Response to Addendum to Integrated River Management Subcommittee Recommendations

Letter from the TVA Board

June 11, 2002

Mr. Bruce D. Shupp, Chair
Regional Resource Stewardship Council
ESPN Productions/B.A.S.S.
Post Office Box 17900
Montgomery, Alabama 36141-0900

Dear Bruce:
Enclosed is TVA’s formal response-of-record to the Regional Resource Stewardship Council’s October 26, 2001, recommendations on integrated management of the Tennessee River system. This response is based on discussions with the Council at its January 31 meeting in Huntsville.

As you remember, there was considerable discussion at the January meeting about the No-Net-Loss of Species recommendation. TVA’s position was that we could not accept the recommendation based on a literal interpretation of the text. Council members discussed how they intended for the recommendation to be interpreted, but we can only respond to the letter of the recommendation, not the intent. Based on that discussion and on follow-up conversations with Council members, TVA will return that recommendation to the second-term Council at its first meeting in the summer and request that the Council consider revising it to more clearly reflect the Council’s intent. At this meeting we also plan to discuss our response to the recommendation on water use management approved by the Council at the January 31 meeting.

The Council made a final recommendation that “as soon as the timing is appropriate, the TVA Board request from Congress the reinstatement of federal appropriations at optimal, historic levels.” As we discussed at Council meetings last fall, Congress has stated that federal funds are no longer available to TVA and has identified the funds other than federal appropriations that TVA is to use for its essential stewardship responsibilities.

As TVA’s only Federal Advisory Committee, the Council has played an historic role and set a high standard for stakeholder involvement. We appreciate the time and effort that each Council member invested in learning about the issues TVA faces in its management of the Tennessee River system. The consensus-based recommendations to improve TVA’s policies on water and land management are being implemented and will benefit the quality of life in the Tennessee Valley for years to come.

Very truly yours,

(Original signed by)
Glenn L. McCullough, Jr.
Skila Harris
Bill Baxter

TVA response to Regional Resource Stewardship Council addendum to Integrated River Management Subcommittee policy recommendation on TVA’s integrated management of the Tennessee River system (approved by the RRSC on May 18, 2001). Addendum dated October 26, 2001

Recommendation
Recommend to the Council that consideration of changing the winter pool level from 354 feet to 355 feet in elevation on Kentucky Lake to aid in navigation of the waters below Pickwick Dam be added to the Reservoir Operations Study.

The Reservoir Operations Study will evaluate the benefits provided by the current channel depth on the entire Tennessee River system and will determine if greater value can be created for customers and stakeholders. This review will include incremental increases and decreases in the channel depth and will be closely coordinated with the U.S. Army Corps of Engineers due to the potential impacts on the lower Ohio and Mississippi Rivers.

Recommendation
Recommend to include in the Reservoir Operations Study consideration of the flow requirements on the upper Ocoee River, including a cost/benefit analysis approach for river recreation and economic development.

The upper Ocoee River is unique in the TVA system. A water release for recreational purposes precludes that water being used for power generation because the water bypasses the flume/powerhouse system. On the rest of the Tennessee system, water is used for multiple purposes – the water that boaters use for flat-water recreation purposes is still used for power generation.

The Reservoir Operations Study will be a comprehensive review of TVA’s operating policies and will consider programmatic changes to those policies. Similar methodologies will be used for evaluating impacts on recreation benefits for reservoir and riverine uses. Changes to upstream operations resulting from the Reservoir Operations Study Environmental Impact Statement (EIS) could affect the availability of recreational water releases on the upper Ocoee.

While potential impacts to upstream uses such as rafting on the Ocoee will be evaluated, we do not contemplate proposing changes to specific upstream uses as part of the system-wide Reservoir Operations Study. If these kinds of changes are proposed in the future, they would be considered in another environmental review that would be based on the results of the Reservoir Operations Study programmatic review.

TVA response to Water Quality Subcommittee recommendations on improving biodiversity in the Tennessee River system, dated October 26, 2001

Recommendation
The Water Quality Subcommittee affirms the importance and priority insofar as practical of protecting the Tennessee River system’s existing aquatic biodiversity and restoring its historical biodiversity; therefore, we recommend TVA take the following actions:

1. Maintain the current levels of biodiversity in the Tennessee River system by meeting its obligations under the Clean Water Act and the Endangered Species Act, by continuing its existing efforts on behalf of native species biodiversity, and by adopting a No-Net-Loss policy for native species.

2. Improve the biodiversity of the Tennessee River system by considering native species’ habitat needs when planning and implementing river operations and through the use of TVA regulatory tools.

3. Partner with other agencies, organizations, and stakeholders to identify needs and implement strategies that will improve biodiversity.

4. Initiate planning and actions for the improvement of biodiversity by taking the leadership role with its partners in the Tennessee Valley.

5. Manage TVA lands and waters as examples of responsible stewardship that protects and/or improves the region’s biodiversity.

6. Sustain its preeminent ecological expertise and data collections; and preserve TVA’s institutional memory by documenting the history of TVA’s ecological contributions to science and the Tennessee Valley.

7. Engage in a public awareness campaign to make Tennessee River Valley residents aware of the extraordinary native biodiversity of the region and TVA’s stewardship efforts.

TVA is unable to accept this recommendation as presently written. During the January Council meeting, there was considerable discussion concerning the Council’s intent for the recommendation to be followed on an “insofar as practical” basis. In order to avoid future differences in interpretation, we intend to request that the second-term Council revisit this issue at its first meeting and provide additional clarification.