Aquatic invasive species? On November 15, 2017, Josh Ellis, Vice President of MPC, analyzed and supported the investment in protection and controls at the Brandon Road Lock and Dam.
I am writing on behalf of the Metropolitan Planning Council (MPC) to provide comments on the Great Lakes and Mississippi River Interbasin Study-Brandon Road Draft Integrated Feasibility Study and Environmental Impact Statement. MPC appreciates the extensive work the U.S. Army Corps of Engineers has done to analyze alternatives and develop a Tentatively Selected Plan.
We agree with the concept of planning and implementing aquatic invasive species (AIS) controls at the Brandon Road Lock and Dam. At this location the lock is the only pathway through which species can move upstream. It seems logical and cost-effective to plan controls in an engineered channel and the lock. We believe a combination of controls such as what is recommended in the Tentatively Selected Plan (TSP) makes good sense and the mix of controls should significantly reduce the risk of Asian Carp moving upstream. We appreciate the attention given to safety considerations including the operational plan for the electric barrier. Another positive feature of the TSP and the engineered channel is there may be opportunities to test AIS control technologies and develop innovative solutions.
While we anticipate the measures proposed in the TSP would be effective in limiting the upstream migration of Asian Carp, the Brandon Road project by itself deals only with the oneway migration of AIS (from the Mississippi Basin to the Great Lakes) and is primarily oriented to Asian Carp. The Corps and other stakeholders need to continue efforts to plan two-way controls and address a range of species. We should move forward with plans for Brandon Road acknowledging this is one component of a total AIS control solution; it is not an endpoint, but a key step along a path.
We have three more specific comments on the TSP:
1. MPC and project partners, with funding from the Joyce Foundation, completed an evaluation of the economic benefits or consequences of aquatic invasive species control measures. Our goal in preparing the report was to develop relevant information on the economic impacts of AIS control investments that can be considered by decision-makers and stakeholders as planning and design work continues.
Our consultant for this study, Anderson Economic Group (AEG), reviewed relevant documents and interviewed decision-makers and stakeholders. MPC organized an advisory group that provided input on plans for the study and draft findings. The AEG analysis examined the economic impacts of three control scenarios, including implementation of the TSP. AEG found that the net economic benefits for the Chicago region from infrastructure investments would range from $387 million for a single control point at Brandon Road to $10.4 billion for solutions with multiple control points. The investments would result in between 450 and 2,300 jobs annually. It can be seen that there are positive economic impacts that would result from AIS control infrastructure investments.
If appropriate measures are not implemented and Asian Carp migrate upstream, it is expected there would be significant negative economic impacts. Recreational boating and fishing and related industries are the primary Chicago region sectors most likely to be affected if Asian Carp were to become established in the Chicago Area Waterways System and Lake Michigan. Recreational boating is an important economic sector in the region; spending supports over 3,700 employees and $130 million annually in earnings.
Our point here is there are both ecosystem and economic justifications for planning and implementing measures to control migration of AIS. We attach with our comments the AEG report on economic impacts.
2. We acknowledge a number of options were analyzed by the Corps in the TSP, but in our view there is another alternative that should be evaluated. As USACE understands, freight transportation and shipping through the Chicago Area Waterways is an important element of the regional economy. The Brandon Road lock system was constructed some time ago, and may not be optimally sized for today’s freight transportation methods and equipment. Operation of the modified system is expected to add up to 2.5 hours to lockage times. Can 2.5 hours be somehow be shaved off transportation times? It seems quite possible the Corps could plan for improvements to navigation system capacity and performance that would produce noticeable economic benefits and integrate controls for aquatic invasive species into the designs.
It is evident that some waterways stakeholders are concerned that the Brandon Road structural measures and other possible controls at other locations could make shipping less efficient and more costly. Because of this concern, some of these stakeholders may argue against the TSP. Perhaps we can come up with invasive species control solutions that represent a win-win outcome and garner support from a broad range of stakeholders. Combining lock improvements with AIS controls might also open up some additional funding/financing possibilities.
3. In addition to the structural controls that can be implemented at the Brandon Road Lock and Dam, we see it as critical that the non-structural measures being carried out continue, including commercial fishing/harvesting of Carp, monitoring, and public education and outreach. These measures contribute significantly to reducing AIS populations and migration risks, and will be complementary to the structural controls.
We urge the USACE to act swiftly after carefully reviewing public comments to identify and implement an effective solution at Brandon Road Lock and Dam. Given the discovery in June of an adult carp just 9 miles from Lake Michigan, we cannot lose momentum in addressing this very significant issue.
We appreciate your consideration of our comments. If you have questions or wish to discuss any of our comments or suggestions, please contact me at (312) 863-6045 or jellis@metroplanning,org.
Thank you,
Josh Ellis Vice-President Metropolitan Planning Council