August 22, 2000

Brenda Puloma
Project Manager
Little Rock District Corps of Engineers
P.O. Box 867
Little Rock, AR 72203-0867
Subject: White River Minimum Flow Study

Dear Ms. Puloma:

I attended the July 24, 2000 Scoping Meeting held in Mountain Home, Arkansas for the White River Minimum Flow Study proposed to be officially initiated October 1, 2000. One purpose of this letter is to ensure that Mid-South Fly Fishers be considered to have legal standing as an interested party to the upcoming Environmental Impact Study (EIS). Another purpose of this letter is to provide comments, questions, and concerns as requested at the Scoping Meeting. I signed in at the meeting using the address typed above, which should be used in any correspondence (including forwarding of any documents).

First, the Mid-South Fly Fishers (MSFF) request a copy of the U.S. Army Corps of Engineers (USACE) National Environmental Policy Act (NEPA) Guidelines. This may be sent to the address typed above.

Second, the Mid-South Fly Fishers (MSFF) request clarification of the ownership and control of water within each of the five reservoirs to be included in the EIS. If the Southwest Power Administration (SWPA) or any other entity claim ownership (in part or in whole) or the control of the use of said water either by lease or by sale, we request a copy of the lease agreement(s) or instrument(s) of sale.

The MSFF membership represents over 400 individuals whose use of the resources of the entire White River Basin watershed contribute to the economic well-being of the states involved. We have an interest in the health and management of these resources for the public. It is our understanding that the proposed White River Minimum Flows Study excludes a portion of the White River Basin. We have a concern that neglecting to assess the potential direct, indirect, and cumulative effects of minimum flows on the entire basin's system would compromise the USACE's ability to make sound recommendations for the proposed study area. Watersheds cannot be segmented using arbitrary parameters such as political boundaries or any other regards. Therefore, we request that consideration be given to the entire White River Basin when assessing the direct, indirect, and cumulative effects of minimum flows for the segment of the basin indicated for the proposed study. These direct, indirect, and cumulative effects should include a comprehensive assessment of the fisheries and hatcheries involved, all wildlife involved (including macroinvertebrates), bottomland hardwood forest areas involved, as well as other water uses for flood control, hydropower, domestic water supply, and recreation. Potential effects to other important areas in the White River Basin, such as the Buffalo River along with other tributaries of the White River and the Black River with its tributaries should be included in the assessment.

We understand that the creation of the dams along the White River virtually eliminated the native warmwater fisheries. However, the development of a trout fishery, made feasible by the cold water releases from the dams, has produced a world-class trout fishery, contributing significantly to the economic base of the entire region. We are definitely part of the economic well-being of the communities and states in the areas to be included in the study. Under Public Law 106-53 (the Water Resources Development Act of 1999), the USACE is to evaluate "alternatives and impacts pertaining to reallocation of water storage at five reservoirs in the White River System (Beaver, Table Rock, Bull Shoals, Norfork, and Greers Ferry) as authorized by section 374." [Quotation from the Federal Register/Vol. 65, No.104/Tuesday, May 30, 2000/Notices, page 34453.]

It is understood that the authorized purposes of each of these five reservoirs include flood control, hydropower, water supply, fish and wildlife, and recreation. It is further understood that, at present, storage allocations of these five reservoirs include only flood control, hydropower, and water supply—with the exception of Table Rock Lake, which has a storage allocation for fish and wildlife specifically for the state fish hatchery located there. At the July 24, 2000 scoping meeting in Mountain Home, current storage allocations were outlined for Bull Shoals Lake and for Norfork Lake. What are the current storage allocations (in acre-feet) for Greers Ferry Lake, Beaver Lake, and Table Rock Lake?

As delineated in the Federal Register referenced above, the Environmental Impact Statement (EIS) will "evaluate the effects of alternatives on the authorized project purposes and other identified concerns. Significant issues to be addressed in the EIS include: (1) Impacts on flood control; (2) impacts on hydropower generation; (3) impacts on recreation and recreation facilities; (4) impacts on structure of the dam; (5) impacts on dish [sic] and wildlife resources within and also above and below the lake; (6) impacts on downstream flows on the White River System; and (7) other impacts identified by the Public, agencies or Corps studies." The proposed EIS will address the reallocation of storage from each reservoir lake to be used for minimum flows to sustain the trout fisheries downstream from each dam in the following amounts: Beaver Lake-1.5 feet; Table Rock Lake-2 feet; Bull Shoals Lake- 5 feet; Norfork Lake-3.5 feet; and Greers Ferry Lake-3 feet."

In light of the above, we have the following concerns:

1. We would like an explanation of how these allocation amounts were determined. Are other amounts of allocation to be considered?
2. What methods will be used to determine the effects on the water bodies? For example, will the Instream Flow Incremental Methodology (IFIM) or other methods be used for the tailwaters?
3. What will the direct, indirect, and cumulative effects of continuous cold water releases be on each successive reservoir in the chain?
4. How will the available cold water levels in each reservoir be safeguarded?
5. Will the thermocline be lowered, raised, or remain the same in each successive lake?
6. How will the lakes' thermoclines be affected by allocating water from the current flood pools, from the current conservation pools, or from various percentages of a combination of the current flood pools and conservation pools?
7. What will be the effect on overall reservoir temperatures for each successive lake and for each of the proposed scenarios of reallocaton?
8. What will be the direct, indirect, and cumulative effects on water temperatures for each successive tailwater downstream from each successive dam?
9. How will the fish hatcheries (Norfork and Greers Ferry National Fish Hatcheries use water directly from their respective reservoirs) be affected by any change in the temperature of the reservoirs?
10. What will be the direct, indirect, and cumulative effects on the wetted perimeters of each lake? How will this affect shoreline habitat and vegetation?
11. How will each lake's water levels be affected under each scenario of allocation? What exactly will this water level be in each reservoir?
12. What will be the direct, indirect, and cumulative effects on the wetted banks of each tailwater under each scenario of allocation? How will this affect streambank stabilization? How will this affect streambank vegetation?
13. How will each tailwater's water levels be affected under each scenario of allocation? What exactly will this water level be in each tailwater?
14. How will seasonal hydrologic patterns such as seasonal flooding be affected by further alterations in water release schedules?
15. How will the water levels, the water velocity, the turbidity, and streambank effects affect the ability to wade fish in each of the tailwaters?
16. Will there be any provisions for conditions varying from the average norms such as drought years and overly wet years?
17. In what way will the concentrations of naturally occurring manganese, iron, and hydrogen sulfide be affected in each of the lakes and in each of the downstream tailwaters?
18. In what way will the dissolved oxygen levels be affected in each of the lakes and in each of the downstream tailwaters?
19. Are there alternatives to the proposed reallocation in order to provide enough cold water to sustain the trout fisheries in each of the tailwaters?
20. Will there be any effects on the status of Federal Energy Regulatory Commission (FERC) requirements for the dams having a FERC license (such as Greers Ferry Dam)? Will these be written into the license?
21. Will there be any effects on the operations of dams not holding a FERC license (such as Bull Shoals Dam or Norfork Dam)?

Will the potential minimum flows be through a bypass pipe at the same or different level as the house turbines? Through the house turbines themselves? Or some other method? How would consideration of the level from which the minimum flows originate affect the questions above regarding temperature, dissolved oxygen, and concentrations of naturally occurring substances in all five reservoirs and in all five tailwaters?

The Mid-South Fly Fishers value being a part of the process you are to undertake. Thank you for this opportunity to provide our comments, questions, and concerns. As we are provided documents, including any draft documents, we will respond with further comments and/or questions as deemed necessary.

We realize that some of our questions will be addressed by the study itself. However, answers to other questions may be known now. We would appreciate being apprised of the time frame for receiving these known answers and requests for documents.

Sincerely,

Judy G. Boston
MSFF Conservation Director
1373 Peabody Avenue
Memphis, TN 38104-3637
Telephone (901) 278-8060
Cell Phone (901) 483-5944
E-mail: jgboston@bellsouth.net