by Alan Journet
Conservation Chair, Trail of Tears Group
It was recently reported in the national news that some District Offices of the US Army Corps of Engineers (COE) are not above trying to force their analysts to distort data to promote projects that “friends” of the COE would like to see undertaken. In this case, the friends were barge companies. See earlier story.
The Memphis District of the COE is currently perpetrating on the Missouri environment and the US taxpayers two equally bogus projects: one involving the closing of a gap in the Mississippi levee at New Madrid; the other involving channelizing the Saint Francis River between Missouri and Arkansas. Both projects are being pushed by Missouri’s Representative Emerson (R–8th District) and seem at best primarily designed to benefit a small number of landowners.
Saint John’s Bayou / New Madrid Floodway Project
This project would close the last remaining engineered gap in the existing river levee. By so doing, it would reduce the duration and frequency of Mississippi River backwater flooding for about 36,000 acres of seasonal wetlands. It has been frequently argued, as it was in the Environmental Impact Study (EIS), that closing this levee would benefit the communities of East Prairie and Pinhook (Mississippi County) by reducing the seasonal flooding that they suffer— thus allowing economic development in the area.
Generally such projects require a significant “local” contribution from area residents and businesses before they can be undertaken. In this project, however, this requirement was circumvented when the area was declared an Economic Enterprise Zone. Following this declaration, special dispensation was obtained to use these Federal (taxpayer) dollars to tip the required “local” contribution over the minimum percentage.
This project has been universally criticized by all state and federal environmental and conservation agencies and organizations; the EPA rated it as low as their scale allows. . A slightly modified version of an analysis of the project by Dan Straubel (Audubon Society), Phil Dodson and Ann Drake (Ozark Society), and this author follows:
The New Madrid Floodway occupies several thousand acres of southeast Missouri from near Cairo, Illinois to just upstream from New Madrid, Missouri. The area is enclosed by a Mississippi River levee on the east and by another levee on the west. The gap in the frontline levee at the New Madrid end of the floodway has several intended effects:
- It allows the enclosed area to flood and drain more or less naturally as rainwater flows southeast from the Missouri lowlands;
- During regular Mississippi River flooding, it relieves communities downstream by allowing water to flow in through the gap into the floodway;
- During intense Mississippi flooding, it is proposed that the northern end of the frontline levee be breached, allowing Mississippi River water to inundate the region, thus reducing high water threats to communities further downstream. Closing the gap at the southern end of the floodway will render this plan impracticable.
The proposed project, designed to relieve flooding in East Prairie, has three main components: (1) closing the gap at New Madrid; (2) installing two pumping stations to provide the drainage that would be needed to relieve the floods resulting from the natural flow of water out of the southeastern Missouri lowlands; and (3) channelization within the newly enclosed area, which lies between the mainline levee and the setback levee, to enhance drainage of the floodway.
Because of deforestation and construction of the extensive drainage system in the lowlands, much of the area floods frequently. The region previously supported 2.5 million acres of bottomland hardwood and swamp forest habitat. As a result of the success of the previous drainage programs, there now remain but 50,000 acres of forest, two percent of what was previously present. Much of what was once forest is now seasonally flooded farmland, important for migrating waterfowl and amphibian species. This is the habitat that the project would further drain and destroy.
If we are genuinely concerned about wise management of natural resources and the conservation of wildlife habitat, we must ask two questions: “When have we destroyed enough?” and “At what point do we stop?” Frequently touted arguments about private property rights are not relevant to this particular issue since it’s a question of the use of millions of taxpayer dollars to benefit a handful of landowners at the expense of our environment.
The following set of reasons suggest strongly that this entire project should be thwarted:
- As indicated above, rather than reduce flooding on a regional scale, the project is actually likely to increase it.
- It is unlikely to accomplish its stated purpose of decreasing flooding in East Prairie and neighboring communities. According to evidence provided by the Environmental Defense Fund, flooding in East Prairie is caused to a large extent by seasonal storm run–off. The residents would be better served by a project that addresses problems with their storm drainage system. The community would benefit from a simple (and much less expensive) levee constructed to surround and protect it. Such a project would be far less extensive, leaving much of the New Madrid Floodway unaffected.
- Closing the gap in the mainline Mississippi levee and installing pumps to keep the newly enclosed area dry will have severe negative impacts on many species. These include many fish and other aquatic species that use the currently seasonally flooded area as spawning and nursery habitat or dwell permanently in the rivers and wetlands of the region. They also include many waterfowl species that use the area for rest and feeding during their annual migrations. According to the US Fish and Wildlife Service (USF&WS), to make up for this loss of wetlands, 36,000 acres of mitigation wetlands would be required, an area difficult or impossible to find and expensive to purchase. Furthermore, given the problematic nature of mitigation projects, there is no guarantee that even this would be adequate to retain the critical wetland services currently provided.
Curiously, in contravention of standard policy, in its Draft Supplemental Environmental Impact Study (DSEIS) the COE failed to identify where its proposed mitigation sites will be. This prevents either the COE or any reviewer from determining to what extent mitigation is likely to be successful. Since wetland mitigation historically has failed more often than it has succeeded, the absence of any proposed sites or techniques is a serious flaw that must be remedied before the DSEIS can even be judged.
Additionally, it should be noted that the COE suggests that the same mitigation acres will serve purposes that require mutually exclusive water depth conditions: i.e. a fish spawning area and fish nursery cannot coexist with the shallow depths required for red oak propagation. Because wetlands mitigation has not been generally successful, it is unlikely that mitigation for this project will work, and even if it did, oak trees take 50 years to produce the benefits required.
The COE is proposing 50 breeding cycles during which the wildlife species involved will have no available habitat. Following this era, the COE presumably expects these species to magically reappear from some unknown refuge. Furthermore, the COE is already thousands of acres in arrears on the mitigation projects to which it is previously committed. We thus have little confidence in the commitment of the COE to undertake the necessary mitigation.
The cost of this project in relation to its benefits renders it a net national economic loss. The avowed purpose—economic development in East Prairie —will probably not be realized for the hydrological reasons identified above since successful economic development is only likely where one hundred year floods are prevented—and this project doesn’t even pretend to address such a long– term flood cycle. Thus, the main benefit will be to a relatively small number of landowners farming the presently seasonally flooded area.
These landowners will be able to raise more profitable crops on land that would become protected. This is not economical primarily for two reasons: (1) increasing yields in an era of overproduction will depress further the national income farmers gain from their crops, and should be considered a national cost of the project NOT a benefit; (2) spending nearly 100 million dollars to benefit a few large landowners while not solving the problem for which the project is proposed is not reasonable.
In the Gulf of Mexico at the mouth of the Mississippi there now exists a huge “gulf dead zone,” a region of hypoxia where marine life is depleted. This is thought to be a result of agricultural nutrients flowing down the river. Since wetlands serve as nutrient filters it is unwise to reduce those few that remain as this will likely exacerbate the problem in the gulf.
Because the project does not solve the storm drainage problem in East Prairie, the prime cause for the floods experienced by that community, it fails to address its primary objective, and must be counted a failure even in its own terms. Furthermore, since current national flood plain policy quite reasonably discourages investment in areas with the flood risk that East Prairie would experience even after completion of the project, an economic boom in Mississippi County is improbable.
Interestingly, the only criticism that can be leveled at the alternative plan of constructing a much less costly levee system solely to protect the residential and economic communities around East Prairie is that such a plan would not drain agricultural land. But draining agricultural land is not even legally permissible as a purpose for such a project as the COE has proposed.
The opposition to this project voiced by Missouri’s Department of Natural Resources (MDNR), Missouri’s Department of Conservation, and USF&WS should serve as a strong warning about the havoc that it could cause to the conservation, wildlife, and water resources in the region.
We urge as vigorous opposition to this project as is possible. By stopping it, we can save the government and taxpayers not only 65 million dollars, but we can also conserve wetlands and wildlife while simultaneously maintaining sensible flood control along the Mississippi River.
Variations on the above theme were submitted to all elected state and federal officials who might be able to influence the project, as well as to the Memphis District of the COE. Responses were entirely unsatisfactory, indicating a complete failure to see any environmental problems.
Since then the project has received significant national media and political attention, reaching the level of the President’s Council on Environmental Quality, where it rests (as of this writing). The evidence suggests that all those involved are blindly committed to continuing the project. Although a new EIS has been due for weeks, all parties involved seem to be waiting for what they hope will be a more sympathetic White House come November.
Saint Francis River Channelization Project
This project is designed to deepen and widen the main channel of the St. Francis River for about six miles in the vicinity of one of the last remaining cypress and tupelo swamps in Missouri, a zone that includes the Ben Cash Conservation Area (BCCA). The initial purpose stated by the COE for undertaking this project was to clear debris from bridge foundations and to straighten, deepen, and widen the river channel to “protect the levee” although the report of the COE states that this levee is not in immediate danger. Subsequently, the state DNR granted permission to clear debris, but denied permission to channelize.
The following comments are taken from an analysis I developed of the project:
According to the Environmental Assessment (EA) the Memphis District COE has been requested by the Arkansas House of Representatives to remove the drift immediately below the Highway 90 bridge (Missouri Highway 84).
It is the conclusion of the COE that this drift has blocked the main channel; has diverted flow into borrow pit ditches adjacent to the levee; and has caused ponding that is threatening the integrity of the levee and is threatening some 510 acres of timber upstream. There was, however, no supporting evidence in the EA to substantiate the claims.
It appears to be the intent of the COE to undertake a project that is of far greater dimension than the request from the Arkansas House suggests, and far more extensive than MDNR certified in September of 1998. Indeed, the current plan is for wholesale excavation and channelizing of the river from a little upstream of the bridge to a point just prior to the BCCA.
What is most disturbing about this proposal is its complete failure to consider the potential consequences of the project for one of the few remaining regularly flooded bottomland hardwood/swamp forest areas in the state. When this project is combined with the enormous devastation that the COE is concurrently proposing in connection with the New Madrid Floodway project, the impression generated is of an agency that has lost sight of the importance of wise management and conservation of the few remaining acres of wetland left in southeast Missouri and adjacent states.
As MDNR has indicated, previous channelizing undertaken by the COE is a probable cause for extensive problems in this area—particularly the accumulation of drift. It seems entirely inappropriate to solve problems created by upstream channel projects by employing the same “solution” downstream. Unfortunately, this is also exactly the kind of thinking that leads to proposals for ever taller, wider, and more extensive levees along the Mississippi, when there is abundant evidence that the levees are major contributors themselves to the increased flood frequency they sought to reduce. The Memphis COE seems to be locked into a “control of nature” mentality that case studies throughout the world reveal to be arrogant, outdated, and unrealistic.
Since the primary problem identified by the COE dealt with debris accumulation adjacent to the bridge, it would make much more sense to address that symptom, explore what actions have been undertaken in the past that might have caused it; and then direct attention at projects that remedy those conditions and minimize future problems. Continuing the channelizing process ever further downstream is likely merely to shift the problem from the bridge to the tupelo/cypress swamp and into the BCCA.
As is conspicuously evident to even the most casual observer, channelizing the river, especially a braided river such as the Saint Francis as it flows towards BCCA, will serve to increase stream flow, and result in further scouring of substrate in the “improved” channel. The bank destabilization that the project is certain to cause can only exacerbate the erosion problem. This erosion will then most probably be deposited and build up in the swamp area and where the river enters the BCCA.
In addressing the issue of Rare and Endangered species, the COE seems to be quite content that since the USF&WS certified that no such species exist in the area, there is no threat to species flora and fauna. However, one lesson that we should have learned from the last few years of conservation research is that we should not focus our attention only on those species that we have brought to the brink of extinction.
Rather, we should concentrate our efforts on minimizing further potential devastation to habitats that we have already virtually eliminated. Only such an approach can prevent ever more species from sinking to Rare or Endangered status. Since southeast Missouri once supported 2.5 million acres of bottomland hardwood and swamp forest, it is evident that areas such as the BCCA must be accorded maximum protection. It is disappointing to note that the Corps’ EA seems to pay little regard to the problems that the proposed project might impose on the BCCA.
In the EA, little thought seems to have been given to alternatives that might be less hazardous to the BCCA. The lack of thought accorded either to developing alternative proposals, or the impact of the chosen alternative on the BCCA renders the Finding Of No Significant Impact of questionable merit. If the agency refuses to look where the greatest problems are likely to be generated, and fails to consider less drastic alternatives, the Finding of No Significant Impact, while meaningless from a rational perspective, is inevitable.
More recently, the COE modified its plan slightly by including a meander in the design, and relocating the channel completely to the Arkansas side of the state line, since that state’s responsible agency had already approved the project. This, they seemed then to argue, eliminated any need for Missouri’s concerns to be evaluated or even considered, even though the river remains the state border, and impacts of the project will clearly be felt in this state.
Conclusion:
There has been no evidence in subsequent communications from the Memphis COE that there is any intention to modify either of the projects in light of the comments of conservation and environmental agencies and organizations. Indeed, the most recent communication from Colonel Krueger of that district suggests that the New Madrid project is completely sound from a conservation perspective.
Not all Districts within the COE seem to have lost sight of their responsibility to protect the waterways and wetlands of the nation. With regret, however, we must conclude that some districts seem to be focusing their attention only on the special interests of politicians and a small number of corporate entities and landowners..