September 4, 2002
Mr. Wayne Schloop Army Corps of Engineers
Re: Comments on the Reconnaissance report for the Great Lakes Navigation System Review
Dear Mr. Schloop:
We are writing on behalf of the undersigned environmental organizations to convey our concerns regarding the draft reconnaissance Great Lakes Navigation System review (GLNS). On April 24, 2002, the Detroit District of the U.S. Army Corps of Engineers released a draft report that recommends a $20 million feasibility study to evaluate building a 35-foot deep navigation system on the Great Lakes-St. Lawrence Seaway waterway. We strongly oppose moving the GLNS to the feasibility stage. Nevertheless, if the governments decide to conduct a feasibility study, we would demand that the concerns discussed below would be addressed and resolved.
In response to your request on the scope of the GLNS study, in February 2001, more than one hundred letters from individuals and two of the undersigned organizations urged the Corps to take advantage of the opportunity to use its technical expertise to help solve the problems of toxic sediments and restore wetlands and other aquatic habitats. The GLNS, however, completely ignored these comments. In February 2002, at your request, leaders of the Great Lakes environmental community attending the Great Lakes Summit in Washington, D.C. identified exotic species, climate change, lake levels and wildlife and aquatic habitat restoration as issues that should be included in the GLNS. In response to that meeting, three more of the undersigned organizations submitted written comments before the draft reconnaissance report was released. Once again, the GLNS ignored these concerns. Instead, the report asserts that:
?Primary concerns among stakeholders were the limitations on vessel drafts imposed by low water and restrictive channel and port depths, narrow channels?restrictive lock sizes and channel depths on the St. Lawrence Seaway, the length of the shipping season, and the future reliability of lock structures on the Welland Canal and Montreal-Lake Ontario section of the Seaway.? (Appendix C, p.C-1)
We object to the exclusion of the views of taxpaying residents, Native American communities, hydroelectric utilities, conservation organizations, and businesses dependent on the ecological integrity of the Great Lakes and St. Lawrence River as not being stakeholders. We hope that this time you will consider our concerns and recommend the ?no action? alternative for the GLNS.
For the following reasons, we believe that the proposal will be very detrimental to habitat, species and economies dependent on a healthy Great Lakes and St. Lawrence River ecosystem.
To accommodate Panamax size ships (1000x105x35feet), as proposed in the draft reconnaissance report, the connecting channels, St. Lawrence River and dozens of harbors will need to be deepened as much as 9.5 feet. In areas of soft bottom, the shipping channels ? which include the St. Lawrence, Detroit, St. Clair and St. Mary?s Rivers - will need to be widened to as much as 60 feet to stabilize the deeper ditch. For 1000 footers to safely transit the St. Lawrence River, according to two senior St. Lawrence River pilots, islands bordering the current ship channel will have to be blasted to accommodate the larger vessels. As the Corps? report concludes, ?Dredging to allow a draft of 35 feet could generate hundreds of millions of cubic yards of material requiring placement.? The scale of the disposal problem posed by this massive amount of dredged material, especially because of contamination in those sediments, including PCBs, mercury and other metals, is almost unfathomable. The impacts from dredging will have short and long term adverse impacts. In the short term, the impacts of dredging hundreds of millions of cubic yards of river bottom include destruction of valuable fish habitat and re-suspension of contaminated sediments into the water column. Long term, the deeper channels will have to be maintained regularly, limiting the chance of regeneration of fish habitats and repeatedly resuspending contaminated sediments. Additional long-term impacts of operating larger ships in the basin include larger surge waves that will increase shoreline erosion, turbidity, reduced sunlight penetration, and degraded wetlands. Deeper and wider channels will significantly modify the hydrologic system by increasing flows through the connecting channels causing major modifications to lake levels throughout the system. This would result in lower levels of the Great Lakes upstream of river channels. (Lakes Michigan and Huron have already been lowered by as much as a foot overall because of previous navigation projects in the system.) As greater amounts of water flow through the system, downstream areas will be at greater risk of flooding wetlands and low lying shorelines. To prevent flooding, compensating works will have to be installed to hold back the water. The regulation of levels and flows through the use of dams and compensating works impacts natural water temperature variations and dissolved oxygen concentrations, two of the most important physical factors influencing all aspects of fish life stages If we have learned anything in the past forty years it is that the water flows and lake levels of the Great Lakes are critical and fragile. When artificially manipulated, it can be ecologically devastating. Since the opening of the St. Lawrence Seaway, regulating the water levels in Lake Ontario and the St. Lawrence River have reduced the annual fluctuations by about 40% of the average in spring and 60% during the fall and early winter. The loss of the fluctuations during the fall months has been advantageous for the growth of invasive weeds at the expense of dynamic and diverse wetland plant assemblages. Because many native fish, such as northern pike, spawn in flooded wetland areas, elimination of this habitat has contributed to the decline in northern pike species. Expansion of the navigation system will only compound the problems of artificial water level manipulation.
The report assumes that an ?unconstrained? system will include navigation season extension. Previous Corps of Engineers studies, including a demonstration program in the 1970s, provided overwhelming evidence of problems with winter navigation including increased scouring of shoreline vegetation, damage to waterfront structures, and reduced hydroelectric power generation capacity. Additionally, increased vessel size and traffic that is the goal of the proposed navigation expansion would significantly increase the probability and potential magnitude of oil and chemical spills. These spills could devastate wildlife, recreational activities, and economic livelihoods. Cleaning oil-contaminated areas is time-consuming, difficult, and very costly ? as was evident by the oil spill of 1976 in the Thousand Islands. An oil spill in the winter would be disastrous, as there is currently no existing technology that can effectively remove oil spilled under ice.
The draft report also does not estimate the ecological, social, and economic costs from the introduction of new exotic species to the Great Lakes-St. Lawrence River ecosystem, including the $4 billion Great Lakes commercial and recreational fishing industry. In the 1950?s, when the Seaway was being built, no one anticipated the disastrous impact of the influx of exotic species introductions, a development that has wreaked havoc with the Great Lakes fish and native food web. Because foreign ships would account for the largest proportion of the increase in traffic, the proposed navigation expansion would subject the Great Lakes to exotic species from around the world.
There are 162 exotics species recorded in the Great Lakes basin. Overall, approximately 31% of these have arrived through shipping activities. What is more disturbing is that since 1959, foreign shipping has facilitated the majority of new exotic species introductions. Eight of the 10 most recent invasions since the mid-1980?s are attributed to ballast water discharge from foreign ships entering the Great Lakes basin (Ricciardi and MacIssac 2000). Exotic species have already adversely impacted the ecology of the Great Lakes and St. Lawrence River and cost the U.S. and Canada billions of dollars. As just one example, in the Great Lakes and Mississippi River basins, the cumulative damage from zebra mussels are expected to reach $5 billion in damage by the end of this year. According to the Great Lakes Fisheries Commission, the future costs to control this one species are expected to grow to as much as $100 million per year.
While the draft report predicts that a 35-foot channel and season extension will provide annual benefits of $1.4 billions dollars, it fails to add up the potential costs to a wide range of other interests including hydropower, riparian owners, commercial and recreational fishing, sustenance and native communities and the tourist industry that depend on a healthy, diverse, fully functioning ecosystem.
The only costs mentioned in the draft report are a ?ballpark? figure of $10 billion, just to replace 15 locks at the Welland Canal and St. Lawrence River. But as we have seen with past studies, once the real costs to the taxpayer and to the environment are factored in costs will soar above this $10 billion. Cost estimates for environmental mitigation, polluted sediment disposal, losses to the fishing and tourist industry, decline in riparian property values, and the subsequent loss of tax revenues to the Great Lakes states are associated costs that must be included in the benefit-cost analysis. Previous Corps studies have been wrong in predicting increased traffic through the St. Lawrence Seaway or the Upper Lakes. In fact, navigation expansion on the Great Lakes has been considered before, and was found to be economically unjustified and environmentally unacceptable. Another Corps study to examine the feasibility of building a 35-foot navigation channel from Montreal to Duluth will be a waste of money, and human resources, and will likely divert the region from addressing a broader agenda that can truly benefit the region. This proposal runs counter to the discussions and planning underway throughout the region to mobilize efforts to restore the Great Lakes. Enlarging the current commercial navigation system as proposed in the reconnaissance report will bring irreversible environmental damage to the ecosystem. We recognize the importance of waterborne commerce to the economic health of the region. The Corps, however, should be investigating means of making the existing commercial navigation system more sustainable, by identifying where intermodal improvements can be made and by taking into consideration the problems and threats posed by invasive species, climate change, lowered water levels and impacts to fish and wildlife habitat. We urge you to halt this present Great Lakes Navigation System Review. Our organizations stand ready to assist the Corps with projects that restore our wetlands and fisheries, clean up the toxic hot spots and ensure that our waters are safe to drink, swim and fish for generations to come.
Algonquin to Adirondacks Conservation
Association (A2A) (Ontario, Canada)
Audubon New York
Bay Area Restoration Council
Lake St. Clair Advisory Committee
Michigan Trappers Association
National Wildlife Federation
Save Lake Superior Association
Ontario Toxic Waste Research Coalition
Prairie Rivers Network
Judy Shelly Pratt
Red Cliff Band
Regional Action Group for the Environment
RiverSides Stewardship Alliance
SONS of Lake Erie Fishing Club
St. Clair Channelkeeper
Save the River
St. Clair River International Citizens' Network
STOP (Quebec, Canada)
Tip of the Mitt Watershed Council
Toronto Environmental Alliance,
Walter J. Bock
Trout Unlimited Illinois Council
Trout Unlimited - Michigan Council
Western Pennsylvania Conservancy
Wisconsin Audubon Council, Inc.
Wisconsin Wildlife Federation
Michigan Environmental Council
Minnesota Conservation Federation
Ohio Environmental Council
Michiana Watershed, Inc.
Clean Water Action Council of Northeast Wisconsin
Environmental Advocates of New York
Erie County Environmental Coalition
Federation of Ontario Naturalists
Great Lakes United
Indiana Wildlife Federation
Jackfish Bay PAC (Ontario, Canada)
Lake County Concerned Citizens
Canadian Institute for Environmental Law and Policy
Clean North (Ontario, Canada)
Lake Michigan Federation
Lake Ontario Keeper
League of Ohio Sportsmen
Citizens for Renewable Energy (Ontario, Canada)
Brown County Conservation Alliance
Richard Lindgren Canadian Environmental Law Association
Rick Roman, Bruce Peninsula Environment Group (Ontario, Canada)
Citation: Recent mass invasion of the North American Great Lakes by Ponto-Caspian species, A. Ricciardi and H.J. MacIsaac, TRENDS IN ECOLOGY AND EVOLUTION (2000) 15: 62-65