FIRST and the most important
Attn: Allen Edris
US Army Corp of Engineers
In your correspondence, please be sure you refer to the Lower Cove Run dam project: CELRP-OP-F 2005-2159. You must do so by Sept. 16th. This is crucial. In the attached notice sent out by the Army Corp, they mention several times that the public’s interest matters. This is a federal permit. If the Army Corp of Engineers denies it, it would be a huge blow to the project. Please pass this on and get as many community members to comment as possible. Federal tax money will be used, so those outside the community are just as important.
Ask that the Army Corp of Engineers deny the 404 permit or at the minimum hold a public hearing. When commenting on why the permit should be denied, you can list ANY objections you have to the project.
It can be as simple as stating that you just don’t
want the project. Both purposes are “shady.” There is
no need for additional flood protection in the
If you want to get more technical, you can list problems with the project and its EIS.
The Environmental Protection Agency (EPA) had many concerns and gave the draft EIS an EC-2 rating, which indicates environmental concerns and inadequate data. (Appendix A of EIS)
The WV Division of Highways raised concerns that the dam could cause an increased risk of flood damage to the road and a potential hazard to the traveling public. (p108 of EIS).
The WV Department of Natural Resources expressed several concerns regarding trout habitat, water quality, wetland mitigation, and the calculation of the benefits of the recreational component. (p109-111)
After repeated requests by the public, NRCS still has not provided a cost-benefit analysis of the Lower Cove dam ONLY. NRCS will only do an analysis that includes 4 dams together. They will not analyze if needs have been met by the other 3 dams already built.
After repeated requests, NRCS still has not included flood damage data. They give an annual amount yet no information on how that figure came about.
The projected population growth used in the EIS is exaggerated. NRCS is using a rate twice as high as what as the actual growth has been.
Wetlands will be destroyed. Wetlands act as a natural floodplain. Is the mitigation plan in the EIS appropriate?
Because there are brook trout in the Lower Cove Run and because portions of it go flow through the national forest, several upstream segments are considered Tier 3. A dam will compromise the brook trout habitat/population as dams warm the water.
The workplan from 1974 is still being referenced in the 2009 EIS.
Then ask that, based on those concerns, a public hearing be held in the community where the project in proposed.
Finally, NRCS will need a 401 state certification as well. Request a public hearing be held regarding the 401 state certification for the proposed Lower Cove dam. Ask that the hearing be held in the community where the project is proposed. Concerns include brook trout population, wetlands, and need of the project.
WV Department of Environmental Protection
Office of Water Resources
Regulatory Review Program
If you sent comments concerning the EIS, the responses are included in the final document recently released.
If the responses you received are inadequate, you should email Bill Odonnell at NRCS ( firstname.lastname@example.org ) before the end of September to let him know you are dissatisfied with the responses.
You can view the document at: http://www.wv.nrcs.usda.gov/programs/watershed/lost/lostEIS/lost_riverEIS.html
Thanks for all the help. If you need any additional info, please email me: email@example.com