A Better Alternative
The Combination Thereof (CTO) Alternative D has the same problems as the "One Lake" plan that was found to be "not feasible". It is prohibitively expensive, above the maximum budget threshold allowed by Congress; could require $1 billion+ in environmental mitigation costs; requires expensive mitigation for hazardous waste sites that could introduce contaminants to our drinking water source and modifications to avoid catastrophic failure of 7 bridges including I-20 and I-80; will induce flooding in federally-designated “disadvantaged communities”; and requires numerous additional protracted and costly studies. (Click to view a detailed comparison of the 2024 DEIS Alternatives).
The USACE should discard Alternative D and instead develop a "Combination Thereof" plan that prioritizes and maximizes flood risk management benefits over recreational/commercial opportunities.
The USACE should discard Alternative D and instead develop a "Combination Thereof" plan that prioritizes and maximizes flood risk management benefits over recreational/commercial opportunities.
Alt D "Channel Improvements" |
Alt A1 (NS) |
Alt A1 w/Canton Club Levee |
Canton Club Levee |
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Project First Cost |
$487-$655 million |
$50 million |
$60 million |
$10 million |
Structures no longer flooding |
316 ("Channel Improvements") |
143 |
308 |
165 |
Structures w/induced flooding |
at least 52 |
at least 52 |
none |
none |
Local cost share (35% of total) |
$170-$229 million |
$17.5 million |
$21 million |
$3.5 million |
Costs associated with USACE-proposed Alternatives:
The Corps has offered us either a $60 million Non-structural/Levee plan that protects 318 structures or a $500-$650 million "Channel Improvements" plus Lake plan that protects 316 structures while flooding at least 52 others. It doesn’t make sense. We encourage the USACE to re-consider other Flood Risk Management solutions for Jackson, including how additional options, like the Canton Club Levee proposed in the DEIS, could provide similar high-benefit, low-cost solutions for Jackson.
Alternative A1 as proposed is well below the current Total Authorized Project cost. A large budget remains for adding additional project features, including recreational opportunities, levees such as the proposed Canton Club and Savannah Street levee, bridge conveyance improvements, and tributary restoration to the Alternative A1 plan.
The Corps has offered us either a $60 million Non-structural/Levee plan that protects 318 structures or a $500-$650 million "Channel Improvements" plus Lake plan that protects 316 structures while flooding at least 52 others. It doesn’t make sense. We encourage the USACE to re-consider other Flood Risk Management solutions for Jackson, including how additional options, like the Canton Club Levee proposed in the DEIS, could provide similar high-benefit, low-cost solutions for Jackson.
Alternative A1 as proposed is well below the current Total Authorized Project cost. A large budget remains for adding additional project features, including recreational opportunities, levees such as the proposed Canton Club and Savannah Street levee, bridge conveyance improvements, and tributary restoration to the Alternative A1 plan.
An incremental approach
Pearl Riverkeeper is asking the USACE to consider an incremental approach to Jackson Flood Risk Management. The USACE Planning Guidance recommends an "Incremental Analysis" process that examines increments of plans or project features to determine their incremental costs and benefits. A USACE reviewer noted in the 2020 Agency Technical Review that this type of analysis "specifies that the proposed project features must be shown to incrementally reduce the problem (i.e.the flood risk). It is unclear how construction of the weir and impoundment of water reduces the flood risk to the adjacent communities. The existence of the 1,500 acre lake does not create any additional flood storage capacity or conveyance capacity." The reviewer recommends starting with the feature with the greatest risk reduction, and then adding additional features while documenting the incremental benefits. (source: USACE 2020 Agency Technical Review, PDF page 93)
An incremental analysis could include many of the options already studied by the USACE and listed in the 2024 USACE DEIS, Appendix M: Plan Formulation.
An incremental analysis could include many of the options already studied by the USACE and listed in the 2024 USACE DEIS, Appendix M: Plan Formulation.
Expanded Alternative A1 Plus options
2023 USACE version of Alternative A1
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Expanded Alternative A1: The Alternative A1 plan proposed in a USACE August 2023 internal presentation and referenced in the 2024 DEIS (Main Report, PDF pages 156-157) provided non-structural measures like elevations, flooding, and voluntary buyouts for 600 structures at a cost of $198.5 million. This 2023 Alternative A1 plan resulted in a benefit cost ratio of 2.7, much higher than the benefit cost ratio of any other Alternative posed in the USACE 2024 DEIS.
The 2024 DEIS Alternative A1 reduced the number of structures protected from 600 to 143. The 2024 Alternative A1 is only budgeted at $50 million. There is plenty of room in the budget to protect more homes with non-structural measures. Buying out some of the highest flood risk structures and converting the area to green space could open up bottlenecks to flow and allow for green infrastructure interventions to capture some of the floodwaters. The USACE could include funding for a local Alternative A1 planning office and staff to assist residents with accessing the benefits of this plan. |
Expanded Canton Club Levee: The Canton Club Levee option included in the 2024 USACE DEIS is a levee segment of approximately 1.5 miles proposed for the west bank of the Pearl River in northeast Jackson. This levee would provide flood risk reduction for approximately 100 acres of high-density developed neighborhoods and reduce flood risk for over 250 homes. This area of Jackson had the worst outcomes during the 2020 flood, with some residents experiencing 4 feet of water in their homes. Flood insurance rates in the area are extremely high. The cost estimate for the Canton Club Levee is $10 million. If the Canton Club Levee were expanded to cover the other adjoining northeast Jackson neighborhoods of McLeod and Parkway, over 1,000 structures could be protected.
The NE Jackson neighborhoods of Canton Club, Parkway, and McLeod were built in the early 1970s, right after the Reservoir was filled in 1965. When the Reservoir was built, it was thought that Jackson would no longer flood. Now, most of these homes are located in the 1% Annual Chance Flood Hazard zone, high-risk flood areas.
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Photo: NE Jackson, Barbara Gauntt, Clarion Ledger, 2020 flood. (Foxboro Dr residents had 4 feet of water in their homes and residents were forced to evacuate.)
NE Jackson neighborhoods are located in large watershed that drain water all the way from Madison. Homes located along Purple, Hanging Moss and White Oak Creek are susceptible to flooding from the creeks, even when the Pearl River is not at flood stage. The 2024 DEIS does not include a plan to improve flow for the tributaries. The DEIS states that a higher "lake" elevation could cause increased flooding on the tributaries, further compromising the neighborhood.
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WJTV noted that flooding in NE Jackson was more severe than forecast as water pushed toward a path of least resistance. The 2024 DEIS also noted that flow conditions on the river have changed over the years, and that NE Jackson is now experiencing the worst flooding.
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Two community organizations, 3C1CA (3 Communiites 1 Common Agenda) and MCUP (MS Citizens United for Prosperity) received EPA funding to develop a park design project to help alleviate some of the flash flooding from Purple, White Oak, and Hanging Moss Creeks. The project includes nature-based, green infrastructure solutions that could complement work being considered by the USACE. Click the photo to view the plan.
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Additional Levees: Upgrades to the current non-federal levee are needed to protect the critical infrastructure at Savannah Street Wastewater Treatment Plant. 2018 DEIS estimated cost for the Savannah Street WWTP levee was $1.9 million. The USACE could consider other small levee segments to protect other critical infrastructure or neighborhoods with high flood risk.
Click to view map of 2018 DEIS Alternative B levee proposal
Click to view a map of USACE-suggested levee segments from the 2007 LeFleurs Lake Plan.
Click to view map of 2018 DEIS Alternative B levee proposal
Click to view a map of USACE-suggested levee segments from the 2007 LeFleurs Lake Plan.
"Plan 3: Bridge Improvements", 2024 USACE DEIS, Appendix M, PDF page 37
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Bridge Conveyance Improvements: River forecasters theorize that, in 2020, increased Reservoir discharges, combined with the river already running so high, caused the water to back up at the main channel bridges. When the high volume of water reached the constriction at the Lakeland Dr bridge in Flowood, the water backed up into the neighborhoods of northeast Jackson and businesses in Flowood. (source: NWS, Jackson, Pearl River Flood of 2020 Story Map)
The Plan Formulation for the Pearl River Flood Risk Management project included a "Bridge Improvements" plan that combined opening improvements, bridge lengthening, conveyance improvements (clearing), along with raising the low chord of the lowest railroad bridge. These improvements could be part of the "incremental approach" to providing increased conveyance and flood peak reduction. |
Recreation: If the USACE plans to include recreational opportunities in their Flood Risk Management planning, 740 acres of unutilized City of Jackson-owned property is currently available for use along the Pearl River. The local project sponsor, the Flood Control District, owns 66 acres on the river in Jackson. There is no need to create recreation opportunities by creating a "New Lake". Recreational amenities at these riverfront locations could include green infrastructure features that function additionally as flood reduction measures. These opportunities could expand on the current efforts of connecting Jackson's four existing museums within the LeFleur Museum District via bike and pedestrian trails. A map of City-owned, unused property on the river, and other potential recreation locations is posted below.
The USACE could leverage already developed park plans, including the Festival Park plan, the Pearl River Nature Park plan developed for 3C1CA/MCUP by Spackman Mossop Michaels, and more designs developed for Great City Foundation. The Festival Park plan involved remediating the LeFleurs Landing Site on the Pearl River in Jackson and converting it to green space with room for an amphitheater or other amenity. This plan dates back to 2003 when Mayor Harvey Johnson Jr. coordinated a cleanup of the LeFleurs Landing site for the proposed 89-acre Festival Park.
Other Conveyance Improvements: The 2018 DEIS, Appendix A included a plan for clearing vegetation along the channel and overbank areas for the entire reach between Richland and the Ross Barnett Reservoir. (River forecasters have noted that the current, more limited vegetation clearing is reducing flood peaks in the project area.)
Tributary Restoration and Storage: Pervasive tributary flooding occurs more frequently than river flooding and disproportionately affects federally-designated "disadvantaged communities". Including a tributary restoration plan in the Flood Risk Management project could leverage work already being undertaken by NRCS, State and other local entities. The 2024 USACE DEIS, Appendix E suggests that "Future projects could consider additional storage in tributary, either by upstream detention, or by side channel storage." This option could also afford recreational access to the waterway.
Analysis of current flooding conditions: The CTO (Alternative D and E) plans may not be correctly prioritizing the areas most impacted by river flooding. Although the NE Jackson neighborhoods experienced the most severe flooding in 2020, the "Channel Improvements"/"Lake" projects provide the most flood peak reduction for the Meadowbrook Rd/Eastover area of central Jackson.
The 2020 flood event, the 3rd highest flood on record, gave agencies like the National Weather Service (NWS), Jackson office, an opportunity to study the changes to Pearl River hydrology. Jackson development in the floodplain has changed the dynamics of the river, such that the river is not behaving in the same way as it did when the first "Lake" plans were developed in 1996.
National Weather Service, Jackson, and other river forecasters have noticed that changes to the river bed, the overbanks, and to the land between the levees in Jackson, are making an impact to the amount of water (flow) running through the Jackson gauge at certain river stages. The river is now pushing MORE water through the gauge at LOWER stages. In 2020, data showed that, with nearly the same outflows, the river stage was almost 3 feet lower than what occurred in 1983. The forecasters have theorized that the river bed has been scoured of sand and silt by higher discharges from the Reservoir. Another theory is the clear-cutting and mowing of the land between the levees in Jackson is allowing the water to move through unimpeded.
In addition to changes in river hydrology, operations at Ross Barnett Reservoir have been vastly improved over the years, due to upgrades via modern technology in river gauging (volume and flow) and forecasting (USWS, USGS, USACE), allowing the Reservoir to provide flood peak reduction for Jackson. It is estimated that if it weren't for deft operation at the Ross Barnett Reservoir, the flood stage at Jackson could have been at least 1-1.5 ft higher during the 2020 flood event.
Flood prediction maps prepared prior to 2020 did not accurately depict the flooding that actually happened in 2020. The Hinds County Emergency Manager noted that the neighborhoods north of Lakeland Drive experienced almost 2 feet more flooding than expected based on the flood prediction maps. Areas south of Lakeland Drive, particularly in downtown Jackson, experienced flooding as expected.
(source: NWS, Jackson, Pearl River Flood of 2020 Story Map)
The 2020 flood event, the 3rd highest flood on record, gave agencies like the National Weather Service (NWS), Jackson office, an opportunity to study the changes to Pearl River hydrology. Jackson development in the floodplain has changed the dynamics of the river, such that the river is not behaving in the same way as it did when the first "Lake" plans were developed in 1996.
National Weather Service, Jackson, and other river forecasters have noticed that changes to the river bed, the overbanks, and to the land between the levees in Jackson, are making an impact to the amount of water (flow) running through the Jackson gauge at certain river stages. The river is now pushing MORE water through the gauge at LOWER stages. In 2020, data showed that, with nearly the same outflows, the river stage was almost 3 feet lower than what occurred in 1983. The forecasters have theorized that the river bed has been scoured of sand and silt by higher discharges from the Reservoir. Another theory is the clear-cutting and mowing of the land between the levees in Jackson is allowing the water to move through unimpeded.
In addition to changes in river hydrology, operations at Ross Barnett Reservoir have been vastly improved over the years, due to upgrades via modern technology in river gauging (volume and flow) and forecasting (USWS, USGS, USACE), allowing the Reservoir to provide flood peak reduction for Jackson. It is estimated that if it weren't for deft operation at the Ross Barnett Reservoir, the flood stage at Jackson could have been at least 1-1.5 ft higher during the 2020 flood event.
Flood prediction maps prepared prior to 2020 did not accurately depict the flooding that actually happened in 2020. The Hinds County Emergency Manager noted that the neighborhoods north of Lakeland Drive experienced almost 2 feet more flooding than expected based on the flood prediction maps. Areas south of Lakeland Drive, particularly in downtown Jackson, experienced flooding as expected.
(source: NWS, Jackson, Pearl River Flood of 2020 Story Map)
Lakeland Dr bridge
Ross Barnett Reservoir operations: "The reservoir does not have a requirement to implement flood reduction in any specific way but has been actively reducing peak flows during large inflow events since at least 1979 with an estimate that peak flows are reduced by as much as 28 percent due to these operations.""State and local entities may consider operational changes at the Ross Barnett Reservoir and revising the Ross Barnett Water Control Manual to formalize continued flood reduction capacity inform future discharge operations." (Main Report, PDF p 112)
USACE 2023 Incremental Measures that were rejected in the 2024 DEIS:
The USACE could re-visit the Tributary Conveyance Improvements, Small Levees, and Bridge Modifications that were rejected in favor of Alternative D's more expensive and destructive "Channel Improvements".
Slide from 2023 USACE internal presentation obtained via FOIA request. "Channel improvements of Tributaries, Small Levees, and Bridge Modifications" were included in the list of structural measures that could be implemented under the CTO plan. Those options were not included in the 2024 USACE DEIS CTO plans.
Other Opportunities
- Purchasing new pumping stations for the current Fairgrounds and East Jackson Levees: Since 2020, the Rankin Hinds Pearl River Flood and Drainage Control District Engineer has been advocating for replacing the pumps at both the Fairgrounds and East Jackson pumping stations. Estimated cost to replace the 8 pumps is $7 million.
- Potential Removal of Weir at J.H. Fewell Drinking Water Plant: The current weir the the J.H. Fewell Drinking Water Plant could become obsolete if JXN Water and the City of Jackson follow through on their plans to close the aging plant. JXN Water's Ted Henifin said in 2023: "...if his team of contractors plug enough of the city’s leaks, Jackson could reach a point within the next year where it wouldn’t need the century-old J.H. Fewell, one of the system’s two treatment plants. City officials have for years hoped to retire Fewell, which would save Jackson “significant money” from not having to operate it." Removing the weir could improve fish passage to critical habitat, restore downstream boat access on the Pearl River, and alleviate a deadly safety hazard.
- Flood Plain Ordinances: The 2018 DEIS notes that flood plain ordinances could provide future protection of a more restricted flood plain. "Updated ordinances should be considered and consistent throughout the area. They can help lead to better public awareness and increase education about the hazards of building in flood prone areas."
- Comprehensive Watershed Plan: The 2024 USACE DEIS states that: "A comprehensive watershed study of the Pearl River is necessary to fully understand the basin’s hydrology, hydrodynamics, and ecosystem. The scope of the study should be from the headwaters to the terminus at the Gulf of Mexico." (Main Report, PDF p 113)
- Reconnecting Jackson to the Pearl River: Wildlife viewing stations, trails, overlooks, boat ramps, and fishing piers on current unutilized City-owned property could harness the flood risk management benefits of natural, preserved green space, while also providing recreational amenities for the City of Jackson.
Benefits gained by discarding the CTO Plans in favor of Expanded A1 Plus
- No "Sacrifice Flooding": 52 structures (43 residential homes and 9 other structures) located in "disadvantaged communities" will not experience the first-floor flooding of 5" or greater caused by the CTO Alternative.
- Improved Water Quality and Drinking Water Supply: If not implemented, the Alt D channel improvements and new weir will not introduce toxic contamination and increased sediment loads at the existing J.H. Fewell Drinking Water Plant. Water quality improvements could be achieved via wetlands restoration and green infrastructure projects.
- Improved Downstream Conditions: Another river alteration will be avoided. Downstream water quality could improve with improvements to water quality in the project area through wetlands restoration and green infrastructure projects. A first-ever Comprehensive Watershed Plan could be completed. Potential removal of the sill at Pool's Bluff.
- No bridge countermeasures or utility transmission line relocation required
- No increased levee pumping station capacity or new slurry walls required
- No mitigating potential HTRW (Hazardous, Toxic, Radiological Waste Sites) and other hazardous waste sites within the floodplain: except for potential remediation at LeFleurs Landing Site to allow for recreational use.
- No Congressional approval for an increase in authorized project cost required
- Benefits instead of harms to endangered and threatened species
- No Loss of Public Lands: Potential for revitalization instead of destruction of portions of LeFleur’s Bluff State Park, Jackson’s only current public access to the Pearl River and a popular recreation area.
- No new weir/dam on the river
- Greatly reduced habitat mitigation required: Potential terrestrial mitigation required for the Levee segments.
- No need for new organizing authority to manage operations between Ross Barnett Reservoir and a new Alternative D impoundment
- Preservation of wetlands that currently provide flood risk management
Pearl Riverkeeper asks that everyone make his or her own decision regarding the Pearl River Flood Risk Management Project using sound science and engineering. We encourage the review and thorough analysis of all available information. We welcome comments and feedback. Please email Pearl Riverkeeper or visit our Facebook for comment space. Our publishing, or re-publishing, of anyone else's research or opinions is not an endorsement on our part of those conclusions.
