On January 7, 2019, MPC Vice President Josh Ellis provided feedback on the recommended plan based on the U.S. Army Corps of Engineers study at the Brandon Road Lock and Dam to address the movement of aquatic invasive species towards the Great Lakes.
January 7, 2019
Comments regarding the Great Lakes and Mississippi River Interbasin Study – Brandon Road Draft Integrated Feasibility Study and Environmental Impact Statement – Will County, IL
The Corps and the State must act swiftly and decisively to implement protections against upstream migration of Asian Carp
The Metropolitan Planning Council (MPC) submits the following comments regarding the U.S. Army Corps of Engineers’ study of measures at the Brandon Road Lock and Dam (BRLD) to address movement of aquatic nuisance species toward the Great Lakes. MPC appreciates the extensive work the Corps has undertaken to analyze alternatives and develop the Recommended Plan.
We strongly agree with the concept of planning and implementing aquatic invasive species (AIS) controls at the BRLD. At this location the locks are the only pathway through which species can move upstream. It is logical and cost-effective to plan controls in an engineered channel and the locks. We believe a combination of controls such as what is recommended in the plan makes good sense and the mix of controls should significantly reduce the risk of Asian carp moving upstream. Another positive feature of the plan and the engineered channel is there may be opportunities to test AIS control technologies and develop innovative solutions.
We have the following comments on the Recommended Plan:
1. Asian carp pose a clear, significant risk to the Great Lakes ecosystem. Carp would outcompete native aquatic species for food and habitat and reduce native populations. Additionally and importantly, if Carp were to become established in Lake Michigan this would threaten our regional economy. Recreational opportunities including boating, fishing, and swimming generate $3.2 billion annually and support 33,000 jobs in Illinois. We also note that aggressive management of aquatic invasive species is a signature goal of Our Great Rivers: A Vision for the Chicago, Calumet and Des Plaines Rivers. The threat of Asian carp in the Chicago Area Waterways and the Great Lakes is an urgent concern. The Corps and the State must act swiftly and decisively to implement protections against upstream migration of carp. MPC urges the Corps to act resolutely to limit Asian carp migration by taking the following actions:
? Move rapidly to construction. The recommended protections must be implemented as soon as possible to protect the Great Lakes. The Corps should deliver the Chief’s Report to Congress as soon as possible. ? Commit funding this year and next year to support the next phase of the project, Preconstruction Engineering and Design (PED). The Corps has the authority to move to the next phase of work and should fund it and act promptly on PED. ? Continue non-structural measures including monitoring and removing large numbers of Asian carp upstream of the BRLD. These measures are essential components of the overall plan for controlling Carp migration. These measures have largely been supported with Federal Great Lakes Restoration Initiative (GLRI) funds. A contingency plan should be developed to identify how these measures could continue in the event GLRI funds are not available.
? Working with the State, begin Phase II environmental assessment of the property adjacent to the BRLD that potentially will be used for construction staging and the control building. In order for the project to proceed it is imperative that this property be assessed and any contamination issues found be addressed. ? Pursue the fastest possible timeline to complete the project. In the Tentatively Selected Plan (2017), the timeline for implementation of measures at BRLD projected a construction completion date of 2025. The timeline in the Recommended Plan has been shifted back two years to 2027. This is moving in the wrong direction, given the risks to the regional ecosystem and the regional economy. We urge the Corps to look for opportunities to expedite the project and complete it as soon as possible.
2. The new electric barrier at BRLD should remain operational at all times, if feasible. Addressing safety concerns, the electric barrier would be housed within an insulated engineered channel, reducing the potential for stray currents. The electric barriers would be powered down when vessels are passing through the engineered channel and the lock. The Plan notes that operational processes may be adjusted based on in-water testing upon completion of construction.
We appreciate and support the Corp’s intention to adjust operating times of the electric barrier after initial testing and to shut the lock if the barrier malfunctions at any time. However, we anticipate that the effectiveness of the barriers will be severely inhibited by any powering down while vessels are traversing the locks. We urge the Corps to consider definitively resolving questions about operation of the electric barrier during the PED phase. We note the Corps’ finding that “The Recommended Plan would be most effective if the electric dispersal barrier operates continuously at optimal parameters to deter fish.” (Section 9.2.12)
Along with this comment on the electric barrier, we recommend that PED work allow for the possibility the mooring cells can remain part of the project. The mooring cells would be important if the Corps, either as a result of PED or due to post-construction testing, decides to operate the new electric barrier continuously. Removing the mooring cells at this point seems to pre-determine that there is no future scenario in which the electric barrier would be run at its most effective level of operation.
3. Construction of the Recommended Plan will create barriers at the BRLD that will prevent the upstream migration of native fish and mussels. Mitigation of this effect is very important. We support the Corps’ selected mitigation plan - trap and transport – which will contribute to native fish and mussel recovery in the Upper Des Plaines River. This approach provides for a high likelihood of success in allowing upstream migration of native species while limiting the risk of ANS transfer. If, during the planned project performance monitoring, it is determined that the trap and transport method has not been effective in mitigating native species losses above the barrier, we would encourage the Corps to consider implementing the other mitigation plan alternatives.
In conclusion, we urge the U.S. Army Corps of Engineers to act decisively to complete and implement the Recommended Plan and pursue the most expeditious feasible timeline for completion.
Thank you again for your work on this important matter, and for your consideration of comments on the Recommended Plan. If you have any questions about our comments please contact me at (312) 863-6045 or jellis@metroplanning.org.
Josh Ellis Vice President Metropolitan Planning Council 140 S. Dearborn St., Suite 1400 Chicago, IL 60603