Upper Mississippi River Basin Association Comments

on

Emergency Action Plan Evaluation

in

Upper Mississippi River Comprehensive Plan

(May 25, 2005)

In May 2003, the Upper Mississippi River Basin Association (UMRBA) recommended that the UMR Comprehensive Plan, authorized in Section 459 of the 1999 Water Resources Development Act, explore the development of an “emergency action plan” (EAP). UMRBA envisioned the EAP as being a “systemwide operational strategy for conveying floodwaters during major flood events.” In general, it was assumed that such an EAP could be the basis for answering questions associated with when and where “floodfighting” should be focused. When the EAP effort began, it was not known how far this planning process could or should go in terms of either the hydrologic and economic analysis or the interest and ability of the stakeholders to pursue the implementation strategies required.

UMRBA greatly appreciates the efforts of the Corps of Engineers to accommodate the States’ expressed interest in developing an EAP by developing “emergency action scenarios” (EAS). The series of four EAS developed as part of the Comprehensive Plan reflect successively higher levels of systemic floodfighting. The evaluation of these scenarios, including their hydrologic impacts (i.e., maximum induced stage frequency increases) and benefits (i.e., reduced residual annual damages), provides important new information and insights. Simply having such analysis available is a valued contribution to future floodplain management decisions. In particular, the analysis has demonstrated that:

• induced damages of floodfighting are not of particular concern for emergency response efforts north of Keokuk, Iowa;
• induced rises resulting from emergency protection efforts in urban and industrial areas are not significant; and
• induced damages are thus of general concern only for systemic agricultural levee raises in river reaches between the confluence with the Ohio River and Keokuk, Iowa.

UMRBA believes that further efforts to build upon the scenario analysis to formulate an actual Emergency Action Plan is beyond the scope of the Comprehensive Plan. In particular, the States agree with the assertion in the Corps’ draft EAP report (distributed in January 2005) that further plan development would require agreement on:

• criteria for successive protection (i.e., prioritized order of what areas are to be protected), including a systemic definition of critical infrastructure,
• definition of high damage potential in agricultural areas, and
• definition of significant hydraulic impact.

Identifying these parameters; conducting the necessary additional analysis, including cost estimation; and developing the attendant implementation framework are clearly well beyond the scope of the current Comprehensive Plan study effort.

In conclusion, UMRBA thanks the Corps of Engineers for its good faith efforts to provide useful new information to inform future floodfighting decisions on the part of private parties and public agencies. The States look forward to seeing the final report and recommend that the report describe these analyses but make no further recommendation regarding their use.