stone revetment has been provided under the Project. Bank protection has been confined to leveed areas except for the Tansy Point location and two locations in the Kalama area where industrial, facilities were endangered by bank erosion. The proposed bank protection consists of stone riprap dumped on a bank which has previously been sloped to the proper grade. The riprap extends 10 to 15 feet below normal water levels, usually to a toe trench excavated in the river bottom. The riprap slopes upward 30 to 50 feet above the normal water level along the bank or levee to an elevation deter mined to be sufficient to eliminate most erosion damage.
On-site construction activities involved in placing the revetment include clearing the work area, excavating and filling the bank to provide the required slope, and placing bedding materials and quarried stone riprap. Off-site activities include disposing of excavated materials, obtaining the riprap stone from nearby quarries, and digging the bedding and embank ment material from borrow pits. Current practice calls for contractors to obtain stone, bedding, and embankment material from any convenient source, subject to restrictions on the quality and grade of the material obtained. Bedding materials used include gravel, sand, and crushed rock from quarries. Soils in the project area are not used as bedding for revetments because they are insufficiently penmeable to water and tend to be washed out. Ordinarily these materials are obtained from commercial sources^ as suitable new quarries or borrow areas are not readily available in or near the project area. More than four-fifths of the quarried material used in the Bank Protection Project has come from previously-existing quarries. Since 1967, one new quarry has been opened to provide revetment stone for the Lower Columbia River Bank Protection Project. This quarry is 2-3 acres in area. If a contractor chooses to open new borrow areas rather than use commercial sources, contract specifications require him to restore the borrow area on completion of construction work. On-site and off-site construction activities are subject to contract restrictions requiring environmental protection. These restrictions are subject to/} change and may be modified in response to the unique conditions existing at each site where bank protection works are proposed. Generally, however, they include the following:
(a) Construction activities will be confined to the areas defined by plans and specifications.
(b) Trees, shrubs and other landscape features, except those marked for clearing, will be protected from defacement during construction. Damaged landscape features will be restored as nearly as possible^ to original conditions.
(c) All signs of construction will be obliterated and the construction area restored to near natural conditions.
(d) Items of possible historical or archaeological interest will be left undisturbed and will be reported to the Corps.
(e) All applicable laws concerning water pollution will be complied with. The Contractor will demonstrate his ability to contain any accidental spills.
(f) Disposal of waste materials will be restricted to approved areas.
Stone revetments typically become covered with silt deposited during high flows. Grass, vines, willows, cottonwoods, and other vegetation may grow on the revetment. The larger woody plants are removed periodically because they may weaken the revetment and interfere with inspection. Cutting, burning, and spraying with herbicides are typical removal methods. All such routine maintenance is conducted by local project sponsors. Revegetation of revetment work areas ordinarily has not been attempted in the past except where grass seeding or sodding has been needed to prevent erosion. Beginning with 1972 construction, each revetment site will be considered for revegetation to restore scenic value and wildlife habitat. Planting of woody vegetation must be restricted to the shoulder at the top of the revetment. Revegetation will be carried out under the direction of landscape architects and will be subject to the approval of the property owner.
Local participation is a prerequisite to provision of bank protection. The nature and degree of participation required is established by the Flood Control Acts of 1936 and 1950. Levees in the Columbia flood plain are maintained by local diking or drainage districts. In order to obtain bank protection for their levees, a local district must agree to provide rights-of-way for the revetment^ to assume responsibility for any damages resulting from the bank protection work, to maintain the revetment, and to make any highway, highway bridge, or utility alterations. The total width of right-of-way required for construction and maintenance of the revetment usually is less than 100 feet.
The local areas to be protected in FY 72 and FY 73 consist mostly of improved agricultural land used for raising dairy and beef cattle, silage crops, berries, and vegetables. Portions of the cities of Woodland and Washougal, Washington, are within levees of Cowlitz County Diking Improve ment District Number 2 and the Washougal Area, respectively. Scappoose Drainage District and Cowlitz County Diking Improvement District No. 15 protect suburban residences of persons employed in Portland, Oregon, and Longview, Washington, respectively. The Longview and Washougal areas are expanding as a result of industrialization, so that the drainage districts in those areas probably will include less agricultural land and more suburban residences, roads, and services in the future. The Woodland area is expected to grow slowly in population. Population in the Scappoose District is expected to increase several-fold during the 50-year economic life of the bank protection works as the area becomes increasingly suburban in character.
The current benefit-to-cost ratio as of January 1972 for the entire Lower Columbia River Bank Protection Proje- t is estimated at 2.0 (annual benefit = $1,227,000; annual cost ■ $607,90^) at an annual interest rate of 2.5 percent, or 1.3 (annual benefit « $1,205,000; annual cost = $912,900) at an interest rate of 5.4 percent. These ratios assume 1971 prices and a 50-year economic life for each bank protection work. Benefits include reduction in flood damages, increased agricultural land use, and improved drainage. Other claimed benefits include reduction in cost of repairing residential and commercial properties, and reduced losses due to interruption of industrial processes. The estimated benefit-to-cost ratio for all revetment projects protecting the Scappoose District is approximately 5. The ratio for projects in Cowlit?; District No. 2, including the Burke Slough location, is estimated at about 24. Ratios for the Washougal Area locations and Lower Fisher location are estimated to be 2.1 and 1.4, respectively. 2. Environmental setting without the project. The Columbia River forms an important avenue for water-borne commerce, and the adjoining lands are traversed by main rail and highway routes which serve the inland areas. Located as it is along such a thoroughfare, the area contains several centers of population, and agricultural lands have been brought into production to satisfy the needs of that population.
From Bonneville Dam (river mile 145) to thie sea the slope of the Columbia River is very flat and subject to tidal action. The flood plain varies between two and six miles in width along most of the distance from the Willamette River to the mouth. The river has many islands, side channels, and sloughs. On the flood plain, levees have been built to protect the low lands from the annual flood which occurs in May, June,and July. The flood plain area has been estimated at approximately 170,000 acres. In that area, 49 flood control districts have provided varying degrees of flood protection for about 96,000 acres. Inside the protected areas there are about 12,000 acres used fo” urban and industrial purposes and 80,000 acres use for cropland and improved pasture. Some of the un protected areas consist of undeveloped pasture and land covered by dense brush and small trees.
The climate along the lower Columbia River is characterized by mild, wet winters and warm, dry summers. With the exception of short periods when continental air masses prevail, maritime air masses dominate the area throughout the year. The region is subject to frequent winter storms during the period from November through March. Because of maritime influences the annual range of temperatures is comparatively narrow. The major portion of the Columbia River runoff occurs during the snowmelt period May through July. Peak flows due to snowmelt come in June. Since the completion of Bonneville Dam in the 1930's, a series of power and storage tiflmn have been constructed on the Columbia River upstream from the project area. Since 1960, there has been a large increase in installed storage capacity upstream. That storage is being used to regulate flows on the lower river. Regulation tends to increase the annual duration of bankfull flows, with a resulting increase in bank erosion. Currently, peak flows persist from 30 to 60 days and range from 20 to 40 feet above low water at river mile 125. Downstream that range in stage decreases, and from river mile 30 to the ocean, flood flows have a relatively small effect on river stages. Conversely, the daily tidal range during low water periods ranges from 1 to 2 feet at Bonneville Dam to 7 to 9 feet at Astoria.
Major population centers, excluding Portland, which is on the Willamette River several miles upstream from the Columbia River, are Vancouver, Kelso- Longview, and Camas-Washougal, Washington; and St. Helens, Rainier, and Astoria in Oregon. The cities of Kelso and Longview are protected by levees while the others are located generally above flood levels.
Timber resources in the region adjoining the project area support large, integrated timber-processing industries in the Kelso-Longview, Camas- Washougal, and Vancouver areas in Washington and the St. Helens area in Oregon. Other industries are food processing, aluminum refining and manufacturing, and services. Lar^? industrial expansion along the flood plain is likely in the near future. Because of topography and need to locate industries near navigable waters, development is expected to be concentrated along the river downstream from Columbia River mile 125.
The geologic history of the lower Columbia River includes a tremendous glacial flood which scoured out the valley to great depths. Raising of the ocean level following the last glacial period produced a drowned valley that subsequently has been filled with stratified sand, silt, and clay. The low-density sand and silt and soft clays that make up the present river banks are easily eroded by currents, tidal action, and waves generated by wind and water-borne traffic.
The alluvial material forming the flood plain has been used for raising crops and grazing for many years. In the early 1900's, it was realized that use of the flood plain for any agricultural activity other than intermittent grazing would require levees to protect the land from annual floods. Most of the levees and other flood protective facilities in the area were constructed prior to 1925. Within the protected areas, farming, of varying degrees of intensity, has developed. At present, most of the farms are relatively small. Many are operated as part_time farms, the owner or operator working in the lumber or fishing industry. As a result of the farming activities, most of the land in the leveed areas has been cleared of trees and brush. The brushy areas inside the levees usually are located along the sloughs or ditches that drain the farmland. Land in the flood plain and outside the levee protection has not been developed extensively. Cleared areas are being used for intermittent pasture, but much of the low land is covered with small trees and brush.
Just downstream from the Portland-Vancouver area there are two developed wildlife areas, the Sauvie Island Game Management Area in Oregon and the Ridgefield National Wildlife Refuge in Washington. These areas provide a wintering area for migratory waterfowl and public hunting opportunity for sportsmen. The wildlife areas are also used extensively for bird-watching, nature studies by local school groups, fishing, and general outdoor recrea tion. Substantial portions of both areas are protected by levees. In the leveed portions, pumps are used to control water levels to provide maximum use of the area by waterfowl, and to deliver water to lowland lakes and sloughs which are planted to wildlife food crops. The pumping program on Sauvie Island is an important factor in manipulating bird use and increasing hunter activity on the management area during the early part of the wildfowl hunting season.
A third wildlife refuge in the lower Columbia, the Lewis and Clark National Wildlife Refuge, has been proposed by the U.S. Bureau of Sport Fisheries and Wildlife. This refuge would include most of the low-lying
islands between river miles 20 and 40. Two of the largest islands in this reach have levees and revetments, but most of the islands are flooded daily by the tide.
The flood plain of lower Columbia River is a wintering area for large numbers of migratory waterfowl and a nesting place for others. Some of the islands and river banks afford a good nesting habitat for ducks and small numbers of geese, and the river is used as a wintering area and resting place for ducks, geese, and whistling swans during periods of migration. Recent estimates indicate that wintering ducks have averaged in excess of 100,000 birds annually at the Sauvie Island Game Management Area alone, and in the area from Sauvie Island to Astoria, the daily average count is in excess of 120,000 birds. Other species utilizing the Columbia River and adjacent riparian habitat include wading birds, such as the blue heron, green heron, night heron, and bittern, rails, and egrets; and shore birds, such as the killdeer, snipe, sandpipers, dowitcher, yellow-legs, and avocets. Rare or endangered species nesting in the arsa are the osprey and northern bald eagle. Hawks, owls, songbirds, doves, and bandtailed pigeons also inhabit the riparian habitat.
The project area supports many small furbearing animals. The Oregon State Game Commission has reported a population of about 10,000 beavers, muskrats, and otters using the streamside habitat of lower Columbia River. Mink, raccoon, and nutria also are found here, as are squirrels, rabbits, foxes, and various reptiles and amphibians. Elk and bear are uncommon on the flood plain. Black-tailed deer are common, but the Columbian white-tailed deer is present in only small numbers and in a restricted range. The Bureau of Sport Fisheries and Wildlife has a project underway
to buy and lease land at about river mile .35, between Cathlamet and Skamokawa, Washington, to establish the Columbian White-tailed Deer Refuge. This species is now considered endangered.
The principal species of fish found in the main channel of the lower Columbia River are four species of Pacific Salmon (chinook, sockeye, coho, and chum), steelhead trout, cutthroat trout, American shad, white sturgeon, lamprey, and eulachon (Columbia River smelt), all of which are anadromous. Because of the number of species of fish involved and the differences in their migration patterns, the total number of fish in the river at any one time varies from month to month, and from year to year. The four varieties of salmon and the steelhead trout are the most important for commercial and sport fishing. Other game fishes found in the sloughs and backwaters of lower Columbia River include largemouth bass, white crappie, bluegill, black bullhead, brown bullhead, yellow perch, channel catfish, and flounder. Carp are abundant in these backwaters and are fished commercially in Vancouver Lake.
Tie flood plain of lower Columbia River is rich in relics of a highly developed Indian society which existed in the area until the early Nineteenth Century. Many village sites have been located, but the area has not been subject to thorough archaeological study.
The National Register of Historic Places lists two sites on or near the shoreline of lower Columbia River. These are: The Fort Vancouver National Historic Site in Clark County, Washington; and Chinook Point, in Pacific County, Washington. In addition, the Bybee-Howell Historic House on Sauvie Island in Multnomah County, Oregon, has been approved for nomination to the National Register. A fourth historic site in the Project area is the Knappa vicinity, in Clatsop County, Oregon. It is believed to be the setting of an Indian village visited by members of the Lewis and Clark Expedition in 1805. 3. The environmental impact of the proposed action. Continued provision of bank protection will permit existing agricultural, residential, and industrial uses of leveed portions of the flood plain continue and to increase. Existing levees protect several cities and towns, the Portland International Airport, and large industrial facilities, in addition to suburban residential and agricultural uses. Without protection from floods, these improvements would have to be relocated or abandoned. In a typical drainage district (Scappoose), flood protection maintains land values at approximately twice the levels possible without levees.
While bank erosion is extensive along unleveed shorelines of lower Columbia River, it is unlikely that more than a few bank protection works will be constructed in such areas under the presently authorized Project. Benefit-to-cost ratios for proposed bank protection works in unleveed areas are generally favorable only when extremely valuable properties, such as industrial facilities, are to be protected.
Short-term effects of revetment construction include increased turbid ity in water adjacent to the work area, and dust and noise resulting from use of construction machinery at quarry and levee sites.
The relatively small quantities of material derived from clearing and excavation, mostly sandy silt or clay, are used to fill depressions and improve drainage of farming areas in or around the protected area. Such disposal areas are leveled and seeded. Habitat suitable for waterfowl and other marsh- or shore-dwelling wildlife often is destroyed by this practice.
In most areas, trees and brush must be cleared when revetments are placed. Clearing is necessary to prepare the bank slope and to provide access for construction and maintenance. It is limited to the length of the revetment. Cleared areas on the bank above the revetment are seeded or planted according to contract specifications, so that the only permanent loss of vegetation is in the area of the revetment. Typically, revetments are constructed at sites of active erosion. Revetments thus may replace cut or slumping earth banks plus vegetation further up the bank which will be lost eventually if erosion continues. Revetments often must be extended up- and downstream from the eroding reach into areas of stable banks, in order to prevent washing out at either end. Stable, vegetated banks are replaced by revetments in these cases.
The increased siltation during revetment construction and the permanent loss of overhanging and emergent vegetation at the project site could have local effects on fish and other aquatic animals. Siltation resulting from revetment construction can kill fish eggs, fry, and benthic invertebrates. Juvenile salmonids and other small fishes inhabitat inshore areas where vegetation protects them from predators and swift currents. Numbers of these fishes are probably reduced in revetted areas. Revetment construction could interfere with fish migration, although revetments are not usually constructed during the spring and early summer period of peak emigration
of juvenile salmonids.
Periodic clearing of vegetation from the revetment face by project sponsors may cause local adverse impacts. All methods of removing vegeta tion, including cutting, burning, and application of herbicides, can cause local deterioration of air or water quality.
The abundant wildfowl and fish in the project area furnish a basis for much outdoor recreation throughout the year. A recent survey estimated more than 200,000 man-days of recreational use from April 1966 to March 1967 on the Sauvie Island Game Management area alone. It is not believed that theproject has had or will have any significant adverse effects on such use of the lower Columbia flood plain. The total area directly affected by revetments in place and proposed under the project is about 175 acres. The loss of that area of riverbank should have little effect on the populations of wildfowl and small mammals inhabitating the flood plains. Revetments have relatively little effect on access by hunters, fishermen, sight-seers, picnickers, and other recreationists. The revet ment slope often affords safer proximity and access than does the bank it replaces. Revetted banks are generally considered less pleasing in appearance than natural banks.
It is unlikely that any sites of historic interest will be affected by the Project. In contrast, it is quite probable that items of archaeological interest will be unearthed in construction of bank protection works. The construction contractor is required by contract to notify the Corps project officer when artifacts are found ip »u p w w <^uiw.b ^ The Corps is in turn required by law to notify the National Park Service. The NPS is responsible for all salvage activities. 4. Any adverse environmental effects which cannot be avoided should the proposal be Implemented.
The clearing and excavating involved in construction of bank revetments would disturb the habitat of wildfowl and small mammals. The areas covered with dumped stone are permanently lost as habitat for animals requiring brush or tree cover unless plant cover could be cultivated which would provide suitable habitat while permitting maintenance of the revetment. Suitability of the revetted area for fish is permanently affected by removal of vegetation. Local silting and turbidity occur during construction, but this will be scheduled so as to minimize the effects on migrating fish.
Some borrow areas for stone, gravel bedding, and embankment materials may be newly developed for a specific revetment. In these cases, temporary loss of wildlife habitat and of aesthetic quality may be significant, but restorative measures are required by contract provisions. However, most borrow areas are existing operations used for general construction in the area. Impacts from additional use of existing quarries are probably minor.
Disposal of material resulting from construction can have adverse effects on the regional environment. Excavated materials from the riverbanks and toe trenches generally are impracticable or unsuitable for use as embank ment material. This excavated material usually is disposed of close to the construction area. Material from the toe trench frequently is replaced after the riprap is placed and accepted. This procedure temporarily increases turbidity and silt pollution, but helps to reestablish the bank line above and below water level. Excavated material usually is placed in disposal areas above normal high water if outside the protected area, or in depressions if inside the levees. Disposal areas inside the levees ordinarily are low, poorly drained sections of farmed fields or blind sloughs not in the drainage patterns of the district. Filling would improve such areas for farming purposes but would eliminate them for use by waterfowl. In the past, brush and trees from clearing operations have been disposed of by burning. Current specifications for construction require that contractors dispose of combustible material in accordance with current Federal, state, and county regulations, especially as regards air pollution. Currently most of the work on the project is in areas where open burning is not allowed. Trees and brush usually are chipped and buried in disposal areas. Occasionally, trees or chips are sold to pulp manufacturers. 5. Alternatives to the proposed action. (a) The alternative of no action must be considered to end with the eventual loss of existing flood protection. At every location where bank protection has been provided by the Project, surveys prior to construction had indicated that erosion of the river bank would endanger a levee or industrial facility within a 5- or 10-year period. Recommendation by the Corps of bank protection works at a given site is an engineering judgment based on topographic surveys, soil studies, visual observations, comparison of aerial photographs over a series of years, and experience with similar areas along the lower Columbia River. Breaching of a levee would leave the protected area vulnerable to annual floods. Such flooding would result in damage to improvements such as farm buildings, residences, roads, and industrial plants. Along the downstream section of the project area, inunda tion of land by frequent high tides would preclude its use for intensive farming.
Loss of levee protection and resultant flooding would have considerable effect on social well-being rnd economic productivity in the Project area. Recent studies of several leveed areas have indicated that the value of agricultural lands would be reduced by about 40 percent in a drainage district where the land elevation is relatively high and affected primarily by annual floods, while the value would be reduced by 90 percent in a dis trict where the land would be subject to frequent inundation by high tides. Periodic flooding would make some presently populated areas uninhabitable and would greatly reduce the desirability of other areas.
(b) The Bank Protection Project could be supplemented or replaced by local efforts to maintain existing levels of flood protection along lower Columbia River. The inadequacy of flood control measures taken by local governments and districts with limited tax bases and jurisdictions was one factor leading to the flood control legislation enacted by Congress in 1936. The presumption of a national interest in maintaining some level of flood protection underlies the Bank Protection Project. (c) Subsidized flood insurance could serve as a complement to bank protection, which is itself a public subsidy provided to residents of the Columbia flood plain. A combined program of flood insurance and flood plain zoning could provide subsidized financial protection to present users while discouraging uneconomic encroachment on the flood plain. These objectives could be met by a program incorporating the following elements: subsidized flood insurance for existing users of the flood plain; insurance at unsubsidized rates for all new construction; compulsory or semi-compulsory purchase of flood insurance for all flood plain users; and compulsory local zoning of the flood plain. The National Flood Insurance Program, administered by the Department of Housing and Urban Development, has most of these features. Insurance and zoning usually would complement all measures such as bank protection, flood proofing, and flood warning systems, since these all would tend to reduce expected damages and insurance rates. An insurance and zoning program would be an alternative to bank protection only when it reduces expected flood damages in a leveed area to the point where further investments in bank protection are not economically justified.
(d) Bank erosion at some sites on lower Columbia River is caused by wakes of vessels. Speed limits for vessels passing erosion sites would tend to alleviate erosion. No speed limits are now enforced on Columbia River. The two agencies having jurisdiction over navigation are the Coast Guard and Corps of Engineers. The Corps has authority to impose vessel speed limits when Federal property may be damaged or when flood-control structures are endangered during periods of flooding or high water. The policy of the Corps has been to strengthen levees with protective works so that they can withstand waves generated by vessels, rather than to inter fere with navigation by imposing speed limits. Navigation interests are opposed to limits on vessel speed for economic reasons, and their opposition makes this alternative unlikely of adoption.
(e) Protection of the riverbanks along the lower Columbia by provision of vegetative cover has not been successful. Most of the bank areas above normal high water are covered with wild grasses, small brush, and trees. However, below the normal high water level, the relatively long duration
of high flows limits or kills vegetative cover in exposed locations and erosion begins promptly on the unprotected bank before new cover can became established.
(f) Structural alternatives that could be considered in lieu of dumped-stone revetments are pile dikes, set-back levees and placing of dredged spoils along eroding banks. All those alternatives have been used along the river. The advantages and disadvantages of those alternatives are outlined briefly as follows.
Pile dikes, extending from the bank 100-200 feet into the channel approximately normal to the direction of flow, provide effective protection for banks eroded by river currents. Three dikes were installed at Tansy Point location in the Columbia River estuary where swift tidal currents were scouring the river bottom and wind-generated waves were eroding a bank above the water level. At that location, as well as at most locations where pile dikes can be used effectively, a dumped-stone revetment is required between the pile dikes, since wave caused erosion is not prevented by the dikes. Cost of this type of installation is far greater than the cost of revetment alone. Adverse effects on the environment would be similar to those for the usual dumped-stone revetment. Some success has been achieved by placing dredged sand on the bank between the pile dikes. The protection provided has been fairly satisfactory, but the environmental effects are similar to those described in the following paragraphs for bank protection with dredged sand. The Federal cost of installing pile dikes is about $175 per linear foot.
Sand dredged from the ship channel has been placed along many miles of river bank of the main channel of the lower Columbia River. That saad has come from dredging operations required to deepen, or to maintain autho rized depth in, the ship channel. The sand has been placed in locations convenient to the dredging operations, and only incidentally has it been used to protect eroding banks. However, this placement of sand along the river bank has prevented much erosion damage and formed many beaches which are recreation areas. Bank protection by this method may be economically feasible when the dredging is required for channel maintenance and the cost is chargeable to that function. If sand were dredged solely to provide bank protection the estimated cost per foot is approximately twice that of stone revetment, assuming an optimistic 10-year life for the sand protection, a 50-year life for dumped-stone revetment, and the Federal cost of dredging. For this reason, dredging solely to provide bank protection has never been attempted in Columbia River. Further, sand can be.used only along wide and shallow sections of the river as the flat slope (1 vertical on 8 or 10 horizontal) requires filling of large areas to provide protection. Sand will continue to be available in large quantities from maintenance dredging operations.
The effects of any of the above structural alternatives on the environ ment of the lower Columbia River flood plain are believed to be as great as for the commonly used dumped-stone protection. Sand protection provides wide beach areas for recreation, but fills shallow channel areas and covers fish and wildlife habitat along the river. Use of pile dikes would require placement of stone or sand along the bank to protect from wave erosion and the installation of dikes could only increase environmental damage.
Set-back levees have been considered as alternatives to revetment construction. Such levees do not prevent bank erosion; rather, they provide levee protection by accepting additional land loss, moving the levee landward, and allowing the bank to erode. That method may be economically feasible on a temporary basis if the cost of land is low and no drainage facilities must be relocated from the old to the new levee. In most areas, the land inside the levee is used for farming or industrial purposes and to use it for another levee would reduce its economic productivity. Some productivity remains, since the levee and riverward berm can support grazing. Construction of a set-back levee requires a strip of land 200-300 feet wide. If the land is suitable for farming or bears residences or other improvements, the local drainage district ordinarily must purchase it for levee construction. This is beyond the financial means of many districts, and local interests are generally not willing to purchase or donate land for public recreation or wildlife habitat. For these reasons set-back levees are not often a practical alternative to revetment. Where land can be obtained, however, set-back levees can be constructed at costs which compare favorably with rock revetments. Set-back levees permit the shoreline to remain in a vegetated state, to the extent that vegetation can survive erosion of the bank. In areas having high existing or potential recreational and biological value, set-back levees would be especially appropriate. Because the recreational benefits of set-back levees accrue primarily to the public, purchase of the required strip of land by public agencies may be justified. Land purchase is not authorized by the Flood Control Act of 1950, and no state or Federal agencies have purchased lands for set-back levees to be constructed by Portland Army Engineer District. Increasing desirability of the Columbia River shoreline for recreational use may provide an incentive for such purchases in the future. Provision for land purchase would make set-back levees an attractive alternative to revetment, since the two techniques do not differ greatly in construction cost per linear foot.
In areas where a continuing erosion problem exists, it must be antici pated that the berm riverward of the set-back levee will eventually be lost through erosion. On the Sacramento River, California, this problem has been met by combining set-back levees with revetment along the shore of the berm. The result is a tree- and brush-covered berm, periodically inundated by high flows but protected from erosion at more typical river surface elevations. 6. The relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity. Human use of the flood plain of the lower Columbia is changing. Sub sistence hunting and trapping have declined, to be replaced by farming on much of the land area. The harvest of timber has been and continues to be a major activity in areas adjacent to the flood plain. The timber resources of the flood plain have not been restored as farming activities have taken over the cleared land. Timber processing is becoming increas ingly important. Fishing, both sport and commercial, has been a major activity since before settlement began in the region. With the increas ing population of metropolitan areas, industries have developed along the river and many of these are in leveed areas. The use of water and land areas for recreation is increasing with the expanding population.
Maintenance of existing levees through construction of protective works is necessary to maintain current uses and permit future uses of leveed areas, which total about 50 percent of the flood plain. Land use in some pro tected areas probably will continue to be largely agricultural. In other areas, use of protected land will probably change with time. An example is the Scappoose district, where bank protection will permit an expansion of the resident population and of industrial activities. Industrial expan sion probably will spread outward from present industrial centers: the Portland-Vancouver area, the Longview-Kelso area, the St. Helens area, and the Camas-Washougal area. In some areas, bank protection probably will be a factor in promoting industrial expansion.
Termination of construction of bank protection would have the long term effect of changing land presently available for agricultural use to flood plain covered with brush and trees, usable for intermittent pasture, hunting, fishing, and trapping. As the land in leveed areas constitutes a substantial percent of the flat land suitable for intensive farming in the Columbia River flood plain, the loss of flood protection for lands would have a large impact on the economy of this area. Flood protection provided by levees has permitted extensive residential, industrial, and commercial development of the flood plain of lower Columbia River. While the wisdom of unlimited flood plain development is being increasingly questioned, there is no question that loss of flood protection through failure to maintain levees would have disastrous consequences for present users of the Columbia flood plain.
Revetment of additional portions of the shoreline of the lower Columbia will not materially reduce the potential of this area for maintenance of waterfowl populations in the two large refuges. Small areas of wildfowl habitat will be destroyed by filling low-lying areas with excavated material.
Those revetments existing and authorized under the Bank Protection Project involve only a small fraction of the total shoreline of the lower Columbia. However, the total shoreline area altered by all revetments protecting levees, highways, and railroads, and by spoil dumps and land fills, is considerable and increasing. The construction of each additional revetment subtracts from the total of natural shoreline providing fish and wildlife habitat and scenic value. With continued industrialization and development of the shoreline of lower Columbia River, unmodified natural shoreline is becoming increasingly scarce and valuable. In order to appraise the adverse long term effects of any proposed construction on the shore of lower Columbia River, one must view that construction as an increment in a very extensive and accelerating process of shoreline development. 7. Any irreversible and irretrievable commitments of resources which would be Involved In the proposed action should it be implemented. Irreversible commitments of resources will be confined to the area of the revetment, the disposal areas, and the borrow areas. Wildlife habitat will be destroyed in the area occupied by the revetment. This condition will exist as long as the revetments were in place unless vegeta tive cover were permitted to grow. Material from excavation will be used to fill small areas (usually \ acre or less) of low-lying land which will eliminate those areas as habitat for some kinds of wildlife, particularly waterfowl. Revegetation of disposal areas, levee shoulders, haul roads, and work areas with selected plant species will reduce the effects of revetment construction on local wildlife. Excavation of new quarries and borrow pits, or expansion of existing ones, may cause long lasting or permanent damage to scenic values. Careful excavation procedures combined with restorative measures will minimize this damage. 8. Coordination with other agencies.
Since its inception the lower Columbia River Bank protection project has been carried out in close cooperation with the many diking and drainage districts in the project area. Most of the revetment locations have been determined on the basis of a request by a local agency, which in turn supplies the items of local cooperation as required in the authorizing act. A total of 13 diking and drainage districts and three port authorities have provided local cooperation for the construction work at 42 locations.
No public hearings have been held concerning the presently authorized Project, since informal meetings with individual landowners and diking and drainage district officials have been considered to provide a sufficient measure of the wishes of local people.
This environmental statement is intended to provide an overview of the impacts of the Lower Columbia River Bank Protection Project in its entirety. A more detailed analysis is attempted for those bank protection works to be constructed in FY 1972 and FY 1973. It is anticipated that the environmental statement for this ongoing project will be updated at three-year intervals. While the updated statement will deal with those bank protection works chosen for in the upcoming three-year interval, such work at many sites of bank erosion cannot be planned sufficiently in advance of construction to be included in the environmental statement. Should these bank protection works present problems which are not covered in the environmental statement, the statement will be amended accordingly.
Construction of each bank protection work will be preceded by compliance with the Fish and Wildlife Coordination Act of 1958. The advice of state--- and Federal agencies responsible for fish and wildlife resources will be sought well in advance of construction. Construction of each work also will be preceded by coordination with agencies responsible for archeological and historical resources. These include the National Park Service, the Washington State Parks and Recrea tion Commission, and the Oregon Highway Department. COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT ENVIRONMENTAL PROTECTION AGENCY
(1) Comment: Does the need for construction of eight more revetments outweigh the adverse effects that will be imposed on the environment?
Response: Some form of bank protection is necessary if flood protection is to be maintained in leveed areas. Adverse effects of bank protection must be weighed against the very considerable consequences of loss of flood protection. The form which this bank protection must take, whether revetment or some alternative, will be determined for each erosion site on the bases of engineering feasibility as well as economic, legal, social, and environmental considerations.
(2) Comment: Pictures of the sites of erosion and diagrams of the proposed revetments should be furnished in the environmental statement.
Response: Pictures of most of the sites where construction of bank protection is proposed for FY 72 and FY 73 will be included in the Final Environmental Statement. Drawings of the revetments are not prepared until a few months before construction. While not available in the statement, they will be included in letters of coordination prepared for each site and sent to fish and wildlife agencies.
(3) Comment: What measures will be taken to minimize adverse effects
of construction?
Response: Obligations of the construction contractor to protect the landscape and resources of the project area are presented in the
Final Environmental Statement. (4) Comment: Effects of the project on land use in the Columbia flood plain and especially on the river shore should be discussed further.
Response: Discussion of effects of bank protection on land use is expanded in the Final Environmental Statement.
(5) comment; The loss due to revetment construction of aesthetic qualities of the shore and of wildlife habitat should be emphasized.
Response: Discussion of the desirable features of shoreline areas which are lost by revetment is expanded in the Final Environmental Statement. The Statement also includes pictures of sites where bank protection work is proposed in FY 72 and FY 73.
(6) Comment: Insufficient attention is given in the statement to the need for new borrow areas and their impacts.
Response: Discussion of quarry and borrow areas is expanded in the Final Statement.
(7) Comment; Construction should only take place during months when adverse impacts, particularly on migrating fishes, would be minimal.
Response: Construction of bank protection works on Columbia River is not normally possible during the spring and early summer period of high flows. Coordination with fish and wildlife agencies permits selection of the best available period for accomplishment of the work.
DEPARTMENT OF THE INTERIOR
(8) Comment: The statement should comment on effects of the project on historical values.
Response: The Final Statement Includes such comments. (9) Comment; It is not clear whether the statement is meant to cover the entire project, only the bank protection work to be done in FY 72 and FY 73, or some other fraction of the total project.
Response; The statement is intended to analyze impacts of the entire project with specific attention given to those revetments to be constructed in FY 72 and FY 73. Subsequent construction will be covered by updated impact statements and letters of coordination. The final environmental statement has been revised to clarify this point.
(10) Comment: Analysis of the impact of individual projects is inadequate, particularly as regards alternatives to the proposals.
Response: Discussion of bank protection works proposed for construction in the near future has been expanded in the Final Statement. Information on the feasibility of alternatives to revetment of specific bank erosion sites is generally not available. Pre-construction planning has been oriented toward revetment construction, with little detailed analysis of alternatives.
(11) Comment: The cumulative effect of river bank protection on fish and wildlife resources in lower Columbia River is not discussed in the statement.
Response: The problem of cumulative effects of bank protection and other modifications of the shoreline is noted in Section 6- of the Draft Statement. This problem is given greater attention in the Final Statement, but quantitative analysis is not possible given the information presently available.
(12) Comment: The possibility of revegetating the revetment surface should be discussed further. Response: Discussion has been expanded in the Final Statement to indicate that, while the revetment face is not planted, all other areas cleared or disturbed in the construction of the revetment, plus any excavated material disposed of, will be planted to restore natural vegeta tive cover unless the landowner is not agreeable.
(13) Comment: Environmental restraints on borrowing and quarrying have little significance in the project area unless they apply to private lands.
Response; Restraints imposed in contracts let by Portland Army Engineer District have limited application to commercial quarries and gravel pits, in that the contractor is encouraged to purchase materials from sources where environmental protection is provided. State laws, rather than Corps regulations, are the true force promoting such protection in commercial mining operations. If a contractor elects to open new quarry or borrow sites for construction of bank protection works, he is required to comply with all environmental provisions of the contract in the construc tion of the quarry or borrow material.
(14) Comment: A decision is needed by the Corps to revegetate areas denuded by project operations.
Response: Responsibilities of the construction contractor for protection of vegetation in project areas are summarized in the Final Environmental Statement. In response to several requests, the specifica tions for construction of bank protection in contracts let by the Portland Army Engineer District now provide for revegetation of protected banks.
(15) Comment: The discussion of benefit-to-cost ratios does not seem pertinent to the objective of an environmental impact statement. Response: The Office of the Chief of Engineers has directed that all environmental statements prepared for Corps projects include a benefit- to-cost ratio. While of limited value, the ratio permits one type of comparison of the proposed project with alternate uses of public funds.
(16) Comaent; A more detailed breakdown of land use is desirable.
Response: Detailed, up-to-date information on land use is
unavailable for most of the flood plain of lower Columbia River.
(17) Comment; Flood plain zoning should be considered as an alternative to additional flood protection.
Response: Flood plain zoning and other non structural alternatives to bank protection are considered in the Final Statement.
(18) Comment: Sauvie Island Game Management Area and Ridgefield National Wildlife Refuge are used extensively for bird-watching, nature studies by local school groups, fishing, and general outdoor recreation.
Response: This information is included in the Final Statement.
(19) Comment: Lists several errors and deletions in the discussion of fauna of lower Columbia River and its flood plain.
Response: The suggested changes are incorporated in the Final Statement.
(20) Comment: Siltation resulting from revetment construction can kill fish eggs, fry, and benthic animals.
Response: This information is included in the Final Statement. (21) Comment: Regulation of vessel speed should be considered as a means of slowing or preventing bank erosion.
Response: Discussion of speed regulation is included in Section 5 of the Final Statement.
(22) Comment: Growth of vegetation below the normal high water level of Columbia River is inhibited by high flows only in exposed areas.
Response: This information is incorporated in the Final Statement.
(23) Comment: Section 6 of the Draft Statement is primarily an attempt to justify the proposed plan of development.
Response: In the discussion of long-term productivity of the Columbia flood plain it is proposed that levee maintenance is economically and socially justifiable. Section 6 has been revised to more fully consider the environmental economic effects of the many existing and planned altera tions of the Columbia shoreline.
(24) Comment: There is still considerable hunting and some trapping
in the project area.
Response: This information is included in the Final statement.
DEPARTMENT OF THE INTERIOR - BUREAU OF MINES - WESTERN FIELD OPERATION CENTER
(25) Comment: Proper recognition is given in the draft environmental statement to impacts on mineral resources.
Response: None required. DEPARTMENT OF THE INTERIOR - GEOLOGICAL SURVEY
(26) Comment; We can foresee no adverse effects other than those noted to the hydrology of the project areas after the construction phase is complete.
Response; None required.
DEPARTMENT OF THE INTERIOR - BUREAU OF LAND MANAGEMENT
(27) Comment; The Bank Protection Project will not affect lands under BI2I jurisdiction.
Response; None required.
DEPARTMENT OF COMMERCE
(28) Comment; Regulation of vessel speed and releases of water from upstream dams should be considered as alternatives to bank protection.
Response: These alternatives are considered in the Final Statement.
(29) Comment: The freshwater fishes resident in sloughs and backwaters of Columbia River are vital only to the sport fisheries.
Response; This is true of most species, but a commercial fishery for carp has developed in a backwater slough and lake near Vancouver, Washington.
(30) Comment; Short-term effects of revetment construction will interfere with fish migration.
Response; This possibility is considered in the Final Statement. (31) Comment; The land rivervard of set-back levees could be used for agriculture during flood-free periods.
Response; This information is included in the Final Statement.
(32) Comment; Disposal of dredge materials in convenient locations often has an adverse effect on fish resources.
Response; This information in included in the Final Statement. *
DEPARTMENT OF COMMERCE - COLUMBIA FISHERIES PROGRAM OFFICE
(33) Comment; Set-back levees are an alternative to revetments that would preserve the vegetated shoreline and fish and wildlife values.
Response; The Final Statement indicates that set-back levees are technically practical and environmentally preferable alternatives to revet ments, but are not economically feasible in many cases.
DEPARTMENT OF TRANSPORTATION - THIRTEENTH COAST GUARD DISTRICT
(34) Comment; Construction of future revetments may cause some navigation aids to be temporarily relocated or discontinued, although the extent of such impacts cannot be determined from available information.
Response; Locations of future bank protection works cannot be accurately predicted.
U. S. DEPARTMENT OF TRANSPORTATION - FEDERAL HIGHWAY ADMINISTRATION
(35) Comment: The project would affect no Federally*aided highways adversely.
Response; None required. DEPARTMENT OF AGRICULTURE - SOIL CONSERVATION SERVICE (PORTLAND)
(36) Comment: We suggest that by the use of a soil cover over the top of the riprap, down to the high water line, and a vegetative cover a more pleasing installation would result.
Response: A program of planting vegetation on protected banks will be undertaken by Portland Army Engineer District, as indicated in the Final Environmental Statement.
DEPARTMENT OF AGRICULTURE - SOIL CONSERVATION SERVICE (SPOKANE)
(37) Comment: No comments are offered.
Response: None required.
STATE OF WASHINGTON - DEPARTMENT OF ECOLOGY
(38) Comment; Construction methods and scheduling should be planned to minimize adverse environmental impacts. The work area should be restored to a natural state, as far as possible.
Response: Contractual requirements for moderation of effects of construction and for restoration of the work area are summarized in tte
Final Statement.
STATE OF WASHINGTON - DEPARTMENT OF FISHERIES
(39) Comment: The Draft Statement does not point out that only a fraction of the Columbia shoreline is made up of sloping, vegetated banks.
The Environmental Statement should relate the total length of Project revet ments to the amount of this type of shoreline available along lower Columbia River, rather than to the total amount of shoreline. Response: We concur that this would be a more meaningful comparison, but we are not capable of such a detailed analysis of the Columbia shoreline at this time.
(40) Comment: There should be a distinction between the repair of existing levees and the construction of levees in previously undisturbed areas.
Response: The Lower Columbia River Bank Protection Project has not resulted in construction of any new levees in previously undisturbed areas.
C41) Comment: The Washington Department of Fisheries would support any study initiated by the Corps of Engineers to determine the extent to which the Columbia shoreline has been altered by man, possibly with the objective of determining a minimum elevation beyond which structures could not legally extend.
Response: A quantitative assessment of shoreline features of lower Columbia River will be prepared by Portland Army Engineer District in late 1972. The purpose of this study will be to aid in the evaluation of environmental impacts of maintenance dredging and spoil deposition. The study will require coordination with resource agencies of Oregon, Washington, and the Federal Government.
(42) Comment: We wish to review the EIS and specific details for each of' the eight projects proposed for FY 72 and FY 73.
Response: Details of construction plans and time schedules for each of the eight proposed revetments will be sent to interested fish and wildlife agencies at the earliest possible date prior to construction. STATE OF WASHINGTON - DEPARTMENT OF GAME
(43) Comment: A stronger commitment should be made to encouragement of vegetative growth.
Response: See response to comment #14 .
(44) Comment: Filling of sloughs and other areas notable as wildlife habitat with excavated material should be kept to a minimum.
Response: The choice of disposal areas on land is limited by the wishes of the landowner. Any filling of sloughs or other intertidal areas is subject to review by appropriate state and Federal agencies.
(45) Comment: Set-back levees should be given greater consideration.
Response: See response to comment # 33 .
STATE OF WASHINGTON - HIGHWAY COMMISSION
(46) Comment: The proposed bank protection work may affect highway projects on Puget Island and in the Vancouver area. Work in these areas should be coordinated with the District Highway Engineer in Vancouver.
Response: It Is not anticipated that bank protection works prpposed for the above areas will encroach on state highways.
STATE OF WASHINGTON - INTERAGENCY COMMITTEE FOR OUTDOOR RECREATION
(U7) Comment: We have no comment at this time.
Response: None required. STATE OF WASHINGTON - PARKS AND RECREATION COMMISSION
<^8 ) Comment: Properties on the Washington shore of Columbia River which are listed in the National Register of Historic Places are Fort Vancouver, and Chinook Point in Pacific County.
Response: This information is included in the Final Statement.
(49 ) Comnent: The Corps should notify the State Liason Officer when any archaeological material is located in the course of project construction in Washington.
Response: The Corps is required by law to inform the National Park Service of such finds. Additional coordination be carried out.
(50) Comment: The Corps should undertake an archaeological survey of lower Columbia River.
Response: At the present time, such a survey would not be an authorized Corps function. The possibility of an active role for the Corps in assessing natural resources is now under review.
STATE OF OREGON - FISH COMMISSION
(51) Comment: All environmental statements should include a section of recommended actions or project features preventing environmental degradation or enhancing environmental values within the project area.
Response: Sections 1 (project description) and 5 (alternatives) should permit evaluation of environmentally beneficial features of the project and comparison with alternatives. STATE OF OREGON - HIGHWAY DIVISION
(52) Comment: Hauling of revetment materials over state highways should be coordinated with the Highway Division to minimize problems in areas and time periods of heavy traffic.
Response: Cooperation with the highway division and state police is the responsibility of the contractor. The Corps of Engineers has no control over the movements of contractor«owned equipment on public roads.
(53) Comment: The Bybee-Howell Historic House and the site of an Indian village visited by Lewis and Clark are sites of historic interest in the Project area.
Response: This information is included in the Final Statement.
STATE OF OREGON - DEPARTMENT OF GEOLOGY AND MINERAL INDUSTRIES
(54) Comment: The Corps of Engineers should contact the 0DGM1 to insure that provisions of the Mined Land Reclamation Act are being complied with in quarrying and borrowing operations.
Response: Compliance with such state laws is the responsibility of the private contractors performing the work and the operators of quarries and gravel pits.
COWLITZ - WAHKIAKUM REGIONAL PLANNING COMMISSION
(55) Comment: The proposed action is necessary for protection of property.
Response: None required.
(56) Comment: Future coordination should be more timely. Response; Our intention is to provide ample time for coordination and review of all bank protection works (see Section 8 of the Final Statement).
COWLITZ COUNTY. WASHINGTON. BOARD OF COMMISSIONERS
(57) Comment: The Board supports the work as outlined.
Response: None requited.
CLARK COUNTY. WASHINGTON. DEPARTMENT OF PUBLIC WORKS
(58) Comment; A d vert environmental effects of the proposed action will be outweighed by benefits.
Response: None required.
PORT OF PORTLAND. OREGON
(59) Comment: Scotch broom should be considered as a vegetative cover for revetment.
Response: In selecting plant species for vegetative cover at bank protection sites, Corps landscape architects will consider local conditions and the probable uses of the vegetation, which may include erosion controlj aesthetic enhancement, food and shelter for wildlife, or various combinations of uses.
CITY OF WASHOUGAL. WASHINGTON
(60) Comment: We offer no objections to your plans in the Washougal area.
Response: None required. OREGON ENVIRONMENTAL COUNCIL
(61) Comment: We wish to obtain information on costs and benefits of the Bank Protection Project.
Response: The information was sent by letter.
OREGON ENVIRONMENTAL COUNCIL
(62) Comment: Planning for bank protection should include multi-county zoning commission public hearings to define what areas, if any, are not to be 'protected' but left in a natural state.
Response: The primary purpose of the Lower Columbia River Bank Protection Project is to prevent breaching of the levees. Lands which have been filled or otherwise altered may also be protected. Bank protection thus involves work to repair or protect an existing facility, rather than new construction. The existing levee or fill certainly affects land use by providing flood protection. Construction of a revetment to protect the levee or fill only has the effect of maintaining the existing flood pro tection. The effect of revetment on the shoreline is discussed in the Environmental Statement. Coordination with concerned state and Federal agencies, intended to minimize impacts on the shoreline and inshore areas, will be carried out for each bank protection work.
. Banlc protection works have not heretofore come into conflict with local zoning laws. With the present trend toward public management of shorelines, flood plains, and tidelands, an increased degree of public participation in planning bank protection works may be required in the future, possibly including public meetings.
(63) Comment; Bank protection encourages residential and industrial development, in turn providing justification for future bank protection. Response: Bank protection on lower Columbia River is authorized only for protection of existing lands and structures. Enhancement of property values through changes in land use and encouragement of new developments are not authorized objectives. In practice, land uses in some leveed areas are changing in the direction of increased development, in turn justifying further bank protection works. The E nvironmental Statement has been modified to reflect effects of bank protection on long-term changes in land use.
(64) Comment: Contracts for surface mining of riprap stone and bedding material on private lands should contain provisions for environmental protection of these areas.
Response: See response to Comment #13.
(65) Comment; Why can't bank protection work be done by local diking districts or private interests?
Response: The several Flood Contrdl Acts establish the responsi bility of the Corps of Engineers to perform bank protection work. Only further acts of Congress can release the Federal Government from this responsibility. Local interests are free to undertake bank protection works for their own benefits, although the financial capabilities of local groups do not generally permit them to construct adequate works.
MR. HOWARD RONDTHALER
(66) Comment: The Draft Statement fails to state the cost of revetment
per linear foot.
Response: The information is included in the Final Statement. Statements were sent to, but written comments have not been received from the following:
Hr. Rexford A. Resler Harold T. Nelson, Regional Director Regional Forester U.S. Bureau of Reclamation, Region 1 U.S. Forest Service, Region 6 Mr. Cliff Soderstrom Hr. Jim Kelly National Marine Fisheries Service Office Environmental Affairs Department of Commerce Mr. Fred Kindel Mr. Hans A. Krauss Sacramento Army Engineer District United States Department of Agriculture Soil Conservation Service
Mr. Clint Stockley Mr. Quentin Bowman Washington Department of Fisheries Oregon State Water Resources Board
Mr. Fred Martinson Mr. Gene Herb Washington Department of Game Oregon State Game Commission
Mr. Leonard Wilkerson Mr. Richard Trosper Oregon Division of State Lands Washington Department of Fisheries
Mr. Bill Roberts Washington Dept, of Natural Resources
Board of Commissioners Mayor Columbia County, Oregon Woodland, Washington
Mayor Hr. A. T. Beall, Manager Scappoose, Oregon Port of Camas-Washougal, Washington
Mr. Wallace Johnson, President Mr. Lynn R. Clapp, Engineer Scappoose Diking District,Oregon Cowlitz County Consolidated Diking Improvement District #2, Washington
Mr. Lynn R. Clapp, Engineer Cowlitz County Consolidated Diking Improvement District #15, Washington
Mr. Richard H. Bewersdorff Clatsop County Planning Commission Washington State Sportsmen's Council Inc. Dave Corkran, Chairman Columbia Group, Pacific Northwest Washington Environmental Council Chapter, Sierra Club
Steve Schell Association of Northwest Steelheaders Northwest Environmental Defense Center
Columbia R. Fishermen's Protective Union Mr. R. A. Osborn Engineering Department Burlington Northern
Anne W. Squier Mr. C. G. Topping Oregon Shores Conservation Coalition Shell Chemical
Mr. Jeff Nelson Mr. Bryan Johnson
Mr. Jim Kadera Mr. David Kechley Oregonian for Brock Evans Northwest Conservation Representative
General Construction Co. Mr. Mike Keating
Bachelor Island Ranch, Inc.
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION X 1 200 SIXTH AVENUE SEATTLE, WASHINGTON 98101
March 23, 1972
10A (M/S 325)
Lt. Col. Charles B. Brinkley, Jr. Department of the Army Portland District Corps of Engineers P. 0. Box 2946 Portland, Oregon 97208 Dear Colonel Brinkley:
We have reviewed the draft environmental impact state ment for the Lower Columbia River Bank Protection Project, Oregon and Washington.
Although the statement discusses the unavoidable en vironmental impacts that will accompany the project, some questions arise about the benefits that will be gained by its completion. Does the need for construction of eight more revetments outweigh the adverse effects that will be imposed on the environment? The general terms of the pro posed action are adequately described but it would be useful to provide additional focus on the individual site. Pic tures of each site in its present condition, particularly of eroding areas; and diagrams depicting the profiles of completed project sites should be furnished.
Because of the adverse effects that can arise during and upon completion of a project of this scale, particular care should be taken to incorporate discussions of the fol lowing points.
Individual descriptions of each site will afford a thorough examination of possible avenues for lessening adverse effects if they consider these questions:
What measures have been considered in the planning process to identify and minimize the extent of impacts and to provide for protection of the environment during con struction?
What will be the nature and duration of the sedimenta tion which will occur during construction? What measures have been incorporated in the project plan to minimize the effects of the resultant siltation and turbidity? What strict control measures to minimize water quality degra dation during construction will be specified in the contracts covering the proposed work?
What will be the impacts of the project on use of the surrounding lands? Will project completion cause a change in land use due to the increased flood protection? In short, what will be the ultimate effects of the action in terms of flood plain utilization and altering the banks of the Columbia River from a natural state? The statement predicts an increase in "dust and noise resulting from use of construction machinery at the quarry and levy sites." (pg. 3-1) What measures have been taken to see that these impacts are minimal? Are there any abate ment plans? ' What will be the method tor removal of trees and vegetation?
The plans for more revetments in the area will certainly effect the aesthetics along the Columbia. The idea that "Revetted banks are generally less pleasing in appearance than natural banks" is understated, (pg. 3-2) The loss of natural.conditions along river banks with an abundance of wildlife is a matter of utmost environmental concern both during the construction of the project and after completion.
Insufficient detail is provided by the statement's discussion on borrow areas for materials. What are the pos sibilities of needing new borrow areas? Has any considera tion been given to their possible location? What kind of assurances will be given to keep the impacts minimal? What is meant by "specific revetment?" (pg. 4-1) The statement .says "In these*cases, loss of wildlife habitat and aesthetic quality may be significant." (pg. 4-1) If so, a detailed study is necessary to portray the extent of new borrow areas and the processes that will be used.
The statement is made that "the construction of each additional revetment subtracts from the total vegetated shoreline providing fish and wildlife habitat and scenic value. With continued industrialization and development of the shoreline of lower Columbia River, unmodified natural shoreline may become a scarce resource." (pg. 6-2) Therefore, each project site can be justified only after full and careful consideration of such irreversible impacts. Expediency in revetting the banks of the lower Columbia could lead to sub sequent related projects that are unnecessary and harmful. /construction should only take place during months when ^-minimal adverse impact will occurj Migrating fish should be considered at this time. The project should maintain focus on the environmental problems of each of the eight projects, and every consideration should be given to insure that impact is kept to an absolute minimum. Detailed studies should include water, air, and noise pollution. Abatement plans should be studied and implemented whenever possible. A project such as this can be considered successful only if well planned construction practices are followed and if aware ness of the immediate, the temporary, and the irreversible environmental impacts are carefully emphasized. Thank you for the opportunity to comment on this draft statement.
Hurlon C. Ray / Assistant Regional Administrator ' for Management Comments From Field Review b y Department of the Interior Agencies of Draft Environmental Statement Lower Columbia Bank Protection Project, Oregon and Washington
G eneral
Historical Sites. — The environmental statement does not indicate that attention has been given to the possible effect of the project on historical values. In accordance with the National Historic Preservation Act of 19 66, P. L. 89-665, the National Register of Historic Places should be consulted. Also, as sites being considered fcr nomination to the register by the state may be involved, the State Highway Engineer in Oregon and ‘ Director, State Parks and Recreation in Washington, who are the State Liaison Officers for Historic Preservation, should be contacted. If no National Register Properties are involved, this should be noted in the statem en t.
Alternatives. —We are not certain whether or not this statement is meant to analyze the impact of project work on the eight locations authorized for construction in FY72 and FY73, 96 areas, 61 areas, or the 43 areas shown on the map. At any rate, although the statement presents an ade quate analysis of the general impact of revetment work, an analysis of the impact of individual projects -is-inadequate, particularly as regards al ternatives to the proposals. At the Burke Slough site, for example, the major cause of erosion appears"to be log dumping and rafting operations. An alternative to the project could be relocation of the leg dumping-rafting facilities to an .area with less erosion potential, or to an area already revetted. There are undoubtedly unconsidered alternatives to revetment of at least some of the other project sites. These would include ficod plain zoning to permit less intensive flood control operation at some locations; lowering vessel speed to reduce wash from wakes, a major cause of bank erosion; and relocation of facilities as discussed above.
Cumulative Effect of River Bank Work.- - The greatest concern to us is that the cumulative effect of river bank protection on fish and wildlife resources in the Lower Columbia Pdver area is not discussed. Individually the revetment projects have a minor effect on fish and wildlife resources. However, since these effects do relate to wildlife nesting and juvenile salmonids and other small fishes, the combined impact might be significant. We feel the environmental-statement should address itself to this subject. United States Department of the Interior OFFICE OF THE SECRETARY PACIFIC NORTHWEST REGION P.O. Box 3621, Portland, Oregon 97208
March 31, 1972
Your File: NPPEN-EQ 11 February 1972
Lt. Colonel Charles B. Brinkley, Jr. Deputy District Engineer Portland District, Corps of Engineers P.O. Box 2946 Portland, Oregon 97208
Dear Colonel Brinkley:
this responds to your request for comments on the draft environmental statement for Lower Columbia Bank Protection Project, Oregon and Wash ington (ER 72-169). Coordinated Department of the Interior comments are enclosed for your consideration in completing the final environ mental statement on this activity.
If we can provide any further assistance or clarification, please let us know.
Sincerely,
Emmet E. Wi11ard / Field Representative
Enclosure
Regional Director, Pacific NW Region, Bureau of Outdoor Recreation Director, Geological Survey Regional Director, Bureau of Sport Fisheries and Wildlife Director, Pacific NW Region, National Park Service Asst. Comm, for Ecology, Bureau of Reclamation (Code 150) Spokane Area Planning Officer, Bureau of Reclamation Salem Area Planning Officer, Bureau of Reclamation Director, Office of Environmental Project Review- Council on Environmental Quality Revetment Reveaetation.— The possibility of revegetating revetment areas is discussed briefly and a pilot or experimental program is re ferred to. Since it seems this is an important subject, we suggest that additional discussion on the prospects of revetment revegetation , both as a part of the construction effort and post-construction period, be included.
Editorial
Page 1-4, paragraph 2, last sentence.— We do not understand why this restriction does not apply to private lands since it is private lands that presumably are being protected by the revetments. If the restric tion applies only to government lands, it is nearly meaningless in this a re a .
Page 1-4, last paragraph. — Techniques for revegetation of denuded areas are well established for this region. What is needed is not that the "encouragement" of "vegetative growth" be "considered", but a decision by the Corps to revegetate areas denuded by project operations.
Page 1 -6 .— The use of benefit-cost ratios to justify the plan of develop ment does not fully evaluate the impact of the project on the areas studied. Further, the discussion of benefit-cost ratios, as such, does not seem pertinent to the objective of an environmental impact statement.
Page 2-1, second paragraph. —A more detailed breakdown of land use would be illuminating. 'What is the 4,000 acres protected but not classi fied used for? Is it water? What is the unprotected area used for?
Page 2-2, second full oaracraoh, last sentence.— Since there is an obvious scarcity of industrial sites near navigable waters in this area, it would seem logical to zone the area to permit waterfront occupancy only by industries requiring locations near navigable waters. This would reduce capital investment in areas with a high decree of flood risk, and in turn decrease the need or justification for a high degree of flood con trol in these areas. A recent court case (NRDC vs. Martin) indicates that under NEPA, agencies may not limit consideration of alternatives only to •those that could be adopted by the agency issuing the statement.
Page 2-3, firs*, full paragraph. — Sauvie Island Game Management Area and Ridgefield National Wildlife Refuge are also used extensively for bird-watching, nature studies by local school groups, fishing, and general outdoor recreation. Page 2-3, last paragraph. — There is very little goose nesting.along this part of the river.
Page 2-4, continuing paragraph. — Rails should be grouped with wading birds instead of shorebirds. Egrets should also be placed in the wading birds group. The trumpeter swan does not nest in this area. Whistling swans also overwinter in this area. Osprey, another rare bird, is also found in this area. Hawks, owls, songbirds, doves, and bandtailed pigeons also inhabit the ripaij§in habitat.
Page 2-4, first full paragraph, second sentence.— Mink, raccoon, and nutria should be included with the small furbearing animals. Miscel laneous animals such as squirrels, rabbits, and foxes also inhabit the riparian habitat. Reptiles and amphibians are included in the riparian fau n a.
Page 2-4, last paragraph, last sentence. — Perch, channel catfish, and flounder should be included as fish found in the sloughs and backwaters.
Page 3-1, third naraoranh-, third sentence. — The words "suitable for" should be replaced with "used by" to more accurately portray the situ ation .
Page 3-1, fourth oaraoraph. — Siltation will kill fish eggs, fry, and food organisms.
Page 4-1, first paragraph, last sentence. — Local silting during con struction can smother fish eggs and fry. Benthic food organisms will also be smothered but should gradually repopulate silted’and disturbed a r e a s .
' Page 5-1, first oaracraoh. — Another nonstructural alternative not mentioned is a speed limit or reduction of speeds of water craft. Appropriate laws should be formulated or applicable laws enforced. Waves created by ships, barges, and private boats cause considerable erosion of the shoreline and hence the need for revetments. Much of the erosion, especially in such areas as Burke Slough and Santosh, could be eliminated by speed regu lations. The need for flood protection could also be reduced by flood plain zoning.
Page 5-1, last paragraph, third sentence.— The long duration of high flows does not appear to affect streamside vegetation to any remarkable extent except in unsheltered areas subject to wash from passing vessels, or log dumping operations. Page 6-1.— The discussion under item 6 appears to be oriented primarily to justification of the proposed plan of development.
P a g e 6-1, paragraph 1.— There is still considerable hunting and some trapping in this area. United States Department of the Interior GEOLOGICAL SURVEY Water Resources Division 3<+5 Middlefield Road Menlo Park, CA 94025
March 2, 1972
Deputy District Engineer Portland District, Corps of Engineers P. 0. Box 2946 Portland, OR 97208
Dear Sir:
We have reviewed the environmental statement for Lower Columbia River Bank Protection Project as requested in your letter of 11 February 1972.
We can foresee no adverse effects other than those noted to the hydrology of the project areas after the construction phase is complete.
The foregoing comment is provided informally for technical assistance and is not intended to represent the position of the Department of the Interior.
Sincerely yours,
Elwood R. Lee'Soir'^ Regional Hydrologist Pacific Coast Region United States Department of the Interior
BUREAU OF LAND MANAGEMENT Oregon State Office 729 N.E. Oregon Street (P.0. Box 2965) Portland, OR 97208
FEB 1 G 1972
District Engineer Department of the Army Portland District Corps of Engineers P.O. Box 2946 Portland, OR 97208
Dear Sir:
We have reviewed your draft environmental statement for the Lower Columbia Bank Protection Project. We find that this project as proposed does not occur on or otherwise appear to affect lands under Bureau of Land Management jurisdiction. We therefore have no comments to make on the draft statement.
Sincerely yours,
ASfoehts state Director THE ASSISTANT SECRETARY OF COMMERCE Washington, D.C. 20230
April 18, 1972
Colonel Charles B. Brinkley, Jr. Deputy District Engineer U.S. Department of the Army, Corps of Engineers Portland, Oregon 97208
Dear Colonel Brinkley:
The draft environmental statement for the "Lower Columbia Bank Protection Project," reference NPPEN-EQ, which accompanied your letter of February 11, 1972, has been received by the Department of Commerce for review and comment. 0 The Department of Commerce has reviewed the draft environmental statement and has the following comments to offer for your consideration.
On the first page under Item 4, Alternatives, we suggest that the possibility of regulating speed of boats and releases of water from dams upstream be considered.
On page 2-4, we suggest the word "commercial" might be deleted from the last sentence, inasmuch as all the fish named are vital only to the sport fisheries.
On page 3-1, under Item 3 at the top of, the page, perhaps it should be mentioned that short-term effects of revetment con struction would also interfere with fish migration.
On page 5-2, perhaps the commentary on set-back levees should be enlarged to indicate that during nonflooding years, the land between the set-back levees and the river proper is often used for agricultural purposes. On the same page, it might be desirable to offer some commentary related to the last paragraph that would indicate that disposal of dredge materials in convenient locations often has an adverse effect on fish resources.
On page 5-3, in the first full paragraph, comments, such as those relating to set-back levees for page 5-2 above, probably should be included.
We hope these comments will be of assistance to you in the preparation, of the final impact statement.
Sincerely,
Sidney R. Galler Deputy Assistant Secretary for Environmental Affairs U.S. DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration National Marine Fisheries Service Columbia Fisheries Program Office 811 N.E. Oregon Street P.O. Box 4332, Portland, Oregon 97208
March 7, 1972 NPPEN-EQ
District Engineer, Portland District Corps of Engineers P. 0. Box 291+6 Portland, Oregon 97208
Dear Sir:
We have reviewed the draft environmental impact statement for the Lower Columbia Bank Protection Project and find for the most part that it accurately depicts the situation. We must state, however, that any project work of this nature in the riparian habitat will in some measure affect fishery resources. Location, current patterns, etc., will dictate the magnitude of adverse effects. We realize that much of this protection work needs to be done; however, we must caution you to exercise every means to protect as much of the riparian habitat and associated fishery resource as possible.
We have one objection to make. On page 5”3> you make the unqualified statement that set-back levees would not be an acceptable long term solution to bank protection. We believe that in many instances, set back levees would be the answer to both bank protection and preserva tion of riparian habitat to the benefit of both fish and wildlife.
We would encourage that set-back levees be seriously considered in any bank protection project.
Sincerely,
'George M. Kaydas Acting Program Director
cc: Washington Department of Fisheries Washington Department of Game Fish Commission of Oregon Oregon State Game Commission Portland Area Office, BBS, BSFW DEPARTMENT OF TRANSPORTATION Address reply to: COMMANDER (oan) UNITED STATES COAST GUARD Thirteenth Coast Guard Disti 618 Second Ave. Seattle, Wash. 98104
. 5910 Ser 152 2 2 FEB 1972
From: Commander, Thirteenth Coast Guard District To: District Engineer, Portland District, U.S. Army Corps of Engineers
Subj: Dr/ift Environmental Statement for Lower Columbia River Bank Protection Project; comment on
Ref: (a) Your ltr NPPEN-EQ of 11 Feb 1972
1« Reference (a) forwarded subject draft environmental statement and requested comments on possible impact of this project.
2. This project will possibly cause some aids to navigation structures to be temporarily discontinued or relocated during the construction phase. The alternative proposal of building pile dikes would probably result in the establishment of some new Coast Guard aids.
3. Due to the large area covered by this project, the extent of any impact cannot be accurately determined from available informa tion.
F. A. GOETTEL By direction U. S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION Room 412 Mohawk Building 222 S.W. Morrison Street Portland, Oregon 97204
March 15, 1972
IN REPLY REFER TO 10-00.36
Your reference: NPPEN-EQ Lower Columbia Bank Protection Project
Lieutenant Colonel Charles B. Brinkley, Jr. Deputy District Engineer Department of the Army Portland District, Corps of Engineers P. 0. Box 2946 Portland, Oregon 97208
Dear Colonel Brinkley:
The draft environmental statement for the above referenced project received with your letter dated February 11, 1972 has been reviewed by our staff. We know of no Federally-aided highways that would be adversely affected by this bank protection project.
The statement, as it relates to our programs and interests, appears adequate. Thank you for the opportunity to comment.
Sincerely yours,
' ltoLjn Ilf PHILLIPS y Regional Administi?ator UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE 1218 SW Washington, Portland, OR 97205
March 16, 1972
Lieutenant Colonel Charles B. Brinkley, Jr. Deputy District Engineer Portland District, Corps of Engineers Department of the Army P. 0. Box 2946 Portland, OR 97208 ,
Dear Colonel Brinkley:
This is in response to your request for comments on the draft Environmental Impact Statement for the Lower Columbia Bank Protection Project.
We believe the statement accurately portrays the significant environmental effects that would occur from construction of the project.
The proposed bank protection is necessary to prevent the dike banks from being eroded by tidal and wave action. [We agree with the selection of rock riprap as the bast alternate plan. However, we suggest that by the use of a soil cover over the top of the riprap, down to the high water line, and a vegetative cover a more pleasing installation would result^j
We appreciate the opportunity to review and comment on this proposed project.
Sincerely,
A. J. Webber State Conservationist UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE_____ Room 360, U.S. Courthouse, Spokane, Washington 99201
March 2k, 1972
Lt. Colonel Charles B. Brinkley, Jr. Deputy District Engineer Portland District, Corps of Engineers P. 0. Box 29^6 Portland, Oregon 97208 J
Dear Colonel Brinkley:
The draft Environmental Impact Statement for the Lower Columbia Bank Protection Project sent to this office under covering memorandum dated February 11, 1972, has been reviewed.
No comments are offered regarding the proposals outlined in the draft statement.
We appreciate the opportunity to review and, where appropriate, to comment on proposed projects.
Sincerely yours,
Orlo W. Krauter State Conservationist STATE OF WASHINGTON ©F F©@L@©Y DANIEL J. EVANS JOHN A. BIGGS , GOVERNOR DIRECTOR
March 24, 1972
Lt. Colonel Charles B. Brinkley, Jr., CE Deputy District Engineer Department of the Army Portland District, Corps of Enqineers P.0. Box 2946 Portland, Oregon 97208
Dear Lieutenant Colonel Brinkley:
Our office has reviewed the Lower Columbia River Bank Protection Project Draft Environmental Statement. The Statement presents the project information well, and provides sufficient background data and material to form a comorehensive picture. On the basis of that information, the necessity for construction of bank protection works along the lower Columbia River in the areas specified, appears to be demonstrated.
Thorough review of the design proposal and the possible alternatives, revealed that the adverse environmental effects which cannot be avoided should the project be implemented, would be more than balanced by the overall improvements that would result from flood and bank protection, in the high-use area under construction.
However, we recommend that in all cases of unavoidable disturbance of features of the natural environment (such as, siltation and other types of water poll-ution, excavation of borrow material, disposal of construction debris, operations that involve temporary access, road construction, and clearing vegetation), highest applicable standards be closely followed, or exceeded, to moderate adverse effects and to restrict the duration of their impacts.
Construction activity should be scheduled in such a way as to be compatible with existing natural environmental and land utilization patterns.
Precautions must be taken to achieve full protection of the w ildlife, their habitats, and migrational patterns in the various project areas, specifically as regards any endangered species.
All traces of the construction activity, or related operations that are not beneficial or of permanent use, would best be obliterated to the maximum extent and the ecological balance, as well as the natural appearance of the affected regions be restored or preserved, respectively, as far as possible.
We believe that your office has provided an objective description of the project. Thank you for the opDortunity to review the statement.
Sincerely,
Fred D. Hahn, Assistant Director Planning arid Program Develooment FDH:j 1 cc: Paul T. Benson, OPP&FM WASHINGTON Department of if 'n . v * "*$' ‘*,T.a»‘ t f ~ * \ V >•**«»’ .*««%■» ' •*’*>, ;-• v- ;>';>* m w * ^ ij iu, -A, ti, .Cr*«*^
L
S lI E L J. EVAN S R O O M n s , GENERAL ADMINISTRATION BUILDING • PHONE 753-6600 THOR C. TOLL e {? jO\' G O V E R N O R OLYMPIA. WASHINGTON 98504 D IR E C T O R j L ^ \
March 27,-1972
Charles B. Brinkley, Jr.,Lt. Col. Deputy District Engineer Corps of Engineers P.O. Box 2946 Portland, Oregon 97208
Dear Sir:
Reference is made to Public Notice NPP 72-57 and the draft Environmental Impact Statement (EIS) of February 11, 1972 for the Lower Columbia River Bank Protection Project.
The last sentence on page 1-2 refers to the total shoreline. It should be pointed out that in addition to the leveed areas, a substantial portion of the bankline has been altered by highway construction and private interests. There arc also areas of vertical basalt cliffs. Therefore, it would probably be more apropos to use figures relevant to those portions of the total shoreline which are subject to erosion or inundation by flood waters.
There should also be a distinction between the repair of existing levees and the construction of levees in previously undisturbed areas. The environ mental impact regarding this distinction is clearly different. If a levee already exists, it could be assumed that the natural character of the shoreline has already been altered. It would be pointless to argue that a set-back levee would be an attempt to preserve this natural area which is so vital to the prop er management of the fisheries resource.
However, in areas where there is no existing structure, this Department feels that the environmental impact is much greater. The second paragraph on page 5-3 focuses attention on the relocation of existing levees and ignores the relative effects of new levees. It should be pointed out in the EIS that these remaining, natural sloping, vegetated areas of the shoreline are vital to the fishery resource for varying reasons. The peak downstream migration of juvenile salmon is during the months of May and June. This timing corresponds with the peak run flow of the Columbia Basin. This means that the fish will be migrating along these levees when the water is at its highest stage. Fish need the shal low shoreline areas for their food production capabilities, resting potential, and escapement from predators. We feel that the following statement on page 6-2 should be strongly emphasized in any discussion involving set-back levees: "With continued industrialization and development of the shoreline of lower Columbia River, unmodified natural shoreline may become a scarce resource."
The final paragraph on page 6-2 indicates that some personnel in the Corps of Engineers are becoming concerned for the remaining "unmodified natural shore line" of the lower Columbia River. This Department is also concerned about this same subject. We would strongly support any study initiated by the Corps of Engineers regarding the questions: How much of the lower Columbia shoreline has been encroached upon by man-made objects? How much can we afford to lose? The primary objective of such a study could be the establishment of a minimum eleva tion beyond which encroachments could not extend.
Although loss of fish habitat is described generally on pages 3-1 and 4-1 of the E1S, it is omitted from the second sentence on page 7-1 which should read: "Fish and wildlife habitat would be destroyed in the revetment area." The magni tude of impact on fisheries resources will vary according to location of the proj ect. Therefore, we wish to review the EIS and specific details for each of the eight projects proposed for FY 72 and FY 73. Although innut from the State agen cies on Federally-funded projects will be coordinated through the State Office of Program Planning and Fiscal Management, we would appreciate early notification of each project, and suggest that the State Department of Game and the State Department of Ecology also be placed on the mailing list. Close coordination should be main tained between the various interested agencies with regard to each individual project.
Thank you for the opportunity to comment on this draft Environmental Imnact Statement.
Sincerely,
Thor C. Tollefson i Director cc: Washington Dept, of Game Washington Dept, of Ecology Washington State Office of Program Planning and Fiscal Management Oregon Fish Commission Oregon Game Commission Bureau of Sport Fisheries and Wildlife, Portland Rational Marine Fisheries Service, Portland ' D ir e c to r / Carl N. Crouse A rth u r S. Cn/fin. Y a lim a , Chairm an Hamid A. Pebbles. Olympia Assistant Directors / R alph If'. L irson P.Imer G. Gerken, Quincy
Ronald N. Andrews Jam es R . A r c h , lu tC on n er Glenn Galbraith, II"c/lpinit Claude Eclins, Seattle
DEPARTMENT OF1 G-^IVCIE
600 North Capitol Way / Olympia, Washington 98504
March 24, 1972
Lt. Colonel Charles B. Brinkley, Jr. Deputy District Engineer Department of the Army Portland District, Corps of Engineers P. 0. Box 2946 Portland, Oregon 97208
Dear Colonel Brinkley:
We have reviewed the draft environmental impact statement you identify as Lower Columbia River Bank Protection Project, Oregon and Washington and have the following comments.
Your draft included objective information on fish and wildlife and the impact of the project on these resources. We are pleased to concur with those portions of your text.
Because you have recognized the adverse effects of the proposal,'we strongly urge that methods to mitigate these damages be developed and included as part of the project plan. Your project description (1-4) includes discussion of "encouragement of vegetative growth...being considered for future revetment locations". We suggest a stronger commitment should be made and that it should apply to this particular project.
You also treat the subject of disposal of excavated material and its impact on aquatic and terrestrial habitats very objectively (4-1). Our comment, here, is that the project plan should also include a commitment to restrict filling of these habitats to an absolute minimum. Whenever possible, these sites (sloughs, brush, trees, etc.) should be avoided entirely.
An approach - set-back levees - which we feel needs greater study and consideration by the Corps is discussed in you r point 5, Alternatives to the proposed action. We do not agree with your conclusion , which does tend to imply that use of land for "...farming or industrial purposes" {5-3), is the only valuable or productive use for these lands. We submit that wildlife production and outdoor recreation are also valuable, especially in productive riparian zones. Your draft alludes to the value of remaining "...water and land areas for recreation..." in your opening paragraph of point 6. (6-1). Again, we compliment you on your appraisal of impacts of the project on fish and wildlife. We hope you seriously consider our comments and consider them in your final statement. Thank you for the opportunity to review this draft. Very truly yours,
THE DEPARTMENT OF GAME/^
Eugene S. Dziedzic, Asst. Chief Environmental Mangement Division
ESD:jb cc: Agencies Whi te \SHINCi I ON ST A TL IGHWAY COMMISSION PARl'MENT Of HIGHWAYS ihway Administration Building mpie, Washington 9B504 (SOS) 753-6000
M arch 15, 1972
Mr. Charles B. Brinkley, Jr., Lt. Colonel, CE Deputy District Engineer Department of the Army Portland District, Corps of Engineers P. O. Box 2946 Portland, Oregon 97208
Re: Lower Columbia River Bank Protection by U. S, Army Engineer District, Portland Oregon - Draft Environmental Statement Dear S ir:
In accordance with your request of February 17, 1972, we have reviewed the above-referenced draft environmental statement and find that with the exceptions listed below, the proposed work will not involve any existing or proposed highway projects. The only areas of involvement appear to be as follows:
SR-409, Puget Island - Wahkiakum County Consolidated Diking District No. 1 SR-501, Campbell Lake A rea project SR-501, Vancouver Lake Area project
In these areas we request that the Army Engineers coordinate their activities with the office of our District 4 Engineer. His address is: Mr. R. L. Carroll, District Engineer, Department of Highways, P. O. Box 1717, Vancouver, Washington 98663.
Thank you for the opportunity to review this information.
Sincerely,
G.H. ANDREWS Director of Highways
By: H. R. GOFF Assistant Director for Planning, Research & State Aid HRG:dc RA :RBD cc: R. L. Carroll Nicholas D. Lewis (OPP&FM) ANIEl J. EVANS OVERNOR WASHINGTON STATE OMMISSIONERS: IRS. ELEANOR BERGER XWXIISS & B.HCREATION COMMISSION EFf O. DOMASKIN HOMAS C. GARRETT 7150 CLEANWATER LANE PHONE 753-575 5 ALPM E. MACKEY AMES G. McCURDY AMES W. WHITTAKER THURSTON A1RDUSTRIAL CENTER P. O. BOX 1 1 2B OLYMPIA, WASHINGTON 98504 VllFRED WOODS
:harles h . odegaard, IIRECTOR May 3, 1972
Mr. Ronald Iverson' Department of the Army Portland District Corps of Engineers P.O. Box 2946 Portland, Oregon 97208
Dear Mr. Iverson: Fort Vancouver; Chinook Point As per our telephone conversation of April 27th, those National Register properties along the Columbia River from Camas-Washougal to the mouth are Fort Vancouver, and Chinook Point in Pacific County. As a convenience to the Historic Preservation Program in Washington, it would be most helpful if the Corps were to notify the State Liaison Officer when any archaeological material is located. It would also seem appropriate and beneficial if the Corps were to undertake an archaeological survey of the Lower Columbia River. This area is extremely rich in archaeological materials. To conduct a survey could eliminate the necessity of delay in Corps projects when such materials were encountered. Sincerely,
(Mrs.) Bette E. Meyer, Chief Office of Archae'ology and Historic Preservation Consultation & Education Division April 6, 1972 imwater
Daniel J. Evons, Governor Choi m a n Lt. Co]. Charles B. Brinkley, Jr. Re: Draft Environmental Portland District, Corps of Engineers Impact Statement Department of Commerce and Economic Development P.0. Box 29^6 Lower Columbia Bank Dc .cl B. Ward. Di'ertor Portland, Oregon 97208 Protection Project Department of Ecology John A B grjj, Director Dear Colonel Brinkley: Department of Fisheries Thor C Tollvfson, Director
Department of Game Co-'I N . Crouse, Direc*or Thank you for the opportunity for review of the above report.
Deportment of Highways We have no comment at this time. George H Andrews, Director
Department of Nalurol Resources L. C o le . Commissioner ,-f Pubi c Lords Sincerely,
Stole P a rk s and Recreation Commission STANLEY E. FRANCIS Lhcr'ts H. C:Jtgc3'd, Director Administrator CITIZEN MEMBERS
Lewis A. Bell Warren A. Bishop Mrs. Frederick lemere Dmer Lofgren hick Rattler ROBERT S. LEMCKE Program Coordinator f-DMINISTRATOR ilonley E. Francis SEF:RSL:vc
cc: Paul Benson, OPPFM 4600 Capitol Blvd. 'JT jSQ l W ashington 98504 : rBam a^ sssssssa Phone: 12061 7 5 3 -7 1 4 0 mwater April 6, 1972
'ontel J. Evans, Governor .TJBSKBKff#, Chairman ar Lofgren A«TI<>?ATING AGENCIES Lt. Col. Charles B. Brinkley, Jr. Re: Draft Environmental Impact ' 7vpurtm#nt of Fisheries Dear Colonel Brinkley: Hof C. Tol'efson, Di'trcfor ’ epariment of Gome v l N. Crouse, D-’PCtor Thank you for the opportunity for review of the above report. epariment of Highways ro'ae H Andews, Director We have no comment at this time. ^portmont of Notuial -/sources ;■ * L- C v fe. Cci-irruSJione.' • PcfcSc lands Si ncerely, erfe Porks and Reaeotion om m issio n •loiles H. Odrg^o'd. C> ector STANLEY E. FRANCIS ITIZEN MEMBERS Admini strator ,‘wis A. Beil > urren A . B ish o p '■<», Frederick Lemere '■ tar lo fg re n eck Rotller DMtNISTRATOR ROBERT S. LEMCKE •onley 6 . fre n tit Program Coordinator SEF:RSL:vc * cc: Nicholas Lewis, 0PPFM OFFICE OF THE GOVERNOR STATC CAPITOL SALEM 97310 March 9, 1972 Mr. Charles B. Brinkley, Jr. Lieutenant Colonel, CE Deputy District Engineer Department of the Army Portland District, Corps of Engineers P. 0. Box2946 Portland, Oregon 97208 Re: Lower Columbia Bank Protection Project PNRS #7202 4 070 Dear Col. Brinkley: We have referred your draft Environmental Impact Statement to the appropriate state agencies. We have also published and distributed notice to all state agencies and Councils of Governments. The responses quoted below suggest points to be considered and included in your statement. Oregon State Fish Commission: "'A' .recommendations section should be included in all Environmental Statements. This section should include recommended actions or project features necessary to prevent environmental degradation or to enhance environmental values within the project area." Oregon State Highway Division: "We would like to mention that if it is intended to haul revetment materials over state highways, it would be appreciated if the Corps would coordinate this with us as crossing movement conflicts at peak traffic hours or in heavy traffic zones may be involved." Oregon Geology & Mineral Industries: "On page 1-4 there is a discussion of sources of material to be used for lining the embankment to provide the required slope and to protect from erosion. "I would like to point out that the State Legislature passed a Mined Land Reclamation Act last spring which establishes rules and regulations for reclaiming mined-out pits and quarries after the work has been completed. Copies of this act will be available from this office within the next two weeks. I hope that the Corps of Engineers will contact our office during the construction phase of this project so we can insure that the environmental impact of the quarrying or mining operation will be kept at a minimum." You may use this letter as evidence of your com pliance with Section 102 (2)(C) of the National Environmental Policy Act of the 1969 (83 Stat. 853), and 0MB A-95 (Revised.). Cordially, Kessler R. Cannon Assistant to the Governor Natural Resources OREGON STATE HIGHWAY DIVISION HIGHWAY BUILDING • SALEM, OREGON • 97310 May 2, 1972 Mr. D. H. Basgen, Chief Engineering Division, Portland District U. S. Army Corps of Engineers P. 0. Box 2946 Portland, Oregon 97208 Dear Mr. Basgen: This is in response to your request received March 15 concerning National Register properties likely to be affected by your proposed Lower Columbia Bank Protection Project in Multnomah and Columbia Coun ties . There are no properties currently listed in the National Register of Historic Places in the immediate vicinity of authorized improvements shown on the Project map. However, I believe you are aware that the Bybee-Howell Historic House, a feature of Howell Territorial Park on the west side of Sauvie Island in Multnomah County, is approved for nom ination to the National Register. At the present time, the only other area in which we perceive a possible relationship between an authorized improvement and a historical property is the Knappa vicinity, which is believed to be the setting of an Indian village visited by members of the Lewis and Clark Expedition in 1805. The site is being evaluated at this time. Because this agency does not maintain archeological records, our comments are confined to historic sites and buildings only. We are for warding copies of our correspondence to Professor David L. Cole, Acting Head of the University of Oregon Museum of Natural History, in the event that a statement on archeological values is appropriate. We appreciate this opportunity to comment. Very truly yours, David G, Talbot State Parks Superintendent Elisabeth Walton Park Historian cc: Professor David L. Cole /w/ att. Cowlitz-W ahkiakum Regional Planning Commission COWLITZ COUNTY COURTHOUSE FIFTH AVENUE ANNEX KELSO. WASHINGTON 98626 PHONE 425-6905 April 25, 1972 Mr. Bruce Balme Environmental Impact Statement Coordinator Environmental Quality Branch Corps of Engineers Portland, Oregon Dear Mr. Balme, It was a pleasure to become acquainted with you through our recent telephone conversation. Please be advised that this agency has re ceived six (6'/ copies of the Draft Environmental Statement of the Lower Columbia River Bank Pro tection Project, Oregon and Washington. We appreciate the opportunity to review the statement and would like to review future state ments that affect Cowlitz and Wahkiakum Counties. Recognizing the potential damage to specific environments as set forth, our staff has concurred that the proposed action is necessary for the broader protection of properties involved. The discussion presented relative to the alternative action rather well eliminates these alternatives as desirable choices. Site surveys in the Woodland area indicate that the proposed revetment works south of the City of Woodland have been completed. We would appreciate a more timely presentation of future proposed actions. Sincerely, U.D. Villines Assistant Director March 30, 1972 Port of Portland Box 3529 Portland. Orcjar. '-'I :; 5C3/233-8331 TWX: 910-454-6151 TAX fC m District Engineer Portland District Corps of Engineers P.0. Box 29^6 Portland, Oregon 97208 Attention: Dr. Ronald A. Iverson LOWER COLUMBIA BANK PROTECTION PROJECT Your draft Environmental Statement, dated February 11, 1972, covering the lower Columbia River bank protection project appears to cover all of the factors to be expected as a result of the proposed construction. It is noted that one of the primary adverse environmental effects is the loss of vegetation cover for wildlife. It is suggested that con sideration be given to the planting of Scotch Bloom within the revetment area. This material was used extensively along the shores of Swan Island and resulted in very attractive cover material with a relatively small root system in comparison with other types of vegetation. «ALJJ! Heineman Assistant Director, Marine COUNTY COWLITI Z KELSO, WASHINGTON 98G26 March 24, 1972 Charles B. Brinkley, Jr. Lieutenant Colonel, CE Deputy District Engineer Dept, of the Army, Corps of Engineers Post Office Box 2946 Portland, Oregon 97203 Dear Sir: Our County Engineer has reviewed the Environmental Impact Statement of the Lower Columbia Bank Protection Project, as it re lates to works in Cowlitz County, and based upon his report, this Board supports the work as outlined. Yours very truly, BOARD OF COUNTY COMMISSIONERS _QF COl.'LITZfXOUNTY, WASHINGTON Chairman Commis-sioner Commissioner cc: L. E. Riedesel, County Engineer Commissioners' Journal CITY OF WASHOUGAL 170! C STREET WASHOUGAL. WASHINGTON 9 8 6 7 1 TELEPHONE 835-5556 February 15, 1972 Department of the Army Portland District Corps of Engineers P. 0. Box 2996 Portland, Oregon 97203 Attention: NPPEN-EQ Dear Sir: We have reviewed your report entitled "Draft Envi ronmental Statement, Lower Columbia River Bank Protection Project, Oregon and Washington," dated 11 February 1972. Wc. offer no objections to your plans in the Washougal area. Thank you for the opportunity to comment upon your proposed plans. Yours truly, Ralph E. Hootman Mayor DEPARTMENT OF PUBLIC WORKS COUNTY OF CLARK, STATE OF WASHINGTON 1200 Franklin Street Vancouver, Washington 98660 February 16, 1972 File: 0^0.05 District Engineer Portland District, Corps of Engineers P. 0. Box 29^*6 Portland, Oregon 97208 Dear Sir: Reference is made to your letter of February 11, 1972, NPPEN-EQ, draft Environmental Impact Statement of 11 February, 1972. The chairman of the board gave me your letter to answer after we had discussed the matter with the Board of County Commissioners. It appears to us that the bank protection project is essential and necessary. It appears from the statement that all action that is feasible will be taken to protect the environment. It is understood that there may be some short term effects upon foliage, fish life and wild foul. However it appears that these will be very small in relationship to the benefits. Yours very truly, Cecil [L Kinder v***— • Director, Dept, of Public Works CDK:rm cc: Commissioner George Nutter, Chairman of the Board OREGON ENVIRONMENTAL COUNCIL 4315 S.W. CORBETT AVENUE, PORTLAND, OREGON 97201 / PHONE: 503/222-5369 February 25, 1972 AMERICAN ASSOCIATION O f UNIVERSITY * W OMEN, Portland Branch Colonel Charles B. Brinkley, Jr. AMERICAN INSTITUTE OF ARCHITECTS The Porlland Chopter Deputy District Engineer Southwestern Oregon Chopper AMERICAN INSTITUTE OF PLANNERS Portland District, USACE Oregon Section ERICAN SOCIETY OF LANDSCAPE ARCHITECTS P. 0. Box 2946 Oregon Section, PNW Chapter ANGLERS CLUB OF PORTLAND Portland, Oregon 97208 BAY AREA ENVIRONMENTAL COMMITTEE Coos Boy, Oregon CHEMEKETANS, Salem, Oregon Re: NPPEN-EQ Draft Environmental Impact CITIZENS FOR A CLEAN ENVIRONMENT Corvallis. Oregon Statement - Columbia River Bank CLACKAMAS COUNTY NEW POLITICS CLATSOP ENVIRONMENTAL COUNCIL Protection Project COMMITTEE FOR VOLCANIC CASCADE STUDY Portlond, Oregon COMMITTEE FOR MINAM ACTION, INC. Portlond, Oregon Dear Colonel Brinkley: ENVIRONMENTAL ACTIVIST COALITION Lewis and Clark College EUGENE FUTURE POWER COMMITTEE The folloxTing comments are forwarded for your use EUGENE NATURAL HISTORY SOCIETY 4-H CLUB CARROT-TOPPERS, Scoppoose, Oregon in further work on an Environmental Impact Statement FRIENDS OF THE EARTH .ARDEN CLUBS of Cedar M ill, Corvallis, Gervais, for the Lower Columbia River Bank. Illinois Volley, McKenzie River, Sccppoose ENLEAF CLUB OF FIRST UNITARIAN CHURCH P o rtla n d 1. May we obtain as soon as possible a complete INSURANCE W OMEN’S ASSOCIATION OF PORTLAND statement of your cost-benefit calculations so JIINIOR LEAGUE, Eugene, Portland McKENZIE FLYFISHERS, Eugene, Oregon we can comment on that prior to your March 21, 1972 McKENZlE GUARDIANS. Blue River. Oregon deadline? In particular, we are interested in the STHWE5T STEELHEADERS COUNCIL OF TROUT UNLIMITED, Beaverton, North Portland, number of landowners and acreages which will benefit Portlond, Tigard OBSIDIANS, INC., Eugene, Oregon from the proposed work. OREGON CITIZENS FOR CLEAN AIR OREGON COUNCIL FOR NEW POLITICS 30N COUNCIL OF ROCK AND MINERAL CLUBS Roseburg, Oregon 2. We are concerned that your proposed work, largely OREGON GUIDES AND PACKERS, Vida, Oregon irreversible, will precede by only a short time a OREGON NURSES ASSOCIATION OREGON PARK & RECREATION SOCIETY comprehensive plan for development of the Lower Corvallis, Oregon OREGON SCIENCE TEACHERS ASSOCIATION Columbia shoreline. This shoreline and flood plain iREGON SOCIETY OF LANDSCAPE ARCHITECTS Portland, Oregon area is certainly one of the most significant natural OREGON TUBERCULOSIS AND RESPIRATORY DISEASE ASSOCIATION assets of the adjoining counties (and in fact, the O.S.U. FIN AND ANTLER CLUB Corvallis, Oregon entire Northwest). We think that your planning for O.S.U. MOUNTAIN CLUB, Corvallis, Oregon bank protection should include multi-county zoning PLANNED PARENTHOOD ASSOCIATION, INC. Lane County, Portlond commission public hearings to define what areas, if PORTLAND AUDUBON SOCIETY P.U.R.E., Bend, Oregon any, are not to be "protected" but left in a natural REED COLLEGE OUTING CLUB • Portlond, Oregon state. ROGUE ECOLOGY COUNCIL Ashland, Oregon SALEM BEAUTIFICATION COUNCIL 3. It seems that you are encouraging residential and SANTIAM ALPINE CLUB Solcm, Oregon industrial development of the flood plain by this: ' SIERRA CLUB Pocific Northwest Chapter bank protection which will then justify even greater Columbia Group, Portlond, Oregon SPENCER BUTTE IMPROVEMENT ASSOCIATION "protection" measures for people who locate there - a Eugene, Oregon TRAILS CLUB OF OREGON perpetual job for the Corps of Engineers. In fact, TROUT UNLIMITED planning authorities urge that flood plain areas not UNIVERSITY OF OREGON OUTDOOR PROGRAM Eugene, Oregon be intensely developed. WILLAMETTE PIVER GREENWAY ASSOCIATION VlUAMETTE TUBERCULOSIS AND RESPIRATORY DISEASE ASSOCIATION, Solcm, Oregon MEN'S ARCHITECTURAL LEAGUE OF PORTLAND ZERO POPULATION GROWTH Lone County, Portlond *1. We urge you to read (and. would appreciate your comments on) the Page 1 article of the Wall Street' Journal, July 19, 1971 concerning related channelization projects by the SCS and changes „by the Water Resources Council in technical aspects of completing the "cost-benefit" ratio. ,5« We wonder why you can not include in your contracts for rip-rap stone, etc., a provision for environmental protection from surface mining operations on private lands. Such provision would disqualify bidders who aro despoiling the local area. 6. Why can't this work be done by local diking districts or private interests who stand to gain by such work? Sincerely, ✓ Larry Williams Executive Director cc: Mr. L. B. Day Clatsop Environmental Council VJater Resources Board Brock Evans, Sierra Club Mr. Kessler Cannon OSPIRG LW: j ai United States Department of the Interior BUREAU OF MINES WEST 222 MISSION AVENUE SPOKANE, WASHINGTON 99201 Western Field Operation Center February 24, 1972 Lt. Col. Charles B. Brinkley, Jr. Deputy District Engineer Portland District, Corps of Engineers P.0. Box 2946 Portland, Oregon 97208 Dear Colonel Brinkley: The draft Environmental Impact Statement for the Lower Columbia Bank Protection Project was reviewed by personnel of this office. In many sections of the statement, mineral resources have been cited as an excavated material and as a material to build revetments. In each instance, proper recognition of the impacts is given. We therefore have no comments which would improve the statement. These informal comments on the draft are being furnished for your guidance and do not constitute a formal Department of the Interior or Bureau of Hines review. Sincerely yours, Kenneth D. Baber, Acting Chief Western Field Operation Center 535 S .E . 70th Avenue Portland, Oregon 97215 March 16, 1972 Portland District Corps of Engineers Portland, Oregon Att: Dr. Ronald Iverson Dear Dr. Iverson: I have received the "Draft Environmental Impact Statement for the Lower Columbia Bank Protection Project," and ongoing project of levee repair of the Corps of Engineers. I have read this statement from beginning to ending. It fails to mention cost for the 123,000 lineal feet of revetment neededto secure this plan. Please tell me what would be the cost per lineal foot (the measure stated in the impact statement) of revetment work along the lower Columbia River. I am presuming that the project proposed involves 123,000 lineal feet, as stated. I am presuming that the cost per lineal foot of this work will be for work to be done in one fiscal year, the fiscal year 1973. I will appreciate your response to my questions. Yoursia very truly, Howard M. Rondthaler