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Public Funds for Private Gain?

7/21/2024

 
The USACE's Pearl River Flood Risk Management planning document proposes two main Alternatives for Jackson flood risk management: Alternative D (damming and excavating the river​, price tag $500-650 million) or Alternative A1 (non-structural elevations and floodproofing, price tag $50 million). Why is Alternative D so expensive? That plan includes funding to build a new dam, not for flood control but to create a lake for economic development. Alternative D's budget includes hundreds of millions for required environmental mitigation, bridge countermeasures, and for building the new dam, new pumping stations and slurry walls to protect the current levees. Instead of funding flood risk management for our tributaries, Alternative D  prioritizes a new lake and commercial development in the flood plain. 

At the USACE public meeting in Slidell on July 11, residents asked the Corps of Engineers and the Rankin-Hinds Pearl River Flood and Drainage Control District about whether there would be new development along the dammed lake. Their answers conflict.  Read the transcript excerpt here: 

JACK SESSIONS (private citizen):
​Now, I ask them today is there going to be houses out there –- are y’all going to let houses be built on these lakes? Can anybody answer that?
UNIDENTIFIED SPEAKER:
That’s a yes.
JACK SESSIONS (private citizen):
Because they said from day one that this was strictly going to be flood control, no houses whatsoever. So at the last meeting, I asked that and nobody can answer it. So today, I’m asking it again: are y’all going to let houses be built on this?
BRANDON DAVIS (USACE):
So to answer your questions, the Corps of Engineers is not –- I guess we’re not going to allow houses to be built on that. That land is going to be acquired through our real estate easements arm. The recreation that we’re talking about is boat ramps, bike paths, things of that nature. So the Corps of Engineers is not in the business of residential development or anything of that nature, so that’s –- I wouldn’t see that being there.
JACK SESSIONS (private citizen):
So no houses? Okay.
TOM SHAW (USACE):
Thank you. 

​HOWARD PAGE (private citizen):
Yes, sir. My name’s Howard Page, and a question that was asked just before this gentleman spoke –- I would like –- I saw that the gentleman from Rankin-Hinds, the local sponsor, I would like him to answer the question: are any houses going to be built because of this project? My understanding has always been absolutely, yes, this is absolutely a real estate development project.
And so I was wondering if we could hear directly from you, if you agree. No one ever thought the Corps was going to build houses, so that really wasn’t the answer I was looking for. So I was wondering if this gentleman could answer that question.
UNIDENTIFIED SPEAKER: Good job.
KEITH TURNER (Rankin-Hinds Pearl River Flood and Drainage Control Disctrict):
So first off, this has never been a real estate project, contrary to what many people say. This has always been a flood risk management project from the very beginning, but we’ve also stated from the very beginning that if there are ancillary benefits such as recreation or others, or some economic development, that’s a good thing for the city of Jackson.
So there are no plans right now. There are no specific plans for any development of any sort. What we envision is that the communities that this project has improved as a result of the lake, that a planning process would occur with the communities to develop three areas specifically. One would be, obviously, recreational areas, natural areas, and then some areas would be opportunities for economic development.
That area under D is much smaller than it was under C, but again, there’s no specific plans of any sort. And one thing that’s really important to understand is that the property acquisition, as Brandon mentioned, would be controlled by these parties right here.
We’re responsible, as local sponsors, to actually acquire the property, and it would be controlled by us, and it would not be windfalls for developers of any sort. But specifically, the three areas –- recreation, natural, and some economic development.
HOWARD PAGE (private citizen):
So basically, yes, there is potential for development?
UNIDENTIFIED SPEAKERS: (Multiple voices) Yes.
KEITH TURNER (Rankin-Hinds Pearl River Flood and Drainage Control District): Yes. Yes, if it’s possible, there may be some development there. Now, I didn’t say houses and things, no –- there’s nothing planned of any sort. I’d be glad to talk with you in more detail outside and I can show you those specific areas. They’re not that large, and you know, whether they occur or not, I think it depends on whether the economy supports this thing or not.

Betting on Another Lake

6/24/2024

 
45 years of Flood Risk Management (FRM) efforts for Jackson and 4 separate Lake projects
  • 1979: After Easter Flood, Congress authorizes USACE to develop comprehensive flood control plan
  • 1996: USACE recommends Comprehensive Levee Plan. John McGowan and other local developers propose Two Lakes Plan. The Rankin Hinds Pearl River Flood and Drainage Control District (Drainage District) and the USACE reject the Two Lakes Plan due to high costs.
  • 1998: USACE Comprehensive Levee Plan does not receive local support and is rejected.
  • 2001: The Drainage District accepts the role of developing a Jackson FRM project and adopts the LeFleur Lakes Plan.
  • 2007: After several modification attempts, the USACE rejects the LeFleurs Lake plan because it provides less flood control than the Comprehensive Levee Plan. 
  • 2010: USACE writes a letter to the Drainage District stating that the Corps will not consider any further Lake plans.
  • 2011: John McGowan and Pearl River Vision Foundation promote the "One Lake" Plan.
  • 2018: The Drainage District releases the "One Lake" planning document (DEIS).
  • 2024: The USACE releases a DEIS rejecting the "One Lake" plan as "not feasible". The USACE DEIS includes another Lake plan, Alternative D. 

The human cost of betting on another Lake project
Consider the human cost of going down another labyrinthine Lake path. Just 4 years ago, in 2020, residents in NE Jackson suffered through evacuations and returned to homes inundated with up to 4 feet of floodwaters. Flood insurance costs increase every year and many homeowners are only able to purchase partial flood insurance.

Hurdles to approving a Lake project
Alternative D, the new Lake plan, 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; according to USFWS, it could require a potential $1 billion+ in environmental mitigation costs; it disturbs hazardous waste sites that will introduce contaminants to our drinking water source; according to MDOT, it could cause failure of 7 bridges including I-20 and I-80; and it will CAUSE flooding of up to 5" or greater at first floor elevation to 52 structures in federally-designated “disadvantaged communities”. 

With rapidly rising flood insurance costs and the threat of further flooding, residents literally cannot afford to wait. The CTO Alternatives D and E will require a lengthy process of additional NEPA (National Environmental Policy Act) studies and analysis. Many critical studies and analyses are missing or incomplete in the 2024 USACE DEIS. The USACE states in the document that many of the studies required NEPA process will not be conducted until the Pre-Construction, Engineering, and Design (PED) Phase, which occurs after the USACE Assistant Secretary of Civil Works makes his Record of Decision about the project. A few of the further required studies are listed below. None of these studies will be required for Alternative A1.
  • Mitigation plan (to be developed during PED and included in a subsequent NEPA document)
  • 404(b)(1) Clean Water Act Analysis (to be conducted during PED)
  • Bridge countermeasures to prevent failure of main channel bridges (major evaluation will be a PED effort)
  • Sedimentation study (to be conducted during PED) "During design, additional study and verification would be needed to confirm that adding a large weir would not induce sediment loads to alter the incoming chemistry in such a way to induce failure at the existing J.H. Fewell Plant or any other proposed structure along the newly ponded area. A sedimentation study has been proposed to be completed during the PED phase of this study." (PDF page 201)
  •  Velocity Analyses (to be conducted during PED)
  • Utility Relocation Plan (to be conducted during PED) "It is estimated that 5 to 6 of these lines will require additional utility relocation costs. Coordination with the operating entity to determine specific requirements of each transmission line will be conducted during PED."  (PDF page 124)
  • LeFleurs Bluff State Park Mayes Lake work (to be determined during PED) "Mayes Lake (Sta. 310+00±) may need tie-in work to maintain its current level. A determination about the tie-in work would be made during the PED phase." (PDF page 130)
  • Railway Bridge Planning (to be conducted during PED) "There are a total of 2 active railroad bridges within the project area. All efforts would be made to avoid, monitor, and protect these structures. Additional modeling is required to validate these assumptions during PED. If avoidance is not possible, then coordination with the operating entity to determine specific requirements of each railway bridge will be conducted during PED."(PDF page 131)
  • Fish Passage Design (coordinated during PED) "The fish passage design will be coordinated with The Service and state agencies during the PED phase." (PDF page 135)
  • Borrow Area Analysis (investigated during PED) "Borrow opportunities would be further investigated during PED and a supplemental NEPA document would be prepared at that time." (PDF page 137)
  • Hazardous Toxic Waste Site mitigation (to be determined during PED)
  • Historical and Cultural Site Assessments (adjusted during PED) "The Jackson MSA has significant historical and cultural site presence, final site locations would be adjusted during PED following completion of cultural resource surveys." (PDF page 147)
  • Habitat Mitigation (completed during PED) "Habitat Mitigation would be achieved by implementing Corps constructed mitigation projects and/or purchasing of mitigation bank credits. Further planning and analysis would be completed during PED to determine which strategies, stand alone or combined, would fully compensate for habitat impacts." (PDF page 155)
  • CTO Implementation (additional analysis could be required during PED) "To implement multiple flood risk management features and a more comprehensive solution, additional authority is required either an increase in the total authorized project cost under Section 3104 or a programmatic authority to implement flood risk management features in the Pearl River Basin similar to CAP Section 205 projects. Additional analysis and design, feasibility level decision documents, and supplemental NEPA documentation would be required during the PED phase if such solutions are recommended." (PDF page 256)
  • Levee Studies (calculated in PED) "The currently proposed Alt C being evaluated by USACE does not include any alignment or height changes to the existing Jackson Fairgrounds Levee." "It is also unknown whether the proposed alternative will change the overtopping location on the levee system. This overtopping frequency and location would need to be calculated in PED phases." (PDF page 263)
  •  Impacts of CTO on tributary flooding (the DEIS states that Alt C would increase flooding along the tributaries but does not discuss CTO impacts on tributaries). “It is recommended that a survey of tributaries and structures along the tributaries be incorporated into the model to better estimate flooding and impacts along tributaries.” (PDF page 247)
  • Water quality impacts – additional modeling/data required to determine if either CTO is “viable”
  • Storm Water Pollution Protection Plan (SWPPP) (during PED, downstream impacts will be assessed and coordination with the resource agencies will take place) 
  • Water supply impacts, "Depending on the method and means of selected features additional study could be needed to determine the best methods of design and construction to limit the impact to potable water throughout the system in respect to contaminant retention due to pooling and sediment loading prior to treatment." (PDF page 202)
  • Formal Endangered Species Act consultation on CTO (must be reinitiated) 
  • Weir design

Who pays for One Lake?

6/20/2024

 
Last week, the US Army Corps of Engineers (USACE) released the 2024 Pearl River Flood Risk Management (FRM) Draft Environmental Impact Statement (DEIS). The Rankin Hinds Pearl River Flood and Drainage Control District (Drainage District) has endorsed USACE Alternative D, CTO (combination thereof) with weir, an altered version of the "One Lake" project. According to the USACE "Commander's Report" released with the DEIS, the "Projected First Cost" for Alternative D is $100-$200 million higher than the "Total Authorized Project Cost". 
  • Drainage District 2018 estimate for cost of "One Lake":  $340 million
  • USACE 2024 DEIS Projected First Cost for "One Lake": $1-$2.1 billion. The USACE found the "One Lake" project "not justified".
  • Projected First Cost for Alternative D (CTO with weir/dam): $487-$655 million​ 
             ($147-$315 million more than Drainage District's 2018 cost projection for "One Lake")
  • Total Authorized Project Cost: $370 million (source: Commander's Report, page 5). The Alternative D projected first cost is $117-$285 million above the "Total Authorized Project Cost".
  • Maximum Project Cost Limit: $440 million (source: Commander's Report, page 5).
  • Federal Cost Share Appropriation: $221 million (appropriated by Congress in Oct 2022)

Currently, only $221 million out of the $487-$655 million needed for the Alternative D Lake has been funded. In 2022, Senator Wicker received a $221 million federal appropriation of  Bipartisan Infrastructure  Law funding for the Pearl River Flood Risk Management project. This funding will be used to pay for the federal cost-share of the project.

According to the "Commander's Report", the Non Federal Sponsor (NFS)(Drainage District) shall contribute 35 percent of total project costs. Drainage District cost share for the Alternative D Lake ranges from $170-$229 million. (The $221 million in federal funding cannot be used to pay for the Drainage District cost share.) The Drainage District has not indicated how they will pay for their portion of the project costs.* 

The local Drainage District Board of Directors includes the Mayors of Jackson, Flowood, Richland, and Pearl, representatives from the Hinds and Rankin County Boards of Supervisors (Supervisors Robert Graham and Jay Bishop), and a Governor-appointee. The Governor-appointee position on the Board has been vacant since January 2021. Drainage District revenues are obtained through a 4.75-mil tax assessment on properties protected by the levee system. The majority of the tax revenue comes from properties located in Rankin County. The state-owned properties on the Jackson side of the Pearl River do not pay this tax. A Drainage District spokesperson stated in 2018 that "Property owners who benefit from the One Lake Project would likely face a special assessment tax if the estimated $340 million project becomes reality." It is unlikely that special assessment taxes could raise enough funding to pay for the $170-$229 million local cost-share for the Alternative D Lake.

​(*Drainage District spokespersons did not respond to requests for information regarding project funding.)

The long and winding road to flood management

4/15/2024

 
After the 1979 Easter Flood, one of the most costly and devastating floods in Mississippi, Congress authorized the US Army Corps of Engineers (USACE) to develop flood control plan for Jackson. Flood control planning for Jackson reached a stalemate decades later when the USACE Comprehensive Levee Plan and the local Two Lakes Plan were both rejected. 

In 2001, the USACE relinquished control and the local Levee Board took over responsibility for planning a Jackson flood control project. The Levee Board published the LeFleur Lakes Plan, a flood control and economic development plan which, despite numerous modifications was rejected by the USACE due to unacceptable cost and environmental impact. After decades of reviewing failed local lake plans, in 2010, the USACE wrote a letter to the Levee Board stating that the Corps will not resume any further study of flood control for the purpose of considering any lake alternatives or private development features.  In 2009, the Levee Board, led by Flowood Mayor Gary Rhoads voted to move ahead with the USACE Comprehensive Levee Plan. 

Despite the Levee Board vote and admonishments by the Corps, in 2011, John McGowan and other local developers persist in forming the Pearl River Vision Foundation, a non-profit dedicated to promoting another lake development idea called One Lake. 7 years and millions of dollars of local, state, and federal funds later, in 2018, the Levee Board released their Draft Environmental Impact (DEIS) report, which includes their "preferred plan",  Alternative C, the One Lake plan. 

In 2022, 43 years after the Easter Flood, the USACE is charged with completing the data gaps in the Levee Board's DEIS/FS to inform the Assistant Secretary of the Army (Civil Works)'s final decision on Jackson flood risk management.
​
In 2023, the USACE released a Notice of Intent to publish a Pearl River Flood Risk Management DEIS/FS. Flood management options being evaluated include non-structural alternatives, hybrid options, and Alternative C ("One Lake"), the Levee Board-preferred plan. The USACE scheduled DEIS release for Sept 1, 2023. 

Flood management for Jackson again hits a stalemate. 

On August 8, 2023, Watkins & Eager, the Levee Board's law firm received a copy of a USACE Internal Presentation outlining the Corps estimated "One Lake" cost ($1.3-2.1 billion) and cost/benefit analysis of "One Lake". 

On August 31, 2023, USACE announced 1st delay of DEIS. 

An October 5, 2023, WLBT newspaper article quotes Keith Turner, the Levee Board's Watkins & Eager attorney, saying that USACE Secretary Connor's decision to delay the release, "wasn’t due to the lack of funding. Instead, it was made at the behest of the Rankin-Hinds flood district."

On Oct 21, 2023, USACE announced 2nd delay of DEIS citing lack of funds. Updates in December 2023 and March 2024 provided no timeline for release of the DEIS. 

2024 Pearl River Flood Risk Management Draft Environmental Impact Statement

Many critical studies and analyses are missing or incomplete in the 2024 USACE DEIS. The USACE states in the document that many of the studies required under the National Environmental Policy Act (NEPA) process will not be conducted until the Pre-Construction, Engineering, and Design (PED) Phase, which occurs after the USACE Assistant Secretary of Civil Works makes his Record of Decision about the project. It will be difficult for agencies and the public to fully assess and understand the project Alternatives without this information. Additional NEPA studies and analysis will further delay flood risk relief for Jackson. 

1960s Pearl River

9/28/2023

 
In the 1960s, the Corps of Engineers built 13 miles of levee on the Pearl River in Jackson and straightened 13 miles of winding river and wetlands into a 2.1-mile stretch between Jackson Waterworks and the Coliseum. ​
Picture
Clarion Ledger, 06 Jun 1965
Picture
Clarion Ledger, 06 Jun 1965
​Clarion Ledger, 06 June 1965:
"Huge dirt moving machinery snarls up and down the riverbanks behind the State Fairgrounds and alongside the city’s sprawling maintenance and storage area off South Jefferson street, gobbling up sand and dirt to cut a new channel. 
An enormous drag-line machine, with a three-cubic yard bucket, is slashing huge gaps out of the swamp bottom once occupied by every kind of small animal species and an occasional river bottom swamp-hunter, cutting a new river bottom to eliminate costly annual flooding."
"Rugged dump trucks, looking like oversized green beetles, snarl back and forth to a dump-site where the dirt is being used to construct large floodcontrol dams which will contain Pearl River from the waterworks plant on the north to the Woodrow Wilson bridge on the Old Fannin Road to the south.
A new channel being cut, will straighten Pearl River, making a straightaway water route of just over two miles through the once-wooded section through which the river winds for over 13 miles."
"This vast project will contain Pearl River during the flooding season, will protect valuable property on the City of Jackson and Hinds county side, and will afford unlimited possibilities for further commercial development in Rankin County. 
Very little of the vast digging and grading project is visible since most of it is inaccessible areas of the Pearl River bottoms.
Where squirrels, wild turkey, possum, raccoons, snakes and good fishing holes were once the property of oldtimers who knew and lived with the river, these areas are now nakedly exposed to progress and profitable development."
Picture
"Location of the levees and the entire district of the Pearl River Flood Control project may be seen on this map. The location of the Coliseum and the Allen C. Thompson airport help in reading the map by indicating these landmarks." Clarion Ledger, 12 Jan 1964
Picture

"Engineers Beginning to Tame Flooding Pearl River Threat" "But the era of the flooding Pearl is rapidly giving way to a new day-a day when the Pearl will be a servant rather than the master of the people of this area...Because when the levee and drainage project is complete, the Pearl will no longer be a threat." "When complete, this project will reclaim about 6,500 acres of prime land that has heretofore been virtually useless for commercial development because of periodic flooding. Much of this land is less than three miles from the heart of Jackson.""Green predicts that the levee system will be closed in September 1967. He said that when this is done the ravages of the Pearl will soon be forgotten." Clarion Ledger, 24 Jan 1966
Picture
"Levee, Channel Work Under Way - In connection with the construction of the new highway interchange system for Jackson, the Pearl River Channel in the swamps just east of Jackson is being straightened and levees are to be built on each side to control flood waters. This view reveals some of the work which has been done just west of Casey's Lane (foreground) in Rankin County, with downtown Jackson just beyond the top center of the picture. Aerial photo by Claude Sutherland." Clarion Ledger, 28 Sept 1965
Picture
Photos: Rankin-Hinds Pearl River Flood and Drainage Control District

Pearl darter recovery

8/3/2023

 
50 years after the establishment of the Endangered Species Act and 50 years after the last Pearl darter was seen in the Pearl River drainage, 39 Pearl darters were reintroduced to their native home!! USFWS's Matt Wagner called this event "the biggest win in his career as a biologist”. Pearl darters, now a federally threatened species, were once present throughout the Strong River and in the main stem of the Pearl as far south as I-10. Until today, the last remaining population lived in the Pascagoula River drainage. USFWS endangered species listing and recovery expert, Matt Wagner and team developed a Pearl darter recovery plan and designated a section of the Strong River as "critical habitat" for the fish. Over the past several years, brood stock from the Bouie River near Hattiesburg, MS, were collected and brought to the Private John Allen National Fish Hatchery in Tupelo for spawning. The Hatchery learned through much trial and error to successfully raise pearl darters and, today, 39 of the darters spawned this spring were released to the river!! The Pearl darter species recovery plan includes monitoring, surveying, and research of the species to ensure it can survive long-term in both the Pascagoula and Pearl River systems to the point that it is no longer threatened. Thank you, USFWS, Private John Allen Fish Hatchery, MDWFP and Strong River Camp for your dedication to biodiversity and conservation and for the opportunity to witness this rare, historic event.

One Lake Update

9/7/2022

 
In late July 2022, the Rankin-Hinds Pearl River Flood and Drainage Control District (Levee Board) transmitted their One Lake Environmental Impact Statement (EIS) document to the Office of the Assistant Secretary of the Army for Civil Works ((ASA(CW)) for the next step in the One Lake project review process.  The ASA(CW) and the federal Office of Water Policy Review have 30-45 days to review the document before sending it to other state and federal agencies for another 30-45 day review period.  If the document passes these 2 sequential review periods, the document will be published to the Federal Register and available for a 30-45 public comment period.  It has not yet been determined if the document would be published as another Draft EIS or as a Final EIS. Public comment could begin as early as October 2022.  The US Army Corps of Engineers Headquarters is responsible for preparing final recommendations and conditions based on the state and federal reviews.  
Picture
 
​Many questions remain since the publication of the 2018 One Lake Draft Environmental Impact Statement (DEIS) including:  
  • Who will be taxed to pay for One Lake construction, maintenance and upkeep? HB 1585, 2017 MS Legislative session, gave the Levee Board authority to raise property taxes for owners they determine are "directly or indirectly benefited by the project."  Will City of Jackson residents struggling under drinking water and sewer consent decrees be required to pay for Lake development and maintenance?  The DEIS cost estimate for One Lake construction is $350 million. $133.8 million will be paid for by the federal government. Who will pay for the additional $216.2 million in construction costs and for the additional yearly maintenance costs?  
  • Has MDOT approved a plan that would prevent the catastrophic failure of major interstate bridges? In a Sept 2018 letter to the Levee Board, MS Department of Transportation stated that “If the predicted scour depths occur, there will be a catastrophic failure of all seven of the main channel bridges...” Main channel bridges of concern include two on Lakeland Dr, two on I-55, one on US 80 and two on I-20. MDOT stated that “For this reason all bridges will need to be replaced and the cost to replace the nine bridges should be reflected in the cost of the Pearl River Basin Federal Flood Risk Management Project.”
  • How much will it really cost to remove the Hazardous, Toxic and Radiological Waste (HTRW) sites in the project area?  The DEIS states that the environmental impacts associated with their removal could include, “the temporary addition of large additions of sediment to the Pearl River, the release or exacerbation of current releases of leachate and/or solid and hazardous substances to the groundwater and/or surface water...”   ​The 2018 Independent External Peer Review states: "The 3 HTRW sites identified in the Draft FS/EIS are not sufficiently characterized to determine the adverse affects on the Pearl River and on the overall project cost." and "The potential costs of HTRW site remediation may be significantly understated in the cost estimates and risk analysis, potentially affecting the selection of the TSP (Tentatively Selected Plan)."
  • Has a thorough evaluation of downstream impacts been completed? Mississippi Department of Environmental Quality comment letter, Sept 2018 states: "In regard to water quality impacts in general, MDEQ believes additional evaluation should be done to consider how the proposed project would affect water quality downstream of the project area, including but not limited to changes in stream flow, changes in water availability, changes in velocities, frequency and duration of high/low flow events, and reaeration rates".   USFWS Fish and Wildlife Coordination Act Report, Jan 2020 states: "The productivity of oyster reefs in Mississippi Sound (Half-moon Island, Grassy Island, Petit Island, Grand Banks) depends on the mixing of fresh water from the Pearl River with salt water from the Gulf of Mexico to maintain a salinity range of 5-15 parts per thousand.  The reduction or disturbance of fresh water flow from the Pearl River may upset the established balance, and a more saline environment would in turn cause devastating consequences to existing oyster populations".  In 2018, Senator Cassidy and Representative Scalise added wording to the WRDA 2018 (America's Water Infrastructure Act) that imposes important restrictions on moving the One Lake project to the next phase of detailed technical design, including a requirement to address all adverse downstream impacts.
  • Will the One Lake project increase flash flooding in some Jackson neighborhoods? According to the DEIS (Appendix C, pages 32-36), the higher water level of 258' at the One Lake weir will increase the flood profiles along all 8 Jackson tributaries. The City of Jackson storm drain and tributary channel system is currently not capable of efficiently managing stormwater flash flooding. Heavy rains often cause Lynch Creek to overtop its banks, flooding neighborhood streets, businesses and homes.  Due to the deterioration of century-old sewer infrastructure, this stormwater typically contains raw sewage and other contaminants. 
  • ​How will the City of Jackson protect its already beleaguered drinking water supply during One Lake construction?  AllenES Environmental Evaluation of Hazardous, Toxic and Radiological Waste (HTRW) Sites, Sept 2014, p.16 states: "Other immediate effects that may result from construction of the proposed project could include a temporary loss of the secondary water supply intake for the City of Jackson. Jackson utilizes an existing water treatment plant which is located on the Pearl River at a location scheduled for dredging and development of the “Channel Improvement/Weir/Levee” alternative. The dredging of sediments and subsurface soils in the Pearl River could potentially increase the turbidity of the surface waters to levels unacceptable for human consumption; therefore, the City of Jackson would need to evaluate temporary water supply alternatives during the duration of dredging and construction activities." 
  • What will the water quality be in a lake impoundment that receives millions of gallons of raw sewage and trash from numerous urban creeks?  A wider, deeper lake impoundment, with a weak current stagnating during droughts, would concentrate sewage and other contaminated runoff from urban creeks, leading to harmful algae blooms and potential fish kills. The Lake could become soupy and green, and combined with visible oil sheens, would be unattractive for recreation or development.  
  • Is the One Lake plan the most cost-effective plan? The 2018 Independent External Peer Review states: "The final alternative plans do not definitively demonstrate that the TSP (Tentatively Selected Plan) is the NED (National Economic Development) plan." and "The plan formulation methodology may have failed to identify another alternative that might provide the same or greater NED benefits at a reduced cost." and "It is possible that if additional channelization was included in one or more of the Levees, Floodwalls, and Pumps alternatives described on p. 102 of the Draft FS/EIS, a plan that provides greater benefits with lower costs might exist. It is also possible that if nonstructural management measures (after screening) were included in one or more of the initial array of alternatives, benefits and costs might have been beneficially impacted. As a result, the initial array of alternatives that were considered may have not considered a plan that would be superior to the TSP."  The Aug 2018 USFWS Fish & Wildlife Coordination Act Report is critical of the lake alternative and suggests that the sponsors re-evaluate a levee option without the inclusion of expensive pumps, stating "The levee only alternative includes a cost of 312 million for pumping plants at seven tributaries, however, previous Corp studies found that pumping facilities (i.e., plants) were not economically justified, with costs exceeding benefits by at least an 8 to 1 margin for each of the pump areas (1994 USACE draft Feasibility Study)."
  • Is the One Lake plan the most environmentally damaging plan?  US Fish & Wildlife Service, comment letter, Aug 2018 states: "As currently presented in the EIS and planning documents the proposed tentatively selected plan, while containing some environmental features and proposed mitigation, is the most environmental damaging plan. Overall, greater details regarding plan formulation, design, operation, mitigation, and adaptive management should be presented in another draft of the EIS prior to finalizing." The Army Corps of Engineers Agency Technical Review team states in 2018 "Open" (unresolved) comments: 
    • ​Screening criteria are "substantially flawed".  
    • "In my opinion, we are neither compliant with, nor operating within the spirit of the Clean Water Act." 
    • "there appears to be little consideration for environmental impacts within the selection process.  The TSP (Tentatively Selected Plan) does appear to have the most substantial environmental impacts, including over a thousand acres of wetland fill."  
    • "There is no explanation why the most impactful alternative was selected as the TSP." "The report needs to justify why the TSP impacts are warranted..and why these objectives can't be met with other alternatives."
    • "We cannot select an alternative if another practicable alternative could be selected with fewer impacts to waters of the United States."
    • Regarding an Adaptive Management Plan:  "This plan has specific requirements, almost none of which appears within the Feasibility Study."
  • Where is flood control for the City of Jackson? In 1996, US Army Corps of Engineers Feasibility Report, Flood Control, Pearl River Basin, Jackson Metropolitan Area, Mississippi recommended a system of flood walls and levees for flood control called the Comprehensive Levee Plan. This plan failed to receive local support, and, in 2001, Rankin-Hinds Pearl River Flood and Drainage Control District (Levee Board) took over responsibility for planning and executing flood control projects in the Jackson area. In the 26 years since the Corps Levee Plan, the Levee Board has proposed 3 different Lake plans (Two Lakes, LeFleurs Lake and Lower Lake) that failed to meet the Corps standard for being economically or environmentally feasible. A 2010 MS Joint Legislative Committee on Performance Evaluation and Expenditure Review PEER report 540 states: "Many of the plans for flood control in the Jackson metro area mix flood control with economic development. The plans incorporating economic development cost more than levees." Yet the Levee Board continues its push for economic development with another Lake plan, delaying a flood control solution for Jackson. 

Pearl Riverkeeper will be looking for the answers to these questions and more upon the release of the next edition of the One Lake Environmental Impact Statement. 

**The Levee Board never publicly released the 2018 Independent External Peer Review or the 2018 US Army Corps of Engineers Agency Technical Review Summary Report.  These 2 documents were obtained via FOIA request and can be viewed here: 
https://www.pearlriverkeeper.com/one-lake-agency-reviews.html

iNaturalist

7/7/2022

 
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Pearl Riverkeeper is on iNaturalist! The iNaturalist app helps you ID the plants and animals around you and connects you with our local community of citizen scientists and naturalists. Download the app and register for your free account today. Existing and new members, join the Biodiversity of the Pearl River Watershed project to help us gather research quality data on the flora and fauna in our area. Any observation you make in the counties of the Pearl River watershed will automatically be added to our project. https://www.inaturalist.org/.../biodiversity-of-the-pearl...

Water Quality Wednesday

7/7/2022

 
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#WaterQualityWednesday is back!! Our dedicated water quality monitors are out in the watershed this summer protecting your right to clean water! Our volunteers collect valuable data for early detection of issues, determining changes over time and supplementing monitoring by government agencies. For their most recent water quality report, MDEQ was only able to assess 12% of MS rivers and streams and conducted no weekly bacteria testing on inland rivers and lakes. Pearl Riverkeeper volunteers are helping to fill the gap. Shout out to our members and Patagonia for financially supporting this crucial work. View our WATER TESTING RESULTS.

Algae Watch

7/7/2022

 
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Intense heat, high nutrients (from fertilizers or sewer leaks), little rain and lots of evaporation are the perfect conditions for harmful algae blooms like this one on Brashear Creek in Madison. Algae blooms create low dissolved oxygen "dead zones" in the water which can potentially lead to fish kills. Some freshwater blooms are caused by cyanobacteria which have the potential to produce toxins that affect humans, pets, and our ecosystems. **Pets can get very sick and die within hours after swallowing toxins made by harmful algal blooms in bodies of water like lakes and rivers. Do not let your pets drink, play, or swim in water that has signs of a harmful algal bloom.
If you see an algae bloom, please report it to us here: https://www.pearlriverkeeper.com/report-pollution.html
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Pearl Riverkeeper is a licensed member of the Waterkeeper Alliance, the largest and fastest growing nonprofit solely focused on clean water. 

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