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.
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