Appendix B

U.S. Fish and Wildlife Service Executive Summary for the Corps of Engineers System Navigation Study

August 31, 2000

Colonel William J. Bayles

District Engineer

U.S. Army Engineer District, Rock Island Clock Tower Building,P.O. Box 2004 Rock Island, Illinois 61204-2004

Dear Colonel Bayles:

The U.S. Fish and Wildlife Service (Service), Rock Island Field Office, is preparing a Draft Fish and Wildlife Coordination Act (FWCA) Report for the Corps of Engineers (Corps) Upper Mississippi and Illinois Rivers System Navigation Study (System Study). Mr. Ken Barr, Chief of your Environmental Analysis Branch, has requested that we provide you with the preliminary conclusions and recommendations of the forthcoming FWCA report. This letter responds to that request. However, it does not necessarily represent the Secretary of Interior's final position on the proposed project or that of the five state natural resource agencies, which include Illinois, Iowa, Missouri, Wisconsin, and Minnesota (state agencies). Our comments apply to the preliminary array of alternatives provided to us, since the Corps has yet to identify a recommended plan. Furthermore, our conclusions and recommendations are preliminary and subject to change because they are based on project information available as of May 2000.

PROPOSED PROJECT

Some of the current array of project alternatives could result in improvements at up to 11 locks and dams on the Mississippi River and two on the Illinois River. These improvements include small-scale improvements, such as mooring cells and extended guidewalls, and large-scale improvements such as 1200-foot lock chambers. As of this date, no alternative has been identified as preferred by the Corps. All six of the preliminary alternatives are predicted to reduce lockage time and allow increased navigation traffic on the Upper Mississippi River System (UMRS). The predicted incremental increase in tow traffic that would be caused by the



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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway Appendix B U.S. Fish and Wildlife Service Executive Summary for the Corps of Engineers System Navigation Study August 31, 2000 Colonel William J. Bayles District Engineer U.S. Army Engineer District, Rock Island Clock Tower Building,P.O. Box 2004 Rock Island, Illinois 61204-2004 Dear Colonel Bayles: The U.S. Fish and Wildlife Service (Service), Rock Island Field Office, is preparing a Draft Fish and Wildlife Coordination Act (FWCA) Report for the Corps of Engineers (Corps) Upper Mississippi and Illinois Rivers System Navigation Study (System Study). Mr. Ken Barr, Chief of your Environmental Analysis Branch, has requested that we provide you with the preliminary conclusions and recommendations of the forthcoming FWCA report. This letter responds to that request. However, it does not necessarily represent the Secretary of Interior's final position on the proposed project or that of the five state natural resource agencies, which include Illinois, Iowa, Missouri, Wisconsin, and Minnesota (state agencies). Our comments apply to the preliminary array of alternatives provided to us, since the Corps has yet to identify a recommended plan. Furthermore, our conclusions and recommendations are preliminary and subject to change because they are based on project information available as of May 2000. PROPOSED PROJECT Some of the current array of project alternatives could result in improvements at up to 11 locks and dams on the Mississippi River and two on the Illinois River. These improvements include small-scale improvements, such as mooring cells and extended guidewalls, and large-scale improvements such as 1200-foot lock chambers. As of this date, no alternative has been identified as preferred by the Corps. All six of the preliminary alternatives are predicted to reduce lockage time and allow increased navigation traffic on the Upper Mississippi River System (UMRS). The predicted incremental increase in tow traffic that would be caused by the

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway proposed improvements is the sole focus of the Corps' environmental analysis. The “No Action” alternative represents the existing and future traffic levels that will occur without any additional navigation improvements. ENVIRONMENTAL SETTING The proposed project will affect one of our country's most significant ecosystems. The UMRS is a complex mosaic of bottomland forests, wetlands, and aquatic habitats which are home to over 150 species of fish and 44 species of Unionid mussels. Over 40 percent of North America's migratory birds use the Mississippi Flyway. There are 265,000 acres of the National Wildlife Refuge system along the Upper Mississippi River mainstem, and another 10,000 acres along the Illinois River. The five state agencies manage over 140,000 acres on the UMR and the Illinois DNR manages approximately 60,000 acres on the Illinois River. ENDANGERED SPECIES ACT COMPLIANCE The Service and the Corps recently completed formal consultation under Section 7 of the Endangered Species Act which assessed the effects of the existing Nine-foot Channel Navigation Project upon seven federally listed endangered and threatened species. These are the pallid sturgeon, Higgins' eye pearly mussel, winged maple leaf mussel, Indiana bat, bald eagle, decurrent false aster, and least tern. The Service determined that the continued existence of two species, the Higgins' eye pearly mussel and pallid sturgeon, would be in jeopardy if reasonable and prudent alternatives were not implemented by the Corps. The Service and the Corps are-still consulting with respect to the effects of the proposed system-wide navigation improvements described in the System Study. The recently completed consultation for the existing Nine-foot Channel Navigation Project will serve as the baseline condition for the proposed improvements consultation. SUMMARY OF NAVIGATION STUDY ISSUES AND CONCLUSIONS The current analysis is deficient. Identifying and quantifying the environmental effects of commercial navigation traffic on UMRS natural resources has been a controversial issue for more than 25 years. During this time several efforts have investigated one specific navigation effect or another, but a comprehensive evaluation of all navigation-related effects has yet to be accomplished. Such an evaluation would examine the direct and indirect effects of passing towboats on natural resources as well as the effects of operation and maintainance (O & M) of the Nine-foot Channel Navigation Project (e.g., dredging, water level regulation, channel regulatory structures, impoundment). Since the current investigation has been presented as a “system-wide” study designed to identify needed improvements throughout the entire UMRS, the Service and state agencies believe that the system-wide cumulative effects of all Nine-foot Channel Navigation Project related activities should be examined as well.

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway There are five major deficiencies with the Corps of Engineers environmental impact analysis. Two of these deficiencies concern the Corps' incremental traffic effects analysis (Items 1 and 2 below), and three deficiencies involve related navigation effects issues (Items 3 to 5 below). The deficiencies are as follows: The assessment of incremental traffic effects associated with the proposed project is inadequate; site-specific assessments are not complete. Incremental Traffic Effects Analysis The impact analysis has resulted in the development of state-of-the-art navigation traffic effects models. Despite the development of these tools, critical biological and physical information needed to run these models is lacking. Limited knowledge of UMRS species life histories has severely hampered scientists' ability to quantify navigation effects with any degree of certainty. Because of limitations in biological and physical data, fish and wildlife impacts attributable to incremental traffic increases cannot be adequately predicted or quantified at this time. Insufficient time was allotted in the feasibility study to collect the necessary physical, chemical, and biological data in order to quantify with any certainty impacts to fish, mussels, aquatic plants, bottomland hardwoods, and other resources. Our conclusions and recommendations regarding detailed effects due to the incremental increase in traffic are included as Table 1 enclosed with this letter. Site-specific Impacts of Proposed Construction There is insufficient lock and dam design information available at this time to complete a full evaluation of impacts to natural resources resulting from site-specific construction activities (including 1200-foot locks, extended guidewalls, wing dikes, and mooring facilities). Significant resources which may be affected by construction include fisheries, mussel beds, bottomland forests, main channel border, non-forested wetlands, Federal and state-listed endangered species, and recreational use areas. Although preliminary assessments have been conducted, impacts to resources will be investigated in greater detail when separate environmental assessments are completed for each proposed construction site. Additional evaluations which will be necessary include Habitat Evaluation Procedures (HEP), mussel surveys, hydraulic modeling, and screening for endangered and threatened species. Potential impacts associated with the release of contaminants due to construction have not yet been evaluated and will require further investigation.

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway An assessment of baseline traffic effects which will result from the “No Action” alternative is needed to understand the effects of additional traffic. In this System Study, the Corps investigation of systemwide navigation impacts focused only on fish and wildlife effects associated with traffic increases attributable to the proposed alternatives. This approach continues the Corps' practice of addressing the various environmental effects of navigation improvement actions in isolation from one another. The Service does not support this approach. It does not appear to comply with the National Environmental Policy Act (NEPA) because it fails to consider the cumulative effects of all navagation project related actions. The impact analysis is so focused on incremental traffic effects, that the fish and wildlife impacts associated with the baseline traffic condition (“No Action” alternative) are not presented. Without the ability to compare the impacts of the baseline traffic condition against the impacts of the proposed navigation improvement alternatives, we can only speculate about the true environmental significance of the Corps' proposed navigation improvements. Consequently, it is even more difficult to arrive at a mitigation plan which can be linked to incremental traffic effects in any credible manner. According to Corps' policy, as we understand it, baseline traffic effects are not subject to mitigation within the definition of this study. However, the fact remains that baseline traffic continues to degrade fish and wildlife resources. In spite of ongoing habitat improvement programs (e.g., Environmental Management Program), the long-term ecological integrity of the river's fish and wildlife resources still appears to be in decline. This conclusion is supported by the 1998 Ecological Status and Trends Report prepared by the Long Term Resource Monitoring Program (LTRMP). We are particularly concerned about impacts to National Wildlife Refuge system lands and state-managed areas. An assessment of impacts from operation and maintenance activities is needed. The Navigation Environmental Coordinating Committee (NECC) has repeatedly recommended that the System Study include an assessment of the operation and maintenance (O&M) impacts associated with the existing navigation project. Despite repeated requests up through the Department level, the issue of assessing O&M impacts within the System Study is still unresolved. As we have indicated on numerous occasions, unless the Draft Environmental Impact Statement (DEIS) contains a thorough analysis of these effects, it will be a technically deficient document. The Corps has determined that assessment and mitigation of Nine-foot Channel Project O&M effects are not applicable to this System Study. We disagree. Based on the LTRMP 1998 Status and Trends Report, we conclude that the long-term effects from O&M activities probably pose a more serious threat to UMR fish and wildlife resources than future incremental traffic effects identified thus far. Further evidence that ongoing navigation project O&M activities are causing habitat degradation is found in the Service's recently completed Biological Opinion prepared for the UMR Nine-foot Channel Navigation Project endangered species consultation. That consultation concluded that continued O&M activities are causing, and will continue to cause,

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway such a decline in Higgins' eye pearly mussel and pallid sturgeon populations that, unless remedial actions are immediately implemented, their future existence on the UMRS is jeopardized. Some O&M effects have never been addressed in any Corps of Engineers National Environmental Policy Act document. O&M effects that the Corps should investigate further include: (1) facilitated spread of exotic species; (2) habitat degradation from water level regulation; (3) loss of habitat diversity from construction of channel regulatory structures; (4) habitat degradation from ongoing sedimentation due to impoundment; and (5) hindrance of fish passage through navigation dams. These O&M impacts are addressed in more detail in our forthcoming draft FWCA report and supporting appendices. We are likely to conclude that the NEPA analysis found in the draft Environmental Impact Statement for the Systemic Navigation Study is inadequate if these effects are not included in the analysis. An assessment of traffic impacts and mitigation for the Second Lock was never completed. Traffic-related impacts resulting from the Second Lock at Melvin Price Lock and Dam have not been quantified. The Corps is proposing additional navigation improvements before the effects of Second Lock improvements are known. (NOTE: The Service has been waiting for such information since the late 1980's in order to prepare a final FWCA report for the Second Lock Project). Since initiation of the System Study, the Corps has declined to assess and determine appropriate mitigation for Second Lock traffic impacts. Traffic from the Second Lock generates the same types of impacts as the additional traffic from the proposed project. The traffic from the Second Lock is, in fact, considered part of the baseline traffic condition for the System Study. In order to quantify the impact of the incremental traffic increases associated with the proposed project, impacts attributable to the Second Lock increment of traffic must be identified and mitigated for as part of the current System Study. In the 1980's, there was considerable disagreement over the navigation effects of the Second Lock. The Service, as well as the U.S. Environmental Protection Agency, state agencies, and several environmental organizations were promised that if the Corps was allowed to construct the Second Lock, the Corps would undertake a full investigation of traffic effects. Such an investigation, described in what became known as the Plan of Study (POS), was designed with the full participation of all agencies and finalized in 1992. In addition, the Corps committed to implementing a program to avoid and minimize Second Lock traffic effects to fish and wildlife throughout the UMRS. The Corps has failed to implement both of these commitments which were contained in the Second Lock Record of Decision. The POS was incorporated into the current System Study impact analysis, but was so reduced in scope that the uncertainty of the results leaves us far short of any comfortable assurance level that fish and wildlife resources will be protected or compensated. Only the St. Louis District has implemented an avoid and minimize program.

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway A Comprehensive Mitigation Plan to address all Nine-foot Channel Navigation Project effects is lacking. We endorse a mitigation approach that offers flexibility, yet commits the Corps to an authorized level of funding regardless of future traffic levels. Our recommendations for adaptive mitigation have been previously described in the draft FWCA report for the Second Lock at Melvin Price Lock and Dam. An adaptive approach would allow us to select the most appropriate measures for impact locations along the UMRS. For an adaptive approach to be successful, the Service and state agencies must be closely involved in the design and selection of measures. There must also be a mutually agreeable coordination procedure established between the Corps, the Service, and the state agencies to implement an adaptive mitigation plan. This could be accomplished by a committee co-chaired by the Corps and Service, with the assistance of the existing St. Paul District's River Resource Forum, the Rock Island District's River Resources Coordinating Team, and a similar group in the St Louis District. Most importantly, there must be adequate assurance that an adaptive approach will actually be implemented. We recognize the Corps' immediate need to specify a mitigation cost for calculating overall project costs and benefits. The Service believes the mitigation costs cannot yet be determined because there are too many data gaps. The Service and state agencies have been asked to accept a fixed mitigation cost in spite of the fact that there is no strong biological linkage between the impacts and the proposed measures. The assignment and scale of these measures to specific incremental traffic effects was prepared with little input from the Service and state agencies. The Service and the state agencies have had insufficient involvement in determining which measures should be applied, and to what degree, for a given impact. For example, in order to mitigate systemic fish impacts, the Corps proposed a $40 million fish passage measure at L/D 19 without coordinating with the natural resource agencies. In spite of our collective non-support for this measure, it is still part of the mitigation plan. Most of the proposed measures will generate habitat improvements, but no methodology was used to demonstrate that identified costs of measures will result in net habitat gains equal to the corresponding level of loss. The net gain in habitat from these measures is speculation at this point. For example, how many larval fish would be generated by a fish passage structure at L/D 19? Normally, an incremental analysis impact planning tool (e.g HEP, WHAG) is employed to determine the type and appropriate amount of mitigation needed to offset each impact. Such traditional tools are not readily applicable to incremental traffic effects. This situation would indicate that an innovative approach, requiring intense coordination among the Corps, the Service and state agencies, is needed to prepare a biologically credible mitigation plan. For this reason, the Service has recommended that an adaptive mitigation approach be used. The adaptive approach would involve implementing mitigation measures on a small scale, monitoring their habitat benefits, and making refinements before it is implemented systemwide. The Corps has indicated a willingness to consider an adaptive approach to mitigation as stated in their December 21, 1999 draft document Adaptive Mitigation Implementation Strategy presented to the NECC. A critical deficiency in this draft document is the lack of a formal process for

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway implementing the adaptive approach. Most importantly, the specific roles and responsibilities of the Service and state agencies must be described. Thus, the proposed mitigation plan is unacceptable because: (1) incremental impacts have yet to be quantified with any certainty; (2) a strong biological link between the quantity of impacts identified with the quantity of habitat improvements proposed has not been established; (3) there is no documentation of any incremental analysis used to illustrate how the proposed mitigation measures were selected; (4) there is no implementation scheme with respect to how mitigation would be accomplished; and (5) the mitigation plan does not include remedial measures for Second Lock impacts, ongoing O&M effects, or baseline traffic. The incremental traffic mitigation package is presented independent of all other navigation traffic effects. By mitigating for the Nine-foot Channel Navigation Project as a whole, we can avoid duplication and fragmentation. It would permit us to remediate impacts appropriately for fish and wildlife that depend on the system as a whole. The incremental traffic mitigation package should be integrated with mitigation for other navigation effects (e.g., O&M effects, baseline traffic, Second Lock) into one system-wide comprehensive plan. Site-specific mitigation plans have not yet been developed. Estimated habitat replacement costs are currently $18.6 million. We are currently unable to determine whether or not this will be adequate since site-specific designs are yet to be finalized. RECOMMENDATIONS Incremental and Site-Specific Traffic Effects Incremental Traffic Effects More credible and accurate predictions of incremental traffic effects must be prepared before an acceptable mitigation program can be developed. In order to achieve this, the following data gaps must be addressed. Collect system-wide bathymetric and sediment data to improve hydraulic model accuracy. Reinitiate the main channel fish entrainment investigation responsive to the recommendations previously given by the Service. Impact models should then be run again to quantify navigation effects on main channel fish. The plant growth models used to determine sediment effects on plants need to be verified against other native submergent plant species growth characteristics. In addition, locations of other submergent vegetation patches downstream of Pool 13 and in the Illinois River must be mapped and evaluated.

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway Preliminary findings that Unionid mussels will not be significantly affected must be verified through further investigation to assess reproductive effects and physiological effects with respect to glycogen content and cellulose activity. In addition, effects of increased traffic related to zebra mussel distribution should be assessed. Impacts associated with the increased need for fleeting and commercial river terminals need to be quantified. The Corps should undertake a comprehensive planning effort to identify suitable and unsuitable navigation development locations. Impacts to National Wildlife Refuge lands and state lands should be identified. Site-Specific Effects The HEP analyses previously conducted for Locks 20-25, Peoria, and LaGrange should be revised and re-evaluated consistent with proposed design plans. Additional HEP analyses should be initiated and completed for all other proposed construction sites. Potential impacts to fishery resources should be evaluated in greater detail using both HEP and hydraulic modeling at all proposed construction sites. Results of previous mussel surveys should be reviewed to determine where additional surveys are needed. Measures to avoid and minimize harm to mussels must be incorporated into the design plans. Current lists of state endangered and threatened species potentially affected by construction should be expanded to include all known records of occurrence at the county level. Species identified in the county lists should be presumed to potentially occur in the immediate vicinities of the corresponding locks and dams unless they can be ruled out based on habitat. Field sampling to determine the presence or absence of species should be conducted where appropriate. The potential for release of contaminants resulting from construction activities should be assessed for each proposed construction site. More detailed investigations should then be conducted at sites with high potential for release. Impacts to recreational opportunities should be analyzed in connection with loss of aquatic and terrestrial habitats, loss of boat ramps, loss of access to areas currently fished (including banks and areas behind guidewalls), and loss of access to wildlife viewing areas.

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway Baseline (“No Action”) Traffic Effects The traffic impacts associated with the project baseline condition must be quantified and presented along with the incremental traffic effects analysis. A mitigation plan to offset baseline traffic effects should be included in a system-wide comprehensive plan to mitigate all Nine-foot Channel Navigation Project related impacts. Cumulative Effects of O&M Activities The Corps of Engineers should complete an updated assessment of system-wide O&M impacts (e.g., sedimentation, spread of exotic species, alteration of the natural hydrograph from dam regulation, channelization, shoreline erosion, and fish passage) associated with the existing Nine-foot Channel Navigation Project. This should be completed as part of the current System Study. Coupled with this analysis should be the development of a system-wide program to avoid and minimize these impacts. This effort should include, but not necessarily be limited to, the following: Alternative measures to improve fish passage at navigation locks and dams should be evaluated and implemented if appropriate. The Corps' channel regulatory works program should investigate and implement mitigation techniques that can both maintain a navigation channel and restore aquatic habitat diversity. Navigation dam water regulation procedures need to be investigated and revised to allow for fish and wildlife considerations. Alternative water level manipulation protocols need to be developed to determine optimum drawdown scenarios. This should include development of a drawdown schedule that balances fish and wildlife needs with commercial navigation and public use. The Corps should immediately seek authority to manage its navigation project lands and waters for the benefit of fish and wildlife as a project purpose equal to navigation. This equal authority should include the ability to implement fish and wildlife management actions deemed critical to the long-term preservation of fish and wildlife and their habitats. The Corps of Engineers should investigate the feasibility of eliminating the waterway connection between Lake Michigan and the Illinois Waterway. Alternatives to the existing connection should be investigated in order to sever the link that has become a pathway for the movement of exotic species between the Great Lakes and the Mississippi River Basin.

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway Second Lock Traffic Impacts As part of this feasibility study, the Corps should quantify the increment of traffic attributable to the Second Lock at Melvin Price Lock and Dam and, in consultation with the Service and state agencies, include appropriate mitigation (if any) in the current System Study. An avoid and minimize program, as described in the Second Lock ROD should be implemented system-wide in conjunction with a comprehensive mitigation plan. Mitigation Continue funding support to the Environmental Management Program (EMP). Without the EMP, the current level of knowledge concerning navigation impacts gained thus far would not have been possible. The EMP's Habitat Rehabilitation and Enhancement Program should be considered as a means to evaluate the effectiveness of different types of measures that could mitigate Nine-foot Channel Navigation Project effects. Monitoring and evaluation of mitigation measures should be integrated into the LTRMP so that, habitat values can be maximized and dollar costs minimized. Implement an adaptive mitigation approach that comprehensively mitigates for all incremental traffic effects as well as the Second Lock, baseline traffic, and O&M effects. Because of the extreme uncertainty associated with future impacts, a strategy that allows flexibility in implementing mitigation actions is necessary. The adaptive approach should include the ability to monitor mitigation actions to evaluate their effectiveness for future actions. Therefore, we recommend that an adaptive mitigation strategy be developed that includes the following: Since the majority of navigation effects are anticipated to occur during the latter half of the fifty-year project life, funding for a comprehensive mitigation plan should be provided by a trust fund that allows for funding over the fifty- year life of the project. This is necessary to assure the availability of funding after the completion of the proposed improvements. An independent panel of scientists should be convened to give assistance in preparing a General Plan to: (a) improve the quantification of incremental, Second Lock, O&M, and baseline traffic effects; and (b) develop a strategy to implement an adaptive mitigation approach. A Navigation Mitigation Steering Committee consisting of the Corps, Service, and state agencies should be established immediately. The Committee should be co-chaired by the Rock Island District and the Rock Island Ecological Services Field Office. The Committee will provide direction to adaptive mitigation

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway implementation but should utilize the existing fish and wildlife work groups (e.g., River Resources Forum in the St. Paul District, the River Resources Coordinating Team in the Rock Island District, and any similar group in the St. Louis District) for development and implementation of specific projects. Membership should include the state agencies and the U.S. Environmental Protection Agency. Voting members should include one each from the following: a) Corps of Engineers; b) Fish and Wildlife Service; c) Iowa Department of Natural Resources; d) Illinois Department of Natural Resources; e) Minnesota Department of Natural Resources; f) Missouri Department of Conservation; and g) Wisconsin Department of Natural Resources. The Committee should monitor work being done through the EMP to insure that applicable information is being incorporated into the adaptive mitigation planning process. The Corps, in co-leadership with the Service, should complete a General Plan for implementing adaptive mitigation. The plan should use available information obtained from the EMP's habitat rehabilitation and long-term monitoring programs as well as additional information from studies needed to fill data gaps recognized in this investigation. This General Plan should be endorsed by the Committee. The adaptive mitigation concept will develop short-term (5-year) mitigation implementation plans. As one term comes to an end, the Corps, with assistance from the Service and in cooperation with the Committee, will evaluate the effectiveness of mitigation measures. This information, along with new data, will be used to develop the mitigation implementation plan for the next term. The goal is to always have full compensation of unavoidable habitat losses. The General Plan will address actions which should be taken concurrent with navigation improvement construction. The General Plan should also address the mitigation funding requirements and allocations so that funding is insured throughout the life of the project and achieves the greatest mitigation value. The plan should be updated as the results of monitoring studies become available. An initial mitigation implementation plan should be developed under the co-leadership of the Corps and the Service. It should be endorsed by the Committee. Primarily, the first term plan should implement all feasible measures to avoid and minimize impacts. The District should complete all subsequent plans in sufficient time to be entered into the Corps' budget cycle and insure adequate funding. Compensation to mitigate adverse impacts should not be considered until all practicable measures to avoid and minimize impacts have been implemented.

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INLAND NAVIGATION SYSTEM PLANNING: The Upper Mississippi River—Illinois Waterway We believe the above recommendations provide a flexible solution to a very difficult problem. However, a strong commitment from the Corps of Engineers will be necessary to bring this program to fruition. Without such a commitment, we can only conclude that the impacts of any increases in navigation traffic will not be adequately mitigated, and balanced use of this nationally significant ecosystem will not be achieved. Of all the issues discussed in this letter, mitigation planning is possibly the most urgent. We need to increase our coordination efforts to: (1) develop a detailed mitigation implementation strategy and (2) develop a method to link impacts and mitigation measures. The Service recommends that "workshop meetings" of the NECC be scheduled soon to address these two issues. This recommendation is supported by the NECC representatives from all the state agencies. Please feel free to contact me or Mr. Jon Duyvejonck of my staff to continue our coordination on this or any other navigation issues. This letter provides comments under the authority of and in accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.); and the Endangered Species Act of 1973, as amended. Sincerely, Richard C. Nelson Supervisor Enclosure cc: NECC