TVA Response
Response to RRSC Recommendations of August 29, 2001
Contents
of this page
Letter
from Kathryn J. Jackson
Letter from the TVA Board
Response
on water quality monitoring
Response on watershed improvement process
Response on reservoir releases improvement
Response on transmission line rights-of-way
Response on campgrounds issues
Response
on navigation responsibilities
Letter from Kathryn J. Jackson
December
6, 2001
RECOMMENDED RESPONSE-OF-RECORD TO REGIONAL RESOURCE STEWARDSHIP COUNCIL RECOMMENDATIONS DATED AUGUST 29, 2001
At its August 28 meeting, the Regional Resource Stewardship Council approved recommendations to TVA addressing water quality monitoring, watershed improvement, reservoir releases improvement, transmission right-of-way maintenance, campground policy, and navigation responsibilities.
Attached
is our proposed TVA response to these recommendations. The response is
based on the points Skila used in the discussions with members of the
Council at its October 25 meeting. In general, TVA accepts the recommendations
made by the Council with the following exceptions:
• The portion of the water quality monitoring recommendation concerning
linking water quality databases is accepted subject to the qualification
that any required investment must contribute to TVA’s business needs.
• The right-of-way management recommendation to use natural methods
for maintaining vegetative cover is accepted on a pilot basis.
• The response to the recommendation that federal funds be used to
maintain and improve the Tennessee waterway system is similar to our previous
position that existing legislation does not allow TVA to receive direct
appropriations, but that if appropriations do become available they would
be used.
• The response to the recommendation that costs and benefits of an
increased minimum navigation channel depth be included in the Reservoir
Operations Study is that it will be considered as the scope of work for
the two-year study is developed.
The
attached response will serve as TVA’s official response-of-record
to the Council’s recommendations. The next Council meeting is scheduled
for January 31 in Huntsville, Alabama. In order to ensure that the Council
receive this response prior to this meeting, I would appreciate receiving
your comments or changes by January 7.
Kathryn J. Jackson
Executive Vice President
River System Operations & Environment
WT 11A-K
Attachments
January 30, 2002
Mr. Bruce D. Shupp,
Chair
Regional Resource Stewardship Council
Post Office Box 17900
Montgomery, Alabama 36141-0900
Dear Bruce:
Enclosed is our formal response-of-record to the Council’s August 29 recommendations on water quality monitoring, watershed improvement, reservoir releases improvement, right-of-way maintenance, campground policy, and navigation. This response is based on discussions with the Council at its October 25 meeting at Lake Barkley.
We are pleased that we are able to accept the great majority of the Council’s recommendations. Our position on each recommendation is documented in the enclosed response-of-record.
TVA staff is reviewing the Council’s recommendation on improving biodiversity in the Tennessee River system that was approved at the October 25 meeting. We plan to discuss our response with the Council at its January meeting in Huntsville.
Once again, we appreciate the work of the Council in developing its recommendations. Your recommendations will help guide TVA as we pursue our objective of achieving excellence in business performance and public service for the people of the Tennessee Valley.
Very truly yours,
Glenn L. McCullough, Jr., Chairman
Skila Harris, Director
Bill Baxter, Director
Enclosure
TVA Response to Regional Resource Stewardship (RRSC) Recommended TVA Policy on Water Quality Monitoring dated August 29, 2001
Recommendation
The Water Quality Subcommittee recognizes the invaluable nature of the
work done by TVA. That work done early on by the agency formed the basis
of the world’s understanding of reservoirs. The work should be continued
and should be integrated into other water quality and natural resource
monitoring efforts. Specifically, TVA’s monitoring efforts should
be coordinated as much as possible with state watershed assessment cycles,
the data should be managed in the national water quality database, and
the results of TVA’s assessments should be compared with state-adopted
water quality standards and coordinated with state and other federal agencies.
The level of TVA’s efforts are considered to be currently adequate,
and should in the future be coordinated with the capabilities and levels
of efforts of the states and other federal agencies.
TVA accepts this recommendation to coordinate its water monitoring efforts and share its water quality data. TVA recognizes the value of its water quality database and would like to make it more useful. TVA will work to coordinate efforts among agencies and organizations to avoid duplication and share results. TVA will explore ways to strengthen the links among various water quality databases so long as the investment contributes to TVA’s business needs. If there is a way to cost-effectively integrate data management systems that can link to a national water quality database or otherwise address data exchange needs, we will consider that option. TVA will work with interested state agencies to identify potential benefits of a regional approach to water quality monitoring.
TVA Response to Regional Resource Stewardship (RRSC) Recommended TVA Policy on Watershed Improvement Process dated August 29, 2001.
Recommendation
The Water Quality Subcommittee recognizes the valuable resource TVA has
developed with its watershed teams in bringing their expertise to bear
on solving water quality issues in the Tennessee Valley. The watershed
team program should be continued and strengthened by integrating its activities
with TVA’s sustainable economic development initiative and using
its experience to highlight economic trends that may adversely affect
water quality. The program should also be integrated with the states’
water quality planning processes, using that integration to build on others’
expertise, experience, and efforts.
TVA accepts this recommendation. TVA Watershed Teams convene and facilitate community actions that examine information about resource conditions and economic development trends. This work is part of the Watershed Teams’ annual work plans and they are measured on their success in helping communities improve water quality to support a variety of sustained uses. TVA interacts with all seven Valley states to ensure that TVA’s actions are complimentary to the states’ five-year watershed planning cycles.
TVA
Response to Regional Resource Stewardship (RRSC) Recommended TVA Policy
on Reservoir Releases Improvement (RRI) dated August 29, 2001.
Recommendation
Maintain the gains achieved by the Reservoir Releases Improvement (RRI)
program by continuing to support the operation, maintenance, and enhancement
of the water quality improvements to meet tailwater commitments and designated
uses.
TVA accepts this recommendation and will continue to operate and maintain RRI systems as required to ensure tailwater commitments and designated uses are achieved.
TVA Response to Regional Resource Stewardship (RRSC) Recommendation on TVA Transmission Line Rights-of-Way Maintenance Policies and Practices dated August 29, 2001.
Recommendation
TVA should make more effort to contact property owners whose land is to
be cleared or
re-cleared so that potential problems may be worked out prior to clearing
or re-clearing. TVA should ensure that contractors follow appropriate
policies and have information about land to be cleared or re-cleared that
is adequate to prevent violations of state and federal laws. TVA should
take greater responsibility for ensuring that relationships with property
owners reflect TVA’s intent to be cooperative and responsive.
TVA accepts this recommendation. TVA acknowledges that many property owners wish to be notified before re-clearing activities begin. TVA currently assigns personnel to monitor contractor performance and survey sites for compliance. In addition, TVA will put contractors on notice of increased performance and add language to right-of-way re-clearing contracts detailing expectations for contractor notification to property owners about planned work activities. New contracting procedures to enhance contract enforcement will include the use of penalty and dismissal clauses which contractors must review, accept as enforceable, and sign. TVA will also post information on its web site to identify which transmission lines are targeted for re-clearing maintenance.
TVA acknowledges the need to continue improving relationships with property owners, while also working to maintain reliability of transmission lines and continuing to meet easement obligations.
Recommendation
Whenever possible, TVA should create or participate in innovative approaches
and partnerships with other units of government or private agencies or
property owners who have an interest in natural methods for maintaining
vegetative cover for purposes such as recreation and wildlife conservation.
For example, a state park with transmission lines may agree to maintain
the vegetative cover to provide natural habitat, rather than having TVA
clear the land on a regular basis.
TVA accepts this recommendation on a pilot basis. TVA will examine innovative right-of-way maintenance methods, working in partnership with others. The pilot effort will be monitored and increased if proven cost effective. TVA will explore partnership opportunities with local governments, state wildlife and park management agencies, federal agencies such as DOE, and conservation organizations. In addition, TVA will continue seeking cost effective ways to let landowners/land managers know about vegetative cover to provide wildlife habitat.
Recommendation
TVA has done significant work to research and compile user-friendly information
about landscaping rights-of-way with natural shrubs. Once installed, this
sustainable natural cover could dramatically reduce the cost of future
maintenance of transmission line rights-of-way. In addition, this method
could reduce complaints and instances of environmental law violations.
TVA should institute a pilot project in the use of natural cover with
the goal of analyzing its long-term benefits for the purpose of establishing
reasonable goals in the amount of right-of-way planted in sustainable
cover.
TVA accepts this recommendation. TVA will analyze the results of previous research and will begin a pilot project this year (FY 2002) to provide additional data needed to evaluate the costs and long-term cost and ecosystem benefits of various vegetation management alternatives, including use of natural cover and native species. An application of herbicides will be necessary to reduce the brush density to an acceptable level for native plant survival. If the pilot demonstrates that use of natural ground cover is a cost-effective way of maintaining rights-of-way and providing ecosystem benefits while continuing to allow needed access for maintenance of transmission system assets, TVA will establish annual goals for rights-of-way planted in sustainable cover.
TVA Response to Regional Resource Stewardship (RRSC) Policy Recommendation to TVA on Campgrounds Issues dated August 29, 2001.
Recommendation
TVA [should] continue operating under its existing procedural guidelines
pertaining to the development and operation of commercial campgrounds
on TVA-retained lands. However, in applying these guidelines, TVA should
remain sufficiently flexible to ensure that both its commercial campground
operators, and their rental clients, are afforded ample opportunity to
bring themselves into compliance. This recommendation is particularly
applicable for those situations where commercial operators have allowed
the construction of porches, decks, roofs, and other appurtenant structures
in association with seasonally rented campsites.
TVA accepts this recommendation.
Recommendation
TVA should negotiate with the individual campground operators where these
structures occur to ensure that such structures are removed as attrition/turnover
occurs. If TVA and the commercial operator(s) agree that porches, decks,
roofs, or other types of appurtenant structures will be allowed, then
TVA should provide guidance in what types of structures it will approve.
TVA accepts this recommendation.
Recommendation
The porches, decks, roofs, and other appurtenant structures now in place
should be allowed to stay until such time as the seasonal renters no long
use that particular site or if a structure becomes a hazard due to poor
design or lack of maintenance.
TVA accepts this recommendation.
Recommendation
Also, TVA should work with campground operators in revising existing leases,
licenses, and easements to ensure that in the future, any and all such
structures not removed by seasonable renters once they no longer wish
to rent the campsite will be the property of the campground.
TVA accepts this recommendation.
TVA Response to Regional Resource Stewardship (RRSC) Policy Recommendation on TVA’s Navigation Responsibilities and Issues on the Tennessee River System dated August 29, 2001.
Recommendation
TVA [should] continue its integrated management of the Tennessee River
system.
TVA accepts this recommendation.
Recommendation
Navigation infrastructure [should] be maintained and improved in order
to continue operations at optimal levels.
TVA accepts this recommendation.
Recommendation
The system is in immediate jeopardy due to the need for a new replacement
lock at Chickamauga Dam, and [the Regional Resource Stewardship Council]
recommend that replacement of the lock be a priority.
The Board acknowledges the need for a replacement lock at Chickamauga Dam and will continue its efforts to work with the U.S. Army Corps of Engineers (USACE) and Congress to secure funding for this project.
Recommendation
TVA [should] fully support the lock addition project at Kentucky Dam.
TVA accepts this recommendation.
Recommendation
The Regional Resource Stewardship Council strongly advocates the use of
federal funds to maintain and improve the Tennessee waterway system.
The TVA Board’s position, as discussed at the August RRSC meeting, is that federal funds are no longer available to TVA, and existing legislation specifically identifies the funds other than federal appropriations that TVA is to use for its essential stewardship responsibilities. If federal funds become available from sources other than direct appropriations to TVA, or if Congress chooses to provide appropriations to TVA for the purpose of maintaining and improving the Tennessee waterway system, such funds could reduce the need for funding of these activities from power revenues.
Recommendation
Necessary funding [should] be provided in an equitable and timely manner.
In order to address this recommendation, TVA and the USACE will work together under its existing Memorandum of Understanding to provide funds to monitor and improve the infrastructure.
Recommendation
TVA [should] continue its strategic partnerships with other federal agencies
to ensure continuity of operation and maintenance of the Tennessee River
system and explore additional funding opportunities.
TVA accepts this recommendation.
Recommendation
The economic costs and benefits of an increased minimum navigation channel
depth be evaluated. This should be part of any comprehensive analysis
of operational changes to the multiple-purpose river system.
TVA will consider this recommendation as it develops the scope of work for the Reservoir Operations Study. As we work with you and other stakeholders, we will determine what can be included in the study while meeting our two-year schedule. back to the groups on the success of the plans in achieving their objectives.