Commander responds to stakeholder claims on basin management

By Col. Jeff Hall, Savannah District Commander

Editor’s note: This week Col. Hall received an email from a Lake Hartwell stakeholder which expressed frustration with how the Corps manages the Savannah River Basin. The grievances in this letter indicated its author held common misunderstandings of our operations. The essential claims of the stakeholder’s email were:  

  • Drought is wreaking havoc in the Savannah River Basin
  • During droughts environmental agencies make arbitrary demands to release excessive amounts of water from reservoirs. These demands are contrary to good sense and scientific data
  • The Corps lacks the courage to stand up to environmental agencies and make changes to the drought plan
  • The Corps likewise lacks good sense and ignores scientific data
  • The Corps’ current drought plan is antiquated and unfit to address today’s drought challenges
  • “Save Our Lakes Now” has proposed a worthy plan based on good sense

Read the full letter here. We are making Col. Hall’s response available to our readers to help clarify these misunderstandings for everyone: 

Dear [Sir and Ma’am],

Thank you for giving me an opportunity to explain a process that is often misunderstood by stakeholders in the Savannah River Basin. Based on some of the claims and accusations in your email I perceive there are a few areas where I might help provide some clarity.

First, I acknowledge your concern over the nation’s persistent drought this past decade. I understand your frustration. It is important to keep in mind the bigger picture in this case: the recent drought isn’t isolated to the Savannah River Basin; nearly all of the continental United States recently endured these disagreeable conditions caused by rain deficits. December 2012 marked the beginning of some relief in the Southeast after an exceptional dry period which lasted 18 months. During those 18-months the Savannah River Basin experienced a rain deficit of nearly 24 inches. This represents roughly 35 percent less-than-average rainfall for that 18-month period.

Allow me to articulate what the Corps has accomplished in these 18 months:

1) At the first signs of this last dry period we exercised our authority and not only reduced, but held outflows from Thurmond Dam to 3,800 cubic feet per second (cfs). We held these flows from October 2011 until we achieved some relief in February 2013.

2) We attempted coordination with the Federal and State natural resource agencies to reduce outflows to 3,600 cfs. When that coordination didn’t yield any greater flexibility, we engaged in the rigorous and time-consuming process of conducting another limited Environmental Assessment (EA) that was completed in July 2012 using data from the 2007-2009 drought of record.

3) Based on the above mentioned EA we were able to update our current drought plan with features that allows us to make adjustments to flows based on inflows as measured in the unregulated Broad River (a tributary to the Savannah River), which can be an early indicator of drought.

Thus, contrary to your claim the plans we have in place right now are a product of the most-recent data, most-complete knowledge and latest studies available. And the last EA only represents the most recent update. Our current drought plan is a product that has undergone multiple adjustments throughout a series of droughts, beginning in the 1980s.

Even still, there may be room for this plan to improve, and we are not opposed to making changes for the better. We are indeed working now to implement the next step of the Savannah River Basin Comprehensive Study, which will tell us, 1) how much we can reduce reservoir releases before unacceptable impacts occur to the economy and environment, and 2) how long releases can be kept at the lowest recommended level.

You mentioned your frustration on the repeated references to the need for this study, but there are two things to keep in mind about what goes into a drought plan for any basin:

1) A comprehensive basin study should be performed. The Corps is not at liberty to change its operations without receiving environmental approvals for those changes. The Corps is held accountable by other state and federal agencies to operate as it has previously described and for which it has been approved. Making changes requires identification of the value, impacts and risks of the proposed alternative. Complete and reliable information on the basin isn’t available at this time. The effort to introduce change is in progress now, but it takes time and money, the latter of which is in short supply considering our nation’s current fiscal dilemma. We anticipate having the resources to begin the next part of this study as early as July this year.

2) Even with the best drought plan, the root cause of the entire problem will still exist: rain deficits. The best drought plan cannot produce more water; it can only ration the limited water available. And when resources are rationed, no single person or entity will have access to enough.

Other organizations have suggested alternative operating procedures, and we are taking some of these proposals into consideration with the Comprehensive Study. It is important to understand, however, that these proposals amount to guesses and their ability to adequately and fairly ration water without causing unacceptable harm in any single area has not yet been demonstrated. That is why studies need to be performed.

You mentioned in your email that environmental concerns are important to you. Since this is the case, you should know that some of the current data demonstrates our release of 3,800 cubic feet per second (cfs) can create artificial drought conditions downstream today, even when the rest of Georgia enjoys a surplus of water. Data taken May 14, 2013 from the U.S. Geological Survey shows all Georgia rivers and tributaries are flowing at or above average flows for their 28-day average except for the Savannah River downstream of Thurmond Dam. See the image below.

A view of the U.S. Geological Survey stream gages in Georgia, May 13, 2013.

A view of the U.S. Geological Survey stream gages in Georgia, May 13, 2013.

This data, which can be accessed live here, demonstrates that the Savannah River south of Thurmond Dam is experiencing below average flows for this time of year. Presently, nature isn’t causing this – we are. We have not allowed releases above 4,000 cfs for more than 20 months due to drought conditions. And since we are still holding outflows at this level the graphic shows that we are maintaining artificial drought condition downstream while the rest of the state enjoys sufficient water – an imbalance we will soon rectify now that the reservoirs are above the drought triggers. My point is that we know the lower basin can survive on 3,800 cfs, but we also know this flow amounts to a ration of water and the ecosystem needs more water over long periods to be healthy. This is one limited example of the kinds of conditions that must be examined in detail to determine the right course of action during drought.

But more importantly, before any agency (such as the Corps) can take action in a way that affects the environment, the National Environmental Policy Act (NEPA) requires that agency identify and consider the effects of the proposed action, and seek the views of the public and other state and federal natural resource agencies before deciding whether to implement the action. No single agency, including the Corps or the U.S. Fish and Wildlife Service (as you suggested) can operate in a vacuum or make arbitrary demands. We all must comply with state and federal laws. Those laws provide the framework within which we operate.

For the reservoirs on the Savannah River, the Corps describes how it intends to operate those reservoirs, identifies the risks, value and impacts of those operations, and seeks to obtain environmental approval from other agencies to operate in the selected manner. We must operate in the approved manner, otherwise we violate the law. We can seek approvals to operate in a new manner, but we must obtain those approvals before we can operate in that new way – even if we are convinced it would be better than the previously-approved plan. Those required approvals provide certainty of the effects that our operations will cause. Complying with our environmental approvals keeps us accountable when dealing with limited fresh water. The laws are designed to help governing authorities ensure fair and equitable measures are in place when demands for a common resource exceed supply – such as in a drought.

During drought it helps to remember three things: (1) the public had a voice in determining how the Corps would operate when it sought public comments and approval to operate in that manner, (2) the involvement of the state and federal agencies ensures the impacts of the drought will be felt equitably by all stakeholders until water becomes plentiful again, and (3) the Corps’ implementation of the approved operating plan means the government is doing what it said it would – which may be the best we can all expect during the hardship of drought. During drought none of us have control over what really matters – rain. In the end we are at the mercy of the weather.

The Corps has a share in the responsibility for water conservation, but the Corps is only one agency among many with an oar in hand. Since water is a shared and communal resource the best way to address a shortage is look to each user in the community to share in conservation. This takes an organized effort from every concerned party. Perhaps the newly-formed Water Caucus between Georgia and South Carolina is a good start toward asking hard questions about how all stakeholders, from industry to municipalities can share in the conservation effort.

One thing is certain: the solution doesn’t rest with the Corps alone. It rests with us all.

I hope this helps with your concern and questions.

VR COL Hall

About US Army Corps of Engineers Savannah District

The U.S. Army Corps of Engineers Savannah District oversees a multi-million dollar military construction program at 11 Army and Air Force installations in Georgia and North Carolina. We also manage water resources across the Coastal Georgia region, including maintenance dredging of the Savannah and Brunswick harbors; operation of three hydroelectric dams and reservoirs along the upper Savannah River; and administration of an extensive stream and wetland permitting and mitigation program within the state of Georgia. Follow us on Twitter @SavannahCorps and on Facebook.com/SavannahCorps
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  • Jerry Clontz

    I note with interest that Col. Hall attached a copy of one letter. Why did he not attach a copy of the blog from Save Our Lakes Now that was the basis for the letter?

  • Mark Welborn

    Thank you for this information Colonel Hall. I would like to mention two points in relation to your letter. First, the obvious reason that the Savannah River below the Thurmond Dam is receiving less than average water now when all other streams are above average is because it received far above natural water flow for YEARS while the rest of the basin suffered with conditions much worse than the natural water flow would have created in order to prop up the lower Savannah. Secondly, it does not take scientific studies or large sums of money to recognize that the four foot winter drop is no longer necessary for flood control since all of the other reservoirs have been constructed in the basin after the guide rule was implemented. (Russell, Keowee, Jocasse and Bad Creek) If four feet was adequate before their construction, then much less than that would suffice now. Please address why the Corp. will not discontinue this harmful practice.

    • Hello Mark and thank you for your thoughtful comment.

      I may not fully understand your first point. Correct me if I’m wrong, but I think you are suggesting we have skewed what the natural average stream flow would be below Thurmond because we have been releasing above-average amounts of water for many years. If this is your point I would say that it seems sensible at first, but in the end this is mathematically impossible. The average stream flow cited in Col. Hall’s message is based on the 28-day average over 80 years. Considering our limitations, this average cannot be altered because in this 80-year period the same amount of water will pass through the channel with or without the dams. The dams simply function to delay water release – but all the water is eventually released as new water comes behind it. If anything, the greater surface area of the reservoirs would skew the average flow even lower – water that might have passed down the river ends up evaporating instead. The graphic communicates this fact: 4,000 cfs is below-average compared to the last 80 years of data.

      To your second point: Is the winter drawdown indeed no longer necessary? We are inclined to agree this is a possibility. But there are two points to consider. 1) It’s been more than 50 years since this drawdown was designated for the reservoir(s) and research shows that climate has changed in the basin. In fact, those who voice the misconception that our drought plan is 50 years old argue we need a new plan because weather patterns have changed from 50-plus years ago. Although wrong about the plan being old, they are correct that weather patterns have changed. In the past 50 years we have gradually been experiencing dryer dry periods and wetter wet periods. This is one reason why a comprehensive study is needed. It is plausible that the same amount of drawdown is still necessary because, although we have more storage now, we also have more forceful volumes of rain falling in shorter periods of time. I’m not arguing we still need the four feet. I’m only making an argument that responsible stewardship demands we study this to be sure it is safe to change the drawdown amount. 2) Once a study determines less drawdown is needed, we still need an act of congress to authorize a change in flood storage allocation. Congress approved the original four-foot drawdown and the Corps does not have the authority to change it. This is one reason why we are pursuing the comprehensive study. It will give us the necessary data to recommend changes based on certainty of the outcome.

      I hope this helps. Please enjoy the full reservoirs! ~Russell

  • Barry Ouzts

    Having owned a place on the lake for 20 years, I have seen and studied the water level problems. The more one studies the entire job of the corp. The more one comes to realize how complicated it is and the good job they do. Those that are cocksure of the problems and answers to those problems, usually have not studied them well yet. Thank you, Barry Ouzts

  • jimmy

    Colonel Hall, first thank you for your service in the military. While we all understand that drought is the main reason water levels have been down and we don’t expect the lakes to stay full, letting them drop to 14 feet down severely impacts their viability. I believe all we are asking is that you use the data you have and help us help you get the necessary changes made to a plan that is not working.

    You stated above that changes were made at the first sign of drought in 2011. Looking thru your website, the drought started in May 2011 with almost half the average rainfall and contiued with much less than average thru October of that year. The lakes were full at the beginning of June but Hartwell dropped almost 3 feet that month. Starting on July 2, outflows from Thurmond were increased to 6000 cfs and reached as high as 7000 cfs with many weeks in the 6500 range. The flows weren’t reduced until we hit the first trigger level. I have a hard time believing anything was done other than what was required at the first trigger level. Could you please explain.

    Someone else has commented on this but it does seem quite short sighted to say the lakes have created an artificail drought for a month or so when an artificial river has been flowing for over a year. I’m not suggesting this but if you don’t want an artificial river or drought, then make the outflows equal the inflows.

    One last question. I read that you take input from several agencies but who makes the final decision and what are the consequences if you can’t meet all of the request? In my business, I take input from several groups but it’s up to me to make a balanced decision. A decision some will not like.
    Again, thank you for your comments.

    • Dear Jimmy: We have addressed your first objection in the past, but for the benefit of other readers I’ll do my best to articulate it again. Drought-condition outflows are tied to two things: reservoir levels and percentile of the Broad River inflow during Drought Levels 2 and 3. You are suggesting we further restrict outflows at normal reservoir levels based on amount of rainfall compared to average. If we were to apply your suggestion evenly across the drought plan, it would allow us to increase flows when the reservoirs are at lower drought levels as long as we are receiving above-average precipitation (such as this last December). Can you see how this would be unpopular? But I don’t think you really want this. I think your proposal comes with the implication that we do not apply the rule evenly; that is, to keep the outflow restrictions in place when reservoir levels are lower. If we do this, it would marginalize hydropower as a project purpose. Hydropower is one of the original purposes set by Congress and it had significant influence on the justification for building the dams. It is what allows us to repay the taxpayer for the construction of the dams and contributes to keeping power costs low in the Southeast. But in order for hydropower to realize its usefulness in any meaningful way, SEPA needs a certain level of predictable, reliable access to hydropower during peak power demands. Currently, they do not enjoy this access when we are in the mildest form of drought (defined as four feet down). With your suggested added restriction, hydropower would be, de facto, excluded as a purpose.

      Concerning your last question: What Col. Hall communicated was that in order to deviate from the approved plan, we need to attain concurrence from all the state and federal agencies. A single objection from any of the agencies means we must stick to our approved plan. The Corps makes the final decision when the plan changes, but only after the an Environmental Assessment where the state, federal, and public agencies and the public in general have input. The suggested operation must also be in compliance with the Clean Water Act and the Endangered Species Act. ~Russell

      • jimmy

        Russell, Somehow we are just not communicating because I never got a follow up reply to my simple question. I didn’t make any suggestions to do anything. The Colonel stated that the Corp started reacting to the most recent drought as soon as it started and my question is what did you do other than follow the rule that says drop to 4200cfs when the lake gets four feet down which I believe you are required to do. I don’t think that qualifies as responding. There was a previous post that suggested you managed the top 4 feet of water for all five puposes equally. Increasing the flows to 6500cfs and watching the level drop 2 feet per month is not managing. The bottom line is that the lakes were full at the beginning of June 2011 and down 10 feet by November, that’s only 5 months.

        I am an electrical engineer and understand the power grid quite well. You are correct that when the lakes were built they provided over 30% of the grid requirements. That percentage now is less than 6% unless you have some data I don’t. If we had sustained normal rainfall, then hydropower would not be marginilized as you state and the outflows for generation could be kept at whatever level mother nature provided. In fact, the generators are much more effecient when the lake is full which is one of the main reasons the power companies keep their lakes full. Also, the total number of Mwh’s you can produce is based on how many gallons of water you have, not how fast you run the generators. Yes, you can make a lot of power at 6500cfs but if it’s not raining, then you are going to operate at a much lower output for a longer period and the net is that you didn’t make anymore power than you would have at a slower flow earlier. In fact, it may be less because the lower the level, the less efficient the generators. Hydropwer is a great resource when it rains but it’s quite ineffecient when it’s fuel, water, is not replenished.

        The last item I think I understand . The Corp can’t deviate from the current plan because there is virtually no way to get concurrence of anything different from that many agencies. Is there a schedule of when the new comprhensive study is going to begin? And when it begins, how will the public be provided access or input to the process. Also, does the Corp at least have an opinion of how the plan should be changed? I think the public would get behind you more if you used the 50 plus years of data you have and the expertise to develop a better plan. All we see now is “our hands are tied”, which they are, but offering some alternative steps and asking for the publics help would go a long way.

        As always, thank you for your time.

        • Touché, Jimmy. Thank you for your thoughtful reply. (RE: past discussion on this, I’m referring to your dialogue with Billy here: )

          As the Colonel stated, after requesting deviation from the plan, he also implemented and completed an EA and was able to make adjustments to the drought plan at its completion. As you know, EAs can take up to a year to complete. It’s a slow process, but the most effective tool available – and the decision to implement was immediate.

          We expect the Comp Study to begin within a few months and the process is anticipated to take two years. We are examining at least five alternatives to the plan and are recommending incorporation of adaptive management. The study may suggest there are more benefits from leaving the pools closer to full. If that is the case, we will go back to congress and recommend a change.

          However, you suggested a greater volume of electrical power might be achieved if, while at full pool, we limited generation to slower flows to avoid the less efficient lake levels and drought trigger. This may or may not be true, but it doesn’t matter. The significance and usefulness of hydropower is not in its volume, but in its timing – that is *when* it is available. Hydroelectric dams have the ability to provide power almost immediately, making it uniquely useful during periods of peak demand, especially for rural areas. Outside of hydropower, peaking power is costly to procure on the open market. Although power generated at federal dams represents a small component to overall grid requirements, it is a very expensive component to purchase from conventional energy supplies. Likewise, these projects weren’t built to contribute significant amounts to the national grid. They were chiefly designed to electrify rural areas in peak demand periods.

          Even further, I will add that if SEPA consistently cannot depend on access to hydropower *when* power companies demand it, those customers will arrange to contract for their peaking power elsewhere. (And drought in the last 15 years has already made this a realistic threat.) But understand this: Hydropower funds the whole project, from recreation to dam operations to flood prevention. If enough SEPA customers pull out, if hydropower is no longer a viable source of funding, the cost of running the operations will be passed on to project purposes that benefit most from the changes. The shift of that burden would likely be an unexpected and unpopular surprise.

          ~Russell

          • jimmy

            Russell, Thank you for your honest reply. Sounds like the time to get an EA is the main problem. What would it take to get this changed so you can actually manage the water? If it takes a year, then you will always be into the required releases before you can react.

            I understand peak power requirements quite well also. I have designed several large indusrtial facilities across the US and one of my jobs is to reduce that peak load because unlike residential users, companies pay a peak demand charge and it is based on the largest peak reached during a billing cycle and it is quite expensive. Your release times would indicate though that you are covering peaks caused by residential A/C and stoves coming on in the evening. In either case, the amount of power you can generate is still based on the number of gallons of water you have and during a drought, letting out more early and slowing it down later does not create any more revenue than letting it out slower to begin with. You are correct that hydro is a very good tool to meet peaks but the basic physics is that you need more water to create more power.

            I fully understand the financial issues cased by the recent droughts but letting the lakes down below 10 feet causes many financial issues also. I personally would be in favor of finding additional revenue for the project if the droughts persist and the COE is transparent on how they spend their funds. One instance would be that if you are funding the fish ladders and are draining the lakes to fund them, that would be a problem. I’m not accusing you of doing that but if funding is becoming a problem, then open the books and let’s find alternate meams to conserve the water we have and keep the project viable.

  • ldh

    what drought we are down 1″ for the past 13 months