December 13, 2010
Attend the public hearing in Chicago - December 15th
When: Anytime between 12:00pm—7:00pm
Where: The Gleacher Center – 6th Floor, 450 N Cityfront Plaza Dr, Chicago IL, (312) 464-8787
Register/Details: Click here to register or for more information - You will be given preference for speaking if you register prior to the meeting.
You may use these detailed talking points prepared by Prairie Rivers Network and several national and regional conservation organizations:
- The corps must “prevent” rather than “reduce the risk” of invasive species movement between the Great Lakes and Mississippi River. Risk reduction is not authorized by Congress, is not a credible strategy to achieve prevention and research here could divert resources from quickly determining how to achieve prevention.
- The corps study takes too long. The Chicago portion of the study is not predicted to be complete until mid-2015, or nearly five years from now. The corps should acknowledge the urgency of finding a permanent solution, condense the timeline and produce final results for the Chicago portion of GLMRIS within 18 months rather than mid-2015.
- Congress mandated that GLMRIS should only consider “options and technologies available to prevent the spread” of invasive species through the waterways. Physical separation would achieve this. It is not clear at this time that any other alternative would achieve prevention.
- The GLMRIS study is a prevention study and its results should be used first to prevent Asian carp from invading the Great Lakes. The study timeline and strategy must be structured so a solution is delivered prior to the establishment of breeding populations of Asian carp in the Chicago Waterway System.
- The corps should study and provide a solution for the Chicago Waterway System first regardless of the need to prioritize and act on other aquatic pathways.
- Do not waste time and money repeating work that has already been done or is currently in process.
- Risk Assessment: at least two comprehensive reports describing the likely impacts of Asian carp on the Great Lakes have already been written, one from the U.S. Fish and Wildlife Service and one from Fisheries and Oceans Canada. In addition, Fisheries and Oceans Canada recently commenced a bi-national effort to create an updated risk assessment for Asian carp. There is copious literature describing the potential movement of other invasive species via the Chicago Waterway System and the impacts of the movement of zebra mussels into the Mississippi River basin via the CWS are well-documented. There is absolutely no justification for the corps to place higher priority on conducting its own risk assessment than on preventing the spread of Asian Carp through the CWS.
- Wastewater and Transportation: The Great Lakes Commission and Great Lakes-St. Lawrence Cities Initiative (GLC/GLSLCI) are conducting a study on the water management and transportation alternatives available after a physical separation of the Great Lakes and Mississippi River. Other organizations, such as the Alliance for the Great Lakes and the Natural Resources Defense Council, have also described alternatives for achieving prevention through a physical separation. The corps should incorporate the findings of these projects to hasten its own analysis.
- Economic Analysis: Likewise, the GLC/GLSLCI includes an economic impact analysis, will be conducted by an elite-tier private engineering and transportation team and should be completed by January 2012. The corps should use this economic analysis for identifying the best way to achieve physical separation on the Chicago Waterway System rather than writing its own.
- The corps should create an opportunity for regular preferably at least twice annually – discussion forums during which the public can interact with technical staff for detailed Q&A on project progress. This should be separate and in addition to the requirements of the NEPA process.