US Army Corps of Engineers, Chicago District
231 S. LaSalle St. Suite 1500
ATTN: GLMRIS Comments, Dave Wethington
Chicago, IL 60604
Dear Mr. Wethington,
We are writing in response to the Great Lakes and Mississippi River Interbasin Study (GLMRIS) that was released by the Army Corps of Engineers on Monday, January 6, 2014. The study looked at eight options to control the spread of Aquatic Nuisance Species (ANS), especially Bighead and Silver carp, collectively known as Asian carp.
As the study points out, Asian carp pose a threat to the economy and environment of the region, including tourism, biodiversity, navigation, and more. In spite of the potential harms, Illinois has successfully abated the spread of Asian carp for over a decade thanks to measures such as the electric barriers put in place in Lockport, IL in 2002. The study also finds that if no new actions are taken, there is a significant risk of the Asian carp reaching the lakes after 25 years. This timeline is worth considering given that five of the alternatives will take at least that long to complete.
We want to voice our concerns on four of the study's containment proposals that involve some form of hydrologic separation, whereby the Great Lakes and Mississippi River basins would be separated by permanent physical barriers. Such a measure would have a profound adverse effect on Illinois, Indiana, and states throughout the region and might still allow the Asian carp to reach the Great Lakes during construction.
The study shows that a hydrologic separation would cost tens of billions of dollars while taking an estimated 25 years to come into effect as a mechanism to potentially control the movement of the Asian carp. A plan involving hydrologic separation would also require extensive and costly efforts to prevent flooding and water quality degradation stemming from the project. Even with a multi-billion dollar cost and a 25-year operational timeline, the Army Corps still cannot guarantee that Asian carp will not spread into the Great Lakes.
We believe that vigorous action is needed to control the risk of Asian carp, but we fear that any action that takes an estimated 25 years to implement will actually take much longer -- the report acknowledges real estate acquisition, permitting, and a lack of timely funding could further slow construction -- and involve a substantial risk of Asian carp reaching the Great Lakes.
In addition to the risk of delays, a 2010 study by DePaul University of hydrologic separation estimated that the impact on the Chicagoland area alone would be a $4.7 billion economic loss over 20 years, with a $582 million loss in the first year and $531 million annually in the seven years after. Additionally, a 2010 study by Martin Associates found that barge movements through the O'Brien Lock generates $1.9 billion in economic activity a year and supports over 17,000 jobs in Indiana.
A hydrologic separation would stifle the area economy at a time when, as the study points out, barge and other commercial traffic on the Chicago Area Waterway System (CAWS) is projected to recover to its pre-recessionary levels by 2020. Furthermore, the economic inefficiencies and environmental impacts that would result due to a switchover from barge traffic -- the average barge carries 80 truckloads of freight at a time -- to overland shipping would be severely negative.
While a healthy dialogue on an issue requires consideration of all available options, it is clear that hydrologic separation involves significant economic costs to our region and taxpayers while potentially doing too little to stop the spread of the Asian carp. We encourage the continued study of this important issue, especially new technologies that can protect the ecosystem from the spread of Asian carp. However, any solution that moves forward must be calibrated to offer the greatest efficacy for containment of the carp and the lowest regional economic impact achievable.