COPY OF COMMENTS RECENTLY POSTED ON BALANCING THE BASIN

The corps publishes a blog called Balancing the Basin and offers a place for comments from readers.  Following is a recent comment offered by one of our members that seems very appropriate for the current comment period on the new Drought Plan.

COPY OF RECENT COMMENT SUBMITTED TO BALANCING THE BASIN:

I'm not sure where the post came from but i was asked recently by one of our members (Save Our Lakes Now) about two comments apparently made by the corps. One stated the increased cost of power when SEPA has to buy it and the other stated that 3600 anytime the lakes are down increases the potential for flooding downstream.

Regarding the increased cost of power, SEPA has 7 basins other than the Savannah River Basin to pull power from. That is at the same cost as power generated by our basin. In other words there is no additional cost for power.

Regarding the propensity for more flooding downstream if you keep the lakes more full that is an irrational statement. Obviously more water in the lakes means there is more water in the lakes. That is what we want. What is needed is good flood control not arbitrary reliance on having a drought before you have heavy rains.

COMMENTS ON PROPOSED DROUGHT PLAN

note-- the deadline for comments on the new drought plan was noon today but the Corps did not discuss this with the SRBAC which Save Our Lakes Now is a participant until yesterday.  If you feel strongly and want to make comments I suggest you go ahead and send them in now.  The Corps will be subject to much criticism is a lot of late comments are ignored.  The email address for comments is CESASPD@USACE.ARMY.MIL.

The proposed Corps plan drops releases sooner than the current plan which is a move in the right direction but they are basing their decisions on incorrect assumptions.  Here are three that shout that there are problems with their reasoning:

1. They base their conclusions about the impact on recreation on a faulty Clemson study which indicated little to no effect on economic factors.  The study is badly flawed because you cannot gauge the impact of poor level control when you are in the middle of poor level control.  Real estate values, etc. depend on reputation of a given location.  Our reputation sucks from 2002 forward therefore no measurement during that time period means anything. Additionally, when pressed, the Corps looks only at how many boat ramps and swim areas are impacted rather than real estate values that lake stakeholders are concerned with.
2. The Corps claims that power production quotas have to be met if possible and hold our release rates well above what they should be trying to meet those.  SEPA has 8 basins they get hydropower from.  Anytime we are in drought they can get their power at the same cost elsewhere in the 8 basin system.  In other words power should not even be part of the discussion when it comes to drought control.
3. Finally, if an aquifer were dropping 5ft, 10ft, etc. DNR would be hysterical and wanting to limit water usage of anyone causing that loss.  Here we have the Corps getting a free reign and causing this kind of loss of fresh water with impunity.  The Corps needs to be required to justify wasting fresh water rather than have that a non entity in their discussions.

 

COMMENT JUST ENTERED ON BALANCING THE BASIN CONCERNING DROUGHT

One of our Save Our Lakes Now people just sent in a very informative comment to the latest "Balancing the Basin Release". It is repeated in full below:

This all sounds nice and technical but there is a much simpler reason the lakes aren't more full and possibly fully recovered.  It is simply the refusal by the Corps to conserve as much fresh water as possible during a drought by dropping releases to the minimum demonstrated to have no significant environmental impact.

IN THE CORPS OWN WORDS IN THEIR PLAN FOR WHAT TO DO IF THE LAKES HIT THE BOTTOM OF THEIR CONSERVATION POOL, "3600 CFS HAS NO SIGNIFICANT ENVIRONMENTAL IMPACT DOWNSTREAM OF THE LAKES".  BASICALLY LAKE LEVELS HAVE NO PRIORITY COMPARED TO POWER QUOTAS (WHICH ARE MEANINGLESS BECAUSE SEPA CAN GET THE SAME TYPE POWER ELSEWHERE IN THEIR 8 BASIN SYSTEM ANYTIME WE ARE IN A DROUGHT) AND A KINDERGARTEN TYPE APPROACH TO BEING FAIR TO EVERYONE MEANING THEY WANT TO "TREAT THE RIVER STAKEHOLDERS FAIR COMPARED TO LAKE STAKEHOLDERS".

CONSERVATION OF FRESH WATER IS NOT A KINDERGARTEN GAME.  THROWING AWAY FRESH WATER (EVERYTHING RELEASED FROM THURMOND BECOMES SALT WATER AND IS NO LONGER OF USE TO ANYONE) IS CRIMINAL AND COULD LEAD TO VERY SERIOUS CONSEQUENCES FOR THOSE WHO DEPEND ON THE RIVER FOR THEIR FRESH WATER SUPPLY. THE PERSONS RESPONSIBLE WOULD BE CONSIDERED INCOMPETENT IN ANY BUSINESS VENTURE I KNOW OF. 

QUICK ANALYSIS OF CORPS CHANGES TO DROUGHT PLAN

The Corps has just announced with great excitement changes they plan to make to the drought plan.  Matter of fact they are having a big meeting to discuss this with the public tomorrow night in Toccoa, GA.  The excitement comes from the fact that they are raising the levels where release rates are decreased during droughts.  While this is a move in the right direction their reasoning is based on flawed assumptions and basically amounts to nothing more than smoke and mirrors.

They claim to be balancing the economic impact on hydropower against that of recreation. There are two major problems with their reasoning. First their is no economic impact on hydropower from droughts.  According to the South Eastern Power Association (SEPA) it doesn't matter to them where they are obtaining power from within the 8 reservoir systems they draw hydropower from.  When we are in drought most of the others are not and our loss in production can easily be made up from the others. Second the economic impact on recreation is based on badly flawed data. The Corps tried to measure the economic impact of low lake levels but did so during a time of repeated low lake levels that have destroyed our reputation on level control.  That is like trying to measure the impact on the dollar value of a car from a bad ding when the car is already full of dings. You can only get a true measure when you look at a time when the car is in like new condition.
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Simply looking at the waste of fresh water when you send more water to the river (and hence the ocean) than is available from rain says we need to reduce releases to the minimum possible anytime the lakes cannot be held to full pool due to drought.  Just 100cfs released unnecessarily amounts to about 60million gallons of water being thrown away daily. This tells me that we need to go to the minimum demonstrated safe release rate of 3600cfs as soon as the lakes can no longer be held to full pool due to a drought.  And we need to look at whether even lower release rates would be acceptable.  For the benefit of those who feel dropping all the way to 3600cfs is too much, stop and think of what the river used to be like during droughts before the dams were built.  This is not denying the river water. Rather it is guaranteeing adequate water even in times of severe drought.

CURRENT DROUGHT CONTROL BY CORPS TOTALLY ILLOGICAL

Over the past 15 years the rationale for the Corps continuing our horrible drought control plan is that they have to treat all stakeholders fairly.  Initially there were over 10 excuses and erroneous reasons for not changing the plan but they have all been debunked.  Now the defense against changing the  plan and responding more quickly to drought conditions by way of reduced releases is the need to be fair to river stakeholders. This is the only claim remaining that has even a sound of validity. While it may be OK in telling kindergarteners to share, we are talking about something that is far too valuable for such an argument.

Let's take selfish interests completely out of the picture and relook at this. We are talking one lake of over 270,000 acres and another at least half that large.  Dropping these lakes any more than is absolutely necessary is criminal when you look at the amount of fresh water involved. Every drop of water released beyond that coming down from rain is a horrible and dangerous practice. Basically what Save Our Lakes Now is saying is any time the lakes drop below full pool (too little rain coming in to hold lake level) we need to reduce releases to the absolute minimum that has been demonstrated to work downstream. 3600cfs has been demonstrated to work repeatedly in recent droughts and the Corps even stated that there is no significant environmental impact from lowering release rates to this level (statement was made to justify no TA needed for their Armageddon plan for destroying the lakes one by one in a drought that exceeds our conservation pool provisions).  Hence, until better data showing even less works, we need to immediately go to 3600cfs when the lakes can no longer be maintained at full pool.

Limiting my arguments to pro river stakeholder interests, anything above the minimum tolerable release rate puts them in danger of literally losing their fresh water supplies. It's fine to argue about wanting more water running in the river as long as the lakes have water.  But if that ends, river stakeholders are the ones that will be destroyed. It's sort of like balancing your bank account.  It's nice to spend a little more money than the minimum needed right up to the time you go bankrupt.  Unfortunately following that, their is no further discussion.

POOR CONTROL ADDS UP OVER TIME

Just like a carpenters level, lake level is an accurate measure of where we are in a drought.  But the Corps insists on ignoring that and using weird bases for release rates such as inflows from the Broad River.  Something along the lines of when inflows from the Broad are less than 10% of normal they respond with certain release rates.  Excuse my French but using this instead of lake level is the height of stupidity. When the lakes cannot be held at full pool we are in a drought or the effects of a drought and release rates need to be held to a minimum until the lakes refill.

The corps was guilty for years of using misleading information to justify their poor performance with drought management.  Over the last 10 years we got rid of all those erroneous claims one by one.  But now we are left with downright stubborn refusal to use common logic to minimize the damage to lake levels from droughts.  Insisting on release rates of 4,000 and 3800 versus 3600 while in the middle of a drought has cost over a foot of lake level in the current drought.  Refusing to restrict flows to 3600 immediately when lake levels can no longer be held at full pool has cost many more feet of lake level.  And refusal to stop releases when the river downstream is flooding has cost still more loss of level.

If the Colonel were judged for his handling of Recreation during droughts in the same manner as a CEO handling profits during difficult times he would have been fired for incompetence years ago.

MORE EXCERPTS FORM OFFICIAL CORPS DROUGHT PLAN

Yesterday I published several quotes from the official corps drought plan showing several issues we have been misled about. Following is one more quote from the drought plan that is commonly not known and the results of a formal request for comments by the Corps during the drought of 2008.

The following quote from page 10 of the 1989 drought plan shows where 3600cfs came from:

QUOTE FROM PAGE 10 OF ORIGINAL DROUGHT PLAN--- " THE DEPARTMENT OF ENERGY'S SAVANNAH RIVER PLANT HAS THREE OPERATING NUCLEAR REACTORS AND USES WATER (APPROXIMATELY 945 CFS) FROM THE SAVANNAH RIVER FOR COOLING.  A LARGE PERCENTAGE OF THE WATER IS RETURNED TO THE RIVER AFTER COOLING.  LOW FLOW TESTS CONDUCTED DURING THE 1980-81 DROUGHT ESTABLISHED 3600 CFS AS THE MINIMUM ACCEPTABLE FLOW FOR A ONE REACTOR OPERATION.  DUE TO CHANGES IN THEIR OPERATIONS, THE SRP NOW HAS A MINIMUM DESIRED FLOW OF 4880 CFS TO ENSURE A THREE-REACTOR OPERATION AND 4130CFS FOR A TWO REACTOR OPERATION."

So 3600cfs came from SRP needs when they were operating nuclear reactors.  None of these reactors has been active since the late 1900's.  Matter of fact there is no plan to ever operate those reactors again. Humm?  what does that do to our accepted standard of 3600cfs?

The responses to a query the Corps made for comments from all stakeholders during the drought of 2008 were also illuminating.  The Corps sent out a request to all stakeholders and the public in general for comments as to whether dropping from 3600cfs to 3100cfs would present any problems for anyone. After several months we noted total quiet from the Corps on the results of that inquiry so we sent in a freedom of information request to the Corps. There were over 250 responses from all kinds of stakeholders.  All the responses indicated they were having no problems at 3600cfs and anticipated no problems if the flows were reduced further to 3100cfs. All that is except the NOAA who said it "MIGHT" be problematic to fish and wildlife and water quality. In other words, in the middle of a major drought, 3600cfs was stated to be acceptable and even lower was expected to be acceptable as well.

The full gist of this and the previous blog is to point out that "what the Corps says" is not a reliable basis for understanding their operation of the Savannah River Basin. As with any of us you can expect their remarks to be spun in the direction most favorable to what they want to do. Unfortunately what they tell us is often very misleading.  If you want to test this, ask them why they continue releases from a drought starved Lake Thurmond when the river below the dam is flooding from heavy rains.