Betting on Another Lake

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