June 29, 2000
Commissioner Thomas Pizano, Chairman
Luzerne County Flood Protection Authority
Luzerne County Courthouse
200 North River Street
Wilkes-Barre, PA 18711
Dear Commissioner Pizano:
On behalf of the Officers and Directors of the Greater Wyoming Valley Audubon Society (GWVAS), I would like to offer the following comments on the Wyoming Valley Inflatable Dam Feasibility Study. We appreciate your providing us with the opportunity to comment on the findings of the Feasibility Study, and we hope that you and your fellow Commissioners will give these comments serious consideration when you determine Luzerne County's role in the inflatable dam project.
In our original Comments on the Proposal to Install an Inflatable Dam in the Susquehanna River in Wilkes-Barre, Pennsylvania ("Comments"), which we submitted to Gannett Fleming, Inc. in February, 1999, we outlined our concerns about potential impacts to the wildlife and natural habitats of the Susquehanna River corridor in the proposed project area. We are pleased to see that our Comments, as well as other information that we have provided, have been incorporated into the Feasibility Study. However, we are puzzled by the conclusion, as stated in the Feasibility Study, that "the proposed dam and pool may [emphasis added] not directly affect most terrestrial species known in the study area." We believe that the Feasibility Study clearly suggests that these species will be directly affected by the project. Furthermore, we disagree with the Executive Summary statement that the primary environmental concerns are fish passage, wetlands, water quality, and combined sewer overflows. While these are legitimate concerns that must be addressed, we believe that potential impacts to terrestrial habitats and the species they support are equally important issues. We are also concerned that the conclusions of the Feasibility Study may be based upon incomplete information, inadequate studies, and speculation.
Water Quality
(Section 7.3)
An example of incomplete information and speculation can be found in the Feasibility Study's section on water quality. Although the Feasibility Study thoroughly addresses Susquehanna River water quality in terms of pathogenic organisms from municipal sewage, it fails to satisfactorily consider the appearance of the water in the River's Wyoming Valley stretch. The Feasibility Study dismisses the "color" of the water as an "aesthetic" issue, and seems to assign such "aesthetic" issues minor importance at best. However, such issues as water color may have an impact on the River's desirability for recreation, which would, in turn, impact the analysis of the River's economic potential as a source of water-oriented recreation.
Due to the presence of suspended particulate matter, the water's turbid appearance in the project area differs considerably from its relatively clear appearance in such upstream areas as Falls, PA, where the River is used much more extensively for recreation. The Feasibility Study failed to identify the sources of the suspended materials. It likewise failed to determine if, and at what cost, the suspended material can be eliminated. Given that the River's appearance would be a primary concern of recreational users, this issue must be addressed more adequately before the economic analysis can be accepted as reasonably accurate.
Wetlands
(Section 7.2)
Another example of inadequate information is the Feasibility's Study's assessment of the likely impacts to wetlands in the project area. The preparers of the Feasibility Study admit to having failed to perform "a full delineation of all wetlands...." They also admit to having depended upon "limited field reconnaissance" in estimating total wetland acreage. The absence of a full delineation of all wetlands in the project area, and the limited amount of field work that apparently was employed, call into question the Feasibility Study's conclusion that "existing wetlands are not expected to be negatively affected." The Feasibility Study further states that, "At this stage of the project planning, it would be premature to assume that any change in hydroperiod would be detrimental to existing wetlands." Based upon the apparent lack of field work, and the resulting absence of accurate data, we believe that assuming that changes in hydroperiod would NOT be detrimental to existing wetlands would be equally premature.
Perhaps even more alarming than the apparent absence of effort to perform an accurate assessment of impacts to wetlands are the suggestions that wetlands can be created in other areas as mitigation for lost or degraded wetlands, and that a "post-construction monitoring period would also be a useful method of determining the project affect on soil moisture and hydroperiod." We would like to note, first, that constructed wetlands never have the same value for wildlife as natural wetlands have, and second, that determining the impact of the project after the fact is not an acceptable method by which to determine the project's impact on the ecological integrity of the River corridor. The proposed inflatable dam cannot be viewed as an experiment. The environmental impacts must be determined as thoroughly and as accurately as possible before a decision to move forward can be considered.
Aquatic Habitat and Species
(Section 7.7)
Further examples of inadequate study and speculation can be found in the Feasibility Study's analysis of impacts to aquatic habitats and species. According to Section 7.7.4, "Studies were not performed to model and predict the aquatic conditions with a dam, but potential minor changes to aquatic habitat are described below." In the absence of modeling and other studies, we question the validity of the Feasibility Study's description of "minor changes to aquatic habitat." The Feasibility Study should not be an exercise in speculation. Without adequate information from well-designed scientific studies, no valid conclusions concerning the impact of an inflatable dam on aquatic communities is possible, and without valid conclusions, the project cannot be determined to be of little or no significant impact to aquatic habitat and species.
Terrestrial Habitat and Species
(Section 7.8)
Regarding potential impacts to terrestrial habitats and species, we believe that the stated conclusion that "the proposed dam and pool may not directly affect most terrestrial species known in the study area" cannot be reached based upon the information in the Feasibility Study. Section 7.8.4 of the Feasibility Study confirms our contention that the proposed impoundment would "reduce or eliminate seasonally exposed [shoreline, island, and gravel bar] areas of nesting, foraging, and resting within the lake limits," and that the "reduction or elimination of these habitats would reduce terrestrial wildlife use of the river shoreline." Hence, the impoundment would directly, and negatively, impact populations of waterfowl and wading birds in the project area.
In addition to the negative impacts on waterfowl and wading bird populations, the project could have negative consequences for forest-dwelling species. The Wilkes University study that is cited in the Feasibility Study contends that groundwater levels in the project area fluctuate in direct relation to changes in river elevation. While the Feasibility Study addresses such effects on groundwater levels, it does so incompletely. Section 6.5.4b of the Feasibility Study describes a method for calculating increases in groundwater levels at various distances from the river. Section 7.8.4 describes the floodway forest's dominant tree species, silver maple (Acer saccharinum) as a "facultative wetland species" that is "already adapted for life in wet areas where the water table fluctuates [emphasis added]."
We agree that most plant species in the floodway are likely adapted to fluctuating water levels. However, maintaining a consistently high water level behind a dam would eliminate these fluctuations, thereby possibly resulting in root inundation, and perhaps even surface inundation, for a continuous, approximately four-month period. While some obligate wetland species may tolerate such conditions, not all facultative wetland species exhibit such tolerance. Furthermore, other canopy species exist in the floodway forest, as do various understory woody and herbaceous species. The Feasibility Study fails to address impacts to these species.
The Feasibility Study also failed to determine soil penetration of root systems and the normal levels of groundwater in the project area during various times of the year. Without data concerning the proximity of groundwater to the surface, and without information concerning the depth to which root systems penetrate the soil, the calculations of groundwater fluctuations are meaningless in that they do not, by themselves, adequately address possible impacts to the floodway forest, damage to which would directly result in severely negative impacts to hundreds, and perhaps thousands, of migrating birds, and to resident birds, mammals, and herptiles. We view the omission of information concerning normal groundwater levels and root penetration as a serious shortcoming of the Feasibility Study's analysis of environmental impacts.
Other environmental impacts addressed in the GWVAS Comments, from which the Feasibility Study borrowed extensively, concern the effects of human use of riverine and riparian habitats (Section 7.8.4). Both the GWVAS Comments and the Feasibility Study cite scientific research indicating that increased human use of shorelines, islands, and forests would be detrimental to these habitats and to the wildlife they support, various species of which are known to be particularly sensitive to human disturbance. The negative affects on birds include a lack of breeding success, decreased survivability of broods, and increased vulnerability during molting periods. The Feasibility Study states that bird species "could be substantially affected by additional human contact," and that "the increased recreational activity on the river could lead to the reduction in numbers of certain wildlife that make migratory stopovers in the area or inhabit the area permanently."
The Feasibility Study projects that the proposed impoundment could attract from 200,000 to 400,000 visitors per year (Section 10.2.1). These figures conservatively translate to approximately 1100 to 2200 visitors per day. These numbers would be expected to vary between weekdays and weekends, with weekends likely experiencing much higher visitation than the per-day calculations indicate. Since these numbers are substantially higher than the number of people who currently use the project area, there can be no doubt that the increased human traffic would negatively impact wildlife, while decreasing the overall enjoyment of human users who seek the solitude that the River corridor currently provides. The Feasibility Study failed to determine the project area's "recreational carrying capacity," which we believe would be greatly exceeded by the projected increase in human use.
Economic Analysis
(Section 10)
In addition to the negative impacts to wildlife in the project area, and as an example of unrealistic speculation of the project's economic potential, consider the information on comparable projects. Section 10.2.3 of the Feasibility Study describes several "comparable projects," while claiming that the most comparable project is one in Augusta, Georgia. This project cost, between 1982 and 1995, a total of $349 million, which is approximately twenty-five times the $14 million that have been appropriated for the Wilkes-Barre project. Based upon these figures, the similarity between the Augusta and Wilkes-Barre projects is at best difficult to fathom. As a means by which to defray the costs of an inflatable dam, the Feasibility Study proposes instituting a variety of fees and memberships. While some of these may be appropriate for new amenities, fees for boat and watercraft launching and parking (supported by 77% and 46 % of local businesses, respectively) would be objectionable. Such fees would have the effect of making private a currently publicly accessible resource. In that sense, the impoundment would be very similar to Harveys Lake, to which dam proponents often compare the Wilkes-Barre project, and to which the public enjoys only very limited access.
Perhaps a more comparable project, and one that is at least closer to home, is the Sunbury inflatable dam. A point worth noting about the Sunbury project is that the primary beneficiary, according to the Feasibility Study, has been Mystic Mountains Estates and Village, a real estate development company. If the Wilkes-Barre project is intended to stimulate the local economy through development of lakefront property or other natural areas, then the project's environmental impact will be much more severe, and more far-reaching. Such development would also be contrary to national and local efforts to curb suburban sprawl.
Based upon the Feasibility Study's information concerning impacts to wildlife and wildlife habitat, we question the conclusion that the inflatable dam will not directly affect terrestrial wildlife in the project area. The Feasibility Study makes clear the impoundment's potential to have a direct and negative impact on waterfowl and wading birds, and possibly on forest species. The Feasibility Study makes equally clear the likelihood that increased human use of the project area will have a similarly direct and negative impact on wildlife both on/near the River and in the riparian forest. Therefore, we believe that Luzerne County should not proceed with plans to construct and operate the inflatable dam.
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While the Officers and Directors of the GWVAS oppose the installation of inflatable dams in the Susquehanna River, and we urge you to reject the proposal for an inflatable dam or dams, we recognize the River's potential to be viewed as a community and regional asset, and to stimulate economic development. In our Comments, we outlined ecologically sound economic alternatives to an inflatable dam, and we ask that you give our suggestions serious consideration. We agree with Mr. Timothy E. Goodger, of the National Marine Fisheries Service (M-63), that "non-dam alternatives should be compared to the inflatable dam relative to environmental impacts, as well as to the quality of recreational opportunities provided for the cost required." Such alternatives would result in fewer, if any, conflicts with those who currently use the project area for fishing and canoeing, and for such passive recreational pursuits as wildlife watching. The alternatives would also result in smaller, and perhaps no, burden for both Luzerne County taxpayers and for those who currently enjoy free access to the River, its shorelines, and its floodway forest.
As an example of an alternative, consider the ecologically responsible efforts of the Riverfront Parks Committee of Wilkes-Barre. These and similar efforts that enhance the public's perception of the Susquehanna River while preserving the ecological integrity of the River corridor are sound both environmentally and educationally, and hence, are deserving of federal, state, county, and municipal support. Luzerne County officials, and proponents of economic revitalization via a better-appreciated Susquehanna River, should give serious consideration to supporting such environmentally and educationally sound alternatives to an inflatable dam.
The Officers and Directors of the GWVAS hope that we have made clear our support for continued free access to the Susquehanna River and for various forms of passive recreation, and we hope that we have made equally clear our staunch opposition to installing inflatable dams in the River. We also hope that our opposition to the inflatable dam project is not construed as opposition to efforts to improve the water quality of the River. Although proponents of the inflatable dam have touted the dam as the stimulus for eliminating pollutants and contaminants from the River, we believe that the installation of a dam should not be a prerequisite for improving the River's water quality. On the contrary, we believe that a substantial amount of community support for efforts to rid the Susquehanna of contaminants already exists. Our past abuse of this priceless natural resource should not constitute an excuse to further abuse it by changing its natural character. We can have a river that is contaminant-free, and that is viewed as a regional asset, while allowing the Susquehanna to flow unimpeded through the Wyoming Valley. We urge you to take the lead in focusing the County's efforts on achieving those ends.
Again, thank you for granting us the opportunity to present our views, and thank you for your interest in our comments on this matter.
Sincerely,
Robert L. Wasilewski
Vice President, GWVAS