On Wednesday the Tennessee Valley Authority Board of Directors voted to approve a new Reservoir Operations policy (ROS). The change will create shockwaves among many lake shore landowners, fishermen and fisheries biologists - at least those who enjoy the lakes in Southeast Tennessee.
Under the new policy, TVA won't raise lake levels on Chickamauga, Watts Bar and Fort Loudon to full summer pool until May 15th.
Grave concerns have been expressed by TWRA fisheries biologists, by the Tennessee Conservation League (see letter below), by marinas and by lakeshore landowners.
Many lakeshore dockowners objected stringently to the measure, especially those with shallow water docks that won't be able to float a boat until mid-May.
The 240-member Watts Bar Lake Association met with TVA in early April hoping to talk them out of the change. A representative from Watts Bar attended the meeting held in Oxford, Mississippi.
Association President Lee Miller expressed great disappointment over the vote.
"They had their minds made up on this thing," said Miller. "One-and-a-half feet of water may not sound like much, but it is a big concern for people back in these coves where they don't have 3 feet of water at full pool."
Fisheries biologists also say it could hurt fish populations.
"I feel like we're taking a giant step backwards."
Those are the words of TWRA Regional Fisheries Biologist Anders Myhr.
The ROS was a comprehensive review of how TVA operates the river system. It brings about several changes in operation. The change Myhr and other TWRA biologists are upset with is the plan to delay the filling of three mainstream reservoirs until May 15th.
Myhr says that will have a devastating impact on game fish that spawn in April. He says their best, historic spawning areas are liable to be left high and dry by low, or fluctuating water levels.
"I think fishermen have something to look forward to they don't want to see," said Myhr. "They can look forward to missing year classes of bass and crappie and redear sunfish (shellcrackers). I think they'll all be negatively impacted by this operation."
TWRA Aquatic Biologist Kirk Miles adds, "Fish are going to be ready to spawn and there's a good chance they're not going to have the best spawning habitat available."
TWRA biologists have long been concerned about TVA's reservoir operations. Historically however, they have kept their complaints behind closed doors. They say this time TVA has gone too far and they are going public in hopes of garnering public support.
Myhr and Miles are most concerned by what they call "a yo-yo effect." That's when TVA raises the water levels and then drops the water back down, leaving spawning fish beds high and dry.
Wayne Poppe, a biologist with TVA says that under the new system that "yo-yo effect" is less likely to happen.
"Let's look at it this way," said Poppe. "Pretend the lake is a 5-gallon bucket of water. Under the old system it's three-quarters full with 4 inches of storage. If we have 8-inches of rain predicted, you have to drop the water to get ready for the extra rain. Under the new scenario, however, if you've already got 8 inches of storage in that bucket you don't have to pull it down to make room for more rain."
Poppe says the new plan is designed with flood control as a top priority.
"As we go through this there's been a lot of balance," said Poppe. "Flood control, navigation, aquatic habitat... we tried real hard to create the best overall balance for the entire system."
Poppe and other TVA managers point out the comprehensive public planning process in which the agency received 22,000 public comments, letters, petitions and surveys.
Myhr counters that, "TVA actually combined some of the alternatives presented to the public and the final plan is not anything anybody had the opportunity to comment on."
He adds that TVA will make no changes in the reservoir operations on Kentucky Lake in West Tennessee.
"I feel like Ft. Loudon, Watts Bar and Chickamauga have been picked out to mitigate this thing," he said.
Under the proposed plan, ten tributary lakes in the upper reaches of the TVA system will have higher water levels sooner in the Spring and later in the Fall. TVA has been under significant pressure from dock owners, landowners and boaters to provide more water on those lakes for many years.
Myhr and others feel that TVA is caving in to that pressure and the mainstream lakes are being denied water to provide more water for the tributaries.
Poppe says that is not the case.
"It's erroneous to think that changes on mainstream reservoirs has anything to do with the tributary reservoirs," said Poppe. "It's strictly to give us better flood protection in those situations where we have localized rainfall. We've had occasions recently where flooding has occurred from huge rains that fell just above Chattanooga when Knoxville got hardly any rain. We're looking at trying to provide up to $15 million dollars in flood protection."
Miller wonders why dockowners should be penalized for haphazard development beneath the flood plain.
"Why make other people suffer for something that other people do wrong," asked Miller.
Read the TVA News Release about the change.
Questions raised by the Tennessee Conservation League (April 9 Letter):
Mrs. Janet Herron
Reservoir Operations Study
TVA WT 11A
400 W. Summit Hill Dr.
Knoxville, TN 37902
Let me begin by thanking TVA for this opportunity to provide comment on this most important group of issues. These are the official comments of the Tennessee Conservation League (TCL) regarding the Tennessee Valley Authority’s (TVA) River Operations Study (ROS) recently completed draft Environmental Impact Study (EIS), pursuant to the 1969 National Environmental Policy Act (NEPA).
Clearly, management of the Tennessee River system is a complicated and, at times, controversial activity. The League applauds the professional and very competent staff at TVA, and their work in generating this EIS.
The League has four primary concerns regarding the ROS, and submits the points and a recommendation for your consideration.
1. Roughly 5% of Tennessee reservoir users are marina operators and shoreline property owners. Representatives of these interest groups went before the Regional Resource Stewardship Council and asked for lake levels to be studied. The RRSC complied and recommended that TVA undertake what is now known as the River Operations Study.
Our concern stems from an analysis of the ROS EIS preferred alternative that shows more negative impacts to the natural resources of the valley than positive impacts. Additionally, the positive impacts are limited to items that directly benefit those few users that pushed for the study to occur.
Thus, there is an appearance that TVA has catered the ROS to benefit a fraction of the reservoir users that have been the most vocal regarding reservoir water levels. While the League does not have a particular issue with TVA trying to address improved water levels, we do believe that addressing reservoir water levels at the expense of other natural resources, and users, is not in the best interest of TVA or the public at large.
Lastly, while this ROS appears to try and maximize recreation benefits of the reservoir system, we are concerned that the perception of increased recreation benefits is largely limited to boaters and lake home owners.
2. TVA’s analysis of the impacts of the ROS states the following (taken from presentation given by Wayne Poppe):
a. Slightly negative impacts - water quality, power generation, regional economy, shorebirds and waterfowl, and shoreline erosion.
b. Slightly to substantially beneficial – navigation, recreation, and scenic integrity.
c. + and - impacts – threatened and endangered species, aquatic resources, and wetlands.
d. No change – flood risk and water supply
We are concerned that there are only three distinct benefits identified from implementing the ROS preferred alternative, one of which is based purely upon personal opinion (scenic integrity). Additionally, the greatest positive impact directly favors those 5% of lake users that called for the study initially.
In contrast, five areas of analysis show negative impacts, with three others receiving varied impacts. The overall picture clearly shows that natural resources, on the whole, will receive negative impacts (water quality, shorebirds, waterfowl, and erosion).
3. The Tennessee Wildlife Resources Agency has publicly stated that implementation of the ROS preferred alternative above Chickamauga dam will negatively impact game fish spawning.
The greatest concern stems from the change in the spring “guide curves”. There does not appear to be good information or data as to the effect these changes in the “guide curves” will have on the main stem reservoir fisheries above Chattanooga. This is a concern when one considers that in Tennessee, fishing is a $1.1 billion industry, and that TVA controls reservoir levels on many of Tennessee’s best fisheries.
4. We would like to ask as to how the special weekend release schedules proposed in the EIS for the tail-water fishery areas were developed. Specifically, did TVA engage the users of these tail-waters in developing the weekend schedules? We have not heard of any such public interaction, and caution TVA that if this has not been done adequately, the users of the tail-waters may react negatively to the proposed changes.
Given these concerns, we ask that TVA modify the TVA preferred alternative to address the adverse impacts to water quality, fish, shorebirds, waterfowl, and shoreline erosion. If these changes are not feasible, we would ask that the TVA Board of Directors select the “No Action” alternative in the EIS. From our perspective, the selection of the “No Action” alternative would constitute a win for the Tennessee valley. TVA has done an outstanding job of balancing the complex needs of all the various and diverse reservoir users for many years, and our desire is to see this continue.
In conclusion, regardless of the alternative selected, we recommend that TVA design, implement, and adequately fund a thorough monitoring protocol to determine the specific effects of TVA river operations upon the natural resources of the Tennessee valley.
Should you or your staff wish to meet to discuss these concerns, we will be happy to meet at your convenience. Additionally, please do not hesitate to contact us via phone at 615-353-1133.