DROUGHT PROTECTION FOR RECREATION IS NO MORE DIFFICULT THAN FLOOD PROTECTION

The past several weeks the Corps has demonstrated their expertise at level control for our lakes.  Through their skill serious flooding and expensive damages downstream of our lakes was avoided. 
If the same expertise were applied to drought protection for the recreational infrastructure (which is a responsibility assigned to the Corps by congress just as flood protection is), damages could be kept to a minimum.  What Save Our Lakes Now has been pleading for since the first major drought this century is for the corps to use their skills in minimizing drops in lake level during a drought the same way they minimize increases in lake level during periods of excessive rains.

What many hear is that we want the corps to ignore what is happening downstream in a drought and hold the lakes full.  That is not at all what we are saying.  Just as the Corps recognizes an increase of 5' above full pool is manageable without damages downstream we recognize that a drop in lake level of less than 10' below full pool is manageable without destroying the recreational infrastructure for the lakes. 

During flood conditions lake level becomes the controlling factor such that all changes are designed to stay within 5' of full pool.  During drought conditions lake level is only a secondary concern.  Instead of trying to stay above a 10' drop below full pool, the drought plan becomes a complicated series of release rate adjustments aimed at minimizing the appearance of a drought downstream and further complicated with power generation quotas that basically save pennies on the price of power supplied by SEPA at the expense of hundreds of thousands of dollars to individuals owning homes around the lake and millions of dollars to the overall recreation infrastructure of the basin. So far as water quality, water supply, and environmental concerns, past experience shows they can be satisfied as long as release rates are held at least at 3600cfs.  We know that from the survey done by the Corps following the 2008 drought of record when the Corps surveyed all stakeholders to see if a further drop to 3100cfs would be a problem.  The responses from downstream interests (eg. water supply for Savannah, Fish and Wildlife, industries below Augusta including SRP and Plant Vogel) came back that they were not experiencing any insurmountable problems at 3600 and further reductions in flow should be acceptable.  So all we ask is for the Corps to hold the lakes at full pool until release rates drop below 3600cfs, then hold at 3600cfs until the lakes return to full pool.

The studies being done are not needed to know that 3600cfs is safe.  That has been demonstrated repeatedly in several droughts since the turn of the century.  The purpose of these studies should be to determine if even further reductions to release rates during a drought are practical.

So far as whether to drop the lakes 2' or 4' for the winter, we simply ask that the corps use the same level of concern for drought conditions that they do for flood conditions.  The recent rains should have given them more than sufficient data to figure which to use.  And rather than simply say more is better which is true for flood protection, use good engineering judgment that gives balance between drought planning and flood protection.  For example we now have excellent proof that a major warming in the South Pacific like what is happening now impacts us so that 2' might work normally but 4' is needed under these conditions.  Another way of saying the same thing is please apply your skills as much as possible to keep the lakes from dropping more than 10'.

If you are wondering what damages are happening to the recreational infrastructure (which Congress made a responsibility of the Corps in 1983) with drops of 10 ft below full pool:

• low lake levels make houses around the lake lose value.  We sat in on a preliminary report by Clemson where the data on housing prices showed a drop of over 50% in the value of a house next to the lake when the lake dropped more than 10ft.  Unfortunately this was edited out of the preliminary report. 
• A noted major hotel chain wanted to locate on Lake Thurmond.  When they witnessed the huge drops that occur to lake levels during droughts they moved on to another lake in Georgia.
• Concessionaires at the lakes such as marinas, campgrounds, boat rentals, etc. lose millions of dollars.

If drops greater than 10ft were rare (maybe one every 50 years or so), losses in housing values would be temporary as would the impact on the rest of the recreational infrastructure.  But when they occur frequently as they are now these damages become permanent.

IN OTHER WORDS WHAT WE ARE ASKING IS NOT COMPLICATED.  WE SIMPLY ARE ASKING THE CORPS TO USE LAKE LEVELS AS A GUIDE DURING DROUGHTS THE SAME WAY THEY DO DURING FLOODING.

CORPS SUCCESSFUL ON ALL ISSUES EXCEPT RECREATION

I am taking the liberty to copy a recent comment on Balancing the Basin which illuminates the failure of the Corps when it comes to protecting Recreation (meaning the recreational infrastructure around our lakes).  Some editing has been applied for the sake of clarity.

COMMENT POSTED ON MOST RECENT ISSUE OF BALANCING THE BASIN:
The Corps is doing great with all but one of the responsibilities assigned them by congress.

• Power production may not always meet quota but you get as close as possible.
• Water quality and water supply have been demonstrated to be satisfactory with spans in excess of a year at 3600cfs. 
• We have a 3 lake basin but the holding power of the last 2 have been ignored regarding flood holding capacity which gives ample flood protection.
• Protection of environmental concerns is covered well by maintaining releases above 3600cfs.
• Additionally the corps has looked past the worst case scenarios and designed a plan of which basin to destroy first and second and so on when we exceed the drought of record that put us to the bottom of the conservation pool for both Thurmond and Hartwell.

But the Corps, in doing such a superb job on all these concerns has essentially ignored the recreational infrastructure of our basin. These practices have gone to the point of destroying real estate values for homes built on the lake for recreational purposes and discouraged would be developers that would provide still more recreational access to the lakes.  The Corps has stated repeatedly that they respond immediately to any stakeholder objections to the way they are operating the basin.  This is certainly not true for recreation.

TITLE ENGINEER IN CORPS OF ENGINEERS MISLEADING

As an engineer from industry I have been totally taken back by the corps' refusal to incorporate the vast amounts of information gained over the past 15 years  to improve recreation.  With the experience gained over the last 15 years there is more than sufficient data to permit improving recreation by changes to the drought plan without doing harm to the environment or water supplies.

The title of Engineer as used in industry implies constantly using  the best data available to maximize growth of the businesses they are associated with. Growth for the Savannah River Basin is tied to it's recreational infrastructure.  Because of repeated drops in lake level in excess of 14', recreational money, whether parks and campgrounds, the various concessionaires who provide access to the lakes, or real estate built for the purpose of enjoying the recreational aspects of the basin, is going elsewhere. If this were for only a year or two one could reason that more data is needed.  But this has been going on for over 10 years and the Corps is making none of the changes that are obviously safe. Instead they insist on waiting years more to get more data before changing the drought plan. From what I've seen the fact that we haven't already made changes we know to be safe is a bad omen for what they will do after the studies are complete.

I have deliberately left the argument of SEPA power needs out of this discussion because it is such a weak reason that it deserves no consideration:

• The actual increase in cost of power to the consumer is minor when it has to be obtained from other lakes and power sources. 
• Even if the increased cost of power were substantial there is no way to justify obtaining that money by destroying the real estate values of all the people with houses around the lakes.
• SEPA has stated repeatedly that they want the lakes as full as possible because our power is primarily peaking power that comes on line during peak power consumption. That is endangered greatly when we let the lakes drop 14'

CORPS ACTIONS AND WORDS EXPOSE FAILURE TO RESPECT RECREATION

Look at recent publications by the Corps and they show extreme concern for flooding.  This is one of the seven basin issues the corps is charged with protecting.  For example the most recent Balancing the Basin expresses high levels of concern and advance planning because the weather services are predicting high rain levels in the next few months due to unusual warming in the Pacific Ocean.

Look at publications over the past decade and you will see high levels of concern for Hydro Power, Water Quality, Water Supply, and Fish & Wildlife.  Navigation, rightly so, is no longer a major concern and it is seldom spoken of.  The only responsibility the Corps repeatedly ignores is Recreation.

Note that for each of the concerns other than recreation the Corps uses the best information available to guide their actions.  For example nowhere do they propose studies prior to making changes to protect against flooding.

Although the Corps knows full well how to avoid catastrophic drops in lake level they insist they cannot use this information without waiting years for studies.  We have at least 3 times in the past 10 or so years where release rates of 3600cfs proved sufficient for months on end.  The Corps even claims no impact on the environment from this release rate in their published plan for operation should a drought exceed the capacity of the conservation pools for Thurmond and Hartwell. Dropping to this release rate anytime lake levels cannot be maintained at full pool from available rains would go a long way toward protecting the recreational infrastructure at times of drought.

When you look at Corps publications explaining how they maintain all their other responsibilities you see statements to the effect that they seek approval from all the various entities representing hydro power, water quality, water supply, and fish & wildlife.  Not only do they fail to respond to any cries from the recreational infrastructure, the one group excluded from evaluating all their studies is recreation.

When pressed the Corps pleads ignorance concerning how much damage lake levels do to the recreational infrastructure.  They even made feeble attempts to show no financial damage from lake levels more than 10ft below full pool.  Simple logic tells anyone with common sense that low lake levels have a huge financial impact on recreation.  Take for example the numerous retirement communities around our lakes.  If you were retiring and looking for a great place to enjoy your retirement would you go to a lake where your boat dock will be frequently on dry land?  The same logic can be applied to investments in any part of the recreational infrastructure.  And not surprisingly a quick look at the financial health of these shows massive damages from poor drought controls.

Unfortunately our congressmen who could force major improvements for recreation are buying the fallacious claim by the Corps that major studies are needed before they can improve things.  We do not propose blindly changing things just to improve recreation.  We are pleading for the Corps to use the knowledge they have already gained from recent droughts to minimize damages to the recreational infrastructure by droughts.  Still further improvements may be possible from studies but use of existing knowledge is needed to protect recreation until those studies can be completed.

TEST RESULTS IN BUT CONCLUSIONS DEPEND ON WHO INTERPRETS THEM

We just had a major rain event and the lakes only rose 3ft.  That says under similar circumstances, had the lakes been down 2ft, the lakes would have ended up only 1ft above full pool.  This type of real life. full scale test gives beautiful data for deciding how much draw down should be used each winter for our basin.  But the conclusions that are drawn from such a test depend on who is interpreting the results.

If we look at the results from the perspective of downstream environmental interests or in terms of safety factors for water supply and water quality one could conclude the more draw down the better regardless of the results of this test.  If on the other hand you look at the results from the perspective of impact on recreational infrastructure which includes real estate around the lakes you would conclude that 2' draw down looks adequate.

In short our problem is not in having enough data.  Our problem is in whether true balance is provided between lake and downstream interests.  For the past decade the Corps has been vociferous on downstream needs, power quotas, etc. etc.  Repeatedly we are told that if any agency representing downstream interests balks at any action the corps may wish to take that action is abandoned.  We also have heard repeatedly that power production quotas must be met if at all possible.  During this same period of time, although lake interests have been screaming for less drop in lake levels, the corps has made no effort to accommodate those interests. And it has become glaringly obvious that lake interests are not represented when it comes to drought plan decisions.

Another facet of the same problem is the Corps uses the excuse that they need congressional approval for this or that change.  This could be solved by our congressmen helping the corps with their interpretation of the rules.  But our congressmen remain silent on the issue.  Apparently they have more important issues to contend with. Or maybe this is another example of why people have grown totally dissatisfied with the way congress is handling our problems.

WHERE ARE OUR LAKE ADVOCATES???????????

The new colonel stated he is an advocate for lake interests.  Our congressman in both SC and GA claim to be advocates as well.  But we are on the verge of another disaster for lake levels and all that entails. The Corps is doggedly following the plan that has reeked disastrous results for our recreational infrastructure repeatedly over the past 10 to 15 years.  And our congressmen sit idly by while we go into this madness once more. 

Apparently the thinking is we are not in trouble until the lakes drop 10ft or more.  It is true that actual destruction to our recreational infrastructure doesn't occur till then.  But once you drop more than 2' and continue with releases from Thurmond above 3600cfs a drop of over 10ft will occur repeatedly in our current weather pattern.  NOW IS THE TIME FOR ACTION.  NOT AFTER THE LAKES ARE DOWN APPROACHING 10FT BELOW FULL POOL. Matter of fact action to prevent disastrous lake levels has to occur well before the lakes drop to the levels we are at now.

ITS NOT NICE TO CRITICIZE THE CORPS BUT

We are witnessing a new example of the Corps' total disrespect for the recreational infrastructure of the Savannah River Basin.   Everyone knows that before the Corps can use release rates below normal they feel compelled to get the approval of all downstream stakeholders. Hence in drought conditions the corps seeks approval from all the various stakeholders that might be impacted by low river flows before making such changes.

Now the shoe is on the other foot. The Corps apparently is concerned about projections for heavier than normal rains this fall and winter.  As a result they are using ridiculous release rates in excess of 5,000cfs in the middle of drought conditions. Why are they not now seeking the approval of all stakeholders that might be impacted by low lake levels.  For example as a lake stakeholder I would like to know what the maximum safe release rate is and would it not be possible to hold off on dropping levels now by using higher release rates earlier in a heavy rain event. 

The main concern from the standpoint of lake stakeholders is what if the projections for heavier than normal rains is incorrect.  What if drought conditions persist. Insanity is doing the same thing that has caused destructive lake levels repeatedly in the past and expecting different results.