Sl° SNr,
^ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'- 3 REGION I
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
Date: October 10, 1989
Subject: Region I Section 404 (c) Recommendation to Prohibit
Construction of the Big River Reservoir Project
From: Paul G. Keough. Acting Regional Administrator
Region I
To: Rebecca W. Hanmer, Acting Assistant Administrator
Office of Water
Attached is my recommendation under section 404(c) of the Clean
Water Act that construction of the Big River Reservoir in Kent
County, Rhode Island be prohibited. After carefully reviewing the
administrative record, I have concluded that the project -would
cause unacceptable adverse effects to wildlife and recreation.
The attached recommended determination fully documents the basis
for my findings. As explained therein, the proposed 3400 acre
water supply impoundment would cause'serious environmental dam.age.
It would destroy nearly 600 acres of diverse and : .productiye
wetlands and 17 miles of free flowing streams. The dam- would
worsen existing water quality problems by depriving downstream
areas of water. The project indirectly threatens> an :additiona;l
700-800 acres of wetlands by disrupting existing surface and
groundwater hydrology. As currently proposed, all recreational
uses of the impoundment and the surrounding 4600 acre.management
area would be lost. :; .••"••' ; v • ;
My review of the record indicates that these impacts are
unnecessary and avoidable. .Region I1 s. analysis indicates that a
new water supply would not be needed until sometime-After the. year
2030. However, even should a; need materialize sooner, less
environmentally damaging practicable alternatives exist to building
the Big River reservoir. These alternatives include a number,of
demand and supply management options. The demand management
alternatives alone, such as pricing policy;,^ drought planning and
conservation, would in combination save^more Water than Big River
would provide at maximum yield. •
My staff and I are available to assist you during your .review of
the case and formulation of a final determination. Feel .free to
call me if you have any questions or if you need ^additional
information. Region I staff contacts for this case ,ar« Douglas
Thompson and Mark Kern in the Wetlands Protection Section (FTS 835-
4422) or Ann Williams-Dawe in the Office of Regional Counsel.(FTS
835-3321). .
Attachment
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RECOMMENDATION TO PROHIBIT
CONSTRUCTION OF THE BIG RIVER RESERVOIR
PURSUANT TO SECTION 404(c) OF THE CLEAN WATER ACT
U.S. Environmental Protection Agency
Region I
October 1989
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RECOMMENDATION TO PROHIBIT
CONSTRUCTION OF THE BIG RIVER RESERVOIR
PURSUANT TO SECTION 404(c) OF THE CLEAN WATER ACT
U.S. Environmental Protection Agency
Region I
October 1989
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CONTENTS
PAGE
I. INTRODUCTION 1
II. PROJECT DESCRIPTION AND HISTORY 3
III. SITE DESCRIPTION 10
A) Site and Ecology 12
B) Fish and Wildlife 17
C) Hydrological Values 24
D) Recreation 25
E) Summary 27
IV. ADVERSE ENVIRONMENTAL IMPACTS 28
A) Fish and Wildlife Impacts 29
B) Recreation 43
C) Water Quality Impacts 45
D) Mitigation 46
E) Summary 48
V. ALTERNATIVES 49
A) Need for Water Supply 50
B) Cost of Big River Reservoir 53
C) Demand Management 54
D) Supply Management 59
E) Recreation and Flood Control 62
F) Summary 64
VI. CONCLUSIONS AND RECOMMENDATION 65
REFERENCES 68
APPENDIX I: Species Lists
APPENDIX II: Report of the U.S. Fish and Wildlife
Service July 1989
APPENDIX III: Technical Analysis of Project Need and
Availability of Alternatives
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FIGURES
Figure Name Page
1 Location of Proposed Big River Reservoir,
Rhode Island 4
2 Pawtuxet River Basin, Rhode Island 5
3 Big River Dam 6
4 Big River Watershed, Management Area,
and Impoundment Area 11
5 Wetlands to be Flooded Within the
Big River Reservoir 13
6 Highest Scoring Wetlands For Wildlife Habitat 23
7 General Impacts to Fish and Wildlife from
Impounding a Stream 30
8 Percent Change in Aguatic Habitat Types
in the Big River Watershed 32
9 Wetlands to be Impacted by the
Big River Reservoir 38
10 Soil Types for Wetlands within the
Big River Reservoir 41
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I. INTRODUCTION
This decision recommends prohibiting construction of the Big River
reservoir, a 3400 acre water supply impoundment, in Kent County,
Rhode Island. The reservoir, which has at separate times been
proposed by the U.S. Army Corps of Engineers and the State of Rhode
Island would cause serious environmental damage. It would destroy
575 acres of valuable wetlands, eliminate 17 miles of streams, many
containing cold water fisheries, worsen downstream water quality,
and cause substantial adverse impacts to the recreational values
of the site. It would also threaten the viability of an additional
700 to 800 acres of wetlands by depriving them of groundwater and
surface water.
The proposed reservoir has been controversial and has generated
substantial public opposition. I have carefully considered the
record developed by EPA and the Corps in this case, including
public comments, information presented at the public hearing, and
submissions by other federal and state agencies. For the reasons
described below, I have determined that the filling and inundation
of wetlands and waters for the purpose of building the impoundment
would be likely to have unacceptable adverse effects on wildlife
habitat and recreation. Therefore, I recommend that EPA prohibit
the discharge of dredged or fill material into Big River, Mishnock
River, and their tributaries and adjacent wetlands for the purpose
of constructing the proposed Big River reservoir and its ancillary
facilities. This determination applies to the proposals of both
the Corps and the State.
Construction of the project would involve the placement of soil
and other fill material into Big River and its adjacent wetlands.
Section 404 (c) of the Clean Water Act (CWA, 33 U.S.C. § 1251 et
seq.) , authorizes the Administrator of the Environmental Protection
Agency (EPA) to prohibit or restrict the use of any defined area
as a disposal site, whenever he determines, after notice and
opportunity for public hearing, that the discharge of dredged or
fill materials into such area will have an unacceptable adverse
effect on municipal water supplies, shellfish beds, fishery areas
(including spawning and breeding areas), wildlife, or recreational
areas. Before making such a determination, the Administrator must
provide opportunity for consultation with the Chief of the Army
Corps of Engineers, the property owner(s), and the applicant(s) in
cases where there has been application for a Section 404 permit.
EPA's regulations at 40 C.F.R. Part 231 establish procedures to be
followed in exercising §404(c) authority. The process consists of
four steps: The Regional Administrator's notice to the Corps, the
property owner, and applicant (if any); the Regional
Administrator's proposed decision to prohibit or restrict the use
of a site; the Regional Administrator's recommendation to prohibit
or restrict use of the site; and the Administrator's final decision
to affirm, modify, or rescind the regional recommendation. The
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Administrator has delegated the authority to make a final decision
under Section 404(c) to the Assistant Administrator for Water,
EPA's national Section 404 program manager.
This document, the third step in the process, explains the basis
for my recommendation. The next section describes the proposed
Big River reservoir and summarizes the history of the project.
Section III describes the environmental characteristics of the
project area and the overall Big River watershed, and Section IV
examines the impact of the proposed reservoir on the site. In
keeping with the environmental attributes protected by section
404(c), the document focuses primarily on the significance of the
site for fish and wildlife, and recreation, and the impacts the
project would cause to those values. Section V analyzes the need
for the project and the alternatives available to constructing the
proposed reservoir. Section VI presents my conclusions and
recommendation to prohibit construction of the project. The three
appendices contain technical information in support of this
recommended determination.
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II. PROJECT DESCRIPTION AND HISTORY
The Big River is located in south central Rhode Island. It
originates in Exeter, Rhode Island and flows north to the Flat
River reservoir, the site of the proposed dam, in Coventry, Rhode
Island. The impoundment would be located primarily in West
Greenwich, and would be crossed by Interstate 95 south of the dam.
Figures 1 and 2 show the location of the proposed reservoir, and
Figure 3 shows a cross section of the proposed dam.
As discussed in greater detail below, both the State and the Corps
have, at different times, proposed to build a dam across Big River
to create a reservoir. The proposals differ slightly, in that the
State has proposed a water supply impoundment only, whereas the
Corps has proposed a water supply impoundment that would also
provide some flood control and recreation. The two proposals are,
however, very similar in their project dimensions, site
characteristics, and impacts. This recommended decision focuses
on the reservoir as conceived under either proposal.
To construct the reservoir, dredged and fill material would be
discharged into Big River to form a 70 foot high dam and create a
3,400 acre impoundment, with an average water depth of 25 feet.
The reservoir would produce 27 or 32 million gallons a day (MGD)
of potable water, as estimated by the State and the Corps,
respectively. A slurry wall built down to bedrock in the northeast
portion of the proposed reservoir would intercept approximately 3
MGD of groundwater that enters Mishnock Lake; the slurry wall would
also block additional groundwater that now replenishes Mishnock
swamp and aquifer. Mishnock aquifer and swamp, located outside of
the Big River watershed approximately 1/2 mile northeast of the
proposed reservoir, receive a considerable amount of water from the
proposed reservoir site. A treatment plant, built adjacent to the
proposed reservoir on 51 acres of land, would transport water
through a 96" diameter rock tunnel approximately 6 miles to an
existing distribution system.
The impoundment would inundate approximately 575 acres of wetlands
and 17 miles of free flowing streams. Another 700 to 800 acres of
wetlands could suffer adverse impacts due to deprivation of
groundwater and the reduction of flows downstream in the South
Branch of the Pawtuxet River. Site preparation and flooding would
destroy more than 2,500 acres of terrestrial forest and relocate
six roadways, 300 structures, numerous graveyards, and several dump
sites.
According to state estimates, the project would cost at least $282
million, not including costs for operation and maintenance, a
closed drainage system for 1-95, environmental studies, and
mitigation for wildlife impacts, downstream water quality impacts,
and recreational losses. Under the Corps proposal the federal
government would construct less than half of the project and fund
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Figure 1
1
South Branch
P«»tux«t Hlvtr Boiin
o
LOCATION OF PROPOSED BIG RIVER
RESERVOIR, RHODE ISLAND
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Pawtuxet River Basin, Rhode Island
GLOCESTER
DRAINAGE BASINS
AREA
SO. Ml
EXETER
Pawtuxet River 228.0
Scituate Reservoir 92.8
Flat River Reservoir 56.7
Big River Watershed 29 .7
PERCENT
OF BASIN
100X
41%
25X
13X
Reduced downstream water flows:
45% less flow to the Flat River
Reservoir.
34% less flow to the South Branch of
the Pawtuxet.
15% less flow to the mainstem of
the Pawtuxet.
/v Town Boundary
H State Boundary
N Hydrography
# Road or Highway
N Pawtuxet
River Basin
Proposed Big
River Reservoir
UTM PROJECTION SCALE 1:250,000
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Figure 3: Big River Dam (Source: KAME 1984)
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less than 50% of the initial cost. Most of that expenditure would
be reimbursed by the State, resulting in a federal share of
approximately 2% - 5%.
During the 1960's the State of Rhode Island acquired over 8,000
acres of land surrounding Big River in anticipation of building a
reservoir. In 1978, having failed several times to secure funding
to complete engineering studies, Rhode Island asked the Corps to
consider constructing the reservoir as part of a federal flood
control project. The Corps completed an Environmental Impact
Statement (EIS) on the reservoir project in 1981, which concluded
among other things that the project would cause a "significant
disruption of the food chain and the chemical, physical, and
biological integrity of the aquatic ecosystem." In 1982, EPA
alerted the Corps that because of the adverse wetland impacts, the
project could not comply with the §404(b)(l) Guidelines, the
primary federal regulations that protect wetlands.
Congress authorized the project as part of the Omnibus Water
Resources Development Act of 1986, contingent upon the completion
of additional wildlife mitigation studies no later than November
17, 1987. The Corps has not done these additional studies. Later
in 1986, Rhode Island decided that it again wished to pursue the
reservoir as a state project and subsequently applied to the Corps
for a federal §404 permit. The Corps in 1987 determined that a
supplemental EIS would be required to address alternatives,
mitigation, downstream water quality impacts, and a number of other
unresolved issues surrounding the project.
During 1987 and 1988, EPA voiced its concerns about the adverse
environmental impacts of the reservoir proposal and warned the
State that the project could not comply with section 404
requirements. By December 1987 EPA identified 'the Big River
reservoir as a candidate for a section 404(c) veto and urged the
State to abandon the project. EPA also recommended that the State
thoroughly analyze the need for and alternatives to the project.
In a June 6, 1988 letter EPA urged the Corps to deny the permit
because the project would cause significant degradation of the
aquatic environment which could not be adequately mitigated. The
Corps agreed and on July 1, 1988 sent a letter to Rhode Island's
Governor DiPrete stating that the project as proposed would cause
-significant impacts to the aquatic environment, would not comply
with the §404(b)(l) Guidelines, and probably could not receive a
federal §404 permit. However, during an August 11, 1988 meeting,
the Corps indicated to Governor DiPrete that the Big River
reservoir might again become a federal project, thereby avoiding
the need to acquire a permit, if the State so desired.
On August 24, 1988, EPA's Regional Administrator informed the Rhode
Island Water Resources Board, the Governor, and the Corps that he
intended to begin a §404(c) action because he believed that the
project may have unacceptable adverse impacts to wildlife and
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8
fisheries. Pursuant to 40 C.F.R. §231.3, a 15-day opportunity for
consultation ensued, which ended on September 9, 1988. Neither the
State nor the Corps chose to consult with EPA. Instead, the State
on September 1, 1988 officially asked the Corps to build the dam.
The State withdrew its §404 permit application to the Corps on
September 8,. 1988.
Following the consultation period, the Regional Administrator took
the next step in the §404 (c) process and signed a proposed
determination to prohibit the use of Big River, Mishnock River,
and their tributaries and adjacent wetlands for use as disposal
sites. In accordance with 40 C.F.R. § 231.3(a)(2), EPA published
notice of the proposed determination in the Federal Register on
February 1, 1989 (54 Fed. Reg. 5133), and published a summary of
the proposed determination in the Providence Journal and the
Pawtuxet Valley Times on February 3, 1989. The notice established
a public comment period from February 1, 1989 through July 31, 1989
and indicated that a public hearing would be held. Notice of the
public hearing was published in the Federal Register on May 2,
1989.
EPA conducted the public hearing at Coventry High School on June
8, 1989. Approximately 200 people attended the three-hour hearing.
Thirty-seven people spoke at the hearing, thirty-three of whom
expressed opposition to the reservoir and support for EPA's
proposed prohibition. Several of these speakers urged EPA to move
forward promptly to prohibit the project. Three people
representing the State and one person representing Senator
Claiborne Pell requested EPA to refrain from making a final §404(c)
decision until after Rhode Island completes a new study of
statewide water supply needs and alternatives to meet those needs.
The public comment period ended on July 31, 1989. EPA received
219 comments. An overwhelming majority (88%) of those who
responded opposed the reservoir on environmental or economic
grounds. Roughly 6% favored construction of the reservoir citing
a belief that it would be needed at some point. The remaining 5%
were undecided. The Corps did not submit a formal comment on EPA's
proposed action.1 The U.S. Fish and Wildlife Service provided
detailed information about the effects the reservoir would have on
fish and wildlife resources in the area, which is attached as
Appendix II. A number of environmental groups also submitted
comments concerning the impact of the project and provided specific
information about the existence of practicable alternatives. The
1 The Corps did, however, inform EPA on June 30, 1989 of the
conclusion reached by the Assistant Secretary of the Army for
Civil Works that the Big River Reservoir is not exempt, under
§404(r) of the Clean Water Act from EPA's §404(c) authority. The
applicability of §404(r) to this project had previously been an
issue in this case.
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State did not submit additional comments after the public hearing
except for the Rhode Island Department of Environmental Management,
Division of Groundwater and Freshwater Wetlands, which informed EPA
in writing that if the Rhode Island Water Resources Board applied
for a state permit to build the dam, it would likely be denied.
During the §404(c) public comment period, Governor DiPrete formed
the Rhode Island Water Resources Coordinating Council, and directed
it to develop an analysis of statewide water needs and evaluate
supply and demand alternatives for meeting future needs. The State
initially planned to complete its analysis by the close of EPA's
§404(c) comment period. On April 5, 1989, the Governor informed
EPA that additional time would be needed to conduct the study. A
consultant has since been retained, and the State currently expects
the study to be complete in March 1990.
As noted above EPA received requests both to complete a §404(c)
decision promptly and to postpone its decision until after the
State completes its study. I have decided to move forward with the
process for several reasons. EPA proposed to prohibit the project
primarily because of the serious environmental damage it would
cause; the record developed to date documents the adverse
environmental impacts from the project, especially to wetlands.
There is also considerable information in the record which
indicates that these impacts are avoidable. Since I have concluded
that the adverse impacts of the project would likely be
unacceptable, nothing would be gained by delaying the §404(c)
process. Moreover, before issuing a final decision, EPA
headquarters will provide the State with an opportunity for further
consultation. EPA supports Rhode Island's decision to conduct a
comprehensive review and planning effort concerning its statewide
water policies and needs. Indeed, for the past several years EPA
has urged the State to abandon the Big River reservoir and instead
undertake an analysis of this type. EPA Region I believes the
state study, if properly conducted, will assist Rhode Island in
formulating a rational and environmentally acceptable approach to
water supply issues. The study should be especially useful to the
State in evaluating future options if EPA headquarters affirms my
recommendation, concludes that the environmental impacts of the Big
River reservoir would be unacceptable, and prohibits construction
of the project.
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10
III. SITE DESCRIPTION
The Big River watershed is an outstanding natural resource.
Because of its large size, abundance of habitat types, and relative
lack of disturbance, the watershed supports large and diverse
wildlife communities. The richest wildlife habitat is found within
the area to be flooded by the reservoir. Over 100 species of
breeding birds and 25 species of mammals have been observed at the
site; over 30 species of reptiles and amphibians have been observed
or can be reasonably expected to occur at the site.2 Approximately
100 additional bird and some mammal species feed and rest at the
site during migration and in winter. Because of continued
urbanization and fragmentation of natural areas throughout southern
New England, the large contiguous tracts of land in the Big River
watershed provide essential and increasingly scarce habitat for
many sensitive and rare species.
The proposed Big River reservoir impoundment area (3,400 acres),
is part of the 29.7 square mile Big River watershed. The State
owns the land in the proposed impoundment area along with an
additional 4,600 acres of adjacent lands. This 8,000 acre parcel
comprises the Big River management area (Figure 4) . Big River
watershed drains into the 228 square mile Pawtuxet River Basin
which in turn empties into Narragansett Bay. The wetlands along
Big River, Mishnock swamp and the South Branch of the Pawtuxet
River form the largest wetland complex (over 1400 acres) in the
Pawtuxet River basin and remain relatively unaltered by development
or other human intrusions.
The largest wetlands in the proposed impoundment area border Big
River and six tributary streams scattered throughout the site:
Carr River, Bear Brook, Nooseneck Brook, Congdon River, Mud Bottom
Brook, and Sweet Pond Brook. Variable topography and hydrology
produce a diverse mixture of interspersed wetland and upland
habitats. This allows the ecosystem to support a broad range of
aquatic, semi-aquatic, and terrestrial wildlife communities.
Vertical stratification of the herbaceous, shrub and tree layers
in the wetland and upland communities is complex. Hence, a wide
array of fish and wildlife species use the area for resting,
breeding, rearing, and feeding, and as a travel corridor within the
watershed and to adjacent habitat patches. The streams transport
organic material from upstream areas in the watershed to the
floodplain wetlands, providing food web production for on-site and
2Over 90% of the reported wildlife species observations
occurred with in the limits of the proposed Big River impoundment
area; however, occasional observations were made in parts of the
management area outside of the pool area. EPA expects all
species found in the management area to utilize the impoundment
area, since all cover types are represented.
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Figure A: Big River Watershed, Management Area
and Impoundment Area
COHOOON MIVEM
MOOSfHECK RIVEM
I1O mvCR tEntCEH H008EMECK
AND CAM KIVEm
CAMim BIVEH
•Id MIVER MTWEEN CAMR HIVEM
AMD UAH WIOOK
KAM KtOOH
5.BJ
(.01
I.It
r.tt
t.TJ
4.21
it Area (3,400 - 3,700 acres)
lanaganent Area (0,000 acres)
-Watershed Area (19,000 acres)
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12
downstream biological communities. The riverine wetlands also
assimilate nutrients and pollutants, store floodwaters, and
moderate flow.
People hunt, fish and enjoy other recreational activities in the
wetlands and upland habitats in the project area. The Big River
site contains numerous ponds and 17 miles of streams, the majority
of which support cold water fisheries. Immediately downstream, the
Flat River Reservoir contains substantial warm water fisheries.
As the only free flowing river remaining in the Pawtuxet River
basin, Big River has the potential to provide additional
recreational opportunities uncommon in Rhode Island.
A) Site Ecology3
Land Use. Over 15,000 acres of forest dominate the 19,000 acre
Big River watershed (RI Water Res. Brd. 1986). Wetlands and deep
water habitats comprise the second largest land type (1,729
acres)(URI 1984), while agricultural land (580 acres), roadways
(330 acres), and residential areas (310 acres) account for the
remaining land use acreage in the watershed (RI Water Res. Brd.
1986). The predominance of forest and wetland acreage and scarcity
of disturbed areas within the watershed illustrate the relatively
unaltered nature of the area.
The proposed impoundment area has a high percentage of wetlands.
While the impoundment would occupy 17% of the land in the
watershed, it would contain 33% of the total wetland area in the
watershed. The diverse structure of the wetlands and deep water
habitats along Big River is evidenced by the 14 different wetland
vegetative subclasses and life-form characteristics present (URI
1984). The hydrologic and geographic locations of the wetlands
vary as well; they cross intermittent and perennial streams, border
open water habitats, occur on river floodplains and as isolated
units (RI Water Res. Brd. 1986) . Over three-quarters of the
wetlands in the impoundment area are riparian systems, i.e.,
associated with riverine floodplain or streambank ecosystems
(Figure 5). The highest quality wetlands in the impoundment area
are listed in Table 1.
Forested and shrub wetlands are the most prevalent type of wetland
in the impoundment area. Deciduous and evergreen forested wetlands
comprise 56% (323 acres) of the wetland and open water habitats.
The largest forested wetlands are riparian and occur in contiguous
tracts. Red maple (Acer rubrum) dominates in deciduous swamps with
3 In the preparation of this recommended determination, EPA
Region I retained the services of Dr. Curt Griffin, a professor
of wildlife ecology at the University of Massachusetts. Dr.
Griffin assisted in evaluating the environmental characteristics
of the site and the proposed project's impacts.
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WETLANDS TO BE FLOODED WITHIN
THE BIG RIVER RESERVOIR
LEGEND
TOTAL ACRES IN IMPOUNDMENT A«FA
Tola I Acrei of Wet lands
Totil Acres of Uplind
Miles of Cold Water Streams (Approi.)
WETLAND VEGETATION SUBCLASS
• FORESTED BROAD-LEAVED DECIDUOUS
<3 FOIESTED NEEDLE-LEAVED EVERGREEN
D EMERGENT PERSISTENT
O EMEIGENT NON-PERSISTENT
D BROAD-LEAVED DECIDUOUS SCRUB-SHRUB
a BROAD-LEAVED EVERGREEN SCRUB-SHRUB
D NEEDLE-LEAVED EVERGREEN SCRUB-SHRUB
• OPEN WATER
TOTAL
• UPLAND ISLAND
ROADS
W RESERVOIR BOUNDARY
STREAMS
(30* FOOT CONTOUR)
3411
575
2875
If
ACRES
1*4
12*
3 1
3
84
15
I
114
575
i. 4* (*f
,d frmt ir.
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Table 1: High Quality Wetlands in the Big River Impoundment Area
Wetland
Carr River Floodplain
Mud Bottom Brook
Unnamed, Located East of
Burnt Sawmill Road
Big River Floodplains located
soutn of route 95 and Route 3
Big River Floodplain located
just north of Route 95
Big River Floodplain located
west side of Big River, North
of Reynolds Pond
Bear Swamp Cove and
Big River Floodplain
Bear Brook Floodplain
Wetland
Nooseneck River
Floodplain
Description *
Top scoring in watershed, 81 acres +_,
diverse, class rich; good IntersperTion and
hydrological connection, bottom streamside
location classes Include PSSls, PSS4s,
PSS3C, PF01, P404, R20WH, L10WH, L2EM2b.
Large, 98 acres +, abuts Capwell Mill Pond.
Classes Include FsSls/r, PF01, PFOAc.
Associated with perennial stream from Sweet
Pond to Capewell Mill Pond. Classes include
PSSls/r, PF01, PF04.
91 acres +_, class rich, good hydrological
connectiolT bottom streamside location.
Classes include PSSls/r, PF01, PF04, R20WH,
POW, PSS4s.
Second highest scoring wetland in watershed,
34 acres +_, class rich, good hydrological
. connection and edge, bottom streamside
location. Encompasses lower two coves of
Big River. Classes include R20U, PEMln,
PF01, PF04.
Bottom.streamside location, good position to
other wetlands. Marsh vegetation dominant,
7.5 acres +, classes include PSS36, PEMln,
PF01.
Third highest scoring wetland in watershed,
bottom streamside location, good
hydrological connection and cover. Class
and subclass rich, forested vegetation
dominant. Classes Include R30WH, PF01,
PEMln, PEMS. PSSls/t, PEM/ow. Possibly some
evergreen bog.
Bottom streamside location 14 acres +.,
linear wetland dominated by red mapl?.
Classes Include PF01, POUH.
Bottom streamside location, linear wetland
dominated by red maple. Classes Include
PF01, PSSIE
* classification symbols after Cowardin (1979)
Source: Water Resources Board (1986)
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15
Atlantic white cedar fChamaecvparis thvoides) dominant in evergreen
wetlands. The Rhode Island Natural Heritage Program considers the
riparian cedar swamp along the Carr River to be the most
outstanding community of its type in the State (R. Enser, RI
Natural Heritage Program, pers. conun., 1989).
Shrub wetlands comprise 105 acres of the impoundment site. Shrub
species that commonly occur include highbush blueberry (Vaccinium
corvmbosum), speckled alder (Alnus rugosa), winterberry (Ilex
verticillata), sweet pepperbush (Clethra alnifolia), leatherleaf
(Chamaedaphne calyculata), and Atlantic white cedar saplings (RI
Water Res. Brd. 1986). These shrub wetlands occur along rivers
and streams, and along edges of ponds. Deep water lakes and open
water systems at the impoundment site comprise 114 acres. These
streams, lakes and ponds support considerable cold and warm water
fisheries (RI Water Res. Brd. 1986).
Emergent wetlands (marshes, wet meadows, and fens) constitute 34
acres of the impoundment area which represents 62 percent of the
emergent wetlands of the watershed (URI 1984). Vegetated with both
persistent and non-persistent emergents, typical plants include
tussock sedge (Carex stricta), bayonet rush (Juncus militaris),
rice cutgrass (Leersia orvzoides), and a variety of other rushes.
Emergent wetlands provide high habitat value for waterfowl and
other waterbirds and are an uncommon wetland type in the State
(Tiner 1989).
The Big River impoundment area also contains approximately 2,500
acres of forest, consisting of both deciduous and coniferous
communities, which often appear in mixed forest stands. The
evergreen forest consists of white pine (Pinus strobus) and pitch
pine (Pinus rigida) as pure stands or in combination with each
other. White pine is common, whereas pitch pine is considered by
the Rhode Island Natural Heritage Program to be an unusual and
distinct habitat type within Rhode Island. These pitch pine
communities also provide important habitat for two state threatened
wildlife species, the buck moth (Hemileuca maia), and the Nashville
warbler fVermivora ruficapilla) (RI Water Res. Brd. 1986). The
deciduous forest stands are generally mixtures of beech (Fagus
grandifolia), red maple, white oak (Quercus alba), red oak fOuercus
borealis), and black oak (Quercus velutina). These species provide
important wildlife habitat, especially the oaks, which provide
large acorn mast for wildlife food and abundant cavities in
standing dead trees.
Habitat Values. The majority of the wetlands in the impoundment
area border a complex system of streams. These riparian
communities combine the attributes of aquatic and terrestrial
ecosystems, and provide extensive linear ecotones. Complex
vegetative structure combines with the fluctuating water levels to
provide essential support for abundant riparian fish and wildlife
communities. These features include: (1) predominance of woody
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16
plant communities; (2) presence of surface water, wet soils and a
abundance of nutrients from overbank flooding; (3) close proximity
of diverse structural features (live and dead vegetation, water
bodies, unvegetated substrates) resulting in extensive edge and
structural heterogeneity; and (4) distribution in long corridors
that provide pathways for migration and movement of animals between
habitats (Brinson et al. 1981). This combination of water and
varied vegetation, unique to riparian ecosystems, provide abundant
food, cover, water and which support large and diverse fish and
wildlife populations in the Big River impoundment area.
Woody plants are essential for almost all of the animals, except
fish, at the Big River site. For example, more than half of the
birds at the Big River site depend on vegetation, directly or
indirectly, for food, including nuts and seeds or insects which
feed on plants. Almost all birds depend on vegetation for cover,
resting, or isolation during breeding season. Even water birds
such as wood duck and great blue heron need vegetation cover and
nesting, and primarily feed in water less than 20" deep.
Periodic flooding of riparian wetlands, in conjunction with micro-
topographic changes in the landscape, cause differential hydrologic
regimes which results in diverse patterns of plant communities and
life forms. Thus, trees, shrubs, dead vegetation, marshes, and
open waterbodies are interspersed and in close proximity to each
other. Overbank flooding deposits nutrients and material carried
by Big River into adjacent wetlands. The timing and duration of
flooding produces a seasonal dimension to the landscape which
allows a range of aquatic, semi-aquatic and terrestrial species to
all utilize the site. In addition, water moving in streams and
wetlands transports organic matter to the floodplain thereby
promoting productivity and energy flow in the ecosystem.
The Big River management area is linked hydrologically and
biologically with a much larger area. A portion of the litterfall
and detritus produced within the productive riparian habitat along
Big River is transported and made available to instream and
downstream aquatic communities. Areas immediately downstream,
including Flat River Reservoir, receive organic material from the
Big River watershed. However, numerous dams limit the transport
of material to Narragansett Bay. The Big River watershed supplies
surface and groundwater to over 800 additional acres of wetlands,
including Mishnock swamp (500 acres) and wetlands along the South
Branch of the Pawtuxet River (300 acres) (RI Water Res. Brd. 1986) .
The long, linear riparian habitats along the streams in the
impoundment area and the undisturbed natural habitats of the
watershed serve as important corridors for resident and migratory
animals to move within the watershed and to nearby habitat blocks.
The continuity of these habitats, especially the riparian systems,
enhances the ability of the site to maintain viable wildlife
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17
populations. Genetic variation persists because genetic material
is exchanged freely among animals moving within the large habitat
blocks. Dispersing animals recolonize areas which have suffered
from local extinctions. Carnivores such as river otter, fisher and
bobcat, which require large home range sizes, freely move between
habitat blocks along the extensive riparian corridors. The
remainder of the watershed, encompassing nearly 30 square miles,
is also relatively unfragmented by development and human
disturbance, a critical factor to the many area-sensitive wildlife
species which depend on large contiguous tracts. Further,
recruitment and replacement individuals likely emigrate from the
watershed to colonize smaller fragmented habitats nearby.
In summary, the wetland and upland communities in the Big River
management area provide the full spectrum of natural resource
values. The wetlands are large and varied and interspersed with
extensive upland forested habitats. This interspersion of
habitats, in combination with the complex vertical stratification
of plant communities provide outstanding fish and wildlife habitat.
The riparian wetlands also serve as important corridors for
wildlife movement within and between the watershed and adjacent
areas. Moreover, the wetland and upland habitats of the watershed
are relatively unaltered by development and provide large
contiguous natural habitats for many area-sensitive species. Both
the overall diversity of the fish and wildlife communities and the
presence of rare species underscore the integrity of the watershed.
The actual observations of wildlife at the site, discussed below,
strongly corroborate these predicted high wildlife habitat values.
B) Fish and Wildlife
Recent field surveys of birds, mammals, herptiles, fish and
invertebrates in the Big River impoundment area reveal high species
diversity and the occurrence of numerous rare and area-sensitive
species (Appendix II) . On a regional scale, few other areas in
southern New England provide a comparable mosaic of habitats
capable of supporting such a large and diverse wildlife community.
Birds. Field surveys have recorded at least 106 species of birds
which breed in the Big River management area (Appendix I) . An
additional 94 species of birds are expected to use the site during
spring and fall migration or during winter. Nearly 90 of the
observed species of breeding birds spend some portion of their life
cycle in wetland habitats. Fifty of these species strongly prefer
aquatic habitats or riparian wetlands, such as American black ducks
(Anas rubripes), wood ducks (Aix sponsa), red-shouldered hawks
(Buteo lineatus), barred owls (Strix varia), green-backed herons
(Butorides striatus), and Virginia rails (Rallus limicola).
A number of state listed species occur in the management area. Two
state listed species, the acadian flycatcher, (Empidonax
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18
virescenis) and the winter wren (Troglodytes troglodytes), breed
in the Big River management area according to a 1989 survey/
Between 1983 and 1987, the Rhode Island Breeding Bird Atlas Project
recorded seven additional species listed either as state threatened
or state interest as likely breeders. These include the Cooper's
hawk (Accipiter cooperii) , upland sandpiper (Bartramia longicauda) ,
horned lark (Eremophilia alpestris), worm-eating warbler
(Helmitheros vermivorns), cerulian warbler (Dendroica cerulea),
grasshopper sparrow (Ammodramus savannarum) , and white-throated
sparrow (Zonotrichia albicollis). The RI Natural Heritage Program
considers two additional species listed as state interest, the
great blue heron (Ardea herodias) and pileated woodpecker
(Dryocopus pileatus), as potential breeders within the Big River
area (USFWS 1989). In addition, the bald eagle (Haliaeetus
leucocephalus) and peregrine falcon (Falco peregrinus), listed as
endangered under the federal Endangered Species Act, and the state
listed osprey (Pandion haliaetus) either overwinter or migrate
through the area (R. Enser, RI Natural Heritage Program, 1989,
pers. comm.).
The avifauna of the Big River management area also include 43
area-sensitive species, including 21 forest-interior and 22
interior-edge migratory bird species which nest in the impoundment
area (Appendix II) . These area-sensitive species typically reguire
extensive tracts of land for breeding and decline sharply with
habitat fragmentation and reductions in forest patch sizes. The
breeding birds on the Big River site most susceptible to these
fragmentation effects include the black-and-white warbler
(Mniotilta varia), Louisiana waterthrush (Seiurus motacilla),
northern waterthrush (Seiurus aurocapillus), black-throated green
warbler (Dendroica virens), Canada warbler (Wilsonia candensis),
worm-eating warbler, hermit thrush (Catharus mimimusj,
yellow-throated vireo (Vireo flavifrons), red-shouldered hawk,
Cooper's hawk, and broad-winged hawk (Buteo platypterus) (Appendix
II).
Some of these forest interior species may persist in suboptimal
sized forest patches if large nearby reserves supply recruitment
or replacement individuals. The Big River management area is
sufficiently large to function in this capacity and may play a role
in replenishing the regional populations of area-sensitive birds
that occur in moderate to low numbers in central Rhode Island
(Appendix II). Moreover, several of these area-sensitive species
are long distance or neotropical migrants, currently suffering
4The RI Natural Heritage Program has several categories of
"species of state interest." "State threatened" species are
likely to become endangered in the state; "state interest"
species are not endangered or threatened but occur in only 6 to
10 sites in the State; "species of concern" are listed due to
various factors of rarity or vulnerability.
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19
habitat destruction of both their breeding grounds in North America
and their wintering grounds in Latin America. Long-term population
declines have been observed in this group of birds in areas of the
United States undergoing rapid urbanization, a trend of significant
concern to the U.S. Fish and Wildlife Service. Thus, the large,
unfragmented habitats of the Big River Watershed contribute to the
conservation of both regional forest bird populations and several
neotropical migrant species.
Mammals. Field tracking of large and medium size mammals and
small mammal trapping indicate a large and diverse mammal community
in the Big River management area (Appendix II) . Twenty five
species of wild mammals were recorded on the site in 1989 (Appendix
I), the most common large mammals being white-tailed deer
(Odocoileus virginiana), red fox (Vulpes), and raccoon (Procyon
lotor). Meadow voles (Microtus pennsvlvanicus), masked shrews
(Sorex cinereus), woodland jumping mice (Napaeozapus insicmis), and
short-tailed shrews (Blarina brevicauda) were the most frequently
trapped small mammal species. An additional 21 mammal species
probably occur on the site. At least 30 of these 46 species
actively use wetlands during some part of their life cycle.
Thirteen species strongly prefer aquatic habitats, such as beaver
(Castor canadensis), mink (Mustela vison), muskrat (Ondatra
zibethicus), river otter (Lutra canadensis), raccoon, and water
shrew (Sorex palustris). Capture of the state-listed water shrew
represents only the third record of the species in Rhode Island.
EPA received one report of a southern bog lemming (Synaptomvs
cooperi) in the area as well. Further, Audubon Society staff
observed bobcat (Felis rufus) tracks in the impoundment area in
1989, and a fisher (Martes pennanti) was observed in the
impoundment area in 1988 (Appendix II). Both of these carnivores
are listed as state threatened species.
The Big River and its tributaries provide an important, unaltered
habitat for populations of most of Rhode Island's mammal species.
Larger, rarer species such as the river otter depend heavily upon
large, undisturbed wetland systems with clean water and plentiful
fish. The abundant small mammal populations play a key role in
the biological community as the essential link in the food chain
for several raptor species, such as the red-tailed hawk (Buteo
iamaicensis), red-shouldered hawk, American kestrel (Falco
sparverius), great horned owl (Bubo virginianus), and barred owl.
Small mammals also provide a valuable food source for upper-level
mammals, such as red foxes, gray foxes fUrocyon cinereoaraenteus),
and long-tailed weasels (Mustela frenata).
Herptiles. Herpetological surveys by the RI Division of Fish
and Wildlife staff show that 7 salamander, 2 toad, 6 frog, 7
turtle, and 11 snake species (Appendix I) either occur, or can be
reasonably expected to occur within the Big River Management Area
(Appendix II) . Seven of these species are state-listed: the
marbled salamander (Ambystoma opacum), four-toed salamander
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20
(Hemidactylium), wood turtle (Clemmvs insculpta), worm snake
(Carphophis amoenus), hognose snake (Heterodon platyrhinos),
redbelly snake (Storeria occipitomaculata), and ribbon snake
(Thamnophis sauritus). Extensive stream, river floodplain, and pond
habitats support large populations of spotted turtles (Clemmvs
quttata), painted turtles (Chrvsemys picta), American toads (Bufo
americanus) ,' green frogs (Rana clamitans) , pickerel frogs (Rana
palustris), and probably water snakes fNerodia sipedon). Two-lined
salamanders (Eurycea bislineata) and wood turtles occur in small
stream habitats. Spotted salamanders (Ambystoma maculatum) are
abundant and widespread, especially in ephemeral ponds along the
floodplains of rivers and streams while dusky salamanders
(Desmoanathus fuscus) are uncommon and restricted to cold spring
seepage areas. Most of the salamander species overwinter in upland
sites, while many of the turtles need upland sites to lay eggs.
Some species of snakes frequent the old field habitats.
Reptiles and amphibians favor the juxtaposition of wetland and
upland habitats characteristic of the Big River area. At least 21
of these species depend on or closely associate with aquatic
habitats or riparian wetlands. The seasonal flooding of these
riparian zones is critical to the survival of these species.
Ephemeral ponds dimple the landscape especially in overflow areas
near the major waterbodies. These ponds provide rich invertebrate
food sources for the abundant salamanders, frogs and turtles that
occur in the area. In addition, amphibian larvae develop and adults
breed in these ephemeral ponds. These herptiles also provide a
vital link in the food chain. They are not only important prey
for a wide variety of birds, mammals, and other reptiles and
amphibians, but they also play an integral role in transferring
energy from wetland to upland systems.
Fish. Approximately 17 miles of free flowing streams and 10 ponds
within the proposed impoundment area support both cold and warm
water fisheries. Congdon River, Nooseneck River, Bear Brook, and
Big River (south of Route 3) support brook trout. The RI Division
of Fish and Wildlife stocks approximately 2,000 fish a year into
Big River at six locations. Warm water fish live in most of the
remaining streams and ponds. Approximately 10 species of fish,
including brook trout, largemouth bass, white suckers and redfin
pickerel were collected in the streams (Appendix I) . Pond habitats
support approximately 10 species of fish, such as yellow perch,
golden shiner, and banded sunfish (Appendix I). Largemouth bass
and redfin pickerel spawn in the riverine wetlands. These
seasonally flooded areas supply invertebrates for food and function
as nursery areas (Wilkinson et al. 1987). The fish in turn provide
important food for other wildlife species, such as herons,
kingfishers, mink, raccoon, and river otters.
The Big River site and Flat River Reservoir are two of the best
three fishing areas in the Pawtuxet Basin (Corps, EIS, 1981). Big
River flows into Flat River Reservoir and supplies over half its
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21
water. The RI Division of Fish and Wildlife reports that Flat
River Reservoir has the best warm water fishery in the Pawtuxet
Basin, and the best largemouth bass fishery in the State. The
South Branch of the Pawtuxet River and the mainstem of the Pawtuxet
River contain warm water fisheries, although little recent data
exists for these rivers. Two centuries ago, large runs of
anadromous 'fish including shad, alewives, smelt, and Atlantic
salmon ascended the Pawtuxet River and its tributaries to spawn.
However, these species fell victim to urban pollution, numerous
dams, and low flow problems, and no longer appear in the Pawtuxet
River (Corps, EIS, 1981). The State hopes eventually to restore
the anadromous fisheries (Corps, EIS, 1981).
Invertebrates. While little information exists on invertebrate
communities, several unique or rare species occur within some of
the upland and wetland habitats of the watershed. One of the
largest concentrations of buck moths in Rhode Island, a state
threatened species, is found in the pitch pine community (RI Water
Res. Brd. 1986). Two amphipod species are also of particular
interest. One amphipod, Crangonyx aberrans. is endemic only to
southeastern New England. The other amphipod of interest is
Synurella chamberlaini. a species in New England disjunct from its
main distribution along the middle Atlantic Coastal Plain from
Maryland to South Carolina (Smith 1987) . Collection within the
watershed represents only the third known location for this
amphipod in New England (Appendix II).
Wetland invertebrate fauna nourish first order consumers and also
provide organic matter available to detrital food chains.
Invertebrates thrive in the seasonally flooded riparian wetlands
and in the moist litter and soil. Most invertebrate production
occurs in these seasonally flooded wetlands as opposed to the main
stream channels. Invertebrates are the primary prey for a wide
array of wildlife groups, such as forage fish, salamanders and
frogs, small and medium size mammals, and many bird taxa. They
play a key role in decomposing or processing the plentiful organic
matter in riparian systems so that it is available to the detrital
food chains.
Wildlife Habitat Assessments. Numerous independent wildlife
investigations over the last 13 years reinforce the conclusion that
the Big River site supports unusually valuable wildlife habitat
(Appendix II) . The Corps of Engineers, for example, commented that
the numerous ponds, rivers, swamps, and marshes provide some of the
best wildlife habitat in the State (Corps, EIS, 1981, Appendix H).
Most of these investigations were based on observing animals at the
site and general recognition of the mixture of vegetation
communities. Three studies, however, involved more formal wildlife
habitat assessments of the area.
The U.S. Fish and Wildlife Service (FWS) conducted a Habitat
Evaluation Procedures (HEP) analysis of the forest and wetland
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22
habitats within the Big River management area in 1979. The
evaluation used a "guild" of 26 wildlife species (11 mammals, 11
birds, 2 amphibians, and 2 reptiles). FWS concluded that the
scrub/shrub and forested wetlands, the predominate wetlands in the
management area, provide excellent wildlife habitat, and very few
management actions could improve the wildlife use of the wetlands.
They also concluded that the emergent wetlands on the site provide
important habitat for waterfowl.
A 1984 University of Rhode Island study evaluated the wildlife
habitat of 166 wetland units within the Big River watershed as
wildlife habitat using the Golet evaluation system. Almost all of
the major wetlands in the proposed impoundment area are of
outstanding or high value under the Rhode Island classification
system (Figure 6). The majority of the high quality wetlands in
the watershed, including the 3 most valuable wetlands for wildlife
and 8 of the top 11 wetlands, fall within the proposed impoundment
area. The impoundment area also contains 62% of the emergent
wetlands in the watershed, a somewhat unusual wetland type in Rhode
Island, of high value to waterfowl and other animals.
In 1986, Wetland Management Specialists, Inc., a consultant to the
RI Water Resources Board, also conducted a wetlands wildlife
evaluation for the larger wetlands in the proposed impoundment
area. Using the Rhode Island Department of Environmental
Management (DEM) Wetland Wildlife Ranking protocol (a modified
Golet method), it classified 32 wetland units as having "low,"
"medium," "high," or "outstanding" value for wildlife. DEM
considers wetlands ranked as outstanding (a score of 70.5 or above)
to be unique (RI DEM, 1988) . Nine wetlands, covering 63% of the
total area of all the wetlands evaluated, received outstanding
scores (RI Water Res. Brd., 1987, unpubl. data). In addition, 11
wetlands rated high (29% of land area) and 12 as medium value (8%
of the area). No wetlands received a low score.
A quantitative system which rates each wetland's ability
to support wildlife based on 10 criteria: 1. Wetland Class
Richness (the number of different classes present); 2. Dominant
Wetland Class (the class that occupies the greatest area in the
wetland); 3. Size (total area of the wetland, measured in
hectares); 4. Subclass Richness (the number of different
subclasses present); 5. Site Type (the topographic and hydrologic
location); 6. Surrounding Habitat (the extent and diversity of
natural habitat types compared to developed types); 7. Cover Type
(the relative proportions and degree of intermixing of vegetation
and open water); 8. Wetland Juxtaposition (the proximity of other
wetlands and their degree of hydrologic connection); 9.
Vegetative Interspersion (the degree of intermixing of various
life forms of vegetation); 10. Water Chemistry (pH value).
(Golet 1976).
-------
HIGHEST SCORING WETLANDS FOR
Wl LDLI FE HABI TAT
Wildlife habitat value was assessed
using Golet's (1976, 1979) quantitative
evaluation system which rates each
wetland's ability to support abundant,
diverse wildlife communities.
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(300 FT CONTOUR)
• UPLAND
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• HIGH VALUE
• MEDIUM VALUE OR
NOT EVALUATED
• OPEN WATER
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24
The Water Resources Board's consultant also examined other
potential high quality wetland areas in the watershed and
downstream of the proposed impoundment. The vast majority of the
high value wetlands are located in the impoundment area, Mishnock
swamp or the South Branch of the Pawtuxet River. An additional
five wetlands classified as having high wildlife value, receiving
a score of 60 or greater (RI Water Res. Brd., 1987, unpubl. data),
were in areas that would be affected by highway relocations and
other related activities.
C) Hvdrological Values
Groundwater Recharge and Discharge. Groundwater in the aquifer
associated with Big River is intimately connected with surface
water in streams and floodplains. The normal gradient and
direction of groundwater movement is toward these surface water
features through groundwater discharge. However, during seasonal
flooding, the gradient reverses and water moves from streams to
the floodplain and into the aquifer. Wetlands also discharge water
to streams from water upslope runoff. In addition, during drier
times of the year, wetlands contribute to the basal flow of streams
during low flow conditions, helping to maintain viable aquatic
communities downstream.
Wetlands recharge groundwater more readily into porous soils, such
as the sand and gravel soils near Capwell Mill Pond, Division Road,
and Mishnock swamp to the north. As early as 1952, researchers
recognized that the Carr River area recharges the groundwater which
then flows north into Mishnock Lake and swamp (C.A. Maguire &
Assoc., 1952). Although the quantity of flow has not been
conclusively determined, one consultant measured the flow to be
approximately 3 MGD near Mishnock Lake and concluded that the
majority of the water budget for the lake comes from the proposed
Big River impoundment area (RI Water Res. Brd., 1986). Similarly,
groundwater recharge from Big River watershed may also supply the
bulk of the water budget for Mishnock swamp (RI Water Res. Brd.,
1986).
Flood Storage. Wetlands comprise approximately 17% of the area
in the proposed impoundment, with most located along the streams
and rivers. Many of these wetlands are only seasonally flooded
and provide extensive storage for flood waters from neighboring
streams and from upland sheet runoff. A 6" rise of water, for
example, in a 10 acre wetland places more than 1.5 million gallons
of water in storage (Niering, 1980). The dense vegetation of the
wetlands along Big River slows the velocity of the water, lowers
the peak runoff and allows greater opportunity for groundwater
infiltration. Hence, the vegetation and the porous soils work in
tandem to provide important flood storage and recharge benefits.
Water Quality. Wetlands alter the fate of pollutants by
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25
chemically or biologically removing contaminants from water.
Therefore, most wetlands provide water quality benefits to adjacent
and downstream waterbodies. For a wetland to attenuate pollutants
in this fashion, the water which carries the contaminants must
contact the wetland vegetation and soils. This typically occurs
when streams overtop their banks and flood adjacent wetlands or
when water flows into the wetland vegetation and soils by sheet
runoff. Wetlands often provide natural treatment by removing as
much as 80-90% of the suspended sediments in the water column which
could otherwise interfere with normal plant and animal growth
(Larson, 1981). High turbidity levels, for example, can restrict
sunlight penetration, reduce plant growth, and clog fish gills.
A high density of wetland plants also enhances the processes of
sedimentation, ion exchange, and algal and bacterial growth
necessary for organic degradation of particulate matter. Wetlands
reduce nutrient levels, such as nitrogen and phosphorus, which
often impact downstream waterbodies. Most wetlands release some
nitrogen to the air through denitrification, while others remove
nutrients and toxics from the water column by storing the chemicals
in sediments and peat. Wetlands also store nutrients in the
wetland vegetation during the growing season, and release the
nutrients later in the year when water is colder and less
vulnerable to algae blooms and other forms of nutrient pollution.
EPA expects that the extensive wetlands at Big River provide
similar water quality benefits for downstream aquatic communities.
Interactions between water and wetland vegetation and soils clearly
occur at the Big River site, given the prevalence of riverine
wetlands. The thick vegetation in the wetlands at Big River retard
water flow and allow materials to settle. Although the Big River
watershed is largely undeveloped, there are some sources of
pollution within the watershed. For example, several highways
cross the watershed, including 1-95, the busiest roadway in the
State. Pollutants from spills and normal highway runoff likely
enter the watershed and the river. The rivers and streams within
the site, and downstream waters such as Flat River Reservoir, would
benefit from the wetlands1 ability to remove such pollutants from
the water column.
D) Recreation
Rhode Island contains approximately 400 ponds, lakes, and
impoundments, 100 of which are in the Pawtuxet River basin (USGS
1987; SCORP, 1986). Thirty-four of the ponds in the Pawtuxet River
basin exceed 10 acres (Corps, EIA, 1981, Vol. IV). Big River, the
only free-flowing river in the basin, is one of the few remaining
streams in the State with good water quality, public access for
canoeing, fishing, and swimming, and an undeveloped shoreline (RI
DEM, 1987). The Big River management area accounts for about 17%
of all the publicly owned open space in the State. One of the
largest areas of open land in the State, it is among the last
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26
undeveloped natural areas left in Rhode Island, the second most
densely populated state in the country.
Recreation use in the Big River impoundment area is moderate to
heavy, even though the State does not actively manage the area for
recreation, and the site is one of the most popular hunting areas
in the State (Corps, EIS, 1981, Appendix H) . All of the most
popular game species in the State are found there, including
pheasant, grouse, quail, woodcock, rabbits, and deer. People hunt
and fish in the Big River area in a moderate to heavy capacity
(USFWS 1978; RI Division of Fish and Wildlife, 1989). People hunt
deer 1,000 user-days and small game 2,300 user-days a year at the
site. Last year the Big River management area yielded
approximately 20% of all the deer killed on state lands (J. Myers,
RI Division of Fish and Wildlife, pers. comm., 1989). People fish
for trout in streams within the proposed impoundment area 1,000
user-days, and for warm water species, 800 user-days a year. The
RI Division of Fish and Wildlife stocks approximately 2,000 fish
a year in Big River at six locations. People swim in several ponds
and portions of Big River. Because there is no entrance gate or
fee required, precise estimates of other uses including walking,
nature observation, canoeing, swimming, camping, and off road
vehicle use are not available. Nevertheless, a number of people
commenting on EPA's proposed determination testified to their use
of the area for these activities.
Big River is located approximately 15-20 miles from the large
metropolitan region generally surrounding the city of Providence.
In 1978, FWS concluded that this rare juxtaposition of a large and
diverse tract of open land so close to a heavily populated area
creates tremendous opportunity for recreation. The 1986 State
Comprehensive Outdoor Recreation Plan 1986 - 1991 (SCORP) describes
the uncommon and fragile nature of open space in Rhode Island, and
indicates the importance of protecting large areas of habitat. It
also points out that in many areas development surrounds open space
in the State, making them less valuable for wildlife.
In addition to providing valuable wildlife habitat, the 8,000 acres
of mostly forested land in the management area provide existing and
potential opportunities for activities such as bicycling, walking,
horseback riding, picnicking, and swimming, all activities which
rank high in popularity (SCORP 1986). Also, approximately 1/3 of
the people in the State now explore nature for observation and
photography (SCORP 1986). As one of the last remnants of intact
natural areas left in the State, better access for hiking,
swimming, canoeing, and camping would encourage more people to
experience the area.
The recreational use of waterbodies immediately downstream of the
proposed impoundment are also extensive. Flat River Reservoir,
used for boating, swimming, fishing and other forms of water
recreation, provides the best largemouth bass fishery in the State
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27
and trophy size northern pike. The U.S. Fish and Wildlife Service
estimates fishing use at Flat River Reservoir to be 10,000 user-
days a year. It also estimates that with proper management and
better access, the Flat River Reservoir could provide 25,000 user-
days of fishing a year (USFWS 1978).
E) Summary
Based on the administrative record, I find that the Big River
watershed, especially the proposed impoundment area, contains
excellent fish and wildlife habitat. I base this conclusion on
several factors including direct observations and data supplied by
experts and the public, the conclusions of the 1981 EIS, and a
number of habitat evaluations all of which found the area to be
valuable for wildlife. I also find that the wetlands in the
watershed provide other beneficial functions including flood
storage, water quality maintenance and groundwater recharge and
discharge. Furthermore, I conclude that the site provides valuable
recreational benefits. Although not currently promoted as a
recreation area, the site enjoys substantial use by the public for
fishing and hunting, and provides excellent opportunities for
canoeing, birdwatching, and other outdoor activities.
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28
IV. ADVERSE ENVIRONMENTAL IMPACTS
The proposed Big River reservoir would profoundly alter the natural
habitats of the site. Construction of the dam and associated
facilities would inundate 575 acres of wetlands, approximately
2,500 acres of primarily forested uplands, and 17 miles of free
flowing streams. It would transform a large, diverse complex of
wetland and upland habitats which support a broad array of aquatic,
semi-aquatic, and terrestrial wildlife communities into a shallow
lake favored by only a few species. It would dramatically reduce
the amount of valuable wetland habitat in the watershed. Emergent
and evergreen forested wetlands, the most uncommon wetland habitats
in the watershed, would be most severely impacted. Several unique
or sensitive plant community types, including the riparian cedar
swamp along the Carr River, and the large pitch pine communities
near Division Road would be inundated by the reservoir. Each of
these plant communities has been recognized by the RI Natural
Heritage Program as outstanding examples of habitats uncommon in
Rhode Island. Over 144 species (87%) of vertebrate wildlife (fish,
birds, reptiles, amphibians, and mammals) observed at the site and
an undefined number of invertebrate species would be adversely
affected. Many area-sensitive species and others with specific
habitat requirements, including 23 state-listed species and two
federal endangered species, would be either eliminated from lands
and waters occupied by the reservoir or adversely affected in areas
outside of the reservoir boundaries. One of the State's few
remaining cold water stream fisheries would be destroyed.
The proposed project would affect ecological processes both
upstream and downstream of the dam and have both short and long
term effects on wildlife habitats. It may adversely affect
wildlife populations far removed from the Big River watershed and
contribute substantially to ongoing cumulative adverse effects in
southern New England where urban development has already
significantly reduced the diversity of natural communities. The
destruction of 575 acres of wetlands would be unprecedented, more
than any project permitted in New England since the inception of
the Clean Water Act in 1972. In addition, the dam and slurry wall
will impede the movement of groundwater into Mishnock swamp and
reduce flows to the South Branch of the Pawtuxet River. This long
term alteration of the hydrologic regime threatens the viability
of over 700 acres of nearby and downstream wetlands. The project
would markedly reduce downstream water flow: 45% less flow to the
Flat River Reservoir, 34% less flow to the South Branch of the
Pawtuxet River, and 15% less flow to the mainstem of the Pawtuxet
River. Depriving the downstream areas of flow would exacerbate
existing water quality problems and adversely impact the already
severely stressed biological communities.
Finally, the reservoir would have substantial adverse impacts on
the recreational values at the site. Under current state laws and
policies, all recreational uses within the entire management area
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29
would be lost. Even if state policies change and the Corps builds
the project with a recreation component, many of the existing
recreational opportunities would be eliminated or greatly reduced.
The §404(c) regulations (40 CFR §231.2(e)) direct EPA to consider
the relevant portions of the section §404(b)(l) guidelines (40 CFR
Part 230) in evaluating the unacceptability of a project's impacts.
One such portion, section §230.10(c), forbids the discharge of
dredged or fill material if it would cause or contribute to
significant degradation of waters of the U.S.. Effects
contributing to significant degradation include (but are not
limited to) significant adverse effects on aquatic ecosystem
diversity, productivity, and stability, such as loss of fish and
wildlife habitat, and significant adverse effects on recreational
values. Special emphasis is to be placed on the persistence and
permanence of the effects outlined in part 230, subparts B through
G. Based on the administrative record, I conclude that the
proposed Big River reservoir would cause a significant adverse loss
of fish and wildlife habitat and a significant adverse impact on
recreation.
A. Fish and Wildlife Impacts6
The most immediate and severe impacts to wildlife communities would
occur within the impoundment area, as a result of 1) removing all
the vegetation by site clearing and flooding; 2) reducing the
diversity and interspersion of habitats; 3) reducing nutrient
enrichment of the floodplain; and 4) preventing animal movement
along the long riparian corridors (Figure 7). As explained in the
site description, nutrients, water and site topography combine to
produce different types of vegetation in close proximity providing
ample food and cover for wildlife. Impounding the river would
provide water, but it would also smooth the varied topography and
remove the vegetation. As a consequence, the food, cover, and
reproductive sites for the vast majority of the 250 species
expected at the Big River site could disappear. In contrast, the
dam may improve habitat conditions for only 10 - 20 species, an
order of magnitude less than it would impact.
Clearing of vegetation from the project site and subsequent
inundation would destroy much of the existing habitat values of the
site. As part of the state project, an additional 400 acres would
be cleared of all vegetation within a 300 foot buffer zone around
the reservoir perimeter. Although the degree of impact to wildlife
would vary with the species and season, animals unable to escape
the project area would die immediately. More mobile species would
attempt to relocate in adjacent areas. However, in all likelihood
6For purposes of this §404(c) recommendation, I have
considered impacts to fish as falling within the adverse impacts
to wildlife.
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30
Figure 7: General Impacts to Fish and Wildlife
from Impounding a Stream
IEFORE IMPOUNDMENT
AFTER IMPOUNDMENT
Habitat tor straam-dwallinf fish Habitat for iaka-dwellinf fish
Predominantly ftoodptain/tanes
trial wildlift habitat
Straambank habitat for many sot
ciaiuad wiMlifa spaeias
Natural hydrotaf c rtftma
aachanfa pathways for nutritntt.
datritus and orfanisms between
ehannai and ftoodpiain
DonniUaam transport of datritus
and sadimants
Oomdor for fish and wttdlifa movt
nwnts
Pradominantly aquatic fish habi-
tat
Straambank habitat raplacad by
aitansiva. oftan unstabta short
lina; altarad spaeias
Parmanant inundation aiiminatas
ftoodpiain vafatation and vital
pathways of aichanft
Matantion of datritus and aadi-
nwnts behind dam
Corridor altarad and mtamiptad
SCCKCE: Brinson, 1981
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31
these nearby habitats are at or near carrying capacity
(equilibrium). Thus, animals from the project site may not
successfully relocate and could suffer high indirect mortality.
Many species of wildlife at the site either require wetland habitat
for survival, or depend upon wetlands for a portion of their life
cycle. Over 3/4 of the species recorded at the Big River site use
wetlands during some portion of their life cycle, and approximately
1/3 of these species prefer wetland habitat. Since the proposed
impoundment area is 17% wetland, while the remainder of the
watershed is 7% wetland, many species would be forced into less
suitable habitat. Further, the impoundment generally supports
higher quality wildlife habitat than the rest of the management
area and watershed (URI, 1984).
Some of the wildlife habitat value could return if the vegetation
were allowed to grow back. However, flooding the site would
prevent the regrowth of the complex vertical stratification of
herbaceous, shrub, and tree layers in the wetland and upland
communities. This vegetation provides protection, resting,
breeding, feeding, denning, roosting, and spawning areas for a
variety of terrestrial, arboreal, and aquatic wildlife. The loss
of mast producing vegetation from the area would reduce the
available food for a broad range of wildlife species. The standing
dead trees and snags important to resting, nesting, denning, and
feeding habitat for numerous wildlife species would be lost. The
many different wetland and upland habitat types would be reduced
to a single aquatic type, a large lake. This would greatly impact
aquatic diversity in the 30 sq. mi. watershed as well (Figure 8).
Lake open water would increase from 11% to 77% of the aquatic
habitat types in the watershed.
Destruction • of the vegetation would effectively halt leaf
production in the reservoir area and thereby eliminate the
principal biological source of nutrient cycling in the wetland and
upland habitats. The annual litterfall in these habitats provides
an important energy source to saprophytic food chains as well as
a substantial release of nutrients from vegetation. The organic
matter supports food chains of invertebrates, fish, birds, mammals,
and herptiles both on the reservoir site, and downstream.
The reservoir would not only destroy almost all of the
wildlife-rich riparian wetlands in the watershed, but it would also
inundate the relatively large secure forest-interior habitats in
the center of the watershed. In these large and unfragmented
interior forests dwell the abundant numbers of area-sensitive
breeding birds as well the large terrestrial predators. The long,
linear riparian habitats in the proposed reservoir site serve as
important corridors for resident and migratory animals to move
within and between the watershed and among other habitat patches
in the region. The continuity of these forest and riparian
habitats maintain large viable wildlife populations and allow
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32
Figure 8
Percent Change in Aquatic Habitat Types
in the Big River Watershed
Before Projeci
Water tfi£X)
Uki Oom W«lw 100%
I5OOX!
After Projeci
Forwted 12093
SlmbSwM»l&BG RtMriM/P*B*n09«WitarU&B
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33
dispersing animals to recolonize smaller habitat patches
throughout the region that have suffered local extinctions.
Construction of the reservoir would not only significantly reduce
the diversity and abundance of wildlife species in the watershed
but also block these natural corridors that fish, amphibians,
reptiles, birds, and mammals travel.
In addition to looking at gains and losses in cover type acreage,
project impacts can also be determined by examining wildlife
habitat assessments and impacts to specific groups of species.
Potential wildlife habitat losses can be quantified by a HEP
analysis as acres lost or average annual habitat units (AAHU's)
lost, which attempts to estimate quality of wetlands as well. The
U.S. Fish and Wildlife Service HEP study revealed that wetlands in
the 8,000 acre management area support 488 AAHU's, 390 in the dam
area and 98 in the remainder of the management area (USFWS 1979).
(This also illustrates that even though the dam area is less than
half the size of the management area, it contains the vast majority
of wetlands which are valuable to wildlife.) Including the 90
acres of subimpoundments the Corps proposed as mitigation, the
entire management area after the dam is built would support 180
AAHU's, a decrease of 308 AAHU's overall. Therefore, even with the
proposed mitigation the majority of the wetland habitats in the
management area would be lost to wildlife. The loss of habitat for
all cover types in the management area would be 1,854 AAHU's (USFWS
1979).
The Golet Wildlife evaluation system cannot be used to make
quantitative before and after comparisons. However, one can
examine the criteria of the method and determine how they would
change. Six of the 10 criteria used - class richness, dominant
class, subclass richness, cover type, wetland juxtaposition, and
vegetative interspersion - would be dramatically reduced in value
because a large lake provides no vegetation or diversity of habitat
types.
Birds. Clearing of vegetation and inundation of the Big River
reservoir site would eliminate habitat for a significant number of
bird species which utilize the complex of wetlands and uplands
during some part of their life cycle. The U.S. Fish and Wildlife
Service indicates that at least 90 bird species would be adversely
affected. These include 8 state-listed species, 43 area-sensitive
species, 35 riparian-associated species, and a wide variety of
wetland-dependent and upland species. In contrast, only a few
waterbird species would use the reservoir once completed.
Some of the state-listed species which would be adversely affected
include the Cooper's hawk, acadian flycatcher, winter wren,
worm-eating warbler, and grasshopper sparrow. While secure in most
of their natural range, these species exist in an uncertain
situation in Rhode Island and elsewhere in New England. The loss
of these individuals or populations probably would be irreversible
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34
in Rhode Island and could hamper conservation of some of these
species in the New England region.
A number of area-sensitive species would also be adversely
affected. These species typically require extensive tracts of land
for breeding and decline with habitat fragmentation and reductions
in forest patch sizes. Area-sensitive species most likely to be
eliminated as breeding species in the Big River watershed by the
proposed project include the northern goshawk (Accipter qentilis),
broad-winged hawk, red-shouldered hawk, barred owl, yellow-throated
vireo, northern and Louisiana waterthrushes, American redstart, and
Canada warbler (Appendix II). Because of continued urbanization
and fragmentation of natural habitats throughout New England, many
of these area-sensitive species that require large contiguous
tracts of land have declined in both range and number.
Loss of extensive riparian wetlands in the proposed site would
adversely affect the 35 bird species closely associated with
riverine ecosystems. Included among these are common forest and
edge species, and others that clearly depend on the aquatic-forest
interface. Because these latter species require aquatic habitat
and have a more restricted distribution, they succumb most quickly
to the hydrologic alterations of streams. These riparian edge
specialists include such species as American redstart, yellow
warbler, rufous-sided towhee, northern oriole, and indigo bunting.
In contrast, forest-dwelling riparian birds will be most affected
by activities that reduce the size of forests. This group includes
species such as the red-eyed vireo, wood thrush, acadian
flycatcher, tufted titmouse, and ovenbird (Brinson et al. 1981).
In addition to adverse impacts to state-listed, area-sensitive,
and riparian-associated species, birds with more general habitat
requirements would also suffer deleterious effects from the
proposed project. The forested wetlands and uplands of the
impoundment area which now provide breeding and foraging habitat
for many species of wading birds, ducks, raptors, woodpeckers, game
birds, and passerines would be largely destroyed. The area
currently provides breeding habitat for colonial nesting birds such
as herons, as well as snags for cavity nesting species such as
owls, woodpeckers, and many species of songbirds. The existing
vertical stratification of the vegetation and interspersion of
habitats which encourage substantial bird nesting, feeding, and
resting habitats would be eliminated. Further, the productive
upland and wetland tree species supply food for a substantial
population of herbivorous insects, which in turn provide a primary
food source for a diverse population of bird species. This is
particularly important to migratory species of waterfowl and
neotropical migrants such as warblers, which utilize the rich
insect fauna characteristic of these ecosystems during critical
migration and breeding periods. The project if constructed would
eliminate these critical habitat components in the impoundment
area.
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35
In summary, implementation of the proposed reservoir project would
eliminate habitat critical to the life cycles of many avian
species, decrease the ability of the area to support a large and
diverse avifauna, and force many bird species to abandon the area
for alternative habitats in surrounding areas with concomitant high
mortality. Additionally, the habitats of many state-listed,
area-sensitive, and riparian-associated species would be destroyed,
significantly impacting the conservation of these bird populations
locally and within the region.
Mammals. Construction of the proposed reservoir would destroy
substantial habitat for the 25 mammal species observed within the
project area. Once completed, the reservoir would provide sparse
habitat for aquatic mammals such as beaver, river otter, mink, and
muskrat because of the periodic drawdowns (3-6 feet) planned for
the reservoir. These aquatic mammals require relatively consistent
water levels to successfully establish dens and raise young.
Further, the frequency and magnitude of the drawdowns would
preclude development of emergent and aquatic vegetation zones that
provide necessary food and cover for muskrat and beaver.
The 15 mammal species associated with riparian wetlands would
suffer major impacts. These mammals are important in riparian
systems as part of the food chain and their ability to modify
wetland communities (e.g., beaver). The reservoir would either
eliminate or fragment the connected riparian habitats that mammals
use for travel within the watershed. Further, two state-listed
mammals reported to be in the area, the bobcat and fisher, are
considered area-sensitive species. These two species would be
eliminated from the project site and may be extirpated from the
management area due to the loss of secure interior habitat
(Appendix II).
The extensive riparian wetlands on the reservoir site support
abundant mammalian prey populations that contribute significantly
to food chain support in wetland and upland habitats. Small
mammals, such as mice, voles, and shrews, are important prey for
foxes, coyotes, minks, weasels, fishers, and bobcats, as well as
a variety of hawks and owls. Larger predators such as coyotes,
foxes, red-tailed hawks, and great-horned owls prey upon medium
size mammals, such as rabbits, raccoons, and opossums. The loss
of the abundant and diverse small and medium size mammal
communities on the project site will also adversely affect
mammalian and avian predator populations.
In summary, the removal of vegetation from the project site and
subsequent creation of the reservoir would destroy substantial
amounts of habitat for nearly all mammalian wildlife which occur
in the project area. The reservoir would severely impede the
dispersal, movement and migration of aquatic and terrestrial
mammals. Further, loss of the abundant small and medium size
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36
mammal communities of the reservoir site would have significant
adverse effects on avian and mammalian predator populations.
Herptiles. Destruction of the diverse wetland communities,
flooding of uplands, and loss of the interspersion of upland and
wetland habitats will devastate roost amphibian and reptile
populations on the project site. Of the 33 herptile species that
potentially occur within the project area, all but 4 species will
be either extirpated or severely reduced within the reservoir area.
With completion of the reservoir, only the snapping turtle
(Chelydra serpentina) and painted turtle are expected to increase
in numbers, and populations of the green frog and Fowler's toad are
projected to be unaffected (Appendix II). The proposed reservoir
would provide little habitat to support the other 30 amphibian and
reptile species now in the area. Moreover, the presence of fish
in the reservoir would increase predation on the few amphibian
species that may continue to use the margins of the reservoir.
These fish populations would sharply increase predation on
amphibians and their eggs.
All 7 state-listed species which occur on the project site would
be extirpated, including 2 salamander, 1 turtle, and 4 snake
species. The other 5 salamander species and 6 terrestrial snake
species would also be eliminated by the project. All frog and toad
species will be extirpated from the deep-water portions of the
reservoir except for the Fowler's toad, which is known to occur
only outside the impoundment area, and the green frog, which may
remain stable or increase. Additionally, the large periodic
drawdowns (3-6 feet) planned for the reservoir will inhibit the
establishment of emergent and aquatic vegetation in the littoral
zones, further reducing the potential habitat available for the
other 5 frog and toad species which breed in shallow, vegetated
aquatic zones.
Clearing of the vegetation and dead wood from the reservoir site
would eliminate breeding, feeding, and escape cover for all
herptile species. Further, inundation of the upland communities
would extirpate all 11 terrestrial snake and turtle species on the
reservoir site. Loss of the majority of seasonally flooded
riparian zones and small ponds in the watershed will significantly
reduce the availability of habitat for all amphibians and
semi-aquatic reptiles in the watershed as a whole. Since many
herptiles, especially amphibians, exhibit a strong fidelity to
their natal wetlands, additional populations that inhabit areas
adjacent to the reservoir may be eliminated or significantly
reduced due to loss of their breeding sites.
The loss of a significant proportion of the amphibians and reptiles
in the watershed would in turn adversely affect avian and mammalian
communities. Herptiles are important links in the food chain. For
example, herons, egrets, raptors, raccoons and other mammals, and
snakes eat frogs and salamanders. Snakes in turn are eaten by
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37
large wading birds, raptors, and fur-bearers. These complex food
chains also play a critical role in transferring energy from
wetland to upland systems. The capacity of the herpetofauna to
provide this food chain support would be markedly reduced with
construction of the proposed reservoir.
In summary, the proposed project would extirpate most of the
amphibian and reptile species that now occur within the reservoir
site, and significantly reduce the diversity and number of herptile
species utilizing the watershed. The interspersion of wetland and
upland habitats in the watershed would be destroyed, significantly
limiting availability of habitat for the few herptile species not
killed by the vegetation clearing and subsequent inundation.
Fish. The proposed impoundment would eliminate the stream trout
fisheries from the site (USFWS 1978; Appendix II). In the EIS main
report, the Corps states that the reservoir would support a warm
and cold water lake fishery. Elsewhere, however, the EIS states
that without stripping the organic materials from the basin, the
dissolved oxygen concentrations in the hypolimnion could become
anaerobic during summer stratification, thereby reducing or
eliminating the availability of cold, oxygenated water needed for
brook trout survival (Volume II, Appendix E) . The US Fish and
Wildlife Service determined that the impoundment may support a cold
water lake fishery only if the Corps removed the organic debris at
the site, especially the extensive organic soils (see Figure 9),
and devised a multiple outlet structure for releasing water.
Otherwise, the microbial populations in the pool area would consume
the organic soils, deplete oxygen levels, and cause anoxic
conditions in deeper levels of the waterbody during summer
stratification. The Corps indicated that it would remove only a
small section of the organic soils at the site (Corps, EIS, 1981,
Appendix E).
The record is unclear whether the Corps plan would remove enough
of the organic soils to support a self-sustaining cold water
fishery. The U.S. Fish and Wildlife Service believes that it would
not be adequate, and that there does not appear to be enough
available spawning habitat to promote self-sustaining cold water
populations. The FWS also believes that brook trout may be
eliminated from the watershed because of the loss of critical
spawning, rearing and refuge areas (Appendix II). It is certain
that cold water stream fisheries would be lost as a result of the
project, and EPA is not convinced that a cold water lake fishery
could be established in its place.
In addition, the dam would severely reduce downstream flows to
other important waterbodies with aquatic life. The Flat River
Reservoir provides the best warm water fisheries in the Pawtuxet
River basin, but it is showing some signs of eutrophication (RI
Water Res. Brd., 1986). The FWS concluded that the reduced water
budget would adversely impact fisheries in Flat River Reservoir.
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WETLANDS TO BE IMPACTED BY
THE BIG RIVER RESERVOIR
Area of
Direct Impact
Area of
Indirect Impact
VTH fKtucnm
-
-
_v^
- , FT
WETLAND IMPACT ACR1S
DIRECT IMPACT S75
INDI1ICT IMPACT 77>
TOTAL 1345
ltdncfd down>trcan water flowi:
45% leu How to Ike rill Href
lei er»oli.
34% leu flow lo the Souih Iraack of
Ike Pivlutt.
15% leu flow to tko malnile» ol
tkt Piwllltt.
LEGEND
H IISIIV011 BOUNDARY
(311 IT CONIOOt)
v STIIAMS
• Of LAND
W1TLAND VICITATION CLASSIS
• IOIISTID
D FO11STID/5C10I-SHIDI
D IMIIGINT
O IMIIGINT/SCIOI-SHOI
O SC1DI-SR1DI
• OPIN WATI1
B.la I. if. /rM> »«fi«»a! ft (Kntfi
;»«enlor» mtfl. friftrtt ty umiyi
• / im «irnl fkalf infill .
tun
i nt
03
l-(
fD
i-D
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39
The South Branch Pawtuxet and the mainstem Pawtuxet would also
lose as much as 40% and 15% of their flows, respectively (Corps,
EIS 1981). This would cause additional impacts to the fisheries
in the streams, especially the Pawtuxet River. FWS also indicates
that loss of flow to the Pawtuxet River could jeopardize any future
effort at restoring American shad (USFWS, 1978) .
Invertebrates. Clearing of vegetation and inundation of the Big
River Reservoir site would eliminate habitat for a significant
number of wetland and upland invertebrate fauna. The habitat of
at least one state-listed species, the buck moth, would be
destroyed. This species is found in the pitch pine community
within the reservoir site and represents one of the largest
concentrations of buck moths in the State. Further, two amphipod
species, Cranqonyx aberrans and Svnurella chamberlaini. unique to
the region, would also be extirpated or significantly reduced
within the reservoir area.
The U.S. Fish and Wildlife Service predicts that at least 9 genera
of mayflies (Ephemeroptera), 5 genera of dragonflies (Odonata), 2
genera of stoneflies (Plecoptera), 7 genera of beetles
(Coleoptera), 3 genera of caddisflies (Trichoptera), and 8 genera
of flies (Diptera) will be eliminated from existing lotic habitats
as a result of inundation. These aquatic insects are adapted to
lotic conditions and cannot be expected to survive in the
reservoir. Numerous other wetland macroinvertebrate taxa, such as
annelid worms, molluscs, crustaceans, and other insect groups will
also most likely be eliminated by the reservoir.
These diverse aquatic and terrestrial invertebrate fauna support
the ecosystem by serving as links in food chains and processing
dead organic matter, making it available to detrital food chains.
Aquatic invertebrates supply food to fish, waterbirds, and
amphibians. Wading birds and aquatic mammals such as river otters
eat large molluscs and crayfish; swarms of flying insects are
snapped up by fish, bats, and insectivorous songbirds. Terrestrial
invertebrates also provide an important food source for an array
of herptiles, small mammals, and birds. In addition to their
direct trophic role, many wetland and upland invertebrates play an
indirect role by decomposing and processing organic matter so that
it is available to detrital food chains and nutrient cycling.
In summary, the proposed project will severely deplete the existing
diverse aquatic and terrestrial invertebrate fauna. Further,
because of the magnitude and frequency of the planned drawdowns in
the proposed reservoir, few aquatic and emergent plant communities
will develop in the shallow areas of the reservoir. This will
further decrease both the diversity and abundance of the potential
invertebrate fauna in the completed reservoir. The reduction in
the number and diversity of invertebrates will result in less
available food for higher level consumers.
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40
Indirect and Secondary Impacts.7 The project would cause a number
of additional impacts beyond the direct loss of habitats within the
impoundment area (Figure 10). These adverse effects would be of
three main types. First, construction of ancillary facilities and
related project actions, such as the treatment plant, utilities,
tunnel shafts and roadway relocations, will directly impact
additional aquatic habitat. Second, as discussed earlier,
construction of the dam will adversely impact wildlife communities
within the watershed as a whole, especially for species which are
area sensitive or require large home ranges. Third, and possibly
most significant, construction of the dam and slurry wall will
disrupt the existing surface and groundwater hydrology. The slurry
wall is designed to intercept groundwater which now exits the
watershed and feeds Mishnock Lake and swamp. The dam, if operated
as currently proposed, would markedly reduce downstream flows to
the Flat River Reservoir and to wetlands adjacent to the South
Branch of the Pawtuxet River.
Relocating six highways, and building the treatment plant, water
transport tunnel and dewatering shaft will impact an additional 25
wetlands, including several of high value (RI Water Res. Brd.
unpub. data 1987). The Water Resources Board completed modified
Golet wildlife evaluations for 10 of these wetlands, resulting in
one score of "outstanding," four of "high value" and five of
"medium value." Neither the State nor the Corps has determined the
acreage of wetlands which would be affected by these activities,
so the extent of the impacts is uncertain.
The reservoir site and Big River watershed comprise a large
contiguous, natural vegetated habitat in a region of New England
where urban development dominates land use. The watershed has
remained relatively unaffected by habitat fragmentation and human
disturbance and so provides an unusual mosaic of habitats capable
of supporting large and diverse wildlife communities. In addition
to its direct impacts, the reservoir would fragment the watershed,
interrupt travel corridors and isolate habitat patches. These
effects diminish the overall wildlife value in the remainder of the
watershed and in other nearby areas (e.g., Mishnock swamp).
Species sensitive to these large scale effects - area sensitive
7 As originally conceived, the Big River reservoir was to be
operated in tandem with another impoundment constructed on the
upper Wood River. A number of commenters expressed concern that
the State may eventually intend to construct a dam on the Wood
river and that such an impoundment would cause serious
environmental and recreational impacts. Since neither the State
nor Corps currently proposes a Wood River dam, EPA Region I has
not evaluated the issue in this recommended decision. However,
based on the information currently available, construction of an
impoundment on Wood River would incur substantial adverse
environmental impacts.
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SOIL TYPES FOR WETLANDS
Wl THIN THE BIG RIVER
RESERVOIR
LEGEND
N STREAMS
ROADS
N RESERVOIR BOUNDARY
(300 FT CONTOUR)
• UPLAND
SOIL TYPES
D ORGANIC
• MINERAL
• OPEN WATER
SCALE APPROXIMATELY 1:36,000
DRAFT
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42
breeding birds and large terrestrial predators for example - would
suffer proportionately greater declines. Animals from the
impoundment area likely colonize and replenish the wildlife
population in surrounding habitats. By destroying the most
undisturbed and valuable habitat in the watershed, the reservoir
would eliminate this important function.
A slurry wall would be built along Division Road to prevent
reservoir leakage via infiltration into the groundwater. Since the
slurry wall would be built to bedrock, it may also interrupt a
major component of groundwater flow that replenishes the Mishnock
system (RI Water Res. Brd. 1986). The State proposed to maintain
water levels in Mishnock Lake by piping water from the reservoir.
However, there are no plans to mitigate the reduced flow of
groundwater to Mishnock swamp, a 500 acre forested wetland. This
may have significant consequences because Mishnock swamp is the
largest forested wetland block in the Pawtuxet River basin
providing habitat for interior wetland dependent species.
Although precise predictions about the impact of the slurry wall
are difficult without further study of the hydrology and biology
of Mishnock swamp, the State acknowledges that it could alter the
water table, dehydrate portions of the swamp and eventually cause
a significant loss of wetland habitat (RI Water Res. Brd. 1986).
Loss of water could reduce suitable habitat for the swamp pink, a
species of state concern, and other wetland dependent plants and
animals. Development surrounds Mishnock swamp, except for where
it is connected to wetlands along the South Branch of the Pawtuxet
River and the Big River site. Thus, the Big River dam would
isolate Mishnock swamp from adjacent habitat blocks, thereby
reducing its use as a travel corridor for area sensitive species.
The impoundment would affect the hydrology and biology of
downstream areas (effects on water quality are discussed separately
in Section C below). Previous studies have not considered the full
impacts of the Big River dam on the downstream flow regime (RI
Water Res. Brd. 1986) . For example, approximately 270 acres of
riverine wetlands, including 50 acres of emergent marshes, border
the Mishnock River and the South Branch of the Pawtuxet River.
Flows will be reduced over 40% at the start of the South Branch of
the Pawtuxet and 34% at the USGS gage station downstream of the
Mishnock River. Wetlands along the South Branch of the Pawtuxet
River form a rich mosaic of cover types. Extensive patches of
emergent dominated wetland types are noteworthy aesthetically,
recreationally, and for wildlife, especially waterfowl. Removing
over one-third of the water from these areas will likely result in
pronounced changes in these wetlands. Deprived of water, the
existing plant communities would become stressed and susceptible
to invasion by opportunistic species such as purple loosestrife
(Lythrum salicarial and Phraomites. Eventually, some downstream
wetlands could become upland.
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43
The impoundment would interrupt the export of nutrients and organic
matter to downstream areas. Destruction of the wetlands within the
impoundment would disrupt the pattern of energy flow and movement
of materials, causing adverse impacts to fish and wildlife
communities far removed from the reservoir site. These wetlands
function as transition zones between aquatic and terrestrial
systems and facilitate the exchange of material and energy to
nearby and downstream ecosystems. Placement of a dam on the Big
River would reduce energy export from the watershed and adversely
affect the food chain support for downstream fish and wildlife
communities. The impoundment would collect the majority of organic
detritus produced by the watershed and prevent it from reaching
downstream aguatic communities.
B) Recreation
The proposed reservoir would alter or eliminate many of the
recreational opportunities currently available within the Big River
management area, including fishing, swimming, hunting, river
canoeing, and nature observation. Some of the adverse impacts on
recreation are certain to occur. The extent of other impacts would
depend on whether existing state law and policy changes. The state
project does not include recreation as a component. Although the
Corps project envisions recreation, final decisions about
recreational uses will be made by the Rhode Island General Assembly
and the agency which operates and manages the impoundment (Corps,
EIS, 1981, Appendix C).
The Rhode Island Water Resources Board and the Providence Water
Supply Board have a policy which prohibits any recreation on
primary reservoirs and surrounding environs. (May 6, 1979 letter
in Corps, EIS 1981, Vol. II, Appendix C; Vol. Ill, Appendix H) .
Since the Providence Water Supply Board will manage and operate the
reservoir if it is built (Corps, 1981, EIS; P. Calise, 1988, Water
Resources Board, pers. comm.), it is likely that it would be
managed in the same manner as the Scituate Reservoir, i.e., no
recreation would be permitted. Although some state agencies have
recommended that some recreational uses be allowed at water supply
reservoirs, EPA is unaware of any effort underway to change state
laws or policies (SCORP 1986; DEM response to Corps, EIS, 1981,
Vol. II, Appendix C). Therefore, it appears that if the reservoir
were built, all of the recreational activities described in Chapter
III above would be eliminated from the entire 8,000 acre Big River
management area. Because of the possibility that such policies
will change, however, I have also evaluated the Corps' maximum
recreation option, Option III (Corps, EIS, 1981, Vol. Ill), in
assessing potential changes in recreation at the site.
The proposed impoundment would completely eliminate the cold water
stream fisheries from the site. As discussed earlier, while there
is a potential for a cold water lake fishery to be established, EPA
Region I is not convinced this will occur. The likelihood is that
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the cold water fisheries will be replaced with a warm water
fishery. Cold water fisheries are rare in Rhode Island, while
there appears to be little additional demand for warm water fishing
(SCORP 1986; RI Water Res. Brd. 1986; Appendix II). The Corps
would allow fishing at the impoundment under Option III. But,
since the Big River reservoir would be built next to Flat River
Reservoir, the best warm water fishery in the Pawtuxet River basin,
it is doubtful that the Big River impoundment would offer any warm
water fishing opportunities not already available at Flat River
Reservoir. Finally, there would be adverse impacts on the warm
water fisheries in Flat River reservoir because of reduced flows
and from more frequent drawdowns, upsetting circulation patterns,
changing nutrient recycling, and reducing overall biological
production. (USFWS 1978).
Swimming within the impoundment area would be lost entirely,
regardless of whether the State or Corps builds the dam, because
Rhode Island state law prohibits swimming on reservoirs and
tributaries to reservoirs (R.I.G.L. 46-14-1). Under Option III,
the Corps would allow swimming at some ponds within the management
area and would increase swimming opportunities at Flat River
Reservoir. However, since swimming can already occur in these
areas, and enhanced opportunities at these locations can be
achieved independent of whether a dam is built at Big River, the
Corps proposal is not sufficient to offset the loss of swimming the
impoundment would cause.
The impoundment would substantially diminish opportunities for
hunting, birdwatching, and nature observation. This is because
the project would destroy the most productive area for wildlife
and decrease available land for such activities by 3,400 acres.
FWS estimated that the impoundment would remove about 1/2 of the
wildlife management potential of the site. It would also fragment
an otherwise continuous stretch of habitat into many separate
patches, adversely affecting the wildlife that would otherwise be
associated with active and passive recreation.
River canoeing at the site would no longer be possible if the
reservoir were built. On the other hand, canoeing and boating
would be allowed at the impoundment under the Corps' proposal.
Although the Corps plan would probably increase boating because of
greater access to the site, it is important to note that the same
types of boating opportunities exist at nearby Flat River
Reservoir. There are no similar river canoeing opportunities
nearby.
Finally, the reservoir would adversely impact hiking, off-trail
bicycling, and horseback riding, by removing the middle portion of
the site and making at least 3,400 acres of open public land
unavailable for these activities.
Based on the impacts identified above, EPA Region I concludes that
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the Big River reservoir would likely cause significant adverse
impacts on recreational values at the site. Under any
circumstances, the following impacts would occur: cold water stream
fishing would be lost, and replaced with a more common warm water
fishery; fishing downstream at Flat River Reservoir would likely
be adversely affected; swimming would be eliminated from the
impoundment area; existing opportunities for hunting, hiking, and
horseback riding would be substantially reduced, along with the
opportunity to observe uncommon wildlife species less than 20 miles
from a major metropolitan area; and riverine canoeing would be
eliminated.
The Corps asserts that if it builds the reservoir, there would be
more recreation than what currently exists at the site. It is true
that boating and warm water fishing would increase if such
activities were permitted on the impoundment, although similar lake
fishing and boating are currently available 100 yards away at the
Flat River Reservoir. The other "improvements" would simply make
the site more accessible to the public with parking lots, trails,
boat ramps, and playing fields in the gravel pit area (Corps, EIS,
1981) . These actions would not offset the losses described above.
Moreover, better access can be achieved whether or not a reservoir
is built. Finally, regardless of any measures the Corps would take
to mitigate impacts on recreation, based on current state law and
policy, people would lose all recreational values of over 8,000
acres of State property.
C. Water Quality Impacts
The Pawtuxet River, one of the most polluted rivers in New England,
currently violates state water quality standards for dissolved
oxygen and toxics (metals). Over $60 million dollars has been
spent by EPA during the past 15 years attempting to clean the
river, and local communities must spend an additional $60 million
or more for advanced treatment in the coming years. The Big River
dam would dramatically reduce downstream water releases from an
average annual flow of 60 cfs to 6 cfs (4 MGD). Impounding all but
6 cfs would reduce flows into the Flat River Reservoir by 45%, into
the South Branch Pawtuxet by 34%, and into the mainstem of the
Pawtuxet River by 15%. This would undermine the expensive federal,
state and local clean-up efforts currently underway to enable the
river to achieve water quality standards. Several communities
expressed concerns to EPA during the comment period that the Big
River dam could negate the gains that would be realized from
investing in advanced wastewater treatment.
The adverse impacts of restricting flows would be most pronounced
during the summer months when downstream aquatic life is already
stressed by reduced water volumes, depressed levels of dissolved
oxygen, and elevated levels of metals. Sharply reducing water flow
causes problems besides increasing pollutant concentrations. Water
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46
depth and velocity decrease, reducing feeding and breeding areas
for aquatic life, and the temperature increases, causing greater
dissolved oxygen deficiencies. As described above, diminished
flows may adversely affect the wetlands along the South Branch of
the Pawtuxet River thereby reducing their value to aquatic life for
feeding and resting.
The proposed release of 4 MGD equals the calculated 7Q10 flow of
the Big River (i.e., the lowest flow for seven consecutive days
during a ten year period) . The 7Q10 flow represents an infrequent
and stressful condition that aquatic life cannot be expected to
withstand for an extended period of time. To avoid compounding
water quality problems during the summer and protect downstream
aquatic life, the dam would need to release a flow considerably
greater than the 7Q10. The U.S. Fish and Wildlife Service (1981)
calculated the minimum flow release to sustain aquatic life to be
18 cfs (12 MGD). Neither the State nor the Corps has indicated a
willingness to release water substantially above the 7Q10 since
this would mean a corresponding reduction in reservoir yield for
drinking water.
Precise water release requirements would require extensive water
quality modeling. One factor which complicates modeling, however,
is that the current owner of the Flat River Reservoir (Quidneck
Reservoir Company) claims a right to release no water downstream
if it so chooses (RI Water Res. Brd., 1986). In fact, rather than
augmenting downstream flows, the owner has a contract with Coventry
to retain water during the summer to maintain water levels in Flat
River Reservoir for recreation. Since the Big River Reservoir
would virtually halve the amount of flow into Flat River Reservoir,
it may prompt the owners of Flat River Reservoir to release even
less than the 7Q10 flows at times during the summer.
While reduction of flow most directly affects water quality, the
reservoir would have other effects as well. The value of the
wetlands within the impoundment area for contributing to base flow
by groundwater discharge and maintaining water quality will be
lost. The extent to which the reservoir will replace those
functions is unclear and would depend upon a number of factors
including time of year, contaminants in question and the manner in
which the impoundment is operated.
D. Mitigation
As described above, the project would replace a large area of prime
wildlife habitat with a shallow lake of value to only a few
species. The State did not submit a mitigation plan with its
permit application. The Corps, in its 1981 EIS, proposed several
structural and nonstructural measures to mitigate adverse impacts
including management of forests adjacent to the reservoir,
reclaiming a mined area and putting up some birdhouses. The Corps
proposed to mitigate the loss of wetlands chiefly by constructing
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47
"subimpoundments11 in the upper reaches of the reservoir in an
attempt to enhance or create wetland habitat. If fully successful,
these subimpoundments would contain about 90 acres of wetlands.
EPA Region I does not believe the adverse environmental impacts of
the reservoir proposal can be mitigated. To even attempt
meaningful replacement of the full spectrum of existing wetland
values would require a mitigation plan enormous in scope,
phenomenally expensive and so complex as to be infeasible from both
a scientific and practical standpoint. Even if a plan could be
devised which theoretically replaced wetland values, the Region
doubts it could be relied upon to prevent the unacceptable adverse
environmental impacts of this project given the inherent risks
associated with mitigation.
Recent studies in New England and elsewhere point to a number of
scientific and practical difficulties associated with mitigation,
especially wetland creation. The scientific base is too incomplete
to support any belief that artificial wetlands will provide the
functions of natural wetlands, let alone replace the diverse values
of the many hundreds of acres of wetlands that would be lost at
this site. Some wetland functions, such as flood storage, can
normally be replicated successfully. Attempts to mitigate wildlife
habitat losses have met with mixed success, and often benefit only
a few select species. There has been little demonstrated ability
to recreate on a broad scale other wetland values such as
groundwater discharge and recharge or the complex interactions of
water, soil and plants involved in the uptake and transformation
of nutrients and pollutants. Finally, it would be extremely
difficult, if not impossible, to replicate the important role Big
River system plays in the watershed (i.e., its landscape
attributes). The FWS has concluded that to "design and
successfully implement a compensation plan to replace the functions
and values lost...is clearly beyond the current state-of-the-art
in mitigation planning." (Appendix II)
After considering the project's impacts, unprecedented in New
England, and the poor track record of wetland creation and
enhancement projects to compensate for projects involving much less
severe impacts, I conclude that the adverse effects of the Big
River project cannot be adequately mitigated. In any case, the
mitigation scheme briefly described in the 1981 EIS could not begin
to compensate for the severe impacts to wildlife and other wetland
values which the Big River project would cause. Even if 90 acres
of subimpoundments could be successfully created and maintained,
they would largely involve manipulation of existing wetland
habitat. This would increase the value of these areas for select
wildlife species at the expense of others. It would not measurably
offset the impacts associated with the loss of 575 acres of
diverse, natural wetlands nor would it even attempt to address the
many secondary impacts the project would cause. Moreover, most of
the wetlands which the project would destroy are forested. The
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subimpoundments would provide little or no value for the many
species adapted to life in the forested systems.
E.
The Big River reservoir would disrupt aquatic ecosystems on a
massive scale. Nearly 600 acres of diverse and productive wetlands
would be immediately destroyed with potential long term adverse
impacts affecting more than 700 additional acres. Roughly 2500
acres of upland forests would be destroyed. Seventeen miles of
predominately cold water streams would be lost. These direct and
indirect impacts would sharply reduce the current outstanding
wildlife values of the site. The numbers and variety of birds,
mammals, fish, herptiles and invertebrates would all suffer major
declines. The reservoir would degrade water quality and by
depriving downstream areas of water. The project would
substantially reduce the extent and diversity of recreation
available in the impoundment and management areas.
I conclude that these adverse impacts are significant and violate
the §404(b)(1) guidelines. I reach this conclusion after examining
the quality and quantity of the affected aquatic ecosystems, the
direct and indirect effects and the persistence of the impacts.
I further conclude that significant adverse impacts would remain
even after all practical mitigation occurred. I believe that any
mitigation plan would fall far short of replacing the outstanding
values that would be lost to the project, let alone reduce the
impacts to a level which would comply with the §404(b)(l)
guidelines.
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V. ALTERNATIVES
In addition to evaluating the significance of the potential impacts
from the proposed reservoir, the Region has considered whether the
impacts are avoidable. The preamble to the §404(c) regulations
explains that:
one of the basic functions of 404 (c) is to police the
application of the section 404(b)(l) guidelines. Therefore,
those portions of the guidelines relating to alternative[s]
... may be considered in evaluating the unacceptability of
the environmental impact. ...Of course, even when there is
no alternative available, and "vetoing" the site means
stopping the project entirely, the loss of the 404(c)
resources may still be so great as to be "unacceptable."
44 Fed. Reg. 58076, 58078 (October 9, 1979).
The 404(b)(1) guidelines prohibit the discharge of dredged of fill
material if there is a practicable alternative to the discharge
which is less environmentally damaging to the aquatic environment.
40 C.F.R. §230.10(a). An alternative is practicable if it is
available and feasible in terms of cost, technology, and logistics
in light of the basic project purpose. In this case, the basic
project purpose of Big River reservoir is to satisfy future needs
for drinking water in the Greater Providence area.8
In order to evaluate the practicability of the Big River reservoir,
the Region first examined need for and cost of the project. As
described below and in Appendix III, this inquiry shows that there
is no demonstrated need for new sources of water. The Region
nevertheless went on to consider whether, even if a need did exist,
there are alternatives to meet that need. In so doing, the Region
examined the projected costs of water from the Big River reservoir,
in order to compare costs of otherwise feasible alternatives, and
evaluated a number of possible ways to increase water supplies.
Region I retained the services of Dr. John Boland, an expert in
the field of water supply planning and economics and professor of
* The State project is a water supply project only. The
Corps project would serve the additional purposes of providing
flood control and recreation. According to the EIS, construction
of the dam would not be economically justified for flood control
or recreation alone. Therefore, the Region focused its analysis
on alternatives to satisfy the water supply purpose.
Nevertheless, insofar as the Corps project would provide flood
control or recreation benefits, the Region concludes that they
can be achieved through less environmentally damaging
alternatives.
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Environmental Engineering at Johns Hopkins University, to assist
in the evaluation of the need for, and alternatives to, building
the Big River reservoir. His report is appended hereto as Appendix
III. Dr. Boland's analyses, and additional information in the
record, demonstrate that there is no established need for increased
water supplies within the planning period used by the Corps in the
Big River feasibility study (i.e., until the year 2030), and that
even if a need did exist, it could be satisfied through a variety
of practicable and less environmentally damaging alternatives.
A) Need for Water Supply
Prior to 1980, three major studies of future drinking water needs
in Rhode Island (Maguire, 1952; Metcalf and Eddy, 1967; RI
Statewide Comprehensive Transportation and Land Use Planning
Program, 1969) had recommended building the Big River reservoir to
meet anticipated shortfalls in future public water supply capacity.
In 1981, the Corps of Engineers completed the Big River feasibility
study. The Corps study area (Big River study area) consisted of
the service areas of the Providence Water Supply Board (PWSB),
Bristol County Water Authority (BCWA), and Kent County Water
Authority, with the PWSB supplying over 80% of the water. While
the Corps used a study area somewhat smaller than that used in the
earlier reports, it Corps also concluded that the reservoir was
needed. These studies greatly over estimated the need for drinking
water, and greatly under estimated the cost of building the
reservoir. (Appendix III).
The three earlier studies predicted that by 1990, the demand for
water would exceed the supply, and they recommended that Big River
reservoir be built immediately. The more recent Corps report
predicted that demand would exceed capacity by either 1997 (Corps,
EIS, 1981) or 2007 (Corps, 1982) and that the deficit would range
from 20 to 34 MGD by 2030. All of these studies relied on
population and per capita estimates to forecast future water needs.
Several factors explain why the studies over estimated need.
First, they projected population increases that were greater than
the State's actual population growth. Rhode Island's population
has remained essentially stable for the last decade (SCORP, 1986),
in contrast with the predictions in the previous studies. The
State indicated during the comment period that Rhode Island's
population has grown more rapidly in the last couple of years, but
the population is still considerably below the Corps' earlier
projections. Second, and more importantly, the per capita
assumptions which underlie the forecasts have been proven wrong.
Each of the studies assumed continued future increases in per
capita water use. Even though population growth levels in Rhode
Island were projected to be moderate, estimates of water use were
predicted to rise at a rapid rate. For example, the Corps
estimated that in 1975 people used Scituate water at a rate of 150
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gallons per capita per day (gpcd), and projected that in the year
2000 residential and commercial use would rise by another 20 gpcd.
The 1967 Metcalf and Eddy study had assumed an even faster increase
in the per capita rate.
These assumptions of water use trends directly conflict with
current information from Rhode Island and other areas across the
country, which shows that the average person uses the same or less
water today than 10 years ago (Appendix III). The Providence Water
Supply Board testified at a 1988 Public Utility Commission hearing
that per capita use in 1986 was 138 gpcd, and in 1987 was 124 gpcd,
or 17% below the Corps' estimate for 1975 (Mainelli, 1988). Other
estimates imply current average use rates in the range of 107 to
138 gpcd (Appendix III). Moreover, Rhode Island recently passed
a law requiring 1.5 gallon low flow toilets for all new
construction, renovation, and replacement purposes in the State.
This will further reduce the per capita use of water in the State,
since toilets account for the largest single indoor use of
household water.
Third, questionable assumptions related to industrial water use
underlie the need projections. For example, the Corps study relied
heavily on the Metcalf and Eddy data from the 1960's and did not
predict any decrease in industrial water use despite the effects
of the implementation of the 1972 Clean Water Act and its 1977
amendments. Pretreatment requirements have frequently resulted in
decreased industrial water use, especially .in the electroplating
and metal finishing industries. There are over 100 such facilities
in Rhode Island, and it is logical to assume that these as well as
other industries in the Providence area (Narragansett Bay
Commission, 1988), and have reduced their water consumption. The
Corps, however, projected industrial water use to grow faster than
any other sector of water use through 2030.
Fourth, the studies also underestimated the existing supply
capacity, which the Corps defined as the sum of the safe yields of
existing surface and ground water supplies. For example, the Corps
calculated a 1975 supply capacity based in part on an assumed safe
yield of 77 MGD for the Scituate system. Managers of the
Providence Water Supply Board (PWSB), however, have recently
estimated the safe yield of the Scituate to be 80.3 MGD, with an
additional 9 MGD for release downstream (Archer, 1988). This
additional yield would extend the use of existing water supplies,
as discussed below.
The Corps 1981 EIS predicted that demand would exceed supply in
1997 and that there would be a supply deficit of 34.1 MGD for the
Big River study area in the year 2030. However, revising the
underlying assumptions to reflect the best current information
shows that existing supplies will exceed demand until sometime
after 2030 (Appendix III):
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o PWSB estimates that the dependable yield of the Scituate
Reservoir is 89.3 MGD, and that 9.0 MGD must be released to
the River. This leaves an available yield of 80.3 MGD, 3.3
MGD higher than the 77 MGD used by the Corps.
o The Corps assumed that BCWA would shortly develop an
additional 3.0 MGD of ground water capacity. To date, no
additional wells have been drilled in Bristol County, and
there are no current plans to do so.
o The Corps estimated the dependable yield of the BCWA system
at 3.2 MGD. In 1989, a consultant for BCWA estimated yield
at 4.0 MGD, 0.8 MGD higher than the Corps assumption.
o Per capita use has not increased in the study area since
1975, and it is unlikely to do so in the future. In fact,
there has been a significant decrease in the PWSB area in the
last ten years. If per capita use is held constant at 1975
levels (more than 20 percent above the 1986 level reported
by PWSB), and if the Corps population projections are
accepted, projected residential and commercial water use for
2030 will be 21.5 MGD below the Corps forecast.
o The Corps offers no explanation for its projection of rapidly
increasing industrial water use. In fact, industrial water
use is decreasing throughout the U.S. If industrial use in
the study area is held constant at 1975 levels, the year 2030
projection will be 13.9 MGD below the Corps projection.
The effect of these adjustments is the following:
Dependable yield
Corps estimate 94.1 MGD
Addtl.Scituate yield + 3.3 MGD
BCWA ground water - 3.0 MGD
Addtl.BCWA yield +0.8 MGD
Total supply 95.2 MGD
Year 2030
Projected water demand
Corps, 2030 128.2 MGD
Stable per capita rates -21.5 MGD
Stable industrial use -13.9 MGD
Total water demand 92.8 MGD
Year 2030
2030 Surplus 2.4 MGD
These assumptions are highly conservative, because they: 1) use
Corps population estimates which over estimate growth; 2) assume
no decrease in per capita water use after 1975, despite evidence
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to the contrary; 3) use a dependable yield which is calculated at
a very high level of reliability (at approximately a 1.0 percent
level, as discussed below); and 4) do not include water use
reductions expected from recent pricing changes and new state
requirements governing new and replacement toilets (discussed
below).
Based on the record, EPA Region I concludes that previous
predictions by the Corps and others of a water supply deficit in
the Big River study area within the next twenty to forty years are
unfounded. Using conservative assumptions of supply and demand,
the Region believes that existing water capacity will be sufficient
to satisfy future needs at least through the year 2030. Therefore,
even without consideration of demand and supply alternatives, the
Region concludes that construction of Big River reservoir is
unnecessary in order to meet drinking water needs.
B) Cost of Big River Reservoir
EPA has reviewed the cost figures for the Big River reservoir in
order to assess the practicability of alternatives to the proposed
project. The cost of the project has escalated dramatically with
each study. The 1952 Maquire study estimated the reservoir would
cost $32 million (1989 dollars). The 1967 Metcalf & Eddy report
and the 1981 Corps study estimated the cost to be $92 million and
$210 million, respectively (1989 dollars). The most recent (1988)
cost estimates place the project at $282 million for construction
costs alone.
The average cost of water delivered from Big River reservoir would
exceed $9.14 per 1000 gallons, based on the latest construction
cost estimate of $282 million and yield estimate of 32 MGD
(Appendix III). The PWSB now charges about $.40 per 1000 gallons,
9 The Corps 1981 EIS assigned the project a positive
benefit/cost (B/C) ratio by the slimmest of margins (1.12 to 1).
Region I has not performed an update of the B/C analysis of the
project. However, since the cost of the reservoir has risen
while the benefits appear to have remained unchanged (or
decreased given the lack of need), an accurate B/C ratio would
likely be less than 1:1.
10 In addition, EPA believes that this figure is extremely
conservative because it underestimates the cost and overestimates
the yield. Costs for operation and maintenance, environmental
studies, wildlife mitigation efforts, recreation mitigation, and
a closed drainage system for 1-95 have not been added to the cost
figures. Moreover, the water yield from the Big River reservoir
would be substantially less than 32 MGD if the State releases
flows sufficient to protect downstream water quality (see
discussion in chapter IV on water quality).
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somewhat less for larger users. Hence, water from Big River
reservoir would cost over 2000% more than what Providence users
currently pay. The simple demand alternatives presented below
would cost only a fraction of what Big River reservoir would cost.
Almost any conservation alternative, as well as the supply
augmentation alternatives EPA considered, would be cost effective
compared to the expense of the Big River dam (Appendix III).
C) Demand Management
Demand management consists of measures that can be taken to
decrease water use, thereby allowing current supplies to meet
existing and future needs. These include pricing controls, various
forms of water conservation, and drought management programs. In
March, 1988, Rhode Island adopted its first water supply planning
document, entitled Water Supply Policies for Rhode Island. It
requires water utilities to adopt demand management measures,
including conservation, as an integral part of all water supply
planning. If properly applied, these policies will reduce the need
for future water supplies.
Pricing Policies. Since the amount of water used in any given area
depends, in part, on the price at which it is sold, increases in
the cost of water can lead to decreases in use (Appendix III) •
Prior to a 1988 price increase of 37%, Providence had one of the
lowest water rates of any city in the United States. Although its
rates are still relatively low, the recent price increase should
reduce water use in the Providence system alone by approximately
3.6%, within the next five to ten years. This would reduce year
2030 water use for the Big River study area by 2.8 MGD (Appendix
III).
The PWSB expects to make further changes in its rate design to save
additional water (Russell, 1988). Providence still employs
declining block rates, which allow larger water users to pay less
for water than small, mostly residential, users. This discourages
conservation and the use of non-potable water for many of the
larger industrial and commercial users. Changing this structure,
and adopting other rate design options such as uniform rates,
increasing block rates, summer surcharges, and excess use charges,
would likely result in conserving an additional 4% of water from
the PWSB distribution system, amounting to a reduction of 3.0 MGD
for the Big River study area (Appendix III).
Conservation. Water conservation methods unrelated to pricing
policies also have great potential in Rhode Island, because very
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few conservation programs exist.11 In general, the PWSB has not
seriously applied the water conservation mandates of the State's
recent water policy document. In 1988, the Rhode Island Public
Utilities Commission found the PWSB to have "no policy or
directives" on water conservation, "no public education program,"
"no program of technical assistance for water use reduction" for
any user class, and "no staff trained in, experienced with, or
devoted to conservation matters" (RI PUC, 1988, p. 33).
The water reductions which can result from long term water
conservation measures vary, depending on a number of factors,
including cost and thoroughness (Appendix III) . Predicted
reductions for Rhode Island range from 9% (Corps, 1982) to over 50%
(Metcalf and Eddy, 1979a, 1979b). A 50% reduction would postpone
the need for additional supplies for well over 100 years. Chernick
(1988) estimated that Rhode Island could reduce its residential
water use by 44% by retrofitting homes with low-flow toilets and
flow reducers in showers and faucets, saving over 20 MGD.
Hospitals, hotels, and schools, which use a substantial amount of
water in the Providence area, offer a large untapped potential for
water conservation. In Boston, Massachusetts, for example, the
Lenox Hotel recently reduced its water use by 40% by installing low
flow toilets, low flow showerheads and efficient faucet aerators
in its 220 rooms (Atkins, 1989). Ongoing leak detection and
repair could also save a substantial amount of water. The
Massachusetts Water Resources Authority, for example, expects to
save roughly 7 1/2% of current demand through leak detection (CLF,
p.18).
The State is making some advances in conservation. Rhode Island
Public Law 89-326, adopted January 1989, provides for the mandatory
installation of ultra-low flush toilets (1.6 gallons/ flush) in all
new and replacement construction. This law should save
approximately 15 - 20 gpcd (12% - 16%) in Rhode Island over the
next 30 - 40 years (Appendix III). Taking the Corps estimate of
585,000 people in the Providence area by 2030, between 8.7 and 11.7
MGD will likely be saved in the Big River study area by
implementing this new requirement. Additional water savings would
be possible much sooner by retrofitting toilets and other plumbing
fixtures in residential and commercial buildings. At least 5-8
gpcd can be saved by changing devices other than toilets, such as
showers, faucets, and appliances (Brown and Caldwell, 1984). Thus,
in the PWSB area, these changes would likely save between 2.9 and
11 In recent months, the Water Resources Coordinating
Council, overseeing the State study of water needs, began several
conservation demonstration projects and acquired water
conservation education material for distribution. An important
beginning, this water conservation effort is not yet part of the
water utility infrastructure in the State.
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4.7 MGD.
Water conservation techniques are available for industries as well.
One study has shown a potential for savings of up to 45% (CLF,
p.19). However, without better water supply management records,
it is difficult to estimate the potential water savings for
industries in Rhode Island. Industries could conserve drinking
water by using non-potable water for purposes such as cooling water
or machinery wash water. Indeed, Rhode Island water policy states,
"water of pristine quality is not necessary for non-potable uses,
and should not be committed to such uses if other alternatives
exist" (RI Division of Planning, 1988, p. 2.25). The State could
actively pursue its policy directive of matching water quality
needs with appropriate supplies by changing pricing policies for
large users and requiring industries to switch to non-potable water
or document why they cannot. Issuing matching grants to industries
for pumping and treatment costs may also prove cost effective.
Thirty-five years ago the Providence-Warwick aquifer supplied over
10 MGD for various industrial needs; today, however, businesses use
less than 2 MGD from the aquifer (USGS, 1989). Therefore, at
least 8 MGD of non-potable water is available to meet industrial
needs in Providence. The Corps estimates that industry uses
approximately 20% of Scituate's water, or, 13 MGD of drinking
water. If even half of the industries using non-potable water 30
years ago in the Providence area switch to non-potable water before
2030, approximately 4 MGD could be saved.
In summary, pricing changes and modest conservation measures, some
of which are already underway in the Providence supply area (80%
of the Big River study area), can be expected to result in water
use reductions by 2030 of 12-15 MGD. Other pricing changes and
conservation measures which could readily be adopted could save an
additional 9-13 MGD. Therefore, based on modest existing and
potential water conservation programs, the PWSB system could save
21-24 MGD. Additional reductions from more aggressive pricing and
conservation measures cannot be quantified at this time, but based
on experiences elsewhere, they could be much greater (Chernick,
1988; Metcalf & Eddy, 1979).
Drought Planning. Drought planning to reduce water use during dry
weather is another demand management technique which could reduce
the need for additional water supplies. Water supply planners
predict a safe yield for a water supply source based on a certain
risk of drought conditions. To respond to a drought, a community
can either rely on having available a very large amount of water
that it would normally not need or use, or use less water by
following a drought plan, or do both. However, it is highly
inefficient and generally impossible to have enough water for every
drought condition (Boland, 1988). Minor adjustments in lifestyle
during a low water year generally do not cause major inconveniences
(Appendix III).
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The PWSB bases the safe yield of the Scituate Reservoir (estimates
range from 72 to 89 MGD) on a 1% probability drought. In other
words, the Scituate Reservoir can produce approximately 80 MGD
during drought conditions expected to occur once every 100 years.
The PWSB indicates that 110 MGD is available in normal weather
years, although this may underestimate the yield which could be
realized (Appendix II).
The Corps, in the Big River feasibility study, apparently accepted
the State's reliability target of a 1% probability drought and did
not analyze the possibility of reducing water use, rather than
increasing supply, during periods of drought. Many utilities,
however, base their planning on a 2% - 3% drought risk criterion.
If the criterion were changed for the Scituate Reservoir, to a 3%
probability drought, statistically expected once in every 33 years,
its "safe yield" would increase by 20%, (17.9 MGD) to 98.2 MGD
(Appendix III) . Water use reductions of up to 23% would be needed
during the worst case drought, but reductions in this range could
be achieved through conventional drought management plans with no
more than moderate disruption and cost (Appendix III). For
example, during the drought in the 1960's in New England, water use
greatly decreased with little disruption, and Pawtucket, RI,
reported a reduction of 16-18% in its water use. California
reduced its water use 50% during the 1976-1977 drought (Appendix
III) .
Obviously, drought planning and management can have a substantial
effect on the safe yields of existing supplies, and hence the
projected need for new supplies. While savings are possible on an
ad-hoc basis, water supply planners typically prepare a drought
plan for reducing water use during unusually dry years.
Unfortunately, to EPA's knowledge, no utility in Rhode Island has
a drought plan, including the PWSB. Developing and implementing
a drought plan for the Scituate system alone could significantly
increase the effective yield of supplies in the Big River study
area (Appendix III).
In summary, demand management alternatives such as those described
above are clearly feasible, having been implemented in numerous
communities across the country. The alternatives discussed above
represent only some of the choices available to Rhode Island. A
more comprehensive analysis would likely derive additional options.
For example, more detailed knowledge of user groups and water
systems would allow further estimates of water saving by leak
detection and repair, industrial and commercial recycling, and
outdoor conservation techniques. While the exact cost of
implementing each of the strategies is difficult to quantify, they
are clearly less expensive than the cost of building and operating
the Big River reservoir (Appendix III). Individually, each demand
management alternative could offset a portion of the water from the
reservoir. Combined, they would produce more water than would the
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proposed project (see Table 2). In addition, these alternatives
would be far less environmentally damaging. Since they would
involve decreases in water use rather than creation of new sources
of water, they would not cause adverse environmental impacts.
TABLE 2: DEMAND MANAGEMENT ALTERNATIVES*
Amount of water (M6D)
Recent RI Program Changes:
1. changed plumbing codes for new construction 9-12
2. increased price for Scituate's water 3
Potential Programs:
1. additional changes in pricing structure 2-4
2. residential and commercial retrofit program
not including toilets 3-5
3. use of non-potable water for industry 4-?
4. other — education, fixing leaks,
outdoor uses, industrial assistance ?
Demand Management - Drought Plan
3% risk 18
Demand Management Total: 39-46
* Demand management is projected until 2030 for the PWSB area only.
Adoption of similar measures in other parts of the Big River
service area would lead to additional water savings.
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D) Supply Management
Supply management alternatives increase supplies rather than
decrease water use. Some of the possible alternatives, including
developing groundwater sources, improving existing surface water
yields, using impoundments together with groundwater, developing
unconventional water supplies, and avoiding abandonment of water
supplies are discussed below. EPA Region I has not analyzed each
of these alternatives in detail to identify precise yield
estimates, costs, logistical difficulties and environmental
impacts. When compared to the Big River reservoir, however, with
its tremendous costs and environmental consequences, it appears
likely that some or all of the measures described below would, upon
further analysis, prove to be practicable and less environmentally
damaging.
Groundwater. Rhode Island contains approximately 140 MGD of
groundwater, 113 MGD of which is available for use (Johnson, USGS,
1989). The USGS also indicates that the groundwater is generally
suitable for human consumption, with little treatment necessary.
Exceptions to high water quality include the Providence - Warwick
aquifer and possibly some areas along the Blackstone Valley and
localized areas of contamination.
Unlimited withdrawal of groundwater would be ill-advised, since it
could reduce surface stream flows and cause water quality problems
during drier times of the year. With proper management, however,
there appear to be at least 10-20 MGD of high quality groundwater
available for drinking water in the central portion of the State
(Appendix III). Additional groundwater is available in other parts
of the State, especially most of South County, which EPA recently
designated as a sole source aquifer requiring greater federal
protection. While transmission and pumping costs would be higher
than such costs for Big River reservoir, the well field
construction and treatment costs would be far less than the
construction costs associated with the reservoir project. With
proper well-head protection and measures to guard against
environmental impacts from excessive withdrawals, groundwater
development would appear to be a practicable alternative for
increasing water supplies.
One way to help prevent excessive groundwater removal during low
flow conditions would be to operate groundwater sources in tandem
with some of the 34 largest water impoundments and ponds in the
Pawtuxet River basin. Groundwater removal could occur during wet
weather seasons, when it would have less environmental impact on
downstream low water flows; during drier conditions, surface water
supplies could provide the majority of the water.
Increasing yields from existing impoundments. Another alternative
could be to increase the yields of current supplies through
improved management and to use existing impoundments not currently
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used for water supply. The Scituate system consists of five
reservoirs which drain into the two large branches of the Scituate
impoundment. The upstream reservoirs could be operated in tandem
with the main reservoir to maximize the yield of the entire
watershed and still protect downstream water quality. The State
could construct several gates just downstream of roadways crossing
the watershed, which could not only control flow but also increase
PWSB's ability to contain spills of hazardous materials in case of
an accident.
Some additional water supply could be obtained from the South
Branch Pawtuxet River basin by utilizing existing impoundments and
flood skimming (Appendix III). The basin contains over 10 ponds
and impoundments of significant size. Some of these might be
enlarged to store additional water during periods of high rainfall.
This excess water could be pumped to the Mishnock aquifer or the
Scituate Reservoir to increase their respective yields, similar to
what the Corps expected to do if Big River reservoir were built.
(Corps, EIS, 1981).
In addition, during wet periods, flood waters could be skimmed from
full reservoirs and transferred to other surface and groundwater
reservoirs for storage and use during drier seasons. This could
increase effective yields from existing systems. For example, the
State could skim floodwater from the Flat River Reservoir during
wet weather seasons without producing unacceptable changes in water
level (Appendix III). Monitoring would be needed to determine if
the water requires treatment in order to be potable. The wetlands
in Mishnock swamp could prove effective at reducing coliform levels
if the State were to pump Flat River water to the Mishnock aquifer.
Pumping and transmission facilities would be needed for the
skimming and transfer scenarios described above. In the absence
of detailed studies, it is impossible to determine the costs of
such options. When compared to the Big River reservoir costs,
however, any such alternative may be feasible if the construction
cost, not including pumping or other operating costs, does not
exceed $36 million/MGD (Appendix III).
Unconventional water supplies. There is no technological barrier
to producing drinking water from brackish water or seawater; the
only constraint is cost (Appendix III). During the last few
decades, desalination has become much more common, and its costs
have declined markedly (OTA, 1987). Indeed, the Congressional
Office of Technology Assessment recommends that desalination be
included "as a viable option in any evaluation of water supply
alternatives." (OTA, 1987, p.17).
There are several variables which influence the cost of
desalination. For example, up to 10 MGD of brackish water
containing less than 6,000 to 8,000 mg/1 total dissolved solids
(TDS) can be treated through desalination (reverse osmosis) to the
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level of drinking water in a facility costing about $10 million
(Taylor, 1989). If extensive pretreatment is required, however,
the cost could rise by $1 million to $8 million. Operation and
maintenance costs could be as low as $0.50 to $0.75 per thousand
gallons, but could rise to $1.15 to $1.75 per thousand gallons if
the pretreatment were required.
EPA could not find any information on brackish groundwater in Rhode
Island from shallow or deep wells. If such water is available
with less than 6,000 - 8,000 TDS, and pretreatment is not required,
then the construction and operating costs combined for desalinating
10 MGD would be approximately $1.00 per 1000 gallons (Appendix
III) . Water needing extreme pretreatment would cost approximately
$1.75 per 1000 gallons. This is cheaper than what Bristol County
Water Authority users currently pay and seven times less expensive
than the expected costs of water from Big River reservoir based on
capital costs alone. Therefore, if such brackish water were
available, its exploitation would appear to be a practicable
alternative.
Seawater containing up to 25,000 mg/1 TDS can be treated to produce
drinking water for about $10 - $11 per 1000 gallons, including
operating costs, depending on the quality and quantity of the raw
water and the alternatives for brine disposal (Taylor, 1989). This
is less than 20% higher than just the capital costs of the Big
River project (Appendix III) . If all of the expected costs of the
reservoir, such as operating and environmental mitigation costs,
were included in the comparison, it is highly likely that the
average unit cost for desalinated seawater would be less than the
average unit cost for the reservoir water. Detailed studies would
be needed to evaluate the existence of any logistical difficulties,
such as the availability of energy sources and disposal sites for
brine. Based on current information on cost and technology,
however, it appears that even desalination of seawater would be a
practicable alternative. With proper siting of withdrawal,
treatment, and disposal facilities, it would also be less
environmentally damaging than the Big River reservoir.
Avoid abandoning water supplies. The Bristol County Water
Authority (BCWA) currently plans to abandon its existing water
supplies, with a dependable yield of 4.0 MGD, and to tie into the
Providence system. Aquidneck Island may attempt to do the same
sometime in the future. The BCWA apparently bases its plan largely
on economic considerations (Appendix III). BCWA can purchase water
from the PWSB for $.30 per 1000 gallons. Although a new pipeline
would be required at a cost of $30 - $40 million, BCWA states that
this would cost less than the combination of upgrading the Child
Street Treatment Plant ($20 million), and expanding its existing
supply to meet future needs (approximately $30 million) (COM, 1989) .
Because the State plans to pay 50% of the pipeline costs (100% if
a bond issue passes this year), this plan is even more attractive
to the BCWA.
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BCWA's plan fails to consider the likely increases in the cost of
water from PWSB if the Big River reservoir were built. The average
unit cost of water if the treatment plant were upgraded would be
considerably cheaper than the cost of the Big River reservoir water
(Appendix III). To the extent that BCWA would need additional
supplies in the future, it already has the ability to purchase
supplemental water as needed from PWSB through the existing
connections in East Providence. These options appear to be viable
alternatives for the BCWA system to satisfy its needs without
resorting to Big River reservoir water. There may well be others,
such as desalination of brackish water.
BCWA's current plan, and the State's decision to help fund the
project, seem clearly to violate the state policy against
abandoning existing supplies (RI Division of Planning, 1988).
Moreover, the abandonment of the surface water supplies would
probably prove irreversible (Appendix III). Once abandoned,
continuing siltation, land use changes, and new reservoir
activities would likely preclude any future use of the surface
water sources for drinking water without significant treatment.
The total supply available in Rhode Island would be permanently
reduced, therefore, by the yield of these sources, currently about
4.0 MGD. However, if the supplies are not abandoned, and water
conservation and drought management are given a higher priority,
the needs of Bristol County would have minimal impact on PWSB's
future needs (Appendix III) .
In summary, there appear to be numerous ways in which the water
supplies in the Big River study area can be increased without
exacting the high environmental costs of the Big River reservoir.
Increasing the yield of existing systems, developing groundwater
resources, pursuing unconventional systems such as desalination,
and not abandoning existing supplies are all likely to be
practicable alternatives to the proposed reservoir.
E) Recreation and Flood Control
As explained above, the Big River reservoir is fundamentally a
water supply project. If built by the Corps, it would also
There has been some suggestion that the Big River
reservoir could also serve as a back-up water supply in case the
Scituate Reservoir becomes contaminated. Neither the State nor
the Corps has listed this aspect as a project purpose or benefit.
EPA Region I is unaware of any reservoir, let alone one which
would cause such serious environmental damage, that has been
constructed to provide a back-up water supply. Moreover, Big
River reservoir would be an odd choice for such a purpose, since
1-95 cuts through the middle of the impoundment area. In any
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provide some recreation and flood control. Since neither of these
secondary aspects would justify its construction apart from the
water supply purpose (Corps, EIS, 1981), it is unnecessary to
conduct a separate alternatives analysis for them. In any case,
the Region believes that there are ways to provide recreation and
flood control benefits which would be less environmentally damaging
than the proposed reservoir.
The Region has concluded that the reservoir would have an adverse
effect on existing recreation. Therefore, the no build alternative
would be preferable for recreation. The State could also choose
to further enhance recreation by providing better access and
information about the site.
Flooding of the mainstem of the Pawtuxet River does cause property
damage in several communities during large storms. Increased
urbanization, which causes flash run-off, and extensive development
in floodplain areas are the primary causes of the problem (Corps,
EIS, 1981). A dam at Big River could reduce some of the flooding
downstream on the Pawtuxet, but the benefits would be limited.
Unless the local communities adopt active floodplain protection and
control local urban runoff, the flood protection benefits of a Big
River dam would barely keep pace with increased urbanization and
additional development in the floodplain (Corps, EIS, 1981, Vol.
IV, Chapter 2). Each community could, for example, build detention
basins to control flash run-off from urbanization, which could
decrease peak floods, similar to wetlands. In addition, even the
Corps acknowledges that the Big River watershed represents only
about 13% of the total Pawtuxet River watershed, so that the flood
reductions on the main stem Pawtuxet resulting from a dam on Big
River would be "quite limited" (Corps, EIS, 1981, Vol. II, Appendix
D; Vol. IV, Appendix IV) . EPA also believes that the Corps has not
fully considered the flood protection values of the Big River
wetlands, and as a result overestimated the flood control benefits
of the dam.
In the EIS and in the 1987 re-analysis of flooding on the Pawtuxet
River, the Corps concluded that the Scituate Reservoir could
provide a significant modifying effect on flooding in the Pawtuxet
River (Corps, EIS, 1981, Vol. IV, Chapter 2; Corps, 1987). The
dams at Scituate and Flat River control 40% and 25% of the drainage
basin of the Pawtuxet River watershed, respectively, in contrast
to the Big River watershed, which comprises only 13% of the
Pawtuxet River watershed. Thus, there is clearly more opportunity
to control flood waters at the existing Scituate and Flat River
event, some of the alternatives to constructing the reservoir
could also serve as back-up supplies to Scituate. Finally, it is
likely that there are other alternatives to protect the Scituate
from becoming contaminated in the first place, or to restrict or
treat any contamination that does occur.
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reservoirs, and possibly at other downstream dams, in a way that
would not cause extensive environmental damage. These efforts,
coupled with serious urban flood control and floodplain management
by the communities along the Pawtuxet River, could achieve whatever
limited flood control benefits may be available from building the
Big River dam, with less environmental damage.
P) Summary
Based on the administrative record, I conclude that the impacts
from the Big River reservoir are avoidable. As stated above, the
record shows no demonstrable need for new supplies of drinking
water before the year 2030. Even if the Corps' most generous
predictions were to prove true, however, or if unforseen needs
develop in the future, ample information in the record shows that
there are numerous alternatives to building the proposed Big River
reservoir which are practicable and less environmentally damaging.
These options include demand management alternatives, such as
pricing changes, drought management and conservation; supply
alternatives, such as groundwater and increasing yields on existing
surface water supplies; or a combination of both demand and supply
alternatives. These alternatives appear to be less costly than the
proposed project, and would be far less environmentally damaging.
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VI. CONCLUSIONS AND RECOMMENDATION
The Big River impoundment area contains some of the finest wetlands
in Rhode Island. Numerous studies conducted at the site over the
past 13 years by a number of experts all confirm that the aquatic
habitats at the site support a rich array of wildlife including
mammals, birds, reptiles, amphibians and fish. Largely unspoiled
and comprised of a diverse mixture of habitat types, the Big River
watershed provides refuge for wildlife in a heavily developed
region of New England. In addition to being outstanding wildlife
habitat, the project site provides valuable recreational
opportunities uncommon in the area. The wetlands of the Big River
watershed also function to store floodwaters, recharge and
discharge groundwater, maintain water quality, and provide open
space.
The adverse impacts of the proposed reservoir would be indisputably
significant. If constructed, the reservoir would profoundly alter
the hydrology and biology of the watershed and drastically reduce
its value for wildlife and recreation. The immediate loss of 575
acres of wetlands and 17 miles of free flowing streams would be
unprecedented in New England. Moreover, the project could have
far-reaching indirect and secondary impacts including the possible
degradation of 700-800 additional acres of wetlands in Mishnock
swamp and downstream of the dam by reduced groundwater and surface
water flows. If operated as proposed by the State and Corps, the
dam would worsen downstream water quality and impede efforts
underway to clean up the Pawtuxet River. Many of those commenting
on EPA's proposal to prohibit this project spoke of their frequent
use and enjoyment of the Big River area for fishing, canoeing,
hiking and observing wildlife. Under existing state law and
policies, the project would completely deprive the public of these
important recreational opportunities. Even if the law and policies
change, the extent and diversity of recreation would be
substantially reduced.
To determine whether the significant adverse impacts to wildlife
and recreation could be avoided, I examined potential alternatives
to the Big River project. This in turn led me to review the
underlying assumptions and rationale on which the project rests.
Based on that analysis, I conclude that the need for the project
has not been established. Under very conservative assumptions, a
new water supply would not be needed until well into the next
century. However, even if a need for a new 30 mgd water supply
materialized sooner, I conclude that less environmentally damaging
practicable alternatives or combinations of alternatives are
available which would satisfy that need. Demand management
alternatives include modifying pricing policies, leak detection and
repair, plumbing code changes, drought planning and other
conservation measures. Increasing the proportion of non-potable
water used for power cooling, irrigation, and industrial purposes
can also increase potable water supplies. If implemented in
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combination these demand alternatives would provide more water than
the Big River reservoir would supply. Other alternatives which are
either practicable or warrant investigation include exploitation
of groundwater supplies (possibly with treatment as needed),
increasing the yield of existing surface water dams, avoiding
abandonment of existing water supplies and desalination. Most if
not all of these alternatives would cost less than the Big River
reservoir from both an environmental and economic standpoint.
The regulations implementing §404(c) define an unacceptable impact
to include "significant loss or damage to fisheries...or wildlife
or recreation areas" or as an impact which the "aquatic and
wetland ecosystem cannot afford." The §404(c) regulations direct
me to consider the relevant portions of the §404(b)(l) guidelines
in evaluating whether an adverse impact would be unacceptable. As
explained earlier in this document, I have concluded that the Big
River proposal does not comply with the §404(b)(l) guidelines on
two counts. First, the project would cause or contribute to
significant degradation of the aquatic environment in violation of
the guidelines. The Corps of Engineers and the U.S. Fish and
Wildlife Service agree. The 1981 EIS concedes that the project
would cause a significant disruption to the biological integrity
of the aquatic ecosystem and food chain. In 1988, the Corps
confirmed that the project could not comply with the §404(b)(l)
guidelines because of these significant impacts. Second, the Big
River proposal does not pass the "alternatives test" in the
guidelines since less environmentally damaging practicable
alternatives exist.
After fully considering the record in this case, I conclude that
these significant and avoidable impacts to wildlife and recreation
would be unacceptable under §404(c). The direct loss of 575 acres
of valuable wetlands and 17 miles of free flowing streams is in
itself unacceptable. Indeed, after considering the outstanding
value of the aquatic habitat at the site and the severity of the
adverse impacts, I do not believe the record could support any
other finding. The numerous indirect impacts the project could
cause, including the possible degradation of another 700-800 acres
of wetlands, reinforces my conclusion. As described above, the
impacts to wildlife are unnecessary and avoidable and I conclude
that the proposed reservoir is environmentally unacceptable on that
basis as well. With respect to recreation, I have examined both
the extent of the impacts and whether they are avoidable. Because
the project would cause substantial and avoidable adverse impacts
to recreation, I conclude they are unacceptable. Therefore, I
recommend that the discharge of dredged and fill material be
prohibited in Big River, Mishnock River, their tributaries and
adjacent wetlands for construction of the proposed Big River
reservoir and its ancillary facilities.
In formulating this recommendation, I carefully evaluated the
environmental values of the Big River system, its sensitivity to
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disruption and the adverse impacts a reservoir would cause. The
U.S. Fish and Wildlife Service and others submitted convincing and
well documented evidence of the value of the Big River project area
to wildlife, and the devastating impacts the project would cause
are undisputed in the record. I have also examined the need for
and alternatives to the project. While there has been some debate
about Rhode Island's present and future requirements for water, I
am satisfied that any need that does exist can be met at far less
environmental and economic cost than the proposed project. By
preventing significant and avoidable impacts to wildlife and
recreation, a final §404(c) action would enforce the requirements
of the §404(b)(l) guidelines, a function envisioned by the §404(c)
regulations.
, iff?
Paul G. Keough^ Date
Acting Regional Administrator
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REFERENCES
Anderson, Raymond W., 1967, "Pawtucket, Rhode Island, and the
Drought," J. American Water Works Association, vol. 81, no. 3
(March), pp. 301-303.
Archer, Wiley J., 1988, "Direct Testimony," before the Rhode Island
Public Utilities Commission, Docket No. 1900.
Arthur Young, 1986, "Bristol County Water Authority, Warren, Rhode
Island, Water Demand Analysis," Providence, RI.
Boland, John J., 1978, "Forecasting the Demand for Urban Water,"
in Holtz and Sebastian, eds., Municipal Water Systems: The
Challenge for Urban Resource Management, Bloomington, Indiana
University Press, pp. 91-114.
Boland, John J., 1983, "Water/Wastewater Pricing and Financial
Practices in the United States," MetaMetrics report MMI 19-83, a
report to the U.S. Agency for International Development,
Washington, D.C.
Boland, John J., 1988, "Direct Testimony," before the Rhode Island
Public Utilities Commission, Docket No. 1900, June 24.
Boland, John J., Benedykt Dziegielewski, Duane Baumann, and Chuck
Turner, 1982, "Analytical Bibliography for Water Supply and
Conservation Techniques," Institute for Water Resources Contract
Report 82-C07, U.S. Army Corps of Engineers, Fort Belvoir, VA.
Boland, John J., Benedykt Dziegielewski, Duane D. Baumann, and Eva
M. Opitz, 1984, "Influence of Price and Rate Structures on
Municipal and Industrial Water Use," Institute for Water
Resources, Contract Report 84-C-2, U.S. Army Corps of Engineers,
Fort Belvoir, VA.
Brinson, M., Swift, B., Plantico, R., and Barclay, J., 1981,
"Riparian Ecosystems: Their Ecology and Status," FWS/OBS/-81/17,
155pp.
Brown & Caldwell, 1984, "Residential Water Conservation Projects,"
report to U.S. Department of Housing and Urban Development by
Brown & Caldwell Engineers, Walnut Creek, CA.
Camp, Dresser & McKee, Inc., 1987, "Bristol County Water Authority,
Bristol County, Rhode Island, Water Distribution System Study:
Final Report," Boston, MA.
Camp, Dresser & McKee, Inc., 1989, "Bristol County Water Authority
Cross-Bay Pipeline Project Environmental Assessment," Boston, MA.
-------
69
Chernick, Paul L., 1988, "Direct Testimony," before the Rhode
Island Public Utilities Commission, Docket No. 1900.
Conservation Law Foundation (CLF), 1989 Comment letter.
Copeland, Basil L., Jr., 1988, "Direct Testimony," before the Rhode
Island Public Utilities Commission, Docket No. 1900, June.
Cowardin, L. M., V. Carter, F. C. Golet, and E. T. LaRoe. 1979.
Classification of wetlands and deepwater habitats of the U.S.
Biological Services Program, U.S. FWS, Washington, DC.
Dickson, D.R. and C.L. McAfee. 1988. Forest statistics for Rhode
Island—1972 and 1985. U.S. Dep. Agric., For. Serv., Northeast
For. Exper. Sta. Resour. Bull. NE-104. 96pp.
Dziegielewski, Benedykt, Duane D. Baumann, and John J. Boland,
1983b, "Prototypical Application of a Drought Management
Optimization Procedure to an Urban Water Supply System," Institute
for Water Resources Contract Report 83-C-4, U.S. Army Corps of
Engineers, Fort Belvoir, VA.
Golet, F. C. 1973. Classification and evaluation of freshwater
wetlands as wildlife habitat in the glaciated northeast. Proc.
Northeast Fish and Wildlife Conference. 30:257-279.
Golet, F. C. 1976. Wildlife wetland evaluation model. In Models
for assessment of freshwater wetlands. J. S. Larson editor. Pub.
No. 32. Water Resources Research Center, University of Mass.,
Amherst.
Grisham, Alice, and William H. Fleming, 1989, "Long-Term Options
for Municipal Water Conservation," J. American Water Works
Association, vol. 81, no. 3 (March), pp. 34-42.
Johnston, Herbert E., 1989, letter to V. Laszewski, US EPA,
w/attachments, July 7, 7 pp.
KA/ME. November 1984. Big River Water Supply Project Phase II
report-design development. Keyes Associates, Providence, RI and
Metcalf and Eddy, Inc., Boston, MA.
KA/ME. August 1982. Big River Water Supply Project preliminary
engineering investigations - Phase I. Keyes Associates,
Providence, RI and Metcalf and Eddy, Inc., Boston, MA.
KA/ME. November 1976. Preliminary inventory of vegetation,
wildlife, and aquatic biota in Big River study area. Keyes
Associates, Providence, R.I. and Metcalf and Eddy, Inc., Boston,
MA.
-------
70
Keyes Associates/Metcalf & Eddy, Inc., 1988, letter with
attachments: 80% cost estimates for Cutoff Wall and Dike, Big
River Project, December 30, 5 pp.
Lang, S.M., 1961, "Appraisal of the Ground-Water Reservoir Areas
in Rhode Island," US Geological Survey, Rhode Island Geological
Bulletin No. 11.
Larson, J.S. and R.B. Newton, 1981. The Value of Wetlands to Man
and Wildlife. Publication No. 125. Department of Forestry and
Wildlife Management, University of MA, Amherst.
C.A. Maguire & Assoc., 1952, Report on the Water Resources of the
State of Rhode Island, Providence, RI, January.
Mainelli, Domenic J., 1988, "Direct Testimony," before the Rhode
Island Public Utilities Commission, Docket No. 1900.
Mass. Cooperative Fishery Research Unit. July 13, 1979. Big River
Reservoir. University of Mass., Amherst, Mass. (unpublished).
Metcalf & Eddy, Inc., 1967, "Report to the Water Resources
Coordinating Board, State of Rhode Island, on a Development Plan
for the Water Supply Resources of Rhode Island," Boston, MA, June
30.
Metcalf & Eddy, Inc., 1979a, "Water Supply Alternatives: Main
Report, Volume I," a report prepared for the New England Division,
US Army Corps of Engineers, Boston, MA, January.
Metcalf & Eddy, Inc., 1979b, "Water Supply Alternatives: Technical
Appendixes, Volume II," a report prepared for the New England
Division, US Army Corps of Engineers, Boston, MA, January.
Miller, D. and Getz, L., 1977. Factors influencing local
distribution and species diversity of forest small mammals in New
England. Can. J. Zool., 55:806-814
Narragansett Bay Commission, 1988, Industrial Pretreatment Program
Annual Report, October 1988.
Niering, William A., and R. Scott Warren. 1980. Salt Marsh Plants
of Connecticut. Bulletin No. 25, The Connecticut Arboretum,
Connecticut College, New London, CT 32 pages.
Normandeau Associates, Inc. 1979. Aquatic ecosystem assessment
report. In COE. 1981. Big River Reservoir project interim report.
Vol. III. New England Division, Waltham, MA.
Providence Water Supply Board, 1986, "Annual Report to the Public
Utilities Commission for the Year ending June 30, 1986,"
Providence, RI.
-------
71
Rhode Island Department of Environmental Management. 1988. Ocean
state outdoors: recreation and conservation strategies for Rhode
Island wetlands amendment. Providence, RI. 69pp.
R.I. Department of Environmental Management, Office of
Environmental Coordination, 1987. Pawtuxet River Basin, Non-point
water quality standards review and management plan.
R.I. Department of Environmental Management, Division of Water
Resources. 1985. Rhode Island water quality regulations for
water pollution control, section 6—water quality standards.
Rhode Island Statewide Comprehensive Transportation and Land Use
Planning Program, 1969, "Plan for the Development and Use of
Public Water Supplies," Report No. 10, Providence, RI, September.
Rhode Island Public Utilities Commission, 1988, "Report and Order,"
Docket Number 1900.
Rhode Island Water Resources Board. 1986. Environmental Services
for the Big River Water Supply Project. Phase I Rept., Vol.
l-Existing Conditions. Camp Dresser and McKee, Inc.
Robie, Ronald B., 1978, "California's Program for Dealing With
Drought," J. American Water Works Association, vol. 70, no. 2
(February), pp. 64-68.
Russell, Clifford S., David G. Arey, and Robert W. Kates, 1970,
Drought and Water Supply, The Johns Hopkins Press, Baltimore, MD.
Russell, David F., 1988, "Direct Testimony," before the Rhode
Island Public Utilities Commission, Docket No. 1900.
Smith, D.G. 1987. The genus Synurella in New England (Amphipoda
cranagonyctidae). Crustaceana 53(3):304-306.
Swift, B. L., 1980. Breeding Bird Habitats in Forested Wetlands
of West-Central Massachusetts. M.S. Thesis, Univ. of Mass.,
Amherst. 90pp.
Taylor, J. S., 1989. September 26, 1989 letter to M. Kern, EPA,
4 pp.
U.S. Army Corps of Engineers, 1981, New England Division, "Big
River Reservoir Project: Volume I, Main Report," Waltham, MA,
July.
U.S. Army Corps of Engineers, 1981, New England Division, "Big
River Reservoir Project: Interim Report," Volume II, Waltham, MA,
July.
-------
72
U.S. Army Corps of Engineers, 1981, New England Division, "Big
River Reservoir Project: Interim Report," Volume III, Waltham, MA,
July.
U.S. Army Corps of Engineers, 1981, New England Division, "Big
River Reservoir Project: Interim Report," Volume IV, Waltham, MA,
July.
U.S. Army Corps of Engineers, 1982, New England Division, "Sup-
plemental Report to July 1981 Interim Feasibility Report and Final
Environmental Impact Statement," Waltham, MA, February, 31 pp.
U.S. Fish and Wildlife Service, 1978, Planning Aid letter,
November.
U.S. Fish and Wildlife Service, 1981, Comments on Draft EIS letter,
April.
U.S. Fish and Wildlife Service. 1989. Comments to U.S.
Environmental Protection Agency on proposed Big River Reservoir
project from Vernon B. Lang, Concord, NH. Dated July 28, 1989.
Enclosed as Appendix I.
U.S. Fish and Wildlife Service. 1979. U.S. Fish and Wildlife
coordination act report. Big River Reservoir project. In COE.
1981. Big River Reservoir interim report. Vol. III. New England
Division, Waltham, MA.
U.S. Geological Survey, 1987, National Water Summary 1986, Water
Supply Paper 2325, Washington, DC, pp. 443-448.
University of Rhode Island. 1984. Wetlands and deepwater
habitats of the Big River watershed: Inventory and wildlife
evaluation. Wetlands and land use class (FOR 424) . Dept. Nat.
Res. Science, University of R.I.
Wheeler, Bradford A., 1989, "Pawcatuck Basin Ground Water Reservoir
(PBGWR)," Hope Valley, RI, March 9, 8 pp.
Wilkinson, D.L., K. Schueller-McDonald, and G.T. Auble. 1987.
Synopsis of wetland functions and values: bottomland hardwoods
with special emphasis on eastern Texas and Oklahoma. U.S. Fish
Wildl. Serv. Biol. Rep. 87(12). 132pp.
-------
APPENDIX I
-------
Appendix I: Birds
BIRDS OF THE BIG RIVER STUDY AREA
(SOURCES: MODIFIED FROM CORPS, 1981; BY
OBSERVATIOS AND THE RI NATURAL HERITAGE PROGRAM,
COMMON NAME
STATUS
ASSOCIATED
WITH WETLAND
HABITAT
1989)
OBSERVED
Common Loon
Pied-billed grebe
Canada goose
Mallard
Black duck
Pintail
Gadwall
American wigeon
Shoveler
Blue-winged teal
Green-winged teal
Wood duck
Redhead
Canvasback
Ring-necked duck
Lesser scaup
Bufflehead
Ruddy duck
Hooded merganser
Common merganser
Goshawk*
W
M
A
A
A
M
M
M
M
M
M
B
M
M
M
W
M
M
W
A
WP
WP
WP
WR
WR
WP
WP
WP
WP
W
W
WR
WP
W
WP
W
W
W
W
WP
X
X
X
X
X
Status: B - breeding;
A - all seasons
- winter use; M - migratory;
Associated with wetland habitat:
WR: Riparian-dependent or associated species
(Brinson et al., 1981).
WP: Wetland preferred species (RI Heritage Program, 1989;
DeGraaf and Rudis, 1983).
W: Regularly uses wetlands during part of its life cycle
(RI Heritage Program, 1989, DeGraaf and Rudis, 1983) .
*: area sensitive species
+: State or federal-listed species: either a state
threathened species or a rare and vulnerable species
which may become threathened if current trends persist.
X: Observed in study area
-------
Appendix I: Birds (Continued)
COMMON NAME STATUS
Cooper's hawk*+ A
Sharp-shinned hawk A
Marsh Hawk B
Red-tailed hawk B
Red-shouldered hawk* B
Broad-winged hawk* B
Bald eagle*+ WM
Osprey*+ M
Peregrine falcon*+ M
Merlin M
Kestrel A
Ruffed grouse* A
Yellow-billed cuckoo* B
Black-billed cuckoo B
Screech owl A
Great horned owl A
Long-eared owl A .
Barred owl A
Saw-whet owl A'
Whip-poor-will B
Common nighthawk M
Chimney swift B
Ruby-throated humingbird B
Belted kingfisher B
Common flicker* A
Pileated woodpecker A
Red-headed woodpecker B
Yellow-bellied sapsucker M
Hairy woodpecker* A
Downy woodpecker* A
Eastern kingbird B
Great-crested flycatcher* B
Eastern phoebe* B
Yellow-bellied flycatcher B
Alder's flycatcher M
Least flycatcher B
Willow flycatcher B
Acadian flycatcher** B
Eastern wood pewee* B
Olive-sided flycatcher M
Horned lark + A
Barn swallow B
Cliff swallow M
Tree swallow B
Bank swallow B
Rough-winged swallow B
Purple martin B
ASSOCIATED
WITH WETLAND
HABITAT
W
W
W
WR
WR
WP
W
W
W
W
WR
W
WP
W
W
WP
WP
W
W
WR
W
W
W
WR
WR
WR
WR
W
WP
WP
W
WP
WR
WR
W
W
WP
W
WP
W
WP
W
OBSERVE
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
Appendix I: Birds (Continued)
COMMON NAME STATUS
Blue jay* A
Common Crow* A
Black-capped chickadee* A
Tufted titmouse* A
White-breasted nuthatch* A
Red-breasted nuthatch* A
Brown creeper* A
Wild Turkey A
Bobwhite A
Ring-necked pheasant A
Great blue heron BW
Green heron B
American bittern M
Virginia rail . B
Sora B
Common gallinule M
American coot M
American golden plover M
Black bellied plover M
Killdeer B
Upland sandpiper + B
Solitary sandpiper M
Spotted sandpiper B
Greater yellowlegs M
Lesser yellowlegs M
Short-billed dowitcher M
Pectoral sandpiper M
Bairds sandpiper M
Least sandpiper M
Semipalmated sandpiper M
American woodcock B
Common snipe M
Herring gull M
Ring-billed gull M
Great black-backed gull W
Rock dove A
Mourning dove A
House wren B
Winter wren + B
Carolina wren A
Long-billed marsh wren M
Blue-gray gnatcatcher* B
Mockingbird A
Catbird* B
Brown thrasher B
Robin A
ASSOCIATED
WITH WETLAND
HABITAT
W
W
W
WP
W
W
W
WR
W
W
WP
WP
WP
WP
WP
W
WP
W
W
WR
W
WR
W
W
W
W
W
W
W
WR
WP
W
W
W
WR
WR
W
W
W
W
W
WR
W
WR
OBSERVE
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
Appendix I: Birds (Continued)
COMMON NAME
STATUS
ASSOCIATED
WITH WETLAND
HABITAT
OBSERVE
Wood thrush* B
Hermit thrush* B
Swainson's thrush M
Gray-cheeked thrush M
Veery* B
Eastern bluebird B
Golden-crowned kinglet A
Ruby-crowned kinglet M
Water pipit M
Cedar waxwing A
Starling A
Solitary vireo B
White-eyed vireo* B
Yellow-throated vireo* B
Red-eyed vireo* B
Philadelphia vireo M
Warbling vireo B
Black-and-white warbler* B
Worm-eating warbler*-*- B
Golden-winged warbler M
Blue-winged warbler B
Tennessee warbler M
Nashville warbler B
Parula warbler M
Yellow warbler B
Magnolia warbler M
Cape May warbler M
Myrtle warbler B
Black-throated
green warbler* B
Black-throated
blue warbler M
Yellow-ramped
warbler B
Blackburnian warbler + B
Chestnut-sided warbler B
Bay-breasted warbler B
Blacpoll warbler M
Cerulean warbler + M
Prothonotary warbler M
Pine warbler B
Prairie warbler B
Palm warbler M
Ovenbird* B
Northern waterthrush* B
Louisiana waterthrush* B
WR
W
WP
W
W
WR
W
W
WP
WR
WP
W
W .
W
W
W
WR
W
W
W
W
WP
WP
WP
WR
WP
WP
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
Appendix I: Birds (Continued)
COMMON NAME
STATUS
ASSOCIATED
WITH WETLAND
HABITAT
OBSERVE
Yellowthroat* B
Yellow-breasted chat M
Mourning warbler M
Hooded warbler B
Wilson's warbler M
Canada warbler* B
American redstart* B
House sparrow A
Bobolink B
Eastern meadowlark B
Red-winged blackbird B
Rusty blackbird B
Common grackle A
Brown-headed cowbird A
Orchard oriole B
Northern oriole B
Scarlet tanager* B
Cardinal* A
Rose-breasted grosbeak* B
Evening grosbeak
Indigo bunting B
Purple finch A
House finch A
Pine grosbeak W
Common redpoll W
Pine siskin W
Rufous-sided towhee* B
Savannah sparrow B
Grasshopper sparrow + B
Vesper sparrow B
Slate-colored junco A
Tree sparrow W
Chipping sparrow B
Field sparrow A
White-crowned sparrow M
White-throated sparow + A
Fox sparrow M
Lincoln's sparrow M
Swamp sparrow B
Song sparrow A
Snow bunting M
American goldfinch* A
WR
WP
WP
WP
W
WR
W
WR
WP
W
W
W
WR
WR
W
W
WR
X
WR
W
W
W
W
W
W
W
WR
WP
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
Appendix I: Mammals
MAMMALS OF THE BIG RIVER STUDY AREA
(SOURCES: MODIFIED FROM CORPS, 1981; BY OBSERVATIONS
THE RI NATURAL HERITAGE PROGRAM, 1989; AND U.S. FWS, 1989)
COMMON NAME
Opposum
Masked shrew
Water shrew*
Smoky shrew*
Short-tailed
shrew
Star-nosed mole
Little brown
myotis
Keen's myotis
Silver-haired
bat
Eastern
pipistrel
Big brown bat
Red bat
Hoary bat
Raccoon
Fisher*
Ermine
Long-tailed
weasel
Mink
Striped skunk
River otter
Coyote
Red fox
Gray fox
Bobcat*
Eastern
chipmunk
Woodchuck
Gray squirrel
SCIENTIFIC NAME
Didelphis virainiana
Sorex cinerus
Sorex palustris
Sorex fumeus
Blarina brevicauda
Condvlura cristata
Mvotis lucifuaus
Mvtotis keeni
Lasionycterus noctivaaans
Pipistrellus subflavus
Eptesicus fuscus
Lasirus borealis
Lasirus cinereus
Procyon lotor
Martes pennanti
Mustela erminea
Mustela frenata
Mustela vison
Mephitis mephitus
Lutra canadensis
Canis latrans
Vulpes vulpes
Urocvon cinereoarcrenteus
Lynx rufus
Tamias striatus
Marmota mona
Sciurus carolinensis
Tamiasciurus hudsonicus
ASSOCIATED
WITH
WETLAND
HABITAT OBSERVED
WP
WP
WR
WP
WR
WP
WP
WP
WP
WP
WP
W
W
WR
W
W
WP
WR
WR
WR
W
W
W
W
Red squirrel
Southern
flying squirrel Glaucomys volans
Beaver Castor canadensis
WR
W
WR
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
Appendix I: Mammals (Continued)
COMMON NAME
White-footed
mouse
Boreal red-
backed vole
Meadow vole
Pine vole
Muskrat
Southern bog
lemming*
Black rat
Norway rat
House mouse
Meadow jumping
mouse
Woodland jumping
mouse*
Porcupine
Eastern
cottontail
New England
cottontail
Snowshoe hare
White-tailed
deer
SCIENTIFIC NAME
Peromvscus leucobus
Clethrionomys gapperi
Microtus pennsylvanicus
Microtus pinetorum
Ondatra zibethicus
Synaptomys cooperi
Rattus rattus
Rattus norveqicus
Mus domesticus
Zapus hudsonius
Napoeozapus insignis
Erethizon dorsatum
Sylvilagus floridanus
Sylvilagus transitionalis
Lepus americanus
Odocoileus virginiana
ASSOCIATED
WITH
WETLAND
HABITAT OBSERVED
WR
WR
WR
WP
WR
WR
W
WP
WR
WP
WR
X
X
X
X
X
X
Associated with wetland habitat:
WR: Riparian wetland-dependent or associated species
(Brinson et al., 1981).
WP: Wetland preferred species (RI Heritage Program, 1989;
DeGraaf and Rudis, 1983) .
W: Occasionally uses wetlands during part of its life cycle.
*: State listed species
X: Observed in study area
-------
Appendix I:
Herptiles of the Big River Management Area
(USFWS 1989) .
Common Name
Scientific Name
Salamanders
Marbled salamander*x
Spotted salamander*
Red-spotted newt*
Northern dusky salamander*
Redback salamander
Four-toed salamander*x
Ambystoma opacum
Ambystoma maculatum
Notophthalmus v. viridescens
Desmoanathus f. fuscus
Plethodon cinereus
Hemidactvlium scutatum
Northern two-lined salamander*Eurvcea b. bislineata
Frogs and Toads
Eastern American toad*
Fowler's toad*
Northern spring peeper*
Gray treefrog*
Bullfrog*
Green frog*
Wood frog*
Pickerel frog*
Turtles
Common snapping turtle*
Stinkpot*
Spotted turtle*
Wood turtle*x
Eastern box turtle
Painted turtle*
Red-eared slider*
Snakes
Northern water snake*
Northern brown snake
Northern redbelly snake x
Eastern garter snake
Eastern ribbon snake x
Northern hognose snake
Northern ringneck snake x
Eastern worm snake
Northern black racer
Eastern smooth green snake
Eastern milk snake
Bufo a. americanus
Bufo woodhousii fowleri
Hyla c. crucifer
Hyla versicolor
Rana catesbeiana
Rana clamitans melanota
Rana sylvatica
Rana palustris
Chelvdra s. serpentina
Sternotherus odoratus
Clemmvs guttata
Clemmvs insculpta
Terrapene c. Carolina
Chrysemvs picta
Pseudemvs scripta
Nerodia s. sipedon
Storeria d. dekavi
Storeria o. occipitomaculata
Thamnophis s, sirtalis
Thamnophis s. sauritus
Heterodon platvrhinos
Diadophis punctatus edwardsi
Carphophis a. arooenus
Coluber c. constrictor
Opheodrvs v. vernalis
Laropropeltis t. triangulum
* - Aquatic or wetland-dependent species.
x - State listed species
-------
Appendix I: Fish Observed Big River Site
1. Brook trout
2. Redfin pickerel
3. Chain pickerel
4. Bridle shiner
5. Fallfish
6. White sucker
7. Creek chubsucker
8. Brown bullhead
9. Pumpkinseed Sunfish
10. Langmouth bass
11. Swamp darter
12. Bluegill
Salvelinus fontinalis
Esox aroericanus
E_s. nicrer
Notropis bifrenatus
Semotilus corporalis
Catostomus commersoni
Erimvzon obloncrus
Ictalurus nebulosus
Lepomis gibbosus
Micropterus salmoides
Etheostoma fusiforme
Lepomis macrochirus
1. Redfin pickerel
2. Chain pickerel
3. Bridle shiner
4. Creek chubsucker
5. Pumpkinseed sunfish
6. Yellow perch
7. Banded sunfish
8. Largemouth bass
9. Swamp darter
10. Smallmouth bass
Esox americanus
E. niaer
Notropis bifrenatus
Erimyzon oblongus
Lepomis qibbosus
Perca flavescens
Enneacanthus obsesus
Micropterus salmoides
Etheostoma fusiforme
Micropterus dolomieni
Source: Corps EIS, 1981
University of MA, 1979
-------
APPENDIX II
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
400 RALPH PILL MARKETPLACE
22 BRIDGE STREET
CONCORD, NEW HAMPSHIRE 03301-490
Mr. Michael R. Deland
Regional Administrator
U.S. Environmental Protection Agency
JFK Federal Bldg.
Boston, Massachusetts 02203
Dear Mr. Deland:
p
uii
u •_•
July 28, 1989
JUL 3 | (989 :
REGION I
OFFICE OF THE
REGIONAL /.DM.T.-iSTr >T~ -
I. This report is in response to the February 1, 1989 request for comments
pertaining to your proposed determination to prohibit the use of Big River,
Mishnock River, their tributaries and adjacent wetlands as disposal sites.
The Fish and Wildlife Service fully supports your proposed determination.
Field data that has been collected on aquatic, wetland and terrestrial species
and their habitat in the Big River Management Area and evaluations of this
data provide sufficient justification for EPA to prohibit the Big River
Reservoir Project based on unacceptable adverse impacts (significant
degradation) to wildlife and fishery areas. This report reviews the various
field studies and reports issued on this project from the mid-1970 's up to the
date of your Federal Register Notice (February 1, 1989) (copies previously
furnished to EPA) . We also review field studies that have been conducted
since February 1, 1989 (copies enclosed) . Additional analyses are included
regarding effects of the proposed reservoir on area-sensitive species and
species with strong homing instincts to natal areas. lastly, we provide our
views demonstrating the reasons why the Big River Reservoir fails to comply
with 40 CFR 230.10(a),(b),(c), and (d) as identified under the 404 (c)
procedures at 40 CFR Part 231.
II. Project Description
The Big River Reservoir would be formed by an earth fill dam across the Big
River near the location of the Harkney Hill Road Crossing (Zekes Bridge) in
the Town of Coventry, Rhode Island. Big River Reservoir would be contained
within the Big River Management Area, a tract consisting of about 8,270
acres. The Reservoir would inundate approximately 3,400 acres of upland,
wetland and open water at pool elevation 300 msl. Approximately 3700 acres of
land would be cleared for the project. Streambed elevation at the dam site is
240 feet msl, maximum water supply pool elevation is 300 feet msl, maximum
depth in the impoundment would be 60 feet, and average depth would be about 25
feet. The project would have a drainage area of about 29.7 square miles at
the dam. Approximately 16.9 miles of cold- and warmwater streams and several
ponds including Capwell Mill and Tarbox ponds would be inundated. Other
features of the project are more fully described in the Corps of Engineers
Feasibility Report and various reports developed by the Rhode Island Water
RECEIVED-ERA
fAUG
1 1989,
WWP-WQB
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III. Project Environs
The Big River Management Area contains 5 named streams and 7 named ponds.
These are the Big River which is formed by the confluence of the Congdon and
Nooseneck Rivers, Carr River, Mud Bottom Brook, a tributary to the Carr River
and Bear Brook. The ponds include Carr, Tarbox, Sweet, Phelps and Capwell
Mill Pond all in the Carr River drainage; Rathbon Pond on the Congdon River
and Reynolds Pond in the Big River drainage. All of these ponds except Carr
Pond are shallow and support abundant emergent and submersed aquatic
macrophytes. Carr Pond is deep and contains a rocky bottom. Rooted
macrophytes are scarce.
The 20.8 miles of streams on the Management Area contain both warm- and
coldwater habitat. The Congdon and Nooseneck Rivers and Bear Brook are
coldwater habitat supporting brook trout. Most sections of the Carr River an..-.
Mud Bottom Brook are warmwater habitat. Brook trout are generally not founa
in these waters during the summer season. The Big River south of Route 3 is
coldwater habitat. North of Route 3, the gradient drops and the river becomes
broad and sluggish and is characteristic of a warmwater habitat. With the
exception of Carr Pond, all of the waters are colored (dystrophic) and acidic.
The pH values are generally between 5.0-6.0.
Approximately 800 acres of wetlands exist on the Management Area. Forested
wetlands are the most abundant type. These are predominately red maple swamps
with Atlantic white cedar stands occurring much less frequently. Shrub swamps
are next in abundance. Herbaceous wetlands are least common and are generally
found associated with the perimeters of the ponds located on the Management
Area.
Upland vegetation on the Management Area is predominantly deciduous and
coniferous forest. Several old fields still exist on the Management Area, a
reflection of the past when portions of this area were actively farmed. The
evergreen forest consists of white pine and pitch pine either as pure stands
or in combination with each other. White pine is the predominate species
presently as it has greater site adaptability and is a successional species.
The deciduous forest stands are generally mixtures of beech, maple, white oak,
red oak, and black oak. Mixed woodlands containing tree species found in
these two major cover types are commonly found.
IV. Review of previous investigations/reports
1. KAME 1976
The KAME report was conducted as a joint venture by Reyes Associates, Inc.,
and Metcalf and Eddy, Inc., under contract from the Rhode Island Water
Resources Board. Originally, the study was to be conducted in two phases,
however, only Phase I was completed. It was funded using receipts from the
sale of sand and gravel on the Big River Management Area.
The Phase I report entitled "Preliminary Inventory of Vegetation, Wildlife and
Aquatic Biota in Big River Study Area" was completed on November 8, 1976.
Much of the report consisted of a general literature review of environmental
resources that could be found on the study area. However, the vegetation of
the study area was mapped from black and white photography and later field
verified. In addition, eight (8) aquatic sites were sampled to obtain
information on water quality parameters, benthic communities and fish. The
benthic samples were later sorted and individuals were identified to genus and
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counted. During the field verification work on the vegetation transects,
observations on wildlife sightings were recorded. A copy of the Phase I
Report is available for inspection at the Rhode Island Water Resources Board.
The Phase II investigations were never started due to funding limitations at
the state level. Seasonal field investigations were to have taken place
during Phase II.
2. Fish and Wildlife Service Planning Aid Letter, November, 1978
In 1978, Governor Garrahy requested the New England Division, Corps of
Engineers to complete a feasibility study of the Big River Project for water
supply and related uses. During this initial phase, the Corps investigated a
number of alternative reservoir and/or diversion sites on Big River, Flat
River Reservoir, Wood River, Moosup River and Bucks Horn Brook. This November
27, 1978 report provided a preliminary analyses of the impact of developing
these water supply projects on area fish and wildlife resources. No field
data was collected. The analysis was based on existing information and the
man-day of use approach (method now obsolete) for hunting, fishing or other
passive recreational use.
3. Normandeau Reports, 1979
In 1978, the New England Division contracted with Normandeau Associates, Inc.
(NAI), for field and literature investigations on terrestrial and aquatic
wildlife in the Big River Management Area. Field work was conducted in late
summer of 1978. These reports are discussed separately below:
a. Aquatic Ecosystem Report, January 1979 - The primary objective of this
study was to collect information from field surveys in order to accurately
describe the existing water quality and physical features of the major streams
and ponds and identify any existing or potential sources of point and non-
point pollution. In addition, an inventory of the existing aquatic biota was
conducted which included an analysis of the phytoplankton, periphyton,
zooplankton, benthic macroinvertebrates, herptile and finfish communities.
The NAI investigators described the phytoplankton species as being generally
characteristic of summer aquatic communities and overall as typical members of
communities found in temperate free-flowing and still water habitats (pg. 27-
28). They described the periphyton genera encountered as typical of temperate
softwater streams and ponds. In addition, they concluded that the periphyton
communities observed in the Big River study area were generally indicative of
naturally occurring acidic waters (pg. 43). The composition and abundance of
the zooplankton phyla observed by the NAI investigators were described as
being representative of temperate freshwater communities (pg. 51). With
respect to macroinvertebrates, the lotic locations supported benthic
communities of higher densities, standing crop and species richness (number of
taxa) than those observed from lentic locations. It was also apparent the
lotic habitats supported stable benthic communities of higher diversity and
lower faunal repetition than those observed from the lentic habitats. These
observations are related to an observed greater substrate microhabitat
complexity and a corresponding complex and diverse association of benthic taxa
present within the lotic habitats (pg. 58-60). Only two species of reptiles
(snapping and painted turtles) and two species of amphibians (pickerel and
green frogs) were collected or observed by the NAI investigators. The
existence of a diversity of suitable habitats within the study area suggested
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to the NAI investigators that the herptile cxunnmnity is more diverse and
dynamic than was apparent from the limited field surveys of August 21-
September 1, 1978 (pg. 61). A total of 10 species of fish were collected from
the lentic habitats (Flat River Reservoir, Tarbox Pond and Capwell Mill Pond)
in August, 1978. The most abundant fish in decreasing order of abundance were
largemouth bass, golden shiner, pumpkinseed, yellow perch and banded sunfish
(pg. 65). In the lotic habitats, 11 species of fish were collected. The
bridle shiner, swamp darter, largemouth bass, pumpkinseed, and redfin pickerel
collectively represented over 78% of the total numbers (pg 71). Brook trout
were collected only in the lower Nooseneck River in August of 1978. A total
of 15 species of fish were collected from the lentic and lotic habitats in the
study area.
b. Terrestrial Ecosystem Report, January 1979 - Like its companion report
discussed above, field work for this study was conducted during a one-wee^
period in late August 1978. The NAI investigators also prepared a cover map
of the study area. The more detailed cover types found on the KAME map were
consolidated into 5 cover types. Representative stands in each cover type
were field checked by NAI for the purpose of characterizing the vegetation.
Six census transects were established to determine avian species composition,
relative abundance and habitat utilization. A total of 49 species of birds
were observed in the study area (pg. 34). Seven species of mammals were also
observed during these field studies (pg. 39). A habitat evaluation was
completed for each of the 5 cover types found on the study area. For the
wetland cover type, the NAI investigators describe them as follows:
Vegetative and structural diversity in the red maple and shrub swamps was very
high and wildlife habitat value was excellent (pg. 44). The shallow and deep
marshes were described as providing excellent waterfowl, wading bird and
aquatic furbearer habitat (pg. 50). Carrying capacity estimates were also
developed for 9 species of birds and mammals found on the study area.
4. University of Massachusetts Study, 1979
On May 30-31 and June 1, 1979, the Fish and Wildlife Cooperative Unit at the
University of Massachusetts, Amherst conducted field investigations in the Big
River Management Area. The purpose of the study was to determine species
composition and relative abundance of small mammals, birds, fish and herptiles
on the Management Area. Bird transects were established at 8 sites within the
Management Area, small mammal traps were established on 5 of these transects
also. During the 3-day period, a total of 61 species of birds were observed.
The transect at Tarbox Pond (#8) had the most diverse avian community with 37
species and the pine barrons transect (#7) had the least avian diversity with
11 species. However, comparisons of the bird transect data are cautioned due
to a wide array of bird watching experience of the observers.
Small mammal, trapping was largely unsuccessful. This was attributed to heavy
rains prior to the field work and vandalism at the trap sites. Only one (1)
meadow vole and one (1) red squirrel were collected by trapping. Few signs of
mammals were observed during this 3-day survey as well. The investigators
only reported observing sign of raccoon, chipmunk and gray squirrel.
Fish were collected from 8 lotic and 4 lentic locations within the Big River
watershed using gill nets, seines and electro-fishing equipment. A total of
15 species of fish were collected. Thirteen of the 15 species collected had
been reported by Normandeau in their August 1978 survey. The bluegill sunfish
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and smaHmouth bass had not been reported by Normandeau. In addition, this
survey did not collect largemouth bass, nor the redfin X chain pickerel hybrid
reported by Normandeau. Brook trout were collected at sampling stations in
the Nooseneck River, Congdon River and Pegr Brook. They along with white
suckers were the most abundant species collected in the lotic sites. A total
of 7 species were collected in lotic sites, 11 in lentic sites. The most
abundant fish in lentic sites in decreasing order were golden shiners, yellow
perch, and swamp darters. The remaining species were collected much less
frequently. The crayfish Procambarus acutus was frequently collected in the
Carr, Nooseneck and Congdon Rivers. A single clam, Elliptic complenata. was
collected in the Carr River downstream from Capwell Mill Pond.
Ten species of herptiles were observed in the Big River study area in the
vicinity of the fish collection sites. This included 4 species of frogs
(green, wood, pickerel, northern leopard), 2 species of toads (Fowlers arc
American), 2 species of salamanders (two-lined and red-backed), one snake
(northern water) and one turtle (painted).
5. Fish and Wildlife Coordination Act Report, September 28, 1979
This report considered the effects of the proposed reservoir on aquatic,
wetland and terrestrial wildlife resources in the Big River Management Area
and downstream areas. The fishery evaluation utilized regression formulas to
predict standing crop and productivity for the new reservoir. Water quality
information developed by the Corps was utilized to predict the potential for a
2 story (warm- and coldwater) fishery in the impoundment. Based on data
available at the time, the Service predicted a warmwater fishery. This
conclusion was reached by utilizing Corps water quality data (CE, Appendix D,
June 1979), professional experience, and the limited degree of reservoir site
preparation proposed. The Service also predicted that the stream trout
fishery would be eliminated. Additional studies were also recommended to more
clearly predict reservoir limnological conditions and downstream water quality
related impacts on Flat River Reservoir, South Branch Pawtuxet and the main
stem.
The terrestrial and wetland investigations were carried out by utilizing the
habitat evaluation procedures (HEP) developed by the Service (USFWS, March
1979). The forest and other land use types of the study area (entire Big
River Management Area) were condensed into six habitat types for evaluation
purposes. A total of 26 species of wildlife were used as evaluation elements
in the study. This included 11 mammals, 11 birds, 2 amphibians and 2
reptiles. At least 6 species were used to evaluate each habitat type except
scrub/shrub wetland for which 5 species were used. Sample sites within each
habitat type were randomly selected both inside and outside the pool area.
Thus, the baseline habitat values reflect the habitat conditions in the entire
Management Area. In addition, to estimating baseline (1979) habitat values,
the Service also estimated the management potential value for each cover type.
This evaluation was based on the habitat requirements of the evaluation
species and management practices that could be employed to increase the
quality of the habitat for evaluation species. The Service determined the
baseline habitat values for scrub/shrub and forested wetlands to be 0.81 and
0.65 respectively. The management potential values were determined to be 0.84
and 0.76 respectively (a value of 1.0 is the maximum theoretically
attainable). Thus, these wetlands were found to be functioning at 96 and 86
percent respectively of their management potential value. Compensation for
these losses was found to be extremely questionable because it would require
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the acquisition and management of an additional 3,400 and 2,573 acres of
similar value scrub/shrub and forested wetland, respectively. This is after
deducting the values gained by management of remaining wetlands including 90
acres of open water herbaceous wetlands to be created as sub-impoundments in
the reservoir.
As a result of the serious adverse effects of the proposed project on fish and
wildlife resources on the Management Area and downstream areas, the Fish and
Wildlife Service formally opposed the Big River Reservoir project on September
28, 1979.
6. Department of Interior Report August 1982
On August 12, 1982, the Office of the Secretary issued formal comments on the
Chief of Engineers report on the Big River Reservoir Project. Major issue-,
raised by Interior included: (1) adequate mitigation of fish and wildlife
habitat losses, (2) fish and wildlife impacts associated with reservoir
development and downstream flow depletion, (3) water quality impacts (4)
population projections, and (5) future water needs. Interior also stated that
the direct loss of 570 acres of wetlands made the project environmentally
unsatisfactory.
7. University of Rhode Island Wetlands Study, Spring 1984
During the spring semester in 1984, the Wetlands and Land Use Class (FOR 424)
in the Department of Natural Resources conducted an inventory and wildlife
evaluation of the wetlands and deep water habitats of the Big River watershed.
The conclusions of this report state that the reservoir project would convert
over 500 acres of wetland to deep water habitat, and it would destroy the
majority of the most valuable wetland wildlife habitat in the watershed. In
all, 33% of the watershed's wetlands would be lost. The FOR 424 project
results predict that the construction of the Big River Reservoir would have a
severe, irreversible impact on wetlands and their wildlife.
8. University of Massachusetts Breeding Bird Study, 1986
During May, June and July 1986, data on breeding birds was collected on 10
circular (0.25ha, 28.2m radius) plots within the'" Big River Management Area. A
total of 28 bird species were recorded. Upland forest and wetlands within the
pool area contained the greatest diversity of species. Wetlands within the
pool area contained the greatest numbers of birds. Six additional avian
species were recorded outside of the 10 study plots.
9. Rhode Island Division of Fish and Wildlife, 1986
During April, May, and June 1986, bird and other wildlife surveys were
conducted on the Big River Management Area. Most of this effort was
concentrated on Big River and adjacent lands but at least one survey was
conducted in the Carr River (Capwell Mill Pond) Basin. Some 67 different
avian species were observed during these field surveys. This included
transient and breeding species, although most would be expected to nest in the
study area. Searches were also made for herptiles during the outings. Four
species of turtles were observed; painted, musk (stinkpot), spotted and
snapping. Other herp species reported included ring-necked snakes, green
frogs, spring peepers, American toads and the pickerel frog.
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The Division (Lapisky 1989) has also reported observations of bobcat on Fish
Hill Road and other sightings within 5 miles of the project boundary. A
recent fisher sighting was reported in the Division Road area. Other
observations include beaver, otter, coyote, white-tailed deer, snowshoe hare,
turkey and black duck.
10. Rhode Island Water Resources Board Wetlands Evaluations - December 1986
As part of the environmental studies for the Big River Reservoir Project, the
Water Resources Board obtained the services of Wetland Management Specialists,
Inc., et al, to evaluate the wetlands within the Management Area. While this
effort was never fully completed due to NEPA and Section 404 questions
concerning the reservoir project, the data do reveal that the pool area
contains many high value and outstanding wetlands based on the Golet
evaluation method. Thus, the evaluations completed to-date by the Wats..:
Resources Board consultants concerning the habitat value of the study area
wetlands, support the conclusion reached independently by several other
previous investigators.
11. Breeding Bird Atlas Project (1981-1986)
During this 5-year period (1981-1986), birders in Rhode Island observed birds
during the breeding season in 7 survey blocks that included most of the Big
River Management Area. It should be noted that the 7 survey blocks included
an area many times the size of the Big River study area. The results of this
survey reveal that 104 species of birds breed in or adjacent to the Big River
Management Area.
12. Other Investigations - During the past 40 or more years various
individuals have made observations on fish and wildlife within the Big River
area. Unfortunately, roost of these data remain in the minds of these
observers as few field notes were recorded. In a few instances where data has
been recorded, it remains unpublished and thus, generally unavailable.
V. Review of Current Investigations
1. Mollusc Survey, Spring, 1989
During May and June 1989, Mr. Douglas Smith, Museum of Zoology, University of
Massachusetts, conducted searches for mussels (bivalves) and other
invertebrate fauna in the streams and ponds located on the Big River
Management Area. The results of this investigation are included in Appendix
A. Only one bivalve species, Elliptic complanata. and one gastropod species,
Campeloma decisum. were found. The naturally acidic waters and development
history of the watershed (impoundments) are thought to be limiting factors for
these faunal groups. In addition to the molluscs, Mr. Smith located and
identified seven (7) other invertebrate species on the Management Area that
would be unable to tolerate life in the proposed reservoir. These include
three (3) freshwater sponges, one (1) isopod, two (2) amphipods, and one (1)
crayfish. The two amphipod and single crayfish species are of special
interest. Cranaonvx aberrans is endemic only to southeastern New England,
where it is fairly well distributed in coastal drainage systems. This species
was discovered by D. Smith in 1981 and later described by him as a new species
(Smith, 1983). The other amphipod, Synurella chamberlaini. is a disjunct
species in New England (Smith, 1987). It is fairly widely distributed along
the middle Atlantic nrasi-ai Plain from South Carolina to Maryland.
Previously, Smith (1987) located this species at one location in Massachusetts
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and one location in Rhode Island. This extremely rare species for this region
was found by Smith this spring in Bear Brook which represents only the third
known location for this amphipod in New England.
The crayfish Procambarus acutus acutus is also a disjunct species. It is
widely distributed in the Mississippi River, Gulf and Atlantic Coast drainage
from New Jersey southward. However, it is absent in the drainages of southern
New York and along the Connecticut coastline. It is well distributed in the
coastal drainages of southeastern New England.
2. large and Medium Size Mammal Survey, Winter-Spring, 1989
During the period February-June, 1989, Mr. Chester McCord, a consulting
wildlife biologist, conducted a survey for large and medium size mammals on
the Big River Management Area, Appendix B. This investigation was based or.
observations of mammals (actual sightings) and more importantly, by reading
sign such as tracks, cuttings, pellets, scats, scratchings, etc. Emphasis was
placed on the rare or unusual species such as bobcat, fisher, and black bear.
McCord identified 17 species of wild mammals and one bird, the wild turkey
during his searches on the Management Area. White-tailed deer, red fox and
raccoon were the most frequently noted species. Due to the lack of snow cover
during the study period, tracking was difficult for certain species/species
groups. As a result, McCord felt that species groups such as the mustelids
(otter, mink, fisher, weasel) were probably under-represented in abundance in
his survey, along with muskrat and opossum. The red fox was found to be the
most widely distributed medium size mammal on the Management Area. Sign of
this species (tracks) were abundant and observed throughout the study area.
The white-tailed deer was found to be widely distributed in the reservoir area
south of 1-95. He reported finding deer concentration areas adjacent to the
Big River and along portions of the Carr River drainage. No rare species were
located during this survey, however, both bobcat and fisher have been reported
on the Management Area (Lapisky, 1989). McCord concluded that the lack of
sign on the Management Area indicates that the bobcat is not a permanent
resident. The observations of this species on and near the study area
indicates that it is used by bobcats during dispersal and it is possible that
a dispersing bobcat could establish a home range in the area. With respect to
fisher, McCord felt that the area has more potential to sustain a resident
fisher population than the other rare species (bobcat, black bear).
3. Small Mammal Survey - Spring 1989
During the period April 22-June 20, 1989, Dr. Thomas Husband, University of
Rhode Island, and students in Natural Resources Science conducted a small
mammal survey of the Big River Management Area, Appendix C. Small mammals
were trapped at 12 different sites on the study area using snap traps and can
traps. Emphasis was placed on sampling the riverine and wetland habitats
within the proposed reservoir area.
A total of 101 small mammals comprised of eight (8) species were trapped from
the 12 sites. The meadow vole, Microtus pennsylvanicus. was the most numerous
species captured. The water shrew, Sorex palustris. a rare species in Rhode
Island, was captured on the Congdon River. This capture represents the third
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record of this species in Rhode Island. According to Dr. Husband, the Big
River and its tributaries probably represent one of the last remaining
habitats in Rhode Island for this species. Dr. Husband also emphasized the
ecological role small mammals play in the Big River ecosystem. In particular,
they provide an essential link in the food chain for several reptilian, avian
and mammalian predators. McCord (1989) also recognized that the Big River
Management Area must have a substantial prey base to support the large fox
population that he found.
3. Breeding Bird Survey - Spring 1989
During May and June 1989, Mr. Rick Enser, Coordinator, Rhode Island Natural
Heritage Program and Mr. Adam Fry, Naturalist, Rhode Island Audubon Society,
conducted breeding bird surveys on the Big River Management Area, Appendices D
and E. In addition, Mr. Fry conducted weekly surveys for birds and other
wildlife during the period from February until the start of the breeding bird
surveys, Appendix E.
Mr. Enser's breeding bird survey was conducted utilizing seven (7) transects
in upland habitat, three (3) wetland transects (canoe routes) on Big River (2)
and Carr River (1) and an automobile route to sample habitats not adequately
represented by the other transects. Sampling emphasis was placed on the
reservoir pool area since this would be the place of primary impact.
A total of 80 species were recorded on all surveys, 72 species on canoe routes
and 64 species on upland transects including the automobile routes. These
data were combined with information collected during the Breeding Bird Atlas
project and other field investigations to develop a comprehensive list of
breeding birds on the Big River Management Area. This list currently stands
at at least 106 species.
Mr. Fry's migrant and breeding bird survey was conducted using upland
transects, wetland transects and random searches to sample underrepresented
habitats. Sampling emphasis was placed on the reservoir pool area since this
would be the place of primary iirpact.
A total of 110 species were recorded consisting of 85 breeding species and 84
migrant species. In addition to the bird species, the Audubon investigators
observed 9 species of mammals including bobcat sign (tracks), 9 species of
amphibians, 8 species of reptiles and 18 species of butterflies. They also
draw special attention to 5 birds observed on the Management Area (pileated
woodpecker, northern goshawk, red-breasted nuthatch, white-throated sparrow
and northern junco) and 1 mammal, the bobcat. Each of these birds is
considered to be a rare breeder in Rhode Island, and the bobcat is rarely
observed in the State.
Data from these most recent breeding bird surveys confirm that the Big River
Management Area provides suitable habitat for and does support a highly
diverse breeding bird fauna. This list includes many species that are
dependent on or closely associated with aquatic habitats (18) and/or are
considered area-sensitive species; forest interior (21) and interior-edge (22)
species (Tables 1 and 2). The five most common species recorded on all canoe
routes were common yellowthroat, song sparrow, gray catbird, swamp sparrow and
yellow warbler. The five most common species recorded on upland transects
were ovenbird, black-capped chickadee, veery, rufous-sided townee and pine
warbler.
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4. Amphibian and Reptile Survey - Spring 1989
During the period March - June, 1989, Mr. Chris Raithel, Non-Game Specialist,
Rhode Island Division of Fish and Wildlife, conducted searches for amphibians
and reptiles within the Big River Management Area. Mr. Raithel has been
making periodic searches in the Big River Management Area during the past 4
years as part of a statewide herptile survey. During this time period, he has
developed a list of herptiles that occur in the study area, Appendix F. This
species list includes 7 salamanders, 2 toads, 6 frogs, 7 turtles, and 11
snakes for a total of 33 species. Seven of these species are listed as
probably occurring but specific documentation by him is presently lacking.
VI. Review of Special Topics
1. Impacts on area-sensitive species
At the time the Service completed its Coordination Act report on the Big
River Project (September 1979), insufficient attention was directed at the
concept of forest fragmentation and associated effects on area-sensitive
species (forest-interior and interior-edge species) in and adjacent to the
Management Area. In the intervening decade, a substantial amount of
literature has been published describing the results of habitat fragmentation
research. We now have empirical evidence, as has long been expected, that the
impact on wildlife populations will extend far beyond the actual footprint of
the reservoir (elevation 300 feet msl and its clear zone, elevation 310 msl).
The past and current field investigations in the study area reveal that at
least 21 forest-interior and 22 interior-edge migratory bird species nest in
the impact area (Table 2). In addition, at least 3 forest-interior mammal
species (bobcat, fisher and otter) also utilize the Management Area. We
anticipate regional impacts to occur to many of these most sensitive species
as a direct result of the loss of over 3,700 acres of habitat. The most
sensitive breeding birds on the Management Area to patch area (forest size)
based on available evidence (Rabbins et al, 1989; Askins et al, 1987) include,
but are not limited to, the black-and-white warbler, Louisiana and northern
waterthrushes, black-throated green warbler, Canada warbler, worm-eating
warbler, hermit thrush, yellow-throated vireo, red-shouldered hawk, Coopers
hawk, and broad-winged hawk. The bobcat, fisher and otter are the most
sensitive mammals found on the study area to forest size and forest
fragmentation effects. A number of interrelated effects are associated with
habitat fragmentation. These include the direct loss of habitat, an increase
in edge, increased nest parasitism and predation, increased isolation of
remaining forest, a decrease in the abundance and diversity of area-sensitive
breeding birds, a decrease in the size of remaining forest patches and
increased human disturbance (Whitcomb et al, 1981; Small and Hunter, 1988;
Wilcove, 1985; Ambuel and Temple, 1983; Brittingham and Temple, 1983; Rabbins,
1979, 1980; Rabbins et al, 1989; Blake and Karr, 1984, 1987; Askins et al,
1987; Lynch and Whigham, 1984; Lynch, 1987). All of these factors would occur
to varying degrees of intensity if the reservoir is constructed. As a result
of reservoir construction practices, a sharp edge or habitat discontinuity
will be formed around the 31 mile perimeter of the reservoir (i.e., clearing
and grubbing between elevations 290-303 feet msl and clearing only to
elevation 310 msl). Most of this edge will be formed by the water surface and
a narrow clear zone butting up against forest habitat. Forest-interior bird
species that previously nested in the zone between the edge of the reservoir
and for a distannp of up to 200 meters landward within the forest would find
this habitat to be unsuitable and/or less suitable (personal communication V.
Lang and C.S. Rcbbins; Rabbins, 1988). This would occur from a combination of
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factors. Forest-interior birds do not nest nor establish nesting territories
on forest edges (Whitcomb et al, 1981; Rabbins, 1988). Depending on the
sensitivity of the individual species, this Hi«a-arre from an edge can vary
from a few meters to over 100 meters (Stauffer and Best, 1980). Both nest
parasitism and nest predation are greatest near edge (Small and Hunter, 1988;
Gates and Gysel, 1978; Wilcove, 1985). These factors decrease in intensity as
distance from edge increases. The smooth characteristics of the shoreline
edge would be an efficient predator pathway similar to roads and transmission
line RCW's which would serve to increase the intensity of this impact (Small
and Hunter, 1988). Several remaining forest patches such as those adjacent to
1-95 and other developed areas would be too small to function as suitable
nesting habitat for the area-sensitive migratory birds (Rabbins et al, 1989;
Askins et al, 1987). Some remaining patches may be large enough in terms of
acreage but may be oblong or linear in shape and hence, be unsuitable because
of extensive edge and lack of secure interior habitat (Temple, 1984). The
degree of isolation of these remaining forest patches may also be sufficient
to deter forest-interior or other area-sensitive species from using this
habitat (Blake and Karr, 1984, 1987; Robbins et al, 1989; Askins et al, 1987).
This impact zone (0-200 m) around the 31 mile reservoir perimeter encompasses
an area of approximately 2,300 acres of land. It is also necessary to
consider the relationship of the reservoir edge to other existing edges such
as road relocations to accommodate the project, 1-95, Route 3, cleared land
and residential areas. In essence, we would have a double edge or in places,
a multiple edge effect created because the perimeter of the Management Area
would be surrounded by edges created by highways or existing developments.
This project would carve the "heart" or most secluded interior portions of
habitat out of the Management Area. The remaining lands (public and private)
in the Big River Watershed would be less suitable or entirely unsuitable for
area-sensitive species. As development proceeds on private land around the
perimeter of the Management Area, the habitat fragmentation syndrome would
become more severe. This would be especially evident along ,the south and
southeast boundaries of the Management Area where sizeable blocks of
undeveloped forested habitat currently exist.
Several researchers have linked local animal populations such as area-
sensitive breeding birds to those occurring on a regional basis (Robbins et
al, 1989; Blake and Karr, 1984, 1987; Lynch and Whigham, 1984; Whitcomb et al,
1981). In essence, forest-interior species may occur in suboptimal sized
blocks of habitat if large reserves are nearby to provide recruitment or
replacement individuals. The Big River Management Area is sufficiently large
enough to provide this function for species such as the black-and-itfhite
warbler, veery, and ovenbird. It may not be large enough to provide this
function for species such as Louisiana waterthrush, northern waterthrush,
Canada warbler, worm-eating warbler, red-shouldered hawk, American redstart,
barred owl and northern goshawk, as these species occur in low to moderate
numbers on the study area. This suggests that the Big River Area is a reserve
for these species. It is interesting to note that area-sensitive species with
minimum breeding areas greater than 500 hectares (cerulean warbler, northern
parula) are not represented in the breeding bird fauna on the study area
(Robbins et al, 1989). The pileated woodpecker has a minimum breeding area of
165 hectares according to Rabbins et al, 1989, and it is also not represented
on the study area. This suggests that the Big River Reservoir would have
regional impacts on area-sensitive birds that occur in moderate to low numbers
in central Rhode Island because the reserve for these species would be
eliminated.
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A similar conclusion appears to be reasonable for mammals such as bobcat and
fisher. These species occur infrequently on the Management Area from
dispersal sites to the north and west. With the elimination of the core area
due to the impoundment, the study area would no longer be suitable habitat for
these species. This may tend to limit the regional population of these
species due to the loss of suitable dispersal habitat at Big River.
Within the forest-interior category of migratory birds is a group referred to
as long-distance or neotropical migrants, the warblers, vireos, tanagers, most
of the flycatchers, and many of the thrushes. This group comprises more than
half of our breeding bird population in the eastern deciduous forest (Rabbins,
1988). This group of migratory birds is of concern to the Fish and Wildlife
Service for several reasons. They are concurrently being subjected to habitat
destruction on their wintering grounds in Latin America and on their breeding
grounds in North America. Long-term population declines have been observed in
this group of birds in sections of the United States undergoing rapid
urbanization. Since these species are forest-interior dwellers during their
breeding season, they are adversely impacted by forest fragmentation. Their
breeding strategy also makes this group susceptible to many effects
associated with habitat fragmentation (Whitcomb et al, 1981). As a rule, this
group of birds nests only one time during the breeding season. Therefore,
they have a low recruitment rate because they only produce one clutch each
year. They generally build an open cup type nest near or on the ground which
makes them susceptible to predation and parasitism in fragmented habitats.
Because this group of birds requires extensive tracts of land for breeding,
management for these native songbirds requires long-range ecosystem planning
(Robbins, 1988).
2. Impacts on Species with Fidelity to Natal Areas
During the past several decades, a substantial body of information has been
developed concerning homing and dispersal behavior in wildlife. Certain
amphibian species exhibit a strong fidelity to their natal pond (Snoop, 1965;
Williams, 1973; Ewert, 1969; GUI, 1979; Wilson, 1976; Dole, 1971; Semlitch,
1981). Salamanders, newts, toads, and to a lesser extent, frogs exhibit this
homing instinct. Williams (1973) studied the movement of Ambvstama
salamanders away from their natal woodland pond into their home range
territory in Indiana. He found that Jefferson salamanders moved up to 625m,
spotted salamanders 125m, and marbled salamanders 450m away from the natal
pond. Bishop (1941) collected Jefferson salamanders in New York up to 1610m
away from the nearest breeding pond. Wilson (1976) followed the movements of
spotted and Jefferson salamanders away from a breeding pond in New York. This
Ambvstama population moved about 75m from the breeding pond. Gill (1979)
documented homing behavior in the red-spotted newt in Virginia and also showed
that this species could navigate over a Hjjgfranr» of 400m to the natal pond.
Healy (1974) showed that the red eft stage of this species moved up to 800m
from their natal pond into the terrestrial environment in Massachusetts.
Douglas (1981) studied the post-breeding movements of marbled, Jefferson and
spotted salamanders in Kentucky. He found the initial movements away from the
natal ponds to be 30m, 250m, and 150m for these species, respectively. Later
movements to summer home range were reported for each species indicating that
some individuals moved yet further away from the breeding pond. KLeeberger
and Werner (1983) studied the post-breeding migration of spotted salamanders
in northern Michigan. They found these salamanders moved an average distance
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of 192m (range 157-249m) from the natal pond to summer home range. Ewert
(1969) studied movements of the American toad (Bufo americanus) in northern
Minnesota. He found homing behavior (fidelity) to breeding ponds and post-
breeding migrations to summer range averaging 1200 feet (range 170-3,300).
Clarke (1974) studied a population of Fowlers toad (B. woodhousei fowleri) in
Connecticut. He found they moved up to 312m from the breeding pond to summer
home range. Dole (1971) studied the dispersal of leopard frogs (Rana pipiens)
in Michigan. He found that young leopard frogs commonly moved over 800m from
their natal ponds. A few were recorded to have moved over 5km from the natal
pond. Schroeder (1976) studied the dispersal and movements of young green
frogs (R. clamitans) from their natal pond in Virginia. He found they
commonly moved 183-448m from the larval pond. Some moved up to 4.8km from the
natal pond.
Based on our knowledge of amphibian life cycle processes, the local frog,
toad, and salamander species would be eliminated from the lands and waters to
be occupied by the reservoir pool area, and depending on the species, would be
adversely affected in the remaining lands on the Management Area. Within the
reservoir pool, but excluding the shoreline, approximately 3400 acres of
suitable habitat would be permanently eliminated. This includes the breeding
ponds (reproductive habitat) and terrestrial habitat for the adults. Adjacent
areas within the Management Area would over a period of 1-5 years gradually
lose existing populations of certain amphibians. This would occur as a result
of the adults perishing from natural causes and the lack of recruitment to
replace those lost. Those species with the strongest fidelity to their natal
ponds, such as the Ambystomid salamanders, would be most adversely affected.
Unfortunately, it is not possible to precisely define the areas outside of the
reservoir that would be affected as described above. Discrete studies would
be required for each breeding pond to identify the exact areas that are
"seeded" by amphibian species (adults and newly metamorphosed juveniles)
dispersing from natal or breeding ponds. It seems reasonable, however, that
areas within 200-300 meters of the reservoir edge would be most affected. The
effects would lessen with increasing distance from the edge of the reservoir
and become difficult to detect beyond 800m, as only the American toad, the
red-spotted newt and some frogs move greater distances from natal ponds.
We should also recognize that in addition to habitat effects, discrete
breeding populations of these amphibian species with a strong fidelity to
their natal pond such as the spotted and marbled salamanders and red-spotted
newt may also be lost. This would represent an irreversible and irretrievable
loss of genetic material in these wildlife populations.
VH. Compliance with the 404 (b) (1) Guidelines
Compliance with 40 CFR 230.10(a)
During the formal Departmental level review process of the Big River Reservoir
Feasibility Report in 1982, the Department of Interior raised several
questions concerning the need and environmental acceptability of the proposed
project (DOI letter August 12, 1982). These issues raised by Interior
concerning need for the project, demand modification alternatives and other
issues remain unresolved, despite a *•-•».•>» lapse of 7 years in which the Water
Resources Board and/or the Corps of Engineers had ample opportunity to conduct
studies that would allow them to refute or agree with the analysis and
comments made by Interior. Neither of the project proponents chose to
supplant the administrative record with data to demonstrate that the Big River
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Reservoir was the least damaging practicable alternative to fulfill Rhode
Island's future water supply needs. Rhode Island's future water supply needs
remain an unknown because the necessary studies have not been conducted to
accurately identify these needs and all practicable alternative approaches to
satisfy them. Therefore, we conclude that the Big River Reservoir Project
does not comply with 40 CFR 230.10(a) for the reasons set forth in Interior's
August 12, 1982 letter.
We understand that the State of Rhode Island has recently obtained the
services of a consultant (A.D. Little, Inc.) to investigate the needs issue
and water supply alternatives as a means of addressing this important issue.
The results of this study are not expected before March or April, 1990. As a
result, Agency and public review of this data would likely not occur until
some time in mid-1990, well after the comment period is closed for this 404c
proceeding.
Compliance with 40 CFR 230.10(b)
The Big River Reservoir does not comply with Rhode Island Water Quality
Standards, hence it fails to comply with Section 230.10(b) of the 404(b)(l)
Guidelines. As demonstrated in this report, the Big River Reservoir would
eliminate existing uses presently occurring on the various aquatic
environments found below the flow line of the impoundment (elevation 300 feet
msl). These uses include breeding, foraging and cover habitat for over 100
species of migratory birds that utilize these aquatic habitats for one or more
critical life cycle phases. The reservoir would be unsuitable habitat for
over 90 species of migratory birds presently found there and hence, these
species would be eliminated from the impoundment. The waterbird group
(waterfowl and wading birds) would be the least adversely affected by the
proposed impoundment. Some members of this group would benefit from the
proposed project. However, other species such as black duck and green-backed
heron would possibly be eliminated as nesting species on the Management Area
despite the proposed subimpoundments along the perimeter of the reservoir.
At least 28 species of mammals utilize these stream, pond, floodplain and
wetland habitats for requisite life cycle needs such as breeding, rearing
young, foraging and cover. The proposed impoundment would be unsuitable
habitat for 25 species and less suitable for the remaining 3 (beaver, muskrat
and otter). Some use would be made of the shoreline areas by species such as
raccoon. However, the value of the impoundment for any of these aquatic
mammal species is expected to be limited because of water level fluctuations.
Greater utilization would be anticipated for the subimpoundments. Hence, 25
of the 28 mammals presently utilizing habitats below elevation 300 feet msl on
the Management Area would be eliminated from these areas by the impoundment.
Fourteen species of amphibians and 18 species of reptiles utilize these
aquatic habitats for one or more critical life cycle processes. The resulting
impoundment excluding the shoreline area would be unsuitable habitat for 13 of
these amphibian species and 12 of the reptile species. It would be less
suitable for at least one other, the spotted turtle. Of the 14 amphibian
species, only the bullfrog would be expected to utilize portions of the
reservoir proper and those would be restricted to areas with floating-leaved
and emergent vegetation, providing any such littoral zone develops, given the
range of water level fluctuations expected. We anticipate that it would
attempt to breed around the perimeter of the reservoir, especially in
protected coves, bays and the subimpoundments. The green and pickerel frogs
may also utilize the subimpoundments and perhaps some other shoreline areas as
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breeding sites. In general, any use of the impoundment by amphibians other
than the bullfrog would be limited to the shoreline. We would not expect the
reservoir to be used as breeding habitat by salamanders, toads, peepers, tree
frogs or woodfrogs as these species prefer to utilize small ephemeral and
permanent ponds. These isolated breeding sites lack fish and other predators
that prey on egg masses and juveniles of these species. The adult phase of
most of these species except red-spotted newt is essentially or entirely
terrestrial; hence, the reservoir would be unsuitable habitat for this life
stage.
Within the reptiles, only the water snake, painted turtle, snapping turtle,
and stinkpot would be expected to use the reservoir proper. The wood and box
turtles and remaining 10 snakes are terrestrial species and would be
eliminated from the reservoir area. The red-eared slider is considered an
exotic and is not known to be reproducing in Rhode Island. The spotted turtle
generally does not co-exist in the same habitat with painted turtles in Rhode
Island; hence, it may not utilize the reservoir (personal communication, V.
lang and C. Raithel, RI F&W). The proposed subimpoundments would provide the
bulk of the suitable habitat for the aquatic turtles and the water snake as
they would have stable water levels and hence, the best developed, if not the
only littoral zone with well developed macrophytes in the reservoir.
The existing brook trout population would be eliminated as would the 9
aquatic species identified by Smith, 1989 (Appendix A). None of the 9 species
identified by Smith (1989) and the brook trout could tolerate the expected
environmental conditions of the proposed reservoir. This would result from
the inability of many benthic species to obtain adequate oxygen and food and
eliminate waste products. Most species adapted to lotic habitats have limited
or no ability for long-term survival in a lentic habitat. Species such as
brook trout would not survive over the long-term due to the loss of stream
habitat including the critical spawning, rearing and refuge areas. The
dissolved oxygen and temperature profiles anticipated in the proposed
reservoir would preclude this as a viable habitat during the summer
stratification period for coldwater species such as brook trout. Hence, we
conclude that this wild, self-sustaining population would be eliminated from
the watershed. Based on the benthic data collected by KAME (1976) and
Normandeau (1979), we expect species in at least 9 genera of mayflies
(Ephemeroptera), 5 genera of dragonflies (Odonata), 2 genera of stoneflies
(Plecoptera), 7 genera of beetles fColeoptera), 3 genera of caddisflies
(Trichoptera), and 8 genera of flies (Diptera) to be eliminated from existing
lotic habitats as a result of inundation. These aquatic insects are not
expected to survive in the reservoir as they are adapted only for lotic
conditions.
The Rhode Island Division of Fish and Wildlife manages the Big River
Management Area for outdoor recreation and related purposes. The Division
maintains records on some recreational uses of the area. They estimate that
the Management Area provides 1,000 mandays of deer hunting, 2,300 mandays of
small game hunting, 1,000 mandays of trout fishing, and 800 mandays of
warmwater fishing (personal communication, V. Lang and J. Stolgitis, RI F&W).
In addition, other recreational activities include canoeing, hiking, and bird
watching. However, no estimates are available to predict the level of use for
these activities on the Management Area. In any event, creation of the
impoundment would eliminate many of these uses. Hunting, hiking, stream
fishing and bird watching for instance would be eliminated by the impoundment.
If recreational activities are allowed on the reservoir, then flatwater
(lentic) fishing and canoeing opportunities might be retained although the
setting would be radically altered.
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Thus, this project could not comply with even the base level of protection
provided by Rhode Island's Antidegradation Policy, Section 17(a) because
existing uses would not be maintained and protected. In addition, the Big
River and its tributaries are Class A waters whose qualities make these
waters critical to the propagation or survival of important natural resources
as described in this report. Therefore, the Big River and its tributaries
constitute "High Quality Waters of the State" under Section 17 (c). This
classification invokes additional protection as provided by Section 17(d).
However, since the project cannot pass muster at 17(a), we need not consider
this provision further.
The Big River Reservoir could not meet the dissolved oxygen standards
established for Class A waters under Section 6.32 of Rhode Island's Water
Quality Standards. Ihis criterion requires the dissolved oxygen to be not
less than 5 mg/1 at any place or time except as occurs naturally. Section 6.5
allows waters in their natural hydraulic condition to have excursions from
established standards but not waters in an unnatural hydraulic condition. As
we have discussed previously, the D.O. levels in the hypolimnion are expected
to fall below 5.0 mg/1 and possibly became anoxic (COE Appendix D, 1981).
Hence, the project cannot meet this standard. Sections 7.1 and 7.3 provide
additional restrictions on these issues.
We conclude, for the reasons set forth above, that the project does not comply
with 40 CFR 230.10(b).
Compliance with 40 CFR 230.10(c)
The proposed Big River Reservoir would cause or contribute to significant
degradation of waters of the United States. This results from: (1)
Significant adverse impacts on at least 25 species of mammals, 90 species of
birds, 1 species of fish, 12 species of reptiles and 13 species of amphibians
and numerous species of invertebrate wildlife dependent on the aquatic
habitats (streams, ponds, wetlands, floodplains) that would be eliminated if
the reservoir is constructed [230.10(c)(2)]; (2) significant adverse effects
on ecosystem diversity, productivity, and stability resulting from the loss of
3,700 acres of highly diverse fish and wildlife habitat [230.10(c) (3) ] and;
(3) a significant aesthetic and recreational resource would be lost if the
reservoir is constructed [230.10(c)(4)].
As described elsewhere in this report, significant adverse impacts would occur
to over 144 species of vertebrate wildlife (fish, birds, reptiles, amphibians,
and mammals) and an undefined number of invertebrate species. Many area-
sensitive species and others with specific habitat requirements (i.e.,
coldwater streams, ephemeral ponds) would be extirpated not only from lands
and waters occupied by the reservoir, but the remaining lands and waters
within the Management Area and lands and waters outside the Management Area if
this project is constructed. The native brook trout population would be
eliminated from the area occupied by the reservoir due to predicted low
dissolved oxygen (D.O.) levels in the hypolimnion. A similar fate would await
the single mussel Elliptic complanata and snail Campeloma decisum species
found in these waters. These species could not survive the lentic conditions,
sedimentation, low D.O. or water fluctuations. In addition, the native brook
trout population would, over time, be extirpated from the watershed due to the
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loss of spawning, nursery and refuge habitat (cold, well oxygenated water).
Seven of the 9 species identified by Smith (1989) would fall into this
situation as well. All nine species identified by him would perish in the
reservoir. Since the clam E. complanata and snail C. decisum only exist
within the reservoir area, they would be eliminated as the storage pool
filled. The remaining 7 species would survive initially in the remaining
lotic aquatic habitat in the watershed. However, due to the limited amount of
stream habitat remaining, increased isolation of these remaining populations
and their susceptibility to environmental perturbations such as pollution
incidents, D.O. and pH excursions, drought conditions, and other hydrologic
extremes, we anticipate that all 7 species would gradually be eliminated from
the watershed. In addition, due to the extensive loss of stream habitat, the
increased isolation of remaining habitat and other factors identified above,
we anticipate that several genera of insects would, over time, no longer be
represented in the Big River watershed.
Most of the refuge habitat for coldwater stream species in this watershed
occurs within the bounds of the Management Area, and much of this within the
conservation pool. This results from topography, soils, groundwater discharge
zones, extensive wetlands, and impoundments or ponds located in the extreme
upper reaches of the 4 main tributaries to Big River. As an illustration, the
Congdon River is typical warmwater habitat in its upper reaches due to
Rathbon, Hopkins and Money Swamp Ponds. The typical coldwater profile for
this stream develops some distance below Rathbon Pond where groundwater
discharges bring the water temperature into the 60°F range as opposed to 73T
and above found in Rathbon Pond (EWS, July 1989). The Carr and Nooseneck
Rivers also have ponds, extensive wetlands, and/or impoundments in their upper
reaches above the conservation pool. Normandeau (1979) found no brook trout
in the upper Nooseneck due ostensibly to low D.O. and pH below an extensive
wetland. Bear Brook has 2 small ponds in its headwaters and in addition, has
the smallest drainage area of any tributaries to Big River. Because several
other fish species currently found in the watershed require lotic habitat for
spawning sites, we anticipate that the fallfish, creek chubsucker, creek chub,
and possibly white sucker would be subject to wide fluctuations in year-class
strength due to hydrologic extremes, water quality excursions, and other
events in the remaining lotic habitat in Nooseneck River and Bear Brook.
Over a period of years, one or more of these species could be extirpated from
the watershed.
Amphibians, with the possible exception of the bullfrog, would be eliminated
from the reservoir pool area. In addition, some amphibians, such as the
spotted salamander, would be eliminated from adjacent lands on the Management
Area that are presently used as adult home range for salamanders breeding in
areas to be inundated. All but one species of snakes and most turtle species
would be adversely affected by direct habitat loss within the reservoir area.
In addition, the turtles would be affected by the loss of winter hibernacula.
The spotted and wood turtles would be the species most affected by loss of
hibernacula, as they have specialized requirements (boggy areas with hummocks,
clear streams with undercut banks). Area-sensitive bird and mammal species
would be eliminated not only from the area occupied by the reservoir but
adjacent areas within and outside the Management Area as well. In previous
sections of this report, we identified a zone 200 meters deep around the 31
mile perimeter of the proposed reservoir that would be the principle secondary
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impact zone for area-sensitive birds and mammals. Based on data developed by
Askins, et al (1987), and Rabbins, et al (1989), we anticipate that the
following migratory birds would have the greatest potential to be eliminated
as breeding species from the Management Area and/or watershed: Coopers hawk,
northern goshawk, broad-winged hawk, red-shouldered hawk, barred owl, yellow-
throated vireo, northern waterthrush, Louisiana waterthrush, American
redstart, worm-eating warbler, and Canada warbler. The most sensitive mammal
species, the fisher and bobcat, would also be eliminated from the Management
Area due to the loss of secure interior habitat. This loss of habitat would
be sufficient to insure that these species could not become resident or
breeding species in the watershed.
Species of special concern in Rhode Island such as the fisher, bobcat, water
shrew, white-throated sparrow, winter wren, Acadian flycatcher, and the
amphipod Svnurella chamberlaini would be eliminated from the Management Area
and/or watershed. While these species are secure elsewhere in their natural
range, they exist in an uncertain situation in Rhode Island. The loss of
these individuals or populations probably represents an irreversible and
irretrievable loss in Rhode Island.
Ecosystem diversity, productivity and stability would be significantly
adversely affected due to the direct loss of 3,700 acres of wildlife habitat
including over 500 acres of wetlands. In addition, another 2,300 acres of
habitat within a zone of 0-200 meters around the 31 mile reservoir perimeter
would be made unsuitable or less suitable for area-sensitive species of
wildlife. The 3,700 acres of habitat to be cleared for the reservoir
represent the most secluded or . secure habitat on the entire 8,270 acre
Management Area. Once this secure interior habitat has been eliminated, the
fragmentation syndrome will become much more severe as development progresses
around the perimeter of the Management Area. This combination of factors will
lead to a continual decline in the diversity and •abundance of area-sensitive
birds and mammals and other species of wildlife that are presently represented
on the Management Area in restricted habitats, limited numbers or both. The
project will encourage the common, edge, or ubiquitous wildlife populations
(ecological generalists) to increase in numbers at the expense of species with
specialized habitat requirements. Normandeau (1979) described the lentic
systems as containing a much lower habitat and faunal diversity than the lotic
systems. We anticipate that the proposed reservoir would likewise have a low
habitat and faunal diversity compared to the existing lotic habitats.
Ecosystem productivity would be reduced because the reservoir would provide
about 3,400 acres of oligotrophic water in place of the productive wetlands,
floodplains, upland forests and old fields presently existing on site. The
organic carbon production in the existing vegetation communities exceeds that
which would be predicted for the proposed reservoir (Cdum 1971, Wetzel 1975).
The Corps also predicted that Big River Reservoir would be very oligotrophic
(COE, 1981, Appendix E). In addition, reservoir drawdowns associated with
water supply activities would prohibit the development of an emergent
vegetation (littoral) zone which would be the most productive part of the
waterbody. The shoreline would have the familiar bathtub ring around it
similar to that found at other water supply reservoirs in New England since it
would have average drawdowns of 3-6 feet and maximum drawdowns in excess of 30
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feet on an infrequent basis, assuming a 6 cfs release from the dam (OOE, 1981,
Appendix D). However, these drawdowns would be much greater than the 3-6 feet
estimate due to the requirement to maintain the aquatic base flow in the South
Branch Pawtuxet River. The FWS recommended that a minimum flow of 18 cfs be
released from the dam to maintain downstream aquatic communities, hence the
drawdowns would be in the range of 9-18 feet on average with more severe
drawdowns in drought years.
Ecosystem stability would be reduced in our opinion because fewer species of
wildlife would remain in the Management Area and watershed as a result of
removing 3,700 acres of highly diverse habitat from the area. These 3,700
acres contain highly structured and stable vegetation systems as described by
KAME (1976) and Normandeau (1978). Only the gravel mines and roads on the
Management Area would be considered disturbed and hence, unstable
ecologically. The existing food chains would be disrupted and/or eliminated
also. The vegetation present on the study area is responsible for the organic
carbon production that drives the herbivore food chain. These herbivores are
largely represented by insects, small mammals and a single large mammal, the
white-tailed deer. Both Husband (Appendix C) and McCord (Appendix B) made
reference to the mammalian predator-prey system they observed on the study
area. Other predators in this system include the snakes and raptors. Similar
predator-prey relationships exist between insects and songbirds, insects and
amphibians, aquatic and terrestrial insects and fish, fish and their predators
consisting of reptiles, birds and mammals, amphibians and their predators,
again consisting of reptiles, birds and mammals and other more complex
relationships dealing with herbivore-cniruvore-carruvore-decxaiiposer systems and
various combinations of the above. If the project was implemented, the
fluctuations in the reservoir for water supply would cause the impoundment to
remain unstable in an ecological sense. The littoral zone would remain in a
constant flux preventing the establishment of macrophytes and other nearshore
plant and animal communities. This, in turn, would cause the reservoir to be
dominated by algae and diatoms, species that are subject to wide fluctuations
during the annual cycle and from year to year. Due to expected low dissolved
oxygen levels or even anoxic conditions in the hypolimnion, we anticipate the
reservoir to have a very unstable benthic community below the epilimnion
layers. This would be similar to- the "August effect" commonly found in
estuaries such as Boston, New Haven and Bridgeport Harbors. We anticipate the
benthic (ximmunity in these lower levels to be dominated by opportunistic
colonizers such as oligochaetes and chironomid larvae during fall-spring.
During summer stratification, it would likely be devoid of life forms
requiring oxygen for growth or survival.
The fish and wildlife habitat losses associated with the Big River Reservoir
project were investigated and reported on by the Fish and Wildlife Service in
September 1979. The habitat evaluation procedures (HEP) were used to quantify
and display these losses for wildlife in standardized units called habitat
units (HU). The total loss of wildlife habitat as expressed in habitat unit
values is 1,854 habitat units (U.S. FWS, 1979, Table 4). These unit values
were predicted to change slightly during the period of analysis for the
reservoir project (U.S. FWS, 1979, Table 9). Based on the analyses completed
during the planning process, the Service concluded that the construction of
Big River Reservoir would cause significant adverse impacts to fish and
wildlife resources (U.S. FWS, 1979). The significance of these losses
prompted the Service to oppose the reservoir project.
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In a July l, 1988 letter to Governor DiPrete, Colonel Phen, New England
Division, Corps of Engineers, stated that it was his position that the Big
River Reservoir Project would have significant impacts. These significant
impacts include the loss of 570 acres of highly diverse and productive
wetlands by inundation within the proposed impoundment; loss of approximately
150 acres of wetland habitat for the dam construction and roadway relocations;
potential impacts to Mishnock Lake and its adjacent 450 acres of Mishnock
swamp through groundwater fluctuation and loss of freshwater stream habitat to
coldwater fisheries (COE, 1988).
A significant loss of recreational resource values would occur if the Big
River Reservoir is constructed. The Rhode Island Division of Fish and
Wildlife has maintained records on certain uses in the Management Area such as
hunting and fishing. They estimate the Management Area provides 1,000 mandays
of deer hunting, 2,300 mandays of small game hunting, 1,000 mandays of trout
fishing and 800 mandays of warmwater fishing. Opportunities for coldwater
fishing such as stream trout fishing are considered to be in extremely short
supply in Rhode Island (personal communication, V. Lang and J. Stolgitis,
RI F&W). Hence, the loss of the stream trout fishery at Big River is
considered a significant adverse impact. Other recreational activities such
as hiking, mushroom and other edible plant harvesting, bird watching, canoeing
and cycling occur on the Management Area, but accurate estimates of this use
are unavailable. Based on the short distance to the Providence area, we
assume these passive uses exceed traditional consumptive activities (hunting,
fishing). The State of Rhode Island has a statute regulating recreational
uses and other activities on waters used for water supply. It remains unclear
what recreational activities, if any, would be permitted on the proposed
reservoir and adjacent lands and waters in the Management Area.
Given the limited supply and availability of large tracts of highly diverse,
undeveloped land for open space in Rhode Island, we believe the loss of 3,700
acres from the most secluded sections of this tract would constitute a
significant adverse impact on recreational uses and aesthetic values.
We conclude, for the reasons set forth above, that the Big River Reservoir
project does not comply with the provisions of 40 CFR 230.10(c).
Compliance with 230.10(d)
The Big River Reservoir does not comply with this requirement in the
Guidelines. The Congressionally authorized version of this project recognized
that mitigation of fish and wildlife habitat losses was an outstanding issue.
The Congress directed the Corps of Engineers to reevaluate the acquisition of
mitigation lands within one year after enactment of the Act (Water Resources
Development Act of 1986, Title VI, Section 601). This reevaluation has not
been conducted as directed by Congress.
The Fish and Wildlife Coordination Act report dated September 1979 identified
the need to acquire an additional 8,437 acres (evergreen forest-2,464,
scrub/shrub wetland-3,400, forested wetland-2,573) for in-kind compensation of
habitat losses (U.S. FWS, 1979, Table 9). This takes into account management
of remaining lands for wildlife as recommended by FWS. However, if these
remaining lands could not be managed for wildlife, then the requirement for
additional lands outside the Management Area would increase. The Service was
not provided the opportunity during the feasibility study to determine if a
suitable tract or tracts of land were available in Rhode Island to serve as a
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-21-
mitigation area. This issue was raised by Interior in the August 12,. 1982
letter concerning the project. In addition, Interior stated that the
feasibility of finding suitable mitigation lands had not been demonstrated.
Interior also noted a contention by the Corps that additional mitigation lands
should not be acquired because of socio-economic and political complications
(DOI, 1982). We agree with the Corps on this issue that acquisition of
additional lands in Rhode Island for mitigation purposes would be extremely
difficult, if in fact, suitable lands could be located.
It is also important to consider the mitigation plans in light of the
404 (b) (1) Guidelines. This was not done by FWS or other agencies during the
planning process in 1979. Consequently, many of the wildlife management
techniques, especially the high intensity—high profile actions that were
traditionally employed in the past, may themselves no longer be permissible by
today's environmental standards. This is important because much of the
mitigation was to be accomplished through management of existing wildlife
habitat including wetlands. The end result of such a review might dictate a
need for low intensity management on existing wildlife habitat including
wetlands. This would probably require greater acreages than originally
estimated for a suitable compensation plan.
In our discussion on area-sensitive species, we draw attention to a
shortcoming in the 1979 HEP analysis. The models (narrative and verbal) used
in the 1979 analysis did not take into consideration these landscape effects
that are associated with the habitat fragmentation syndrome. We siroply lacked
the empirical data and state-of-art that we now have for evaluating habitat
fragmentation effects. The direct effects of the project on wildlife were
determined based on the flow line (elevation 300 feet msl) of the reservoir in
1979. We now realize that that was an inaccurate assumption. The direct
effects on wildlife extend far beyond the actual footprint of the reservoir.
Direct effects will occur on remaining lands in the Management Area and lands
outside the boundaries of the Management Area. This will drive the area
needed for in-kind compensation much higher than the 8,437 acres originally
determined in 1979. An exact figure has not been determined.
During the 10-year period since the original mitigation proposal was developed
by the Service for the Big River Reservoir, we have had the opportunity to
study wetland mitigation projects including wetland creation. Most of these
attempts have either been failures or have met with very limited success. The
best, but limited, success rate has been for herbaceous wetlands, followed in
decreasing order by scrub/shrub and forested wetland. We remain unaware of
any reports where successful restoration or creation of forested wetlands has
occurred. In recent meetings with COE, EPA, FWS, ConDOT and consultants and
ConDEP on the CCE and 191/291 highway projects in Connecticut, all agencies
present agreed that it was impossible to create a forested wetland to replace
those that would be lost if certain highways were constructed as proposed.
The best that could be hoped for would be to create a scrub/shrub wetland
which over a long period of time (>100 years) might grow and mature into a
forested wetland. When the landscape features are added into this mitigation
problem, the outcome looks even more dubious. The majority of these forested
and scrub/shrub wetlands in Big River are associated with a stream system.
Thus, in order to replicate the functions and values of those being lost, a
similar stream system would need to be created or one found without floodplain
wetlands. We seriously doubt that either of these are doable in Rhode Island
or elsewhere.
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In our cpinion, it is impossible to compensate for the forested and
scrub/shrub wetland losses and landscape effects that would occur if the Big
River Reservoir is constructed. These landscape effects include: the loss of
16.9 miles of free-flowing warm- and coldwater streams, their attendant ponds,
floodplains, tributaries, groundwater seeps and living resources; the loss of
3,700 acres of highly diverse wildlife habitat consisting of mixed forest,
softwood forest, hardwood forest, old fields, floodplains, wetlands, ponds and
streams with complex juxtaposition patterns, serai stages and vegetation
composition; the loss of a highly diverse fauna utilizing the wildlife habitat
and; the loss of 3,700 acres of secure forest-interior habitat from the center
of a 8,270 acre tract of land in a highly urbanized region.
In conclusion, we believe it would be extremely difficult, if not outright
impossible, to design and successfully implement a compensation plan to
replace the functions and values lost because this is clearly beyond the
current state-of-art in mitigation planning.
We conclude, for the reasons set forth above, that the Big River Reservoir
project does not comply with 40 CFR 230.10(d).
VIII. Conclusions
The Fish and Wildlife Service has had the opportunity to review the Big River
Reservoir Project on three separate occasions during the last decade. Our
views of the project have not changed appreciably during this decade. We
identified the project as having significant adverse impacts to fish and
wildlife resources, including wetlands and other aquatic habitat, at the time
the Coordination Act Report was published on September 28, 1979. Based on
this review, the Service formally opposed the project due to predicted adverse
impacts on fish and wildlife resources. In 1982, the Service again
participated in the Departmental level review of the project. As a result of
views and concerns of the Service, the Department of Interior raised
significant issues concerning the need for the project and its environmental
acceptability. As you know, these views were raised by Interior during and
despite a very sensitive time for environmental agencies attesting to the
gravity of the situation at Big River. Our present review reinforces
conclusions reached in earlier reviews. The project would have unacceptable
adverse impacts on wildlife and fishery resources. The environmental case
against the Big River Reservoir has grown stronger during this decade as a
result of information on forest-interior species, species with fidelity to
natal areas, the failure of most wetland mitigation projects to work and the
recognition that landscape features associated with large wetland systems such
as Big River cannot be mitigated except by avoidance.
Therefore, we request that you prohibit the use of Big River, Mishnock River,
their tributaries and adjacent wetlands as disposal sites for the reasons
discussed in this report. Please feel free to contact me with any questions
at 603-225-1411 or PIS 834-4411.
y yours,
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TABLE 1
Birds Nesting on Big River Management Area that Are Closely Associated with
Aquatic Habitats
American Black Duck
Barred Owl
Belted Kingfisher
Canada Goose
Common Yellowthroat
Gray Catbird
Green-backed Heron
Louisiana Waterthrush
Mallard
Northern Waterthrush
Red-shouldered Hawk
Red-winged Blackbird
Spotted Sandpiper
Swamp Sparrow
Veery
Virginia Rail
Wood Duck
Yellow Warbler
TABLE 2
Area-Sensitive Birds Nesting on Big River Management Area
Forest-Interior Interior-Edge
Acadian Flycatcher
American Redstart
Barred Owl
Black-and-White Warbler
Black-throated Green Warbler
Broad-winged Hawk
Brown Creeper
Canada Warbler
Cooper's Hawk
Hairy Woodpecker
Hermit Thrush
Louisiana Waterthrush
Northern Goshawk
Northern Waterthrush
Ovenbird
Red-breasted Nuthatch
Red-shouldered Hawk
Scarlet Tanager
Veery
White-breasted Nuthatch
Worm-eating Warbler
American Goldfinch
American Crow
Black-capped Chickadee
Blue Jay
Blue-gray Gnatcatcher
Common Yellowthroat
Downy Woodpecker
Eastern Phoebe
Eastern Wood-Pewee
Gray Catbird
Great Crested Flycatcher
Northern Cardinal
Northern Flicker
Red-eyed Vireo
Rose-breasted Grosbeak
Ruffed Grouse
Rufous-sided Townee
Tufted Titmouse
White-eyed Vireo
Wood Thrush
Yellow-billed Cuckoo
Yellow-throated Vireo
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D. Bystrak. 1981. Effects of forest fragmentation on avifauna of the
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APPENDIX III
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Appendix III: WATER SUPPLY ALTERNATIVES
John J. Boland, Ph.D., P.E.
Professor of Geography and Environmental Engineering
The Johns Hopkins University
The Big River Reservoir, as proposed by the U.S. Army
Corps of Engineers and the Rhode Island Water Resources Board,
is intended to provide additional public water supply in the
greater Providence area.1 More than 100 documents were
examined in the course of this review. I have employed a
conventional planning approach using procedures consistent
with the Principles and Guidelines published by the U.S. Water
Resources Council.
To evaluate the project purpose, it is necessary to first
review the projections and assumptions that give rise to the
stated needs, then to consider alternative means of satisfying
them. The following sections summarize some the early water
supply documents and describe and evaluate the need for the
proposed project, showing the sensitivity of the Corps'
conclusions to certain key assumptions. This is followed by
a survey of demand management and supply augmentation
alternatives available to the State. It is shown that (1)
likely future need is much less than projected by the Corps
in 1982; (2) various feasible and cost effective measures are
available which would reduce need still further; and (3) a
wide range of practicable, cost effective, and environmentally
less damaging supply alternatives are available.
Water Supply Studies Before 1980
Early State-wide water resource studies include C.A.
Maguire & Assoc. (1952), Metcalf & Eddy (1967), and Report No.
10 of the Rhode Island Statewide Comprehensive Transportation
and Land Use Planning Program (1969). All of these studies
discuss potential shortfalls in public water supply capacity
and mention the Big River Reservoir, among other alternatives,
as a possible means of increasing supply.
The 1952 C.A. Maguire & Assoc. study projects water use
from public supplies to be 112.83 MGD by the year 1980, based
on an assumed population of 950,000. [Actual 1980 population
1 The Corps project would also include the purposes of flood
control and recreation.
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for Rhode Island was 946,154, although total water use for 23
of the 25 largest systems had reached only 104.8 MGD by 1985
(Corps, 1986).] For the year 2001, Maguire projects water
withdrawals from public systems of 144.66 MGD, based on a
population of 1,070,000. Water use projections are the result
of simple per capita calculations, where per capita water use
(91 gpcd State-wide in 1950) is assumed to grow linearly to
135 gpcd in 2001.
Maguire concludes that, as of 1950, existing sources are
inadequate to meet projected demand. Seven possible surface
water developments are evaluated. Of these, the Big River
Reservoir is judged most cost-effective on the basis of a
total projected cost of $5.87 million, estimated in 1952
dollars. Converting this amount to 1989 dollars gives a
project cost of approximately $32 million.
The Metcalf & Eddy study, completed fifteen years after
Maguire's analysis, takes a more optimistic view of population
growth within the State, projecting 1,209,000 persons by the
year 2000, and 1,406,000 by 2020. Water use projections are
the result of a simple per capita calculation, as in the
Maguire study, but Metcalf & Eddy assume a decreasing rate of
growth in the per capita coefficient. Nevertheless, projected
2020 coefficients fall in the range of 150-200 gpcd. The
resulting State-wide forecasts for water withdrawals from
public systems are 168.03 MGD for 1990 and 242.04 MGD for
2020. Interpolating these projections gives a 2001 estimate
of about 195 MGD, substantially in excess of Maguire's
projection of 144.66 MGD.
Metcalf & Eddy, like Maguire, finds existing water system
capacity inadequate for projected needs (combined dependable
yield for all systems is estimated at 150 MGD), recommending
the development of additional surface water impoundments. A
major component of these recommendations is the construction
of the Big River Reservoir, at an estimated 1967 cost of $23.2
million, to include the treatment plant and finished water
aqueduct. This cost is equivalent to approximately $92
million, when measured in 1989 dollars.
The report of the State-wide comprehensive planning
program, published in 1969, predicts a 1990 population of
1,105,000. Following the practice of Maguire and Metcalf &
Eddy, water use is estimated on the basis of a simple per
capita relationship, giving a 1990 estimated need of 174 MGD.
Per capita use is based on 1965 statistics and is assumed to
grow by 1.5 gpcd each year. Possible water use trends after
1990 are discussed, but no projections are provided.
The discussion of water supply alternatives is based on
the earlier Metcalf & Eddy study, including the recommendation
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for the construction of the Big River Reservoir. The State
study includes separate analyses of projected demand/supply
balances in each of four major areas and 29 individual
planning districts. The results indicate that 23 of the 29
districts (and all four of the major areas) will experience
supply shortfalls by 1990. The State-wide deficit is
projected to be 21.85 MGD. Allowing for a 25 percent margin
of safety, this is said to indicate a capacity shortfall of
66.76 MGD. Specific recommendations call for completion of
the Big River Reservoir prior to 1980. A revised cost
estimate is provided, now $36.7 million measured at 1969
prices ($129 million in 1989 dollars).
DETERMINATION OF NEED
Big River Feasibility Study
The Corps Big River reservoir feasibility study follows the
methods of the earlier studies discussed above, and arrives
at similar conclusions (Corps, 1981a, 1981b). The Corps
report defines a study area consisting of the existing service
areas of the Providence Water Supply Board (PWSB), the Bristol
County Water Authority (BCWA), and the Kent County Water
Authority (KCWA), plus the communities of Foster and
Glocester. This area contained 571,187 people in 1980, and
is projected to reach a total population of 655,100 in the
year 2000, and 736,900 by 2030 (Corps, 1982, p. 2). The
number of residents expected to be served by public water
systems is slightly smaller, 633,700 in 2000 and 730,800 in
2030. These latter projections represent average annual rates
of growth of +0.52 percent for 1980-2000, and +0.48 percent
for 2000-2030.
Based on estimated average day water use of 71.8 MGD for
the study area in 1975, the Corps forecasts unrestricted year
2000 demands on public systems at 98.6 MGD, and 128.2 MGD for
2030 (Corps, 198la). Average annual growth rates implied by
these water use projections are +1.28 percent for 1975-2000,
and +0.88 percent thereafter.
Consideration of the possible implementation of water
conservation measures led the Corps to produce alternative
forecasts of restricted average day water use as part of the
original study, and to further reduce those alternative
forecasts in a supplemental study (Corps, 1982) . The revised
restricted (with water conservation) forecast is 89.8 MGD for
2000 and 114.2 MGD for 2030. These estimates reflect average
annual water use growth rates of +0.90 percent for 1975-2000
and +0.80 percent for 2000-2030. In every case, therefore,
water use is predicted to grow substantially faster than study
area population.
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The Corps estimates the capacity of existing sources
available to water utilities within the study area at 91.1 MGD
(average day yield under drought conditions, as of 1975)
(Corps, 1981b, p.A-51) . This estimate assumes a dependable
yield of 77.0 MGD for the Scituate Reservoir system of the
PWSB. Bristol County is assumed to retain its existing
surface and ground water systems (3.2 MGD), and Kent County
will maintain its current supply capability (estimated by the
Corps at 10.9 MGD). The Corps further assumes that the BCWA
will develop 3.0 MGD of new ground water capacity, bringing
the total future supply to 94.1 MGD (Corps, 1982).
In the absence of water conservation, Corps water use
projections indicate that existing capacity will be fully
utilized by 1997, and that a deficit of 34.1 MGD will exist
by 2030. Implementation of the assumed levels of water
conservation would defer the need for new capacity by a full
decade to 2007, producing a year 2030 deficit of 20.1 MGD
(Corps, 1982, p. 4 and Plate 2).
Water Use Forecast
The Corps Forecast
The Corps forecast future water use by a modified per
capita method, based on population and nonindustrial water use
data for 1975. Industrial withdrawals from public systems
were estimated at 14.21 MGD, based on a 1971 study by the
Rhode Island Water Resources Board. This amount was
subtracted from 1975 water deliveries prior to calculation of
per capita coefficients. Industrial uses were projected
separately using a growth factor said to incorporate economic
and technological parameters. No details of this method are
provided, and no separate results are reported (only combined
industrial and residential/commercial water use is stated for
future years). Reconstruction of the Corps' calculations,
however, indicates that industrial withdrawals are expected
to grow from 14.21 MGD (1975) to 17.66 MGD (2000) to 28.12 MGD
(2030) .
Remaining water use, identified as residential and
commercial use, was projected on the basis of a simple per
capita calculation. The estimated per capita coefficient for
1975 (calculated separately for each subarea, but averaging
111.3 gpcd over the entire study area) was increased by 0.80
gpcd/year until the year 2000 and by 0.33 gpcd/year
thereafter. The slower rate of increase after 2000 is said
to reflect an expected increase in public awareness of water
conservation. Areas presently without public water service
were assigned coefficients of 70 and 80 gpcd for 2000 and
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2030, respectively, except for the Village of Glocester, where
85 and 95 gpcd were used (Corps, 1981b, p. A-49).
The initial Corps report adopted population projections
developed by the State in 1975, as well as revised projections
completed in 1979 (Corps, 1981a). The 1975 projections
anticipate State-wide population of 1,173,600 by 2000, while
the 1979 revised prediction is for 1,005,600 persons. The
later, supplemental analysis incorporates 1980 OBERS
projections, which predict a year 2000 State population of
1,086,400 (Corps, 1982).
Projected totals for residential/commercial and
industrial water use were combined to give a water use
forecast for the study region. The results are equivalent to
aggregate per capita use rates of 155.6 gpcd for 2000 and
175.4 gpcd for 2030. After deducting 9.0 and 11.0 percent,
respectively, for water conservation the effective aggregate
use rates are 141.7 and 156.3 gpcd. The comparable figure for
1975 (based on Corps estimates of residential, commercial and
industrial water use) is 123.9 gpcd.
Critique
The water use forecast presented by the Corps is suspect
on several grounds. The first concerns the results obtained
and their reasonableness in the light of data currently
available. The Providence region already experiences
nonindustrial per capita water use that is comparatively high
by U.S. urban standards. Data for 1981, for example, indicate
that per capita residential use, while highly variable,
averaged 82 gpcd in a nationwide sample, well below the
apparent level in the PWSB area (Boland, 1983, p. 4.16; Corps,
1981b, p. A-21) . This discrepancy is due, in part, to an
exceptionally low price level existing in the PWSB retail area
(Boland, 1988) . On this basis, further growth in per capita
use appears unlikely.
In fact, no growth in per capita water use is evident in
the region. This can be illustrated by considering the PWSB
service area, which included 80 percent of the study area
population in 1975 and an even greater percentage of the
industrial water use. The Corps measured 1975 water use in
the PWSB area at 62.4 MGD for an estimated population served
of 416,800, giving overall (including industrial) average use
of 149.7 gpcd (Corps, 1981b, p. A-21). Testifying before the
Rhode Island Public Utility Commission in 1988, PWSB General
Manager Mainelli gave 1987 total water use at 30,236,605
hundred cubic feet and total population served at 500,000
(Mainelli, 1988, pp. 1, 2). Mainelli's figures, therefore,
place 1987 PWSB per capita use at 123.9 gpcd, more than 17
-------
percent below the level of 12 years earlier. Although actual
population served is somewhat uncertain, other estimates
available for the year ended June 30, 1986, imply average use
rates in the range of 107 to 138 gpcd, all significantly below
the Corps 1975 estimate (Chernick, 1988, p. 16; PWSB, 1986,
p. 717).
Nevertheless, the Corps projects rapidly rising per
capita use for fifty years into the future, even in the
presence of water conservation measures. This is contrary to
trends observed elsewhere in the U.S., where per capita rates
are typically stable or falling, and it is exactly contrary
to trends observed in the PWSB area. No discussion or
justification for this result appears in the Corps reports.
The second forecast issue concerns the forecast
techniques employed, especially with respect to use of the per
capita method and the way in which key assumptions were
generated. The only water use data analyzed by the Corps are
for 1975. No adjustment was made for economic conditions,
weather conditions, or for any other factor that may have made
1975 water use data unrepresentative. Also, the population
estimate used for 1975 was subsequently shown to be overstated
(1980 Census count was less the 1975 estimate in most
subareas), yet the basic assumptions were not revised.
The only disaggregation performed was to separate
industrial use from other use, and to project industrial use
on the basis of a 1971 study. There is no indication that the
fact of sharply falling levels of industrial water use,
observed throughout the nation after implementation of the
Clean Water Act in the late 1970's, had any role in the
industrial forecasts. Changes in the composition of
industrial activities, in Rhode Island and elsewhere, away
from water-using "smokestack" industries and in the direction
of more service-oriented, low-water-using activities, are
similarly ignored. In fact, the Corps projected industrial
water use to grow faster than any other sector of water use
through the year 2030.
Non-industrial water use, consisting of residential,
commercial, institutional, and public uses, is not
disaggregated for forecasting purposes, even though individual
sectoral trends are likely to differ. The simple per capita
method used precludes any consideration of anticipated changes
in housing type, household size, income, water price, water
using appliances, commercial and institutional activity types
and levels, weather, water conservation practices, and water
use restrictions. A number of forecasting methods, available
and in common use at the time of this study, are capable of
incorporating some or all of these explanatory variables
(Boland, 1978; Boland, et al.. 1983; and Jones, et al^.. 1984).
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Nevertheless, in a large and complex study area, the Corps
elected to use a method which considers only two explanatory
variables: population and rising per capita water needs.
Finally, the implementation of water conservation is
associated with very modest reductions in forecast water use
(9.0 percent in 2000 and 11.0 percent in 2030). The
conservation program assumed to produce this result is not
described, nor are the methods used to formulate it or the
assumptions employed in estimating effectiveness. As
discussed below, concerted efforts to achieve water
conservation in the Providence area would produce
substantially larger reductions.
Existing Supply capacity
The Corps study defines supply capacity as the sum of the
safe yields of existing surface and ground water facilities.
Safe yield (or dependable yield) is defined, in turn, as the
uniform rate of withdrawal which could be sustained throughout
a repetition of the 1965-1966 drought, assuming that 100
percent of usable storage is available at the beginning of the
drought period (Corps, I981b, pp. D-22 to D-23) . On this
basis, 1975 supply capacity is calculated at 91.1 MGD (Corps,
1981b, p. A-51).
Incorporated in this calculation is a figure of 77 MGD
for the dependable yield of the Scituate Reservoir system.
This estimate was increased from an earlier Corps estimate of
72 MGD. Yet, in recent testimony before the Rhode Island
Public Utility Commission, a witness for the PWSB give the
available safe yield of the facility at 80.3 MGD (Archer, p.
10) . Another witness argued that certain disputed
commitments for future supply to others had been improperly
deducted, and that the dependable yield is more accurately
stated at 89.3 MGD (Copeland, pp. 7-9).
Similarly, the Corps estimate of the dependable yield of
the BCWA system (3.2 MGD) is at the lower bound of the range
of opinion. The most recent available study places the
combined yield of the surface water and ground water systems
at 4.0 MGD, even after allowing for lost reservoir capacity
due to siltation (Camp, Dresser & McKee, 1989, p. 2-4).
Sensitivity of Need to Key Assumptions
If Corps estimates of future water use and supply
capacity are accepted, existing facilities will be adequate
until the year 2007 (Corps, 1982, Plate 2). A supply deficit
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is projected for later years, growing to a level of 34.1 MGD
by 2030. This reflects the following results of the Corps
analysis:
Dependable yield —
Existing sources 91.1 MGD
New BCWA ground water 3.0 MGD
Total Supply 94.1 MGD
Projected water use —
2030, w/o conservation 128.2 MGD
2030 Surplus (deficit) (34.1 MGD)
An alternative Corps projection, incorporating an allowance
for water conservation, reduced projected water use to 114.2
MGD, giving a year 2030 deficit of 20.1 MGD.
However, these results are highly sensitive to the
underlying assumptions. The following adjustments to Corps
assumptions appear warranted in this analysis given more
current information:
o PWSB estimates that the dependable yield of the Scituate
Reservoir is 89.3 MGD, and that 9.0 MGD must be released
to the North Branch Pawtuxet River. This leaves an
available yield of 80.3 MGD, 3.3 MGD higher than the 77
MGD used by the Corps.
o The Corps assumed that BCWA would shortly develop an
additional 3.0 MGD of ground water capacity. To date,
no additional wells have been drilled in Bristol County,
and there are no current plans to do so.
o The Corps estimated the dependable yield of the BCWA
system at 3.2 MGD. In 1989, a consultant for BCWA
estimated yield at 4.0 MGD, 0.8 MGD higher than the Corps
assumption.
o Per capita use has not increased in the study area since
1975, and it is unlikely to do so in the future. In
fact, the PWSB area reports a significant decrease. If
per capita use is held constant at 1975 levels (more than
20 percent above the 1986 level reported by PWSB), and
if the Corps population projections are accepted,
projected residential and commercial water use for 2030
will be 21.5 MGD below the Corps forecast.
o No rationale is offered for the Corps projection of
rapidly increasing industrial water use. In fact,
industrial water use is decreasing throughout the U.S.
If industrial use in the study area is held constant at
8
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1975 levels, the year 2030 projection will be 13.9 MGD
below the Corps projection.
The effect of these adjustments can be shown:
Dependable yield —
Corps estimate 94.1 MGD
Addtl.Scituate yield 3.3 MGD
BCWA ground water (3.0 MGD)
Addtl.BCWA yield 0.8 MGD
Total supply 95.2 MGD
Projected water use —
Corps, 2030 128.2 MGD
Stable per capita rates(21.5 MGD)
Stable industrial use(13.9 MGD)
Total water use 92.8 MGD
2030 Surplus (deficit) 2.4 MGD
In the absence of more detailed supply studies or water
use forecasts, these adjusted figures are believed to
represent reasonable estimates of future water use and water
supply. They are conservative estimates, in that dependable
yield is calculated at a very high level of reliability
(approximately a 1.0 percent level, as discussed below) and
no decrease in water use rates is assumed after 1975, despite
evidence to the contrary.
ALTERNATIVES
The need for the water supply capacity of the proposed
Big River Reservoir, as stated in the feasibility study, has
little foundation in fact or analysis. Using modified, but
still conservative assumptions regarding supply capability and
water use, no new supply is needed before the year 2030.
However, even if the Corps' most generous needs assessment
were to prove accurate, there exists a wide range of
practicable and less environmentally damaging alternatives to
Big River. This section reviews the major categories of
available alternatives.
Water supply capacity needs can be met in various ways.
Given some set of water use forecasts and supply capacity
estimates, any predicted shortfall can be reduced or
eliminated either by decreasing water use (demand management),
by increasing supply (supply management), or by a combination
of these strategies.
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Demand management consists of various long-term water
conservation measures (including changes in pricing policy)
as well as temporary, short term water use reduction programs
(drought management) . These measures, and all of their
variants and combinations, comprise the set of alternatives
which must be considered in any response to a water supply
"need".
Supply management includes increases in the effective
yield of existing sources, new surface water sources, new
ground water sources, and the reclamation of other waters such
as brackish water and mineralized or contaminated ground
water.
Demand Management
The water resource planning literature often uses the
terms "demand management" and "water conservation"
interchangeably. One widely accepted view, which defines
water conservation as "any beneficial reduction in water use
or in water losses," tends to support this usage (Baumann, et
al.. 1979, p. 12). Any step taken to reduce water use
(conserve water) is a demand management measure, and vice
versa.
For purposes of discussion, however, it is helpful to
divide demand management measures into several categories.
One important distinction can be made according to the time
frame of implementation. The term "water conservation" will
be applied to actions and policies sustained over a long
period of time, in the interest of securing a permanent
reduction in water use. These measures are further divided
into (1) those implemented solely through pricing policy and
(2) other long-term conservation methods. The remaining
demand management measures are implemented as needed, for
relatively short periods of time. These measures, triggered
by temporary supply inadequacy, comprise drought management
practices.
Pricing Policy
The amount of water used within any area depends, among
other things, on the price at which it is sold. Economists
speak of the demand for water as typically inelastic, meaning
that the quantity demanded varies less than proportionately
with changes in price. In this respect, water is similar to
other staple goods which are regarded as necessary to normal
everyday life.
10
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A recent review of more than 60 studies of water demand
concludes that the long run price elasticity for public water
supply is -0.10 or less in the winter, and, in the eastern
U.S., in the range of -0.50 to -0.60 in the summer (Boland,
et al. . 1984). The significance of these findings can be
illustrated by considering the impact of the recent rate
increase granted to the PWSB.
1988 PWSB Rate Increase
In 1988, the Rhode Island Public Utilities Commission
authorized the Board to revise its rates so as to collect an
additional $4,237,251, an increase of approximately 37 percent
in total revenue (RI PUC, 1988). This increase will reduce
water use noticeably and permanently (provided rate level is
adjusted periodically to reflect general price inflation).
Although data needed for a more exact calculation are not
available from the PWSB, the following will illustrate the
approximate magnitude of the adjustment.
It is assumed here that the increase is applied uniformly
across-the-board (actually, some rate restructuring was done) .
This results in a 37 percent price increase for those
residential customers with water use under the wastewater free
allowance (200 gpd/household). Other customers, who must pay
an additional $1.05 per hundred cubic feet ($1.05/HCF) for
wastewater service, will perceive a smaller percentage
increase in the total cost of water use: approximately 8.4
percent. Data provided by the Narragansett Bay Commission
indicate that households with water use below 200 gpd
accounted for 1,482 MG during calendar year 1987 (Narragansett
Bay Commission, 1988). Other water use data are provided in
Boland (1988, p. 52). The calculation is shown as Table A2-
1.
As shown on Table A2-1, the overall effect of a permanent
price increase of 37 percent applied across-the-board is to
reduce annual water use by 3.6 percent, compared to use levels
in the absence of the rate change. This reduction is a long
run estimate. Normally, less than half of such a change will
be evident within the first year, with the remainder appearing
gradually over the next five to ten years. In the case of
Providence, a temporary surcharge (expired July 1, 1989, with
provisions for renewal) of $0.085/HCF may accelerate the
adjustment process, without necessarily affecting the size of
the long-run result (RI PUC, 1988, Order, paragraph 10).
11
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Table A2-1.—Estimated Impact of 1988 PWSB Rate Change
FY 1987 water use before price change —
Summer
Winter
Total
households
below
200 and
860 MG
622 MG
1,482 MG
all
other
customers
12,480 MG
9.038 MG
21,518 MG
Totals
13,340 MG
9.660 MG
23,000 MG
FY 1987 water use after price change —
Residential customers below 200 cmd/household
Summer 860 * (1.37)"0'6 = 712 MG
Winter 622 * (1.37)'0'1 = 603 MG 1,315 MG
All other customers
Summer 12,480 * (1.084)"0'6 = 11,890 MG
Winter 9,038 * (1.084)'0'1 = 8.965 MG 20.855 MG
Total 22,170 MG
(-3.6 %)
The impact of a price change can be further magnified by
altering the structure of rates, as well as their level. One
alternative is to adopt a summer-winter differential,
reflecting the higher cost of service associated with serving
summer demands. Since summer demand is also much more elastic
than winter use, directing more of the increase to summer
prices augments the expected water use reduction. If 100
percent of the increased revenue in the above illustration
were obtained from summer rates, for example, the overall
water use reduction would be more than 5 percent.
The effect of a permanent 3.6 percent water use reduction
in the PWSB area (such reductions are permanent if rate levels
thereafter keep pace with general price inflation) is to
reduce year 2030 water use for the Big River study area by 2.8
MGD. This comparatively modest water use reduction reflects
the very low level of existing PWSB charges, especially when
compared to wastewater charges. As water prices increase in
the future, a given percentage increase in water price will
produce a larger percentage increase in the total cost of
12
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water and wastewater service. The result will be increased
sensitivity of water use to changes in water prices.
Future Policy Options
Other tariff design possibilities include the adoption
of uniform (unblocked) rates, the elimination of preferential
rates to industrial customers, changes in the fraction of
total revenue recovered through the commodity charge,
increasing block rates, summer surcharges, and excess use
charges. All of these strategies have the potential of
securing further reductions in water use for a given increase
in total revenue. Testimony in the 1988 rate case indicates
that the PWSB expects to make further changes to its tariff
design in the interest of water conservation (Russell, 1988).
Also, future increases in wastewater charges levied by the
Narragansett Bay Commission, or any reduction in the
residential free allowance (now 200 gpd/dwelling unit) would
bring about further decreases in water use.
Actual construction and operation of the Big River
Reservoir would add a large, though yet undetermined increment
to the PWSB revenue requirement.' While the magnitude of these
changes cannot be estimated at this time (pending further data
on total project cost, the share to be borne by the PWSB, and
the future rate-making policy of the Board), the result would
be an upward adjustment in rate level, with a corresponding
decrease in water use.
It can be seen that already-implemented changes in water
rate levels and tariff design, coupled with the probability
of further changes in the future, will result in steadily
decreasing water use levels, compared to levels projected on
the basis of pre-1988 rates. Based on actions already taken
or planned for the future, ultimate reductions in the range
of 5-10 percent appear likely. A mid-range estimate of 7.5
percent reduction through rate redesign, reduced by the 3.6
percent estimated to be already achieved, gives an additional
3.9 percent still likely to occur as a result of rate-making
policy initiatives. Assuming, again, that these changes occur
only in the PWSB service area, the year 2030 impact is a
reduction of 3.0 MGD.
13
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The price effects discussed have the following impact on
supply planning:
Dependable yield —
Corps estimate 94.1 MGD
Addtl.Scituate yield 3.3 MGD
BCWA ground water (3.0 MGD)
Addtl.BCWA yield 0.8 MGD
Total supply 95.2 MGD
Projected water use —
Corps, 2030 128.2 MGD
Stable per capita rates(21.5 MGD)
Stable industrial use(13.9 MGD)
1988 rate change (2.8 MGD)
Rate re-structuring (3.0 MGD)
Total water use 87.0 MGD
2030 Surplus (deficit) 8.2 MGD
Other Lona-Term Water Conservation
Present Status
The urban portions of the study area are fully metered
and some efforts are made to locate and repair distribution
leaks. Rhode Island Public Law 89-326, adopted January 1989,
provides for the mandatory installation of ultra-low flush
toilets (1.6 gallons/flush) in all new construction.
Otherwise, there is little water conservation activity in the
Providence area at the present time. The Rhode Island Public
Utilities Commission found the PWSB to have "no policy or
directives" on water conservation, "no public education
program," "no program of technical assistance for water use
reduction" for any user class, "no staff trained in,
experienced with, or devoted to conservation matters" (RI PUC,
1988, p. 33) .
Testifying before the Commission in the same docket, Juan
Mariscal of the Narragansett Bay Commission (NBC) testified
that the NBC has recently spent as much as $75,000 per year
on public information largely directed to reducing wastewater
flows, but that the PWSB has taken no action on water
conservation (Mariscal, 1988).
Some additional efforts have been undertaken in Bristol
County, and possibly in one or more of the PWSB wholesale
service areas. Certain individual water users have doubtless
taken steps to conserve water, despite the very low economic
incentive for doing so. However, available evidence,
including current water use levels, suggest that few
conservation practices are in general use at this time.
Table A2-2 lists the general types of water conservation
measures that could be consiBfered for the Big River study
area. Among these are measures which seek to influence the
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Table A2-2.—Potential Water Conservation Measures
Management measures (to be implemented by water supply
agencies or other units of government)
Universal metering
Improved meter maintenance
Distribution pressure regulation
Leak detection and repair
System rehabilitation
Economic incentives (e.g., rebates, credits, subsidies,
or penalties for changes in appliances,
landscaping, etc.)
Distribution of water conservation kits
Distribution and installation of other water-saving
devices
Distribution of leak detection kits
Recycling water treatment plant washwater
Regulations (to be implemented by State or local government)
Plumbing codes for new structures
Retrofitting requirements
Changes in landscape design
Water recycling
Growth controls
Conservation Education (by government, water supply agency,
or non-governmental organization)
Direct mail campaign
News media
Personal contact
Special events
Source: Boland, et al.. 1982, pp. 14-15.
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type of plumbing fixtures installed, either through economic
incentive, plumbing codes, or retrofitting requirements. A
list of fixtures potentially targeted by such measures is
provided as Table A2-3.
Water Conservation Program Formulation
Shortly before the publication of the Big River
feasibility study, the Institute for Water Resources of the
Corps of Engineers developed and promulgated a standard
procedure for formulating and evaluating urban water
conservation programs (Baumann, et al.. 1980). The procedure
consists of two major phases, with a number of specific steps
in each. In the first "Measure Specific" phase, a list of all
possible water conservation measures is prepared. Each of
these measures is subjected to the following tests:
Applicability—does the measure apply to water uses
actually present in the service area?
Technical feasibility—can the measure be implemented and
will it actually reduce water use?
Social acceptability—will the measure be acceptable to
water users?
Implementation conditions—what is required to implement
the measure and what will implementation cost?
Effectiveness—what quantitative reduction in water use
will occur?
Advantageous effects—what other benefits will accrue,
if the measure is implemented (e.g., energy
savings)?
Disadvantageous effects—what other costs will appear,
if the measure is implemented (e.g., brown
lawns and shrubs)?
In the second, "Project Specific" phase, the benefits of
water use reduction are calculated by determining foregone
supply cost: the amounts that the water supply agency will
save, now or in the future if a certain water use reduction
can be achieved. Measures which survive the first stage
screening are then combined in various ways and evaluated.
The final result is the water conservation plan which achieves
the largest aggregate reduction in water use while producing
benefits at least equal to costs. In most cases, benefits
appear principally in the form of foregone water supply costs,
while costs are dominated by initial implementation expense.
Big River Reservoir Cost Estimates
Since the primary motivation for water conservation in
the eastern U.S. is the avoidance of current or future water
supply costs, the expected costs of the Big River project form
the basis of any conservation evaluation. Future supply costs
will depend upon the actual cost of construction as well as
incremental operating, maintenance, and administrative costs.
15
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Table A2-3.—Plumbing Fixtures Considered in Conservation Plans
shallow trap toilet shower flow-control devices
vacuum toilet pressure-reducing valves
incinerator toilet toilet inserts
pressurized flush toilet faucet aerators
wastewater recycling toilet faucet flow restrictors
oil flush toilet
freeze toilet
packaging toilet
composter toilet
dual flush toilet
micropore toilet
water recycling system
low flow showerheads
water dams
toilet flush adapters
shower mixing valves
air-assisted showerheads
spray taps
pressure balancing mix valves
hot water pipe insulation
swimming pool covers
low water-using dishwashers
low flush toilets
minimum use-showers
hose meters
low water-using clotheswashers
moisture sensors
sprinkler timers
thermostatic mixing valves
Source: Boland, et al.. 1982,.pp. 14-15,
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Two different measures of cost can be calculated. The
average cost measure spreads the total cost of the project
over all units of water to be produced. Characterizing costs
in this way implicitly compares the project to the no-action
alternative (Big River is never built). Marginal cost,
identified here as incremental cost savings realized by
slightly deferring the project, measures the incremental value
of the water under the assumption that the project will
eventually be built. It compares one development scenario to
another. Both cost measures are presented here.
Recent estimates place construction cost at $281,796,000,
including the proposed treatment plant and transmission
conduit (Keyes Assoc./Metcalf & Eddy, 1988) . No data are
available for operation and maintenance costs, variable
treatment costs, or pumping costs. Unit capital costs can be
calculated from the information given, however, if a number
of assumptions are made. These are based on the Corps
analysis, and are presented here for the sole purpose of
estimating costs.
o Incremental costs of water produced at Big River will be
at all times higher than for all other sources, including
the Scituate reservoir, so that total cost is minimized
by using Big River water last.
o Big River water will not be needed before the year 2007,
according to the most recent Corps projections.
o Use of Big River water will increase by equal annual
increments from 2007 to the year 2030, when it will be
used at an average rate of 20.1 MGD (according to Corps
projections).
o Water withdrawals from the Big River will continue to
increase after 2030 at the same rate until project
capacity of 31.9 MGD is reached in 2044.
o Construction will occur during the 2002-2006 time period,
with equal cash outlays in each of five years.
o A discount rate of 9.0 percent/year and a planning
horizon of 50 years are appropriate.
Construction postponement to 2002 and continued post-2030
growth are assumed in order to provide the lowest possible
cost measures. An assumption of immediate construction would
increase all costs cited here by a factor of 2.8. Since Rhode
Island already owns the land for the proposed reservoir,
putting off the construction of the dam will only save money
in real dollars. The reason the cost of the reservoir is
greater today than estimates 10 and 20 years ago stems from
further engineering studies of the necessary costs.
Because of the slow increase in projected utilization of
Big River, average cost is found by computing the levelized
unit cost of water delivered from the proposed reservoir.
16
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This unit cost should include all incremental operating,
treatment, pumping, and maintenance costs plus the capital
cost. However, data are only available for capital cost at
this time. These data give a levelized unit cost, stated in
1989 dollars, of $9,136.97/MG (6.83/HCF). This cost is the
amount which, if collected for each unit of water projected
to be delivered by Big River over the planning period, would
produce a stream of revenue exactly equal, at present value,
to the estimated construction cost.
The average cost can also be stated as a capitalized unit
cost. $9,136.97/MG, capitalized over 50 years at 9.0 percent,
gives a value of $36.56 million/MGD.
It should be noted that even this partial estimate of
average unit cost is equivalent to more than 15 times the
current retail price of water in Providence. While it is not
known what share of total cost will ultimately be borne by
PWSB ratepayers, or what rate-making treatment this increment
will receive, a significant impact on rate level can be
expected. With annual debt service in the vicinity of $27.5
million ($281 million construction cost, 9 percent interest,
30 year amortization) , a local cost share of as little as 50
percent would be sufficient to nearly double the current
revenue PWSB revenue requirement (87 percent over the 1989
level). Even if the increase were spread across all water use
and all customers, such a rate impact would lower water use
in the range of 5-10 MGD (see earlier discussion of price
effects).
The marginal cost of the Big River Reservoir is based on
the 1989 present value of estimated construction costs.
Because of the assumed postponement of construction to 2002,
the 1989 present value of construction cost is $77.94 million,
stated in 1989 dollars. A permanent reduction in water use
equal to 0.8739 MGD would allow this investment to be
postponed by one year, for a savings (at present value) of
$6.44 million. This translates into a benefit (considering
construction costs alone) of $7.364 million for every 1.0 MGD
reduction in average water use, even under the implied
assumption that the full cost must eventually be borne.
Amortizing this amount over a 50 year planning horizon, the
marginal capacity cost implied by Big River cost estimates is
$l,84l/MG ($l.38/HCF). This is more than four times the 1988
retail price of water in the PWSB service area.
Effectiveness of Water Conservation in the Big River Study
Area
The water conservation evaluation procedure described
above has been applied throughout the U.S., in Federal, state,
and local studies. Portions of it are embedded in a widely
used water use forecasting model, the IWR-MAIN System (Davis,
et al.. 1988). Resulting water conservation programs vary
substantially from place to place, depending on the projected
cost of additional supply as well as other local conditions.
17
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As reported elsewhere in the literature, predicted reductions
range from several percent up to and beyond 50 percent
(Metcalf & Eddy, 1979a, 1979b). Chernick, in testimony before
the Public Utilities Commission, estimated that household
water use in the Providence area can be reduced by as much as
140 gpd (about 44 percent) by installation of flow reducers
and low flow toilets (Chernick, 1988).
It is difficult to generalize about predictions and
measurements of conservation effectiveness for various
locations, since they are based on different combinations of
measures, and address different water use conditions. One
thing can be observed, however: as projected supply cost
increases, water conservation benefits are greater and more
measures become feasible. High costs, then, lead to high
water use reductions.
In the case of Rhode Island, the cost of water
conservation measures undertaken as partial alternatives to
Big River are properly compared to the anticipated cost of the
Big River Reservoir. To the extent that these measures
eliminate the need to build the Reservoir, they are cost
effective when total implementation and other costs are less
than the unit cost of water from the Reservoir. Since the
capital component alone of that unit cost is more than
$9,000/MG, even very high-cost conservation measures can be
considered.
To avoid possible biases in predictions of water use
reductions, data should be based on empirical measurements of
effectiveness conducted after actual implementation of
conservation measures. Among the reliable studies of this
type are the Brown and Caldwell study of conservation plumbing
fixture performance (1984), a U.S. Department of the Interior-
sponsored comparative analysis of four cities (1982), and the
Planning and Management Consultants, Ltd., analysis of the
Phoenix retrofit program (1988).
In the latter study, Dziegielewski and Opitz report on
the impact of an intensive retrofit program implemented in a
portion of Phoenix, AZ, during 1985. The program distributed
low-flow shower heads and toilet dams to 44,000 residential
units in a 37-square mile area. The study, which combined the
results of several independent analytical approaches,
concludes that installation of the devices resulted in a long-
term water use reduction of at least 9.0 gpcd, or 24
gpd/household.
Water conservation kits could be distributed throughout
the Big River study area whenever indicated by a potential
supply shortage, and maintained through periodic inspection
and replacement as long as needed. Using the 9.0 gpcd figure,
and assuming 80 percent coverage of the Providence area with
water conservation kits in the year 2030 (approximately
585,000 persons), water use would be reduced by 5.3 MGD, for
a benefit of $17.5 million/year, or $192 million at present
value. The economic benefit, more than $1,000 per installed
18
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household (not including energy savings), exceeds the cost of
purchasing and distributing the kits by a factor of at least
50.0.
Under these conditions of high supply cost, many other
water conservation measures would prove beneficial. For
example, substantial subsidies could be paid to encourage the
purchase of water-saving appliances (dishwashers,
clotheswashers, low-flush toilets) without exceeding the value
of the water saved.
Water Conservation Conclusions
There is nothing in the Big River feasibility reports to
indicate that any study was conducted of the potential for
water conservation in the Providence area. It is clear that
the Corps procedure for formulating and evaluating water
conservation plans was not followed (Baumann, et al., 1980).
The data described in the feasibility reports, the forecasting
method employed, and the statements made about water use
forecasts and conservation plans are entirely inconsistent
with the standard procedure.
Already implemented changes in the State Plumbing Code
(revision of June 8, 1989) will reduce water use in new
structures by 15-20 gpcd, with an eventual major impact on
residential water use. Using the lower estimate, if this
fixture turnover is 80 percent complete by 2030, a reduction
of 8.8 MGD can be expected. Also, it is certain that water
use reductions of 9 gpcd (5.3 MGD for the PWSB) or more could
be obtained almost immediately, utilizing only the most cost-
effective and non-disruptive techniques available (water
conservation kits similar to the Phoenix application).
Increased attention to leak detection and repair could bring
about further reductions at nominal cost, although no
estimates are available.
The impact of water conservation from the new State
plumbing code is added to the previous items:
Dependable yield —
Corps estimate 94.1 MGD
Addtl.Scituate yield 3.3 MGD
BCWA ground water (3.0 MGD)
Addtl.BCWA yield 0.8 MGD
Total supply 95.2 MGD
Projected water use —
Corps, 2030 128.2 MGD
Stable per capita rates(21.5 MGD)
Stable industrial use(13.9 MGD)
1988 rate change (2.8 MGD)
Rate re-structuring (3.0 MGD)
1989 Plumbing Code (8.8 MGD)
Total water use 78.2 MGD
2030 Surplus (deficit) 17.0 MGD
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Additional measures could be considered for application
in Rhode Island. With prospective water supply costs in
excess of $9,000/MG, virtually any measure may prove to be
feasible and cost-effective. No water conservation study has
been completed for the Providence area, although both the
State and the PWSB have initiated work in this area. Based
on experience elsewhere, overall water use reductions of 30
gpcd (17.6 MGD for PWSB) or more are within easy reach, and
larger reductions are perfectly feasible (Baumann, et al..
1979; Brown & Caldwell, 1984; Hawk Mountain Corporation, 1988;
Chernick, 1988; Grisham and Fleming, 1989; Vickers, 1989;
Cuthbert, 1989). Reductions calculated above for two specific
measures are well within this potential.
Drought Management
A drought is a period of lower than normal precipitation
which results in reduced streamflows and ground water levels.
Since urban water users irrigate lawns and gardens to
supplement rainfall, drought is a time of low supply and high
demand. Water supply systems are designed on the basis of
anticipated drought conditions. In the case of the Big River
Reservoir, project need is calculated on the basis of
conditions expected during a • repetition of the 1965-66
drought, which is described as-having a return probability of
1-2 percent during any given year (Corps, 1981b, p. D-19).
It is assumed that supply facilities must be capable of
delivering all water demanded during such a drought.
To illustrate the impact of this assumption, the safe
yield from the Scituate Reservoir is estimated at 80.3 MGD,
with 9 MGD released downstream, for a repetition of the 1965-
66 drought. This reflects a total inflow equivalent to
approximately 25 inches over the most severe 24 months of
drought (Corps, 1981b, Plate D-9). The Corps analysis
identifies this condition as a 1.0 percent probability event.
By contrast, a 2.0 percent event is associated with 24-month
runoff of about 28.5 inches (14 percent more), and a 5.0
percent probability event would result in 24-month runoff of
32.5 inches (an increase of 30 percent over the 1.0 percent
event). However, the realizable yield does not continue to
increase as inflow rises. PWSB states that the average yield
of Scituate (over all years since 1940) is 110.1 MGD, only 23
percent more than the 1.0 percent probability yield. This may
reflect lack of storage capacity, increased evaporation rates,
or unnecessary spilling, since mean runoff is at least 140
percent greater than the 1.0 percent level (Corps, 1981b,
Plate D-6).
The analysis performed in the Corps feasibility report
takes no account of the possibility of reducing water use,
rather than increasing supply, during drought. In fact,
widespread reductions occurred in New England during the
1960's drought. Pawtucket, RI, for example, reported a
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reduction of 16-18 percent of expected unrestricted demand
(Anderson, 1967). Later analysis of the entire region showed
restrictions of this kind to be, in most places, relatively
low in cost and non-disruptive (Russell, et al. . 1970). It
is clear that temporary reduction in water use during dry
periods is far less costly than constructing supply facilities
which are needed only during those times (Boland, et al..
1980). '
Accepted procedures are available for formulating and
implementing contingent plans, to be activated in the case of
anticipated water supply shortage (Dziegielewski, et al..
1983a, I983b). These plans include the use of short-term
water conservation measures, such as sprinkling restrictions,
as well as varying degrees of water rationing and water use
prohibitions. A drought management program developed for
Springfield, IL, includes demand reduction measures expected
to yield 6.488 MGD in the year 2000 (24 percent of average day
use) during a 1 percent probability drought, at a unit cost
of $70/MG saved (Dziegielewski, et al. . 1983b, p. 70). This
cost can be compared to the unit cost of water from the Big
River Reservoir, estimated above in excess of $9,000/MG.
Comparable drought-period water use reductions were
estimated for the Washington, DC, area (Boland, et al. r 1980).
Substantially larger reductions, sometimes 50 percent or more,
were actually achieved during 1975-76 drought in Great Britain
and the 1976-77 California drought (National Water Council,
1976; Robie, 1978). No drought management plan was located
for any community in Rhode Island, and no agency is known to
be developing such a plan.
The formulation of a drought management plan for the
Providence area would delay the need for supply augmentation,
even if all demand and supply projections are accurate and no
other demand management measures were implemented. If the
design criterion were changed from the 1.0 percent probability
drought (such as the 1965-66 event) to some drought with a
higher probability of occurrence, the nominal yield of the
Scituate system would be revised upward. Water use reductions
of about the same magnitude as the increased yield would be
required, but only during the most severe droughts. In this
way, a contingent drought plan serves to augment reservoir
yield.
Although the Corps evidently accepted the State's
reliability target, and failed to perform the simulations
needed to estimate supply or demand under alternative
reliability constraints, statistical analyses of runoff
suggest that the yield of the Scituate Reservoir system would
increase by roughly 20 percent for a 3.0 percent probability
drought with a duration of at least two years (Corps, 1981b,
Plate D-9). In order for the system to serve the needs, water
use reductions ranging up to 19 percent would be required
throughout the study area during all droughts with a
probability of 3.0 percent or less; the full 19 percent
reduction would be needed in case of a 1.0 percent drought.
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If drought management were confined to the PWSB system, the
necessary water use reductions would range up to 23 percent.
Reductions of 23 percent are within the capability of
conventional drought management plans, and can be implemented
with no more than moderate cost and disruption. Furthermore,
risks of this type are widely accepted. Many utilities
routinely base supply planning on a reliability criterion of
2.0 or 3.0 percent. The Washington Suburban Sanitary
Commission, after considering the costs and benefits of a
range of alternatives, selected and implemented a reliability
level of approximately 5.0 percent (Boland, et al., 1980).
The effect of changing the planning criteria from a 1%
to a 3% drought, if implemented for the Scituate supply alone,
would be an increase in effective yield of 17.9 MGD, assuming
a release of 9 MGD downstream. This would have the following
effect on supply planning:
Dependable yield —
Corps estimate 94.1 MGD
Addtl.Scituate yield 3.3 MGD
BCWA ground water (3.0 MGD)
Addtl.BCWA yield 0.8 MGD
Lower Scituate reliab. 17.9 MGD
Total supply 113.1 MGD
Projected water use —
Corps, 2030 128.2 MGD
Stable per capita rates(21.5 MGD)
Stable industrial use(13.9 MGD)
1988 rate change (2.8 MGD)
Rate re-structuring (3.0 MGD)
1989 Plumbing Code (8.8 MGD)
Total water use 78.2 MGD
2030 Surplus (deficit) 34.9 MGD
supply Management
Improved Surface Water Yield
In assessing the capability of existing supply works, the
Corps appears to have measured the yield of each surface water
source on the basis of current operating practices. There is
no discussion in the feasibility report of the potential for
increasing yield through improved management. Similarly, no
consideration is given to the potential for harvesting water
from existing structures not now used for water supply.
The Scituate system consists of six reservoirs, five of
them eventually draining into the large Scituate impoundment.
The upstream reservoirs are apparently operated passively,
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with no attempt to optimize the yield of the system. It is
certain that the use of a simulation-based operating rule for
the entire watershed could increase the effective yield; it
is possible that it could be increased significantly.
Implementation of such a rule would require installation of
appropriate gates and controls at several points in the
system. Improvements of this kind would have the additional
benefit of increasing PWSB's ability to contain possible
spills of hazardous materials in the watershed. In the
absence of data or studies, no estimate can be made of the
increased yield that might be available.
Some additional water supply could be obtained from the
South Branch Pawtuxet Basin by utilizing existing
impoundments. The Big River watershed, for example, contains
at least 9 ponds of significant size, in addition to the Flat
River Reservoir which is the terminus of Big River itself.
Many of these ponds are located on land that has been acquired
by the State. Construction of a diversion weir near the
proposed Big River dam site, combined with construction of
outlet works on the ponds (possibly including new or raised
embankments) , would make it possible to harvest stored water
from Big River during low flow periods.
The combined yield of all systems could also be increased
by diverting water from Big River during moderate-flow
periods, permitting the storage at Scituate to be used more
efficiently. (Note that a similar benefit is expected from
the Big River Reservoir, which will add as much as 4.0 MGD to
the effective yield of Scituate [Corps, 1981b, p. D-23].)
Also, some water could be withdrawn from the Flat River
Reservoir without producing unacceptable changes in water
level, provided that attention is given to sanitary waste
disposal practices along the highly developed shoreline.
For all of these alternatives, pumping and transmission
facilities would be need to transport the water to Scituate
for treatment. In the absence of data or a suitable study,
no estimate of available yield, feasibility, or cost can be
offered. Based on the current projection of Big River
Reservoir costs, however, even an alternative used for a few
months of the year may be feasible if the construction cost
does not exceed $36 million/MGD (not including pumping or
other operating cost).
New Ground Water Development
Past water resource studies in Rhode Island show a
curious neglect of the State's ground water resources. In
1952, Maguire and Associates noted the existence of
significant ground water reserves, but claimed that experience
shows that ground water "cannot be depended upon" to provide
adequate quantity and quality "over long periods" (Maguire,
1952, p. 177). The study proposed that ground water be
considered for future water needs only in Newport County
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(Aquidneck Island) and in certain then-rural portions of Kent,
Providence, and Washington counties.
Later, Metcalf & Eddy also proposed a small role for
ground water, expressing concern about present and future
ground water quality, especially in the Blackstone Valley and
in the Providence area (Metcalf & Eddy, 1967). While
available daily yield from the State's aquifers was estimated
at 82.5 MGD, nearly 38 MGD in excess of estimated withdrawals,
this resource is recommended for industrial use and for
certain rural and semi-rural areas (Metcalf & Eddy, 1967, p.
50). Some possibility of additional ground water yield in the
Chepachet Valley is also noted.
These same issues were revisited by Metcalf & Eddy in a
1979 report prepared for the Corps of Engineers as part of the
Pawcatuck River and Narragansett Bay Drainage Basins Water and
Related Land Resources Study (Metcalf & Eddy, 1979a and
1979b). The study area consisted of 2,636 square miles in
Southeastern Massachusetts and Rhode Island, including the
study area of the later Big River Reservoir project. In this
report, the consultant recommends development of ground water
wherever possible, in all parts of the State. Attention to
ground water recharge is also suggested, including the
possible future siting of wastewater treatment plants where
the effluent may assist in maintaining aquifer and surface
water levels.
A 1961 study estimates ground water recharge in the
Providence-Warwick area at 22-42 MGD in excess of withdrawals
(Lang 1961, pp. 13-15). Significant potential yields were
observed in most other areas of the State, including the South
Branch Pawtuxet basin (20 MGD). Further study was proposed
for several areas, including the Big River-Mishnock area,
because of indications that larger quantities could be
available. Other studies suggest that at least 25 MGD of
dependable ground water yield could be developed in the
Pawcatuck Basin (Wheeler, 1989).
A summary of the literature, prepared in the Rhode Island
Office of the U.S. Geological Survey, indicates that total
ground water yield throughout the State is approximately 140
MGD, and that total withdrawals in 1985 were 27 MGD, leaving
113 MGD of potential new supply (Johnston, 1989) . The same
review notes that, of the 10 MGD formerly withdrawn for
industrial uses in the Providence area, only about 2 MGD is
now in use. Elsewhere, the Geological Survey reports on the
quality of Rhode Island ground water, finding it suitable for
human consumption with little or no treatment in most parts
of the State (U.S. Geological Survey, 1987). Areas of
contamination are found to be "relatively small."
Development of additional ground water resources, is a
feasible and effective alternative to the Big River Reservoir.
Yields on the order of 10 - 20 MGD (Big River is expected to
produce 31.9 MGD [see corps, I981b, p. D-23]) are potentially
available in the same general area [South Branch Pawtuxet,
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Potowomut-Wickford (Hunt), and Providence-Warwick area].
Additional ground water is available in other parts of the
State, especially in the southern part. Water quality and
costs of treatment must be carefully checked in the Providence
area. Although transmission and pumping costs would be higher
because of distances and spatial dispersion, most well field
and treatment costs would be modest. With properly managed
withdrawals, disruption of wetlands and downstream flows would
be negligible.
New Surface Water Impoundments
State-wide water resource studies have consistently
identified at least six potential surface water impoundment
sites in addition to the Big River. These include locations
elsewhere in the South Branch Pawtuxet basin (Nooseneck River)
and at least five sites in the Branch-Blackstone basin, near
the State's northern border. Unfortunately, detailed studies
of these alternatives are not available. Investigations are
necessary to determine which, if any, of these proposals are
likely to be cost-effective and/or less environmentally
damaging than Big River. Such investigations are beyond the
scope of this review.
Unconventional Water Sources
The existing water supply system in the study area is
comprised of approximately 88 percent surface water, obtained
from a number of large and small impoundments, and 12 percent
ground water. Opportunities for further surface water
development are, in some cases, blocked by land development
and/or jurisdictional boundaries, while some ground water,
especially in the locales of highest water use, is potentially
contaminated with industrial wastes, or with minerals such as
iron and manganese. Yet some of the fastest growing and most
densely settled areas of Rhode Island are literally surrounded
by water, and ground water is present to some degree in all
parts of the State.
The major hydrologic feature of the State is the
Narragansett Bay, a large estuary containing water which
ranges in salinity from fresh water in the upper reaches to
seawater at the mouth. There is no technological barrier to
the desalination of brackish water or even seawater; the only
impediment is the cost. The same is true for ground water,
which can be demineralized and stripped of many possible
industrial contaminants by means of advanced processes
including membrane filtration techniques.
None of the studies reviewed make reference to the
existence of brackish ground water in Rhode Island. If such
a resource exists, it can be treated by reverse osmosis at
moderate cost. Brackish ground water up to 8,000 mg/1 total
dissolved solids (TDS) can be treated to drinking water
quality in a facility costing not more than $10 million for
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10 MGD capacity (Taylor, 1989) . Combined with operating costs
of about $0.75/1,000 gallons, this gives a unit cost of
$1,000/MG, far below the cost of water from Big River.
Seawater ranging up to 25,000 mg/1 TDS can be treated to
drinking water standards in a reverse osmosis plant costing
not more than $2.5 million/MGD (cost estimated by J. Taylor
[1989] for a plant capacity of 10 MGD). Operating costs may
be as much as $10.00/1,000 gallons. Combined with the capital
cost, this would give a unit cost of $10,900/MG (capital costs
amortized over 20 years at 9 percent, 80 percent plant
availability). Although this cost is high, it is less than
20 percent higher than the capital cost alone of water from
the Big River.
Not Abandoning Existing Supplies
Bristol County Alternatives
A series of planning studies for the BCWA and its
predecessor, the Bristol Water Company, have considered
alternative means of insuring future water supply (Weston &
Sampson, 1979; Tri-Town Water Study Committee, 1983; Weston
& Sampson, 1988; Camp, Dresser & McKee, 1987 and 1989). BCWA
serves the towns of Warren, Barrington, and Bristol, located
just southeast of East Providence. The service area is
bounded on the west by Narragansett Bay and on the east by
Massachusetts. The BCWA supply system consists of two wells
(providing about 20 percent of the total) and several surface
water impoundments located in Rhode Island and Massachusetts.
Dependable yield is calculated at 4.0 MGD, although total
withdrawals have been in excess of that amount in recent years
(Camp, Dresser & McKee, 1989).
The supply alternatives considered by Bristol County
include (l) dredging and diking of existing impoundments,
combined with refurbishment of treatment plant and other
facilities, (2) development of additional surface water
impoundments, (3) additional ground water development, (4)
purchase of water from Fall River (MA), (5) purchase of PWSB
water through connection in East Providence, and (6) purchase
of PWSB water through the proposed Cross-Bay Pipeline (Camp,
Dresser & McKee, 1989). These alternatives are contrasted to
a demand forecast which calls for water use to increase from
4.26 MGD in 1985 to 6.05 MGD in 2020 (Arthur Young, 1986).
The first five alternatives listed above were ruled out
by the BCWA because of perceived difficulty in obtaining
necessary permits (1, 2, and 3), inadequate capacity to
accommodate 100 percent of BCWA's needs (4 and 5), and
environmental impacts (l and 2) (Camp, Dresser & McKee, 1989).
Documents reviewed do not indicate consideration of a mixed
strategy, e.g., maintenance of existing capacity with
supplemental water purchased from PWSB via East Providence.
Other possible supplemental sources are not discussed,
including desalination of brackish ground water. As a result
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of consultant studies and recommendations, BCWA is presently
pursuing the Cross-Bay Pipeline as the preferred source for
the County's future needs, to replace existing ground and
surface water resources (Merrill Lynch, 1986) .
Economic considerations evidently provide a strong
motivation for BCWA's continuing interest in the Cross-Bay
Pipeline. Up to 1988, PWSB sold water to large customers
outside the City of Providence for $0.23/HCF (quantities above
4,000 HCF/year). At the same time, BCWA, using a combined
increasing/decreasing block tariff, charged retail prices
ranging from $1.63 to $4.29/HCF (BCWA, 1988). None of the
studies reviewed appear to consider the possibility of large
increases in the cost of PWSB water, such as those that would
follow the construction of the Big River Reservoir. The
expected cost of the pipeline, recently estimated at $40
million, is itself equivalent to approximately $1.25/HCF.
An inexpensive and feasible alternative would be to
maintain existing surface and ground water sources at their
current capacity, purchasing supplemental water as needed from
PWSB through the existing connections in East Providence.
This would require upgrading of the Child St. Treatment Plant,
as well as strengthening of the distribution system in Bristol
County and possibly in East Providence. Provision could also
be made for limited dry year or emergency withdrawals by water
systems on Aquidneck Island, as discussed below. Combined
with appropriate attention to water conservation and drought
management, the impact of Bristol County on PWSB's future
needs would be minimal.
On the other hand, the proposed abandonment of the
existing BCWA supply facilities will probably prove
irreversible (with the possible exception of the ground water
source). Continuing siltation, land use changes, and new
reservoir activities are likely to preclude any future water
supply uses of the surface water sources. The total supply
capability of Rhode Island would be permanently reduced,
therefore, by the yield of these sources, currently about 3.2
MGD. In this connection, State water supply policy states
that "existing sources of water should not be abandoned" (RI
Division of Planning, 1988, p. 2.6).
Aquidneck Island Alternatives
Similar to Bristol County, the water systems on Aquidneck
Island face the rehabilitation and upgrading of facilities
which have marginal supply capability. Among the alternatives
considered is upgrading the existing connection to the
mainland (across the Sakonnet River Bridge) to permit imports
from BCWA or from PWSB through the BCWA system (Save the Bay,
1983; Metcalf & Eddy, 1984). Unlike BCWA, the City of Newport
apparently does not plan to abandon its existing surface water
source.
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The cost of Big River water, transmitted to Aquidneck
Island via the proposed Cross-Bay Pipeline and the Sakonnet
River bridge, would be comparable to the cost of seawater
desalination, approximately $10,000-11,000/MG. If brackish
ground water (up to 8,000 mg/1 TDS) is available on the
Island, it could be treated for about one-tenth the cost of
seawater. Furthermore, all of the demand management
alternatives discussed above are potentially applicable to
Aquidneck Island.
The Corps did not include Aquidneck Island demands in its
Big River feasibility study. This review suggests that there
is no reason to do so now.
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Conclusions
PUBLIC WATER SUPPLY
Need
In identifying a need for increased water supply
capacity, the Corps relies on forecasts of water use which
omit consideration of all factors known to affect water use
levels except population and increasing per capita demands.
Increases in per capita water use are assumed without
investigation of past or current trends in the Providence
area, and despite generally stable or declining per capita
rates elsewhere in the U.S.
Actual per capita water use in the PWSB service area has
fallen by about one-sixth during the period 1975-1987.
Nevertheless, even after modification to incorporate an
assumed level of water conservation, the Corps forecasts still
indicate sharply rising water use over the entire planning
period. No justification is provided for these anomalous
results.
The Corps measures the supply capability of existing
systems in terms of a repetition of the 1965-1966 drought.
In doing so, it adopts dependable yield estimates at the lower
end of the range of current opinion.
In the absence of water conservation, the feasibility
study indicates that water use will exceed the capability of
current and anticipated supplies by 34.1 MGD in the year 2030.
This is based on a supply of 94.1 MGD and water use of 128.2
MGD. Correction of the Corps estimate to reflect more recent
yield data and to exclude anticipated ground water
development, gives a supply capability of 95.2 MGD. Further
assumptions—(1) per capita use remains stable at 1975 levels
(despite recent declines) and (2) industrial water use does
not increase—reduce water use to 92.8 MGD in 2030. The
result is surplus capacity of 2.4 MGD, even prior to any
consideration of demand management measures or supply
alternatives.
The studies reviewed, therefore, do not indicate a
current need for the Big River Reservoir project.
Alternatives
Even if a need for water supply augmentation is
identified at some future time, there exist numerous feasible,
cost-effective, environmentally benign alternatives. These
include both demand management measures and supply
augmentation actions.
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Demand Management
Pricing Policy
Rate increases already granted to the PWSB will reduce
future water use by approximately 3.6 percent, compared to
levels that would have been predicted on the basis of pre-1988
prices. If this rate increase and expected future increases
are accompanied by appropriate modifications in tariff design,
long term water use reductions in the range of 5-10 percent
can be achieved. Taking the mid-point of this range, year
2030 water use is reduced by 2.8 MGD because of the 1988 rate
increase, and 3.0 MGD to acknowledge the possibility of later
rate re-structuring. Both of these adjustments are based on
the PWSB service area alone.
If the Big River Reservoir were built, the PWSB portion
of the cost would cause a sharp upward shift in revenue
requirement, and therefore in rate level, with a corresponding
further drop in water use. No data are available on the size
of this impact, however.
Other Long-Term Conservation Measures
There is no evidence that the Corps assumptions of water
conservation are based on any systematic consideration of
available methods, or that accepted evaluation procedures were
followed. In fact, reductions comparable to those assumed by
the Corps (9-11 gpcd) can be achieved by implementing a single
measure (water conservation kits).
Many other conservation measures are feasible and cost-
effective, when compared to the cost of the Big River project.
The effect of the already-implemented change in the State
Plumcing Code, mandating the use of 1.6-gallon flush toilets
in new construction, is expected to be 8.8 MGD by 2030. The
immediate effect of 80 percent coverage by water conservation
kits is a water use reduction of 5.3 MGD.
Drought Management Plans
Water supply requirements are identified by comparing
expected water use to supply capability during some selected
drought event. It is the practice of the PWSB, and of the
Corps in the feasibility study, to base this calculation on
the worst dry period of record, the 1965-66 drought. Planning
assumes that facilities must be capable of delivering all
water demanded during such a period. A contingent plan for
water use reduction in times of drought would substantially
reduce the need for water supply augmentation. Although
typical drought management measures are highly cost-effective,
their application has not been considered as an alternative
to construction of the Big River Reservoir.
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Changing the design criterion for the Scituate system
from a 1 percent drought to a 3 percent drought would require
drought management program capable of reducing water use up
to 23 percent during a l percent event (assuming the drought
management occurs in the PWSB area only). This would increase
the effective yield of Scituate by roughly 20 percent. Even
if implemented for the Scituate system alone, this single step
would increase available supply by 17.9 MGD.
The effect updating assumptions regarding need, and of
incorporated selected demand management calculations, is to
increase supply to 113.1 MGD, and to reduce year 2030 water
use to 78.2 MGD. Surplus capacity in 2030 is, therefore, 34.1
MGD.
Supply Management
Opportunities for increasing the yield of the Scituate
system by improved management have not been investigated.
There are a range of possibilities for harvesting water from
the Big River watershed, using existing impoundments after
some upgrading of outlet works. None of these alternatives
appear to have been examined, and no data or costs are
available.
The Big River feasibility study includes no serious
consideration of ground water as an alternative to surface
water impoundments. Yet the U.S. Geological Survey estimates
that more than 100 MGD of potentially developable ground water
exists throughout the State, with the possibility of
additional resources in areas such as Mishnock Swamp. Ground
water quality is generally good, except in specific areas
where contamination has occurred, or may occur in the future.
In most cases, ground water can be developed inexpensively and
requires little treatment.
Bristol County and Aquidneck Island
The principal motivation for BCWA's support of the Cross-
Bay Pipeline appears to be economic: the price of water
purchased from PWSB ranges from 5 to 14 percent of current
retail prices in Bristol County. A practicable, low-cost, and
environmentally benign alternative would be to retain existing
ground and surface water surfaces (upgrading the Child St.
Treatment Plant), implement appropriate conservation and
drought management programs, and purchase any needed
supplemental water from PWSB through the existing connections
in East Providence.
Similarly, Aquidneck Island has a number of supply
alternatives available (including refurbishment and
preservation of existing sources), as well as significant
potential for demand management. In the event that
supplemental supplies are needed on Aquidneck Island, they can
be obtained through existing connections from PWSB via Bristol
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County. If local systems are properly managed, neither
Bristol County nor Aquidneck Island will place large demands
on the PWSB system.
Failure to exploit these opportunities will result in
abandonment of the existing ground and surface water sources.
In the case of surface water, such abandonment is likely to
be irreversible, with a consequent permanent loss of water
supply capacity for the State as a whole.
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REFERENCES
Anderson, Raymond W., 1967, "Pawtucket, Rhode Island, and the
Drought," J. American Water Works Association, vol. 81, no. 3
(March), pp. 301-303.
Archer, Wiley J., 1988, "Direct Testimony," before the Rhode
Island Public Utilities Commission, Docket No. 1900.
Arthur Young, 1986, "Bristol County Water Authority, Warren,
Rhode Island, Water Demand Analysis," Providence, RI.
Baumann, Duane, D., John J. Boland, John H. Sims, 1980, "The
Evaluation of Water Conservation for Municipal and Industrial
Water Supply: Procedures Manual, " Institute for Water Resources
Contract Report 80-1, U.S. Army Corps of Engineers, Fort
Belvoir, VA.
Baumann, Duane D., John J. Boland, John H. Sims, Bonnie Kranzer,
and Philip H. Carver, 1979, "The Role of Conservation in Water
Supply Planning," Institute for Water Resources Contract Report
79-2, U.S. Army Corps of Engineers, Fort Belvoir, VA.
Boland, John J., 1978, "Forecasting the Demand for Urban Water,"
in Holtz and Sebastian, eds., Municipal Water Systems: The
Challenge for Urban Resource Management, Bloomington, Indiana
University Press, pp. 91-114.
Boland, John J., 1983, "Water/Wastewater Pricing and Financial
Practices in the United States," MetaMetrics report MMI 19-83, a
report to the U.S. Agency for International Development,
Washington, D.C.
Boland, John J. , 1988, "Direct Testimony," before the Rhode Island
Public Utilities Commission, Docket No. 1900, June 24.
Boland, John J., Philip H. Carver, and Charles R. Flynn, 1980,
"How Much Water Supply Capacity is Enough?", J. American water
Works Association, vol. 72, no. 7 (July), pp. 368-374.
Boland, John J., Benedykt Dziegielewski, Duane Baumann, and Chuck
Turner, 1982, "Analytical Bibliography for Water Supply and
Conservation Techniques," Institute for Water Resources Contract
Report 82-C07, U.S. Army Corps of Engineers, Fort Belvoir, VA.
Boland, John J., Benedykt Dziegielewski, Duane D. Baumann, and
Eva M. Opitz, 1984, "Influence of Price and Rate Structures on
Municipal and Industrial Water Use," Institute for Water
Resources, Contract Report 84-C-2, U.S. Army Corps of Engineers,
Fort Belvoir, VA.
Boland, John J., Wai-See Moy, Roland C. Steiner, and Jane Pacey,
1983, "Forecasting Municipal and Industrial Water Use: A Handbook
of Methods," IWR Report No. 83C-01, U.S. Army Corps of Engineers,
Institute for Water Resources, Fort Belvoir, VA.
33
-------
Bristol County Water Authority, 1988, (Rate Schedule), Bristol,
RI, April 1.
Brown & Caldwell, 1984, "Residential Water Conservation Projects, "
report to U.S. Department of Housing and Urban Development by
Brown & Caldwell Engineers, Walnut Creek, CA.
Camp, Dresser & McKee, Inc., 1987, "Bristol County Water
Authority, Bristol County, Rhode Island, Water Distribution System
Study: Final Report," Boston, MA.
Camp, Dresser & McKee, Inc., 1989, "Bristol County Water Authority
Cross-Bay Pipeline Project Environmental Assessment," Boston, MA.
Chernick, Paul L., 1988, "Direct Testimony," before the Rhode
Island Public Utilities Commission, Docket No. 1900.
Copeland, Basil L., Jr., 1988, "Direct Testimony," before the
Rhode Island Public Utilities Commission, Docket No. 1900, June.
Cuthbert, Richard W., 1989, "Effectiveness of Conservation-
Oriented Water Rates in Tucson," J. American Water Works
Association, vol. 81, no. 3 (March), pp. 65-73.
Davis, W.Y., D.M. Rodrigo, E.M. Opitz, B. Dziegielewski, D.D.
Baumann, and J.J. Boland, 1988, "IWR-MAIN Water Use Forecasting
System, Version 5.1," Institute for Water Resources Report 88-R-
6, U.S. Army Corps of Engineers, Fort Belvoir, VA.
Dziegielewski, Benedykt, Duane D. Baumann, and John J. Boland,
1983a, "Evaluation of Drought Management Measures for Municipal
and Industrial Water Supply," Institute for Water Resources
Contract Report 83-C-3, U.S. Army Corps of Engineers, Fort
Belvoir, VA.
Dziegielewski, Benedykt, Duane D. Baumann, and John J. Boland,
1983b, "Prototypical Application of a Drought Management
Optimization Procedure to an Urban Water Supply System, " Institute
for Water Resources Contract Report 83-C-4, U.S. Army Corps of
Engineers, Fort Belvoir, VA.
Dziegielewski, Benedykt, and Eva M. Opitz, 1988, "Phoenix
Emergency Retrofit Program: Impacts on Water Use and Consumer
Behavior," Planning and Management Consultants, Ltd., Carbondale,
IL.
Grisham, Alice, and William H. Fleming, 1989, "Long-Term Options
for Municipal Water Conservation," J. American Water Works
Association, vol. 81, no. 3 (March), pp. 34-42.
Hawk Mountain Corporation, 1988, "Hawk Mountain Corporation Water
Saving Summary," September 29, 7 pp.
Kent County Water Authority, 1989, "Testimony and Data in Support
of the Kent County Water Authority Rate Tariff," West Warwick, RI,
July.
34
-------
Johnston, Herbert E., 1989, letter to V. Laszewski, US EPA,
w/attachments, July 7, 7 pp.
Jones, C. Vaughan, John J. Boland, James E. Crews, C. Frederick
DeKay, and John R. Morris, 1984, Municipal Water Demand:
Statistical and Management Issues, Boulder, CO, Westview Press.
Keyes Associates/Metcalf & Eddy, Inc., 1988, letter with
attachments: 80% cost estimates for Cutoff Wall and Dike, Big
River Project, December 30, 5 pp.
Lang, S.M., 1961, "Appraisal of the Ground-Water Reservoir Areas
in Rhode Island," US Geological Survey, Rhode Island Geological
Bulletin No. 11.
C.A. Maguire & Assoc., 1952, Report on the Water Resources of the
State of Rhode Island, Providence, RI, January.
Mainelli, Domenic J., 1988, "Direct Testimony," before the Rhode
Island Public Utilities Commission, Docket No. 1900.
Mariscal, Juan, 1988, "Direct Testimony," before the Rhode Island
Public Utilities Commission, Docket No. 1900.
Merrill Lynch Capital Markets, 1986, "Bristol County Water
Authority: General Revenue Bonds, 1986 Series A," (Prospectus)
New York.
Metcalf & Eddy, Inc., 1967, "Report to the Water Resources
Coordinating Board, State of Rhode Island, on a Development Plan
for the Water Supply Resources of Rhode Island," Boston, MA, June
30.
Metcalf & Eddy, Inc., 1979a, "Water Supply Alternatives: Main
Report, Volume I," a report prepared for the New England Division,
US Army Corps of Engineers, Boston, MA, January.
Metcalf & Eddy, Inc., 1979b, "Water Supply Alternatives: Technical
Appendixes, Volume II," a report prepared for the New England
Division, US Army Corps of Engineers, Boston, MA, January.
Narragansett Bay Commission, 1988, Wastewater Tariff, with
attachments, as submitted to the Public Utilities Commission March
7.
National Water Council, 1976, We Didn't Wait for the Rain . . .,
London, England.
Providence Water Supply Board, 1986, "Annual Report to the Public
Utilities Commission for the Year ending June 30, 1986,"
Providence, RI.
Rhode Island Statewide Comprehensive Transportation and Land Use
Planning Program, 1969, "Plan for the Development and Use of
Public Water Supplies," Report No. 10, Providence, RI, September.
35
-------
Rhode Island Public Utilities Commission, 1988, "Report and
Order," Docket Number 1900.
Robie, Ronald B., 1978, "California's Program for Dealing With
Drought," J. American Water Works Association, vol. 70, no. 2
(February), pp. 64-68.
Russell, Clifford S., David G. Arey, and Robert W. Kates, 1970,
Drought and Water Supply, The Johns Hopkins Press, Baltimore, MD.
Russell, David F., 1988, "Direct Testimony," before the Rhode
Island Public Utilities Commission, Docket No. 1900.
Save the Bay, Inc., 1983, "Water Systems on Aquidneck Island,"
Technical Report No. 1, Providence, RI, March, 48 pp.
Sims, John H., Duane D. Baumann, John J. Boland, Kirk Alley, and
Bonnie Kranzer, 1982, "Consumer Adoption of Water Conservation,"
Southern Illinois University, Carbondale, IL.
Tri-Town Water Study Committee, 1983, "Evaluation of Solutions to
the Water Supply Problems of Bristol County."
U.S. Army Corps of Engineers, 1981a, New England Division, "Big
River Reservoir Project: Volume I, Main Report," Waltham, MA,
July.
U.S. Army Corps of Engineers, 1981b, New England Division, "Big
River Reservoir Project: Interim Report," Volume II, Waltham, MA,
July.
U.S. Army Corps of Engineers, 1981c, New England Division, "Big
River Reservoir Project: Interim Report," Volume III, Waltham,
MA, July.
U.S. Army Corps of Engineers, 1981d, New England Division, "Big
River Reservoir Project: Interim Report," Volume IV, Waltham, MA,
July.
U.S. Army Corps of Engineers, 1982, New England Division, "Sup-
plemental Report to July 1981 Interim Feasibility Report and Final
Environmental Impact Statement," Waltham, MA, February, 31 pp.
U.S. Geological Survey, 1987, National Water Summary 1986, Water
Supply Paper 2325, Washington, DC, pp. 443-448.
Vickers, Amy, 1989, "New Massachusetts Toilet Standard Sets Water
Conservation Precedent," J. American Water Works Association, vol.
81, no. 3 (March), pp. 48-51.
Weston & Sampson Engineers, Inc., 1979, "Bristol County, Rhode
Island: Report on Water System Study," Part 1, Wakefield, MA, 131
pp.
Weston & Sampson Engineers, Inc., 1988, "Bristol County Water
Authority: Draft Report on Water Supply and Transmission Study,"
Wakefield, MA.
36
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Wheeler, Bradford A., 1989, "Pawcatuck Basin Ground Water
Reservoir (PBGWR)," Hope Valley, RI, March 9, 8 pp.
37
-------
s
01
C
o
BIG RIVER RESERVOIR CASH FLOW
Unit Cost=89,136.97/MG; i=O.O9
DDDDDDDOODDDaODDDDDDaDDDDDDD
-6O
I ' ' ' • I ' ' ' ' I ' ' • • I
19 89 1994 1999 2O04 2O09 2O14 2O19 2O24 2O29 2O34 2O39 2O44 2O49
-------
BIG RIVER RESERVOIR
Calculation of levelized unit cost
disc.rate
0.09
Year
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
- 2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
Constr. 1989 Water
Outlay Present
($ mil) Value (MGD)
56.3592 18.3832
56.3592 16.8653
56.3592 15.4727
56.3592 14.1952
56.3592 13.0231
0.8375
1.6750
2.5125
3.3500
4.1875
5.0250
5.8625
6.7000
7.5375
8.3750
9.2125
10.0500
10.8875
11.7250
12.5625
13.4000
14.2375
15.0750
15.9125
16.7500
17.5875
18.4250
19.2625
20.1000
Sales
(MG/yr)
-^
305.69
611.38
917.06
1,222.75
1,528.44
1,834.13
2,139.81
2,445.50
2,751.19
3,056.88
3,362.56
3,668.25
3,973.94
4,279.63
4,585.31
4,891.00
5,196.69
5,502.38
5,808.06
6,113.75
6,419.44
6,725.13
7,030.81
7,336.50
P.V.
Water
Sales
*
64.8038
118.9061
163.6323
200.1618
229.5434
252.7083
270.4829
283.5993
292.7057
298.3749
301.1122
301.3634
299.5202
295.9268
290.8848
284.6579
277.4762
269.5397
261.0221
252.0735
242.8231
233.3818
223.8441
214.2903
-------
BIG RIVER RESERVOIR
Calculation of levelized unit cost
disc.rate
0.09
Year
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
'-2047
2048
2049
2050
2051
Constr. 1989 Water
Outlay Present
($ mil) Value (MGD)
20.9375
21.7750
22.6125
23.4500
24.2875
25.1250
25.9625
26.8000
27.6375
28.4750
29.3125
30.1500
30.9875
31.9000
31.9000
31.9000
31.9000
31.9000
31.9000
31.9000
31.9000
Totals 281.7960 77.9395
Levelized Unit Cost ($/MG)
Sales
(MG/yr)
7,642.19
7,947.87
8,253.56
8,559.25
8,864.94
9,170.62
9,476.31
9,782.00
10,087.69
10,393.37
10,699.06
11,004.75
11,310.44
llj.643.50
11,643.50
11,643.50
11,643.50
11,643.50
11,643.50
11,643.50
11,643.50
308,046.31
=
P.V.
Water
Sales
204.7881
195.3942
186.1554
177.1101
168.2894
159.7179
151.4145
143.3934
135.6647
128.2346
121.1066
114.2815
107.7578
101.7715
93.3683
85.6590
78.5863
72.0975
66.1445
60.6830
55.6725
8,530.1253
9,136.97
-------
Big River GIS/LANDSAT Project
some reasons for development
Landscape Pattern Analysis
Patchiness (Euler Number)
Connectivity (Gamma Index)
Edge Complexity (Fractal Dimension)
Compactness Ratios (Perimeter/Edge measures)
Landscape Attribute Associations (data layers)
i
Significance of Natural Areas/Open Space
I I
-------
Big River GIS/LANDSAT Project
some reasons for development
Depict Data at a Range of Scales
Compare and Assess Wildlife Values
Describe Wetland.,Values
Water Supply Alternatives Analysis
Relationships of Wetlands and Groundwater
Unsuitability of Mitigation
Develop Methodology for Similar Projects
-------
Big River GIS/LANDSAT Project
. • • some reasons for development
Information at Public Forums for EPA and
Conservation Grjdups
Support of Potential Litigation
Briefing of Senior EPA'Regional and
) - i IV ('•• i
Headquarters Staff
Assess and Extend GIS/LANDSAT Technologies
to Wetlands and other EPA Programs
i ; iii !• *»
-------
Some Reasons for Developing the Big River CIS
• Depict and Interrelate Data at a Range of Scales
• Big River watershed
• South Branch Pawtuxet River watershed
• Pawtuxet River watershed
• Compare and assess Wildlife and Fisheries values
• Wetland values of Reservoir Area
• Significance of Open Space
• Landscape Pattern Analysis
• Patchiness (Euler Number)
• Connectivity (Gamma Index)
• Edge Complexity (Fractal Dimension)
• Compactness Ratios (Perimeter/Edge measures)
• Associations between Landscape Attributes (data layers)
• Possible relations between Wetlands and Groundwater
• Unsuitability of Mitigation
• Water Supply Alternatives Analysis
• Methodology for similar Projects in other Regions
• Information at public forums by EPA and Conservation Groups
• Briefing of Senior EPA Regional and Headguarters Staff
• Support of potential Litigation
-------
Table Qualitative list of values of riparian ecosystems.
Adapted from Lugo and Brinson (1978) .
Hydrologic Values
Store flood waters and ameliorate downstream flooding
Serve as areas of aquifer recharge or discharge
Provide year-round source of water in arid climates
Organic Productivity Values
Have higher primary productivity than surrounding uplands
High secondary productivity supports fisheries, trapping,
hunting
Produce high yields of timber and quality lumber
Biotic Values
Serve as required habitat for endangered plant and animal
species, as refugia for upland species, and as corridors for
animal movements
Provide spawning areas.for some anadromous and other fish
species
Produce organic matter from riparian vegetation for aquatic
food chains in small streams
Biogeochemical Values
Have high capacity to recycle nutrients; usually accumulate
nitrogen and phosphorus
Sequester heavy metals and some poisonous chemicals in
anaerobic soil zones and/or clays
Provide buffer zones for maintaining water quality
Accumulate; organic matter and thus provide sink for
atmospheric CO
Geomorphic Values
Contribute to landscape diversity
Provide areas of sedimentation for building soils
Have topographic relief that is maintained by stream
meandering
Other Values
Importance as natural heritage, particularly when they become
scarce
Representatives, of personal intangible values
Location for recreation and relaxation
Natural laboratories for teaching and research
-------
Table 2. Area (acres) of wetlands and deepwater habitats in the
Big River Watershed and proposed reservoir site. (U. of RI, 1984)
Classification Reservoir
Unit* Site
Palustrine Wetlands
Open Water
Emergent Wetlands
Scrub-Shrub Wetlands
Forested Wetlands
Lacustrine Wetlands
Riverine Wetlands
Total Wetlands
Total Deepwater Habitats
»
27
31
105
324
3
18
508
(33%)
69
(36%)
Watershed
72
52
295
1,093
3
23
1,538
192
* - Classification follows that of Cowardin et al. (1979)
-------
Table A2-2.—Potential Water Conservation Measures
Management measures (to be implemented by water supply
agencies or other units of government)
Universal metering
Improved meter maintenance
Distribution pressure regulation
Leak detection and repair
System rehabilitation
Economic incentives (e.g., rebates, credits, subsidies,
or penalties for changes in appliances,
landscaping, etc.)
Distribution of water conservation kits
Distribution and installation of other water-saving
devices
Distribution of leak detection kits
Recycling-water treatment plant washwater
Regulations (to be implemented by State or local government)
Plumbing codes for new structures
Retrofitting requirements
Changes in landscape design
Water recycling
Growth controls
Conservation Education (by government, water supply agency,
or non-governmental organization)
Direct mail campaign
News media
Personal contact
Special events
Source: Boland, et al.. 1982, pp. 14-15.
-------
Table A2-3.—Plumbing Fixtures Considered in Conservation Plans
shallow trap toilet shower flow-control devices
vacuum toilet pressure-reducing valves
incinerator toilet toilet inserts
pressurized flush toilet faucet aerators
wastewater recycling toilet faucet flow restrictors
oil flush toilet
freeze toilet
packaging toilet
composter toilet
dual flush toilet
micropore toilet
water recycling system
low flow showerheads
water dams
toilet flush adapters
shower mixing valves
air-assisted showerheads
spray taps
pressure balancing mix valves
hot water pipe insulation
swimming pool covers
low water-using dishwashers
low flush toilets
minimum use showers
hose meters
low water-using clotheswashers
moisture sensors
sprinkler timers
thermostatic mixing valves
Source: Boland, et al.. 1982, pp. 14-15.
-------
Big River/Natural Areas Slides
SLIDE 1 & 2. The Big River Study Area Location Map (PAWLOC. PLT) .
This schematic map indicates the approximate location of the
Pawtuxet River Basin and the Big River study area in the south-east
corner of New England.
SLIDE 3. Hydrography of the State with town boundaries and
drainage basins. The Pawtuxet watershed covers square miles
of Rhode Island. The South Branch of the Pawtuxet and the Big
River watersheds are located in the south of the Pawtuxet basin.
SLIDE 4. The Big River watershed contains the most extensive
remaining natural areas and wetland systems in the Pawtuxet.
Studies by the US Fish and Wildlife Service, the Rhode Island
Heritage Program, the Eastern Heritage Task Force of the Nature
Conservancy (correct?), and researchers commissioned by EPA have
documented the outstanding natural values of these systems,
particularly for passive and active recreation...
SLIDE 5. wildlife habitat, with at least species of breeding
birds, — species of mammals, -- species of herptiles, and
significant invertebrates such as the fresh water mussel -
SLIDE 6. and the richness of the mosaic of wetland and upland
vegetative communities, including such rare species as Small
Whorled Pogonia (Isotria medeoloides).(sic)
SLIDE 7. An impoundment proposed jointly by the State of Rhode
Island Water Resources Board and the U.S. Army Corps of
Engineers.
SLIDE 8 & 9. [take slide of pie-chart created by Heather] would
directly inundate 575 acres of forested broad-leaved and needle-
leaved wetland, persistent and non-persistent emergent, broad-
leaved deciduous and evergreen scrub-shrub wetland habitats, 2,825
acres of upland, and 20 miles of cold water streams, converting
these habitats to a radically simplified open warm water system.
*
SLIDE 10. Furthermore indirect impacts through groundwater
starvation would threaten the acre Mishnock Swamp, the [take
description from Mark's note], and through lessened low flow
discharges a [ibid] of riparian wetlands along the South Branch
Pawtuxet. Because of imminent threat to the high quality aquatic
resources of this natural area and substantial evidence of
practicable alternatives for water supply in Rhode Island, the New
England Regional office of USEPA initiated in October, 1988 an
action under Section 404(c) of the Clean Water Act which on October
-------
- resulted in a Recommended Determination to prohibit [take
language from R.D.] in the Big River study area. Section 404 of
the Clean Water Act regulates the discharge of dredge or fill
material into "waters of the U.S." which includes almost all
wetlands, streams, rivers and coastal waters. A permit is required
from the U.S. Army Corps of Engineers to place such material, such
as a dam, unless, as in this case, the Corps carries out the
activity. Such impoundments pose one of the most pernicious
threats to aquatic and terrestrial habitats in the lower 48 states,
including such a hall of rogues as the proposed Twin Forks in
Denver, Pamo Dam in California, Ware Creek in , among
others.
To support EPA's initiative we obtained one of two Regional grants
from our headquarters (the Office of Wetlands Protection) to
support implementation of a geographic information systems
application for the Big River application. The $15,000 grant was
extended through substantial quid pro quo with the Rhode Island
CIS program at the University of Rhode Island. EPA's ARC/INFO
system is proving to be the standard governmental CIS in New
England. ARC/INFO stores information in two general forms: "arc"
(lines) and "info"(attributes). Information may be spatially
related (e.g. overlays), processed (i.e. altered as a result of
other information) and readily queried. Potential benefits of
using CIS were expected to include:
[Can these bullet points be put into a slide?]
• depiction and interrelation of data at a range of scales
- Big River watershed
- Pawtuxet watershed
- Rhode Island-wide
• comparison of wildlife and fisheries values
• wetland values of reservoir area
• significance of open space
• possible relations between wetlands and groundwater
• unsuitability of mitigation
• EPA's and Rhode Island's water supply alternatives analysis
• provide a methodology for similar projects in other Regions
depiction of information at public forums by EPA and
conservation groups
• -briefing of senior Regional and Headquarters staff
• support of potential litigation
Consequently a number of thematic coverages were developed for the
Fawtuxet and Big River basins.
SLIDE 11. Wetlands of the Big River were delineated using
National Wetlands Inventory information. This coverage is being
updated and refined for the entire state.
SLIDE 12. Wetlands were also categorized by water regime.
-------
SLIDE 13. and by organic and mineral soil type. Organic deposits
in the impoundment would interact with chlorine to produce chloro-
flouro in drinking water. These and some related
compounds are receiving increasing attention as potential health
hazards in current and proposed drinking water supplies.
SLIDE 14. Wetland wildlife habitat values were calculated and
depicted using Golet's (197-) methodology.
SLIDE 15. To provide a simple measure of some secondary impacts
100' and 200' buffers were calculated around the perimeter of the
proposed impoundment.
SLIDE 16. To provide a comprehensive land use and land cover
classification Prof. Dan Civco of the University of Connecticut
was retained to interpret a May 11, 1987 LANDSAT Thematic Mapper
(TM) digital multispectral image using the PC version of the Earth
Resources Data Analysis System -(PC-ERDAS). Initially it was
anticipated that early spring (May) and early fall (September)
images would be needed to provide a reliable categorization.
However, this study proved to be "one of the most successful land
use and land cover mapping projects" yet undertaken by Dr. Civco.
4 color infrared 1:58,000 prints of National High Altitude
Photography were used to provide an .independent source of landscape
information for development of training sets, for accuracy
assessment and for qualitative georeferencing. Other ancillary
information included standard 1:24,000 topographic maps, 1:24,000
USFWS NWI maps, 78 ground control points on 1:24,000 transportation
maps and in a digital data file, and a digital data file in 50
meter sampling increments of the perimeter of the Pawtuxet River
Basin. The image was successfully spliced from 2 512x512K floppy
disks and a partial image already obtained of the site. The
Landsat TM image was also geometrically rectified using
transformation algorithms. A modified form of the Anderson system
was used to provide 8 and 20 category classifications for most of
the Pawtuxet basin. Ordering difficulties between EPA EMSL-Las
Vegas and EOSAT resulted in coverage that snipped off corners of
the basin. Fortunately these were not critical areas of concern
to this study. Most of the northeast corner of the basin is in
urbanizing land uses. Landsat TM consists of seven bands of
multispectral data. Six reflective bands with a spatial resolution
of 30 meters, and the the thermal infrared (emissive) band with a
resolution of 120 meters. Only the six reflective bands were used
in this study. This view is of bands 3 (red) , 2 (green) , and 1
(blue). The perimeter and unsampled portion of the Pawtuxet basin
is evident as a white pixel edge.
SLIDE 17. May 11, 1987 Landsat Thematic Mapper Image of the
Pawtuxet River basin. This is a view of the same scene in bands
4 (near infrared), 5 (middle infrared), and 3 (red). Vegetation
is more clearly discernible on this and the following images.
-------
SLIDE 18. May 11, 1987 Landsat Thematic Mapper Image of the
Pawtuxet River basin. This is a view of the same scene in bands
5 (middle infrared), 6 (middle infrared), and 3 (red).
SLIDE 19. A digital 8 class land use and land cover map of the
Pawtuxet basin derived from unfiltered TM data.
SLIDE 20. A digital 8 class land use and land cover map of the
Pawtuxet basin derived from filtered (smoothed) TM data. These
delineations are more useful for producing maps than for analysis,
as important complexity and patchiness is lost in the process of
filtering data.
SLIDE 21. A raster (polygon) 8 class filtered land use and land
cover map of the Pawtuxet basin transformed into ARC/INFO format.
An unfiltered image was also produced but was not created as a
slide because of intensive processing time to generate the image.
SLIDE 22. A digital 20 class land use and land cover map of the
Pawtuxet basin derived from unfiltered TM data. Note the much
greater patchiness in this image.
SLIDE 23. A digital 20 class land use and land cover map of the
Pawtuxet basin derived from filtered (smoothed) TM data. These
delineations are more useful for producing maps than for analysis,
as important complexity and patchiness is lost in the process of
filtering data.
SLIDE 24. A raster (polygon) ARC/INFO format 20 class filtered
(smoothed) land use and land cover map of the Pawtuxet basin.
SLIDE 25. A Lansat TM image of the South Branch of the Pawtuxet
River basin in bands 1 (blue), 2 (green) and 3 (red).
SLIDE 26. A Lansat TM image encompassing the South Branch of the
Pawtuxet River basin in bands 1 (blue), 2 (green) and 3 (red).
SLIDE 26. A Lansat TM image including the South Branch of the
Pawtuxet River basin in bands 3 (red), 4 (near infrared) and 5
(middle infrared).
SLIDE 26. A Lansat TM image encompassing the South Branch of the
Pawtuxet River basin in bands 3 (red), 5 (middle infrared) and 6
(middle infrared).
SLIDE 27. A digital 8 class land use and land cover map
encompassing the South Branch of the Pawtuxet River basin derived
from unfiltered TM data.
SLIDE 28. A digital 8 class land use and land cover map of the
South Branch of the Pawtuxet River basin derived from filtered
-------
(smoothed) TM data.
SLIDE 29. A raster (polygon) 8 class filtered land use and land
cover map of the South Branch of the Pawtuxet River basin
transformed into ARC/INFO format.
SLIDE 30. A digital 20 class land use and land cover map of the
South Branch of the Pawtuxet River basin derived from unfiltered
TM data.
SLIDE 31. A digital 20 class land use and land cover map of the
South Branch of the Pawtuxet River basin derived from filtered
(smoothed) TM data.
SLIDE 32. A raster (polygon) 20 class filtered (smoothed) land
use and land cover map of the Pawtuxet basin transformed into
ARC/INFO format.
SLIDE 33. A 3-dimensional projection using the TIN module of
ARC/INFO showing a view of the South Branch basin with a
superimposed image of the impoundment. Vertical height is
exaggerated 10 times.
SLIDE 34. Gravel pit proximal to Big River impoundment area.
[Discuss the uses of ARC/INFO classification in assessing
significance of the pattern of current and probable uses of the
landscape including measures of edge complexity (fractal
dimension), patchiness (Euler number), various compactness ratios
(perimeter/edge, Index of Geometric Intactness, etc.) , connectivity
(Gamma Index), etc.
SLIDE 35. Possum. Although I am officially unable to comment on
the probable outcome of our 404(c) action it appears I suspect the
Rhode Island Water Resources Board and the Governor would agree
they are out on a limb when it comes to flooding the Big River.
Americans consumptive thirst for water and natural communities
appears unquenchable and growing unless actions such as the ones
conducted by EPA continue. As natural area professionals we must
be sure to reframe such debates so that the public is not presented
with the false choice of clean, adequate water and a rich natural
heritage.
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REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
CORPS OF ENGINEERS. OMAHA DISTRICT
215 NORTH 17TH STREET
OMAHA. NEBRASKA 68102-4978
March 17, 1988
Regulatory Branch
P.O. Box 5, Omaha, Nebraska
68101-0005
Mr. Brad Miller
U.S. Environmental Protection Agency
Region VIII, 8WM-SP
999 18th Street
Suite 500
Denver. Colorado 80202-2405
Dear Mr. Miller:
This letter is in response to your March 14, 1988, letter
regarding your "specific suggestions" for the wording of special
conditions for the City of Boulder, Colorado's Department of the
Army permit application number CO 2SB OXT 2 010036.
Regarding your condition 1): The first sentence is fine.
The construction schedule of the park is for the soccer fields on
the west end of the park to be constructed during 1988. This will
impact approximately one acre of wetland. Therefore, we intend to
propose that when and if a permit is issued, the Coot Lake
mitigation site will be developed during 1989. The on-site
mitigation work will be performed when the lake is constructed.
The City of Boulder has stated they have allocated the funds for
1989 for development of the Coot Lake site. This schedule allows
for the development of the majority of the mitigation sites prior
to impacting the majority of the existing wetland sites.
The duration of the wetland mitigation requirement will be
until such time as a viable, self-sustaining wetland is developed.
We have agreed that this is the goal, not to develop a wetland
that requires on-going maintenance, but a wetland that is viable.
The mitigation site will be monitored by both the applicant and
the Corps of Engineers. If at any time during the establishment
period of the "viable, self-sustaining mitigation wetland" it is
determined that this will not be accomplished or alterations will
be necessary, an inter-agency meeting will be held to discuss
future actions. These may include manipulation of the site, or
development of an alternative' site. Whatever method is employed
must be evaluated and approved by the Corps of Engineers.
The duration of this permit will be for the time period
necessary to complete the project and . for the establishment of a
viable, self-sustaining wetland. If that takes ten years, fine.
If during the time the new .wetland is being established an action
occurs that impacts the site (drought, flood, etc.), the applicant
is still required to take .what action is necessary to provide a
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-2-
viable, self-sustaining wetland mitigation site. If park
construction is completed after ten years, but the mitigation site
is not viable, the permit will continue in effect until such time
the mitigation has been accomplished. Successful mitigation will
be met at the time the Corps has determined that the wetland is
viable and self-sustaining.
Once the park construction has been completed, and a viable,
self-sustaining mitigation wetland is created (value for value at
a minimum), the applicant will be considered free of additional
responsibility. Our position, and our mutual goal is to
compensate for the loss of wetland function and habitat which will
result from the applicant's undertaking. Our position is that
once this goal has been met, the applicant is free from additional
responsibility to maintain the mitigation site. We feel this
responsibility will not be met until a viable, self-sustaining
wetland is created.
Regarding your condition 2): This sounds good.
Regarding your condition 3): This also sounds good. We
would only add that the required photographs be taken from the
same marked point each year.
Regarding your condition 4): Our position regarding this
paragraph is discussed under condition 1) above. It is our
opinion that requiring establishment of a viable, self-sustaining
wetland, and accepting no less as successful mitigation serves the
environment better than accepting a site that we know in. advance
will require maintenance for perpetuity.
The exact wording of conditions has not been developed at
this time. A condition will require that the permittee will not
take any direct or indirect action that will adversely impact the
mitigation wetland. The cultural resource issue associated with
this activity should be resolved imminently.
Any additional comments you may have should be forwarded to
this office no later than March 25, 1988. Shortly thereafter, you
will be notified of our intent for this action.
Sincerely,
John'H. Morton, P. E.
Chief, Regulatory Branch
Operations Division
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. REGION '
J.F.KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
June 6, 1988
William F. Lawless, P.E., Chief
Regulatory Branch
U.S. Army Corps of Engineers
New England Division
424 Trapelo Road
Waltham, Massachusetts 02254-9149
Dear Mr. Lawless:
The Rhode Island Water Resources Board has applied for a §404 permit for the
proposed Big River Reservoir project and the Corps has circulated for review a
draft scope of work for a Supplemental Environmental Impact Statement (SEIS) .
During our discussion about this project last month, we both agreed that it
cannot receive a §404 permit if significant impacts to the aquatic environment
would remain after mitigation. Your staff subsequently asked us whether we
believe the significant adverse impacts of this project can be mitigated. We
believe it will be helpful if EPA restates its position on these issues.
These are important questions which should be considered now before embarking
on a lengthy and costly and controversial SEIS. As we discussed, it makes
little sense to invest additional major effort in this project if it cannot
pass the threshold standard for a federal permit. The section 404 (b) (1) guide-
lines forbid issuance of a §404 permit for projects which would cause or con-
tribute to significant degradation of waters of the U.S. [40 CFR 230.10(c)].
This prohibition applies regardless of the type of project under review or
whether practicable alternatives exist. The Big River proposal on its face
violates this standard; the record, contains incontrovertible evidence of the
significant impacts this project would cause. These impacts cannot, from
either a scientific or practical standpoint, be adequately mitigated .£/ We
first summarize the significant impacts, which are a matter of record, that the
project would cause; second, we explain the basis for our conclusion that miti-
gation cannot be relied upon to prevent these impacts.
I. The Big River project Would Cause Significant Degradation of the Aquatic
Environment
If constructed, the Big River Reservoir would disrupt aquatic ecosystems on a
massive scale. The loss of wetlands would be unprecedented, more than any
project permitted in New England since the inception of the 404 program in 1972.
The Council on Environmental Quality definition of "mitigation" [40 CFR
§1508.20(a)-(e)] includes avoidance, but in the context of this discussion, it
refers to attempting to compensate for wetland losses by creating, enhancing
or preserving other wetlands.
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-2-
In summary, the environmental consequences of the Big River project include:
0 Inundation of 570 acres of high quality wetlands;
0 LOSS of 100 to 200 acres of wetland habitat from the relocation of six
highways, construction of the dam, and loss of downstream flows which
supply water to adjacent riverine wetlands;
0 Potential impacts to Mishnock Lake and 450 acres of Mishnock Swamp from
groundwater starvation;
0 Reduced downstream flows from the Big River: 88% less flow to the Flat
River Reservoir, 34% less flow to the South Branch Pawtuxet, and 14% less
flow to the mainstern Pawtuxet;
0 Loss of over 20 miles of fresh water streams and cold water fisheries
(native brook trout);
0 Loss of over 125 acres of fresh water ponds and lakes;
0 Probable water quality impacts on the Flat River Reservoir from reduced
flows with an increased risk of eutrophication.
0 Probable violation of water quality standards in the Pawtuxet River.
These adverse effects are significant within any reasonable reading of the re-
gulations.^ Section 230.10(c) states, in part, that, "no discharge of dredged
or fill material shall be permitted which will cause or contribute to signifi-
cant degradation of waters of the united States. Findings of significant deg-
radation shall be based on the appropriate factual determinations., .with special
emphasis on the persistence and permanence of the effects...." The regulation
then states that significant degradation includes, among other things, "signifi-
cant adverse effects" to wildlife and ecosystem integrity. As summarized above,
the Big River project would cause significant individual and cumulative impacts.
In so doing it would also indisputably contribute to significant degradation, an
outcome the regulations prohibit with equal force.
I/
The term "significant" as used in the §404(b)(1) guidelines means "important,
major or consequential." Sierra Club v. Corps of Engineers, 772 F. 2d 1043,
1053 (2nd Cir. 1985). Note as well that the District Court in the Attleboro
case (Bersani v. Deland) stated that EPA had an independent basis to veto the
404 permit to fill Sweedens Swamp based on impacts alone—impacts which are
far less substantial than Big River Reservoir.
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-3-
We reach this conclusion after examining the quality and quantity of the af-
fected aquatic ecosystems, the direct and indirect effects and the persistence
of the impacts. As noted earlier, the project would represent the largest per-
mitted loss of wetlands in New England in at least 15 years. The quality of
the resources at risk and permanence of the habitat losses further underscore
the sheer magnitude of the impacts. The record clearly shows that the wetlands
at risk are not degraded or otherwise incapable of typical function. In fact,
the wetlands provide the complete range of wetland values including flood con-
trol, water quality maintenance, and wildlife habitat. Associated with a com-
plex groundwater system, the wetlands perform important recharge and discharge
functions. These wetlands are—both legally and ecologically—special aquatic
sites, their value verified not only by our own biologists, but also by those at
the Fish and Wildlife Service (FWS) and the University of Rhode Island.
It appears this project would also violate §230.10(b) of the 404 guidelines,
which prohibits activities that will cause or contribute to violations of any
applicable state water quality standard"!The Big River proposal will violate
Rhode Island's water quality standards for dissolved oxygen (DO) levels in
Class C streams, and anti-degradation requirements. The standards for Class C
streams, such as the pawtuxet River, require a minimum DO level of 5 mg/1 at all
times, arid maintenance of normal seasonal and diurnal variations above 5 mg/1.
The standards also require that no toxics be present in toxic amounts. The
pawtuxet River now violates the DO standard of 5 mg/1 during summer months.
Any additional water removal which worsens this situation would cause or contr-
ibute to a violation of dissolved oxygen criteria and may cause or contribute
to a violation of tpxicity criteria. Furthermore, any decrease in water flows
which would reduce normal seasonal and diurnal variations of DO would also
violate standards.
The anti-degradation section of the standards require that existing water uses
be maintained and protected. The Big River Reservoir would inundate 21 miles
of streams. The tributaries to Big River are self-sustaining cold water fisher-
ies that support native brook trout. Since the reservoir could not support a
self-sustaining cold water fishery, this would result in a absolute loss of
existing uses thereby violating the anti-degradation, regulations. The Big
River proposal would also reduce water levels in Flat River Reservoir, an active
boating and fishing lake. Significant interference with existing recreational
uses in the Flat River Reservoir, due to reduced water levels and resulting
increases in eutrophication, would violate State anti-degradation regulations.
Because recreation would not be allowed on the Big River Reservoir, recreational
fishing and swimming, which currently occur in four fresh water ponds would be
lost as well, another absolute loss of existing uses. Furthermore, the signifi-
cant loss of wildlife habitat in the wetlands in the project area would violate
Rhode Island's anti-degradation provision.
The Corps and EPA have previously recognized the severity of these impacts.
The Corps 1981 EIS [404(b) evaluation, p. 10] concludes in no uncertain terms
that the Big River project would result in "significant degradation of the
chemical, physical and biological integrity of the aquatic ecosystem11 as well
as "significant disruption of the food chain." We affirmed those findings in our
1981 comment letter on the final EIS, concluding that the Big River project
does not comply with the EPA 404(b) (1) guidelines. More recently, in our
December 8, 1987 letter to you and in our January 12, 1988 statement at the
public scoping session we reiterated these long-standing views.
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-4-
II. Significant Adverse Impacts Would Remain Even After All Practical Steps to
Mitigate Impacts
The Corps' March 1, 1985 letter to the applicant indicated that the only way
this project could overcome the significance requirement of the guidelines
would be to mitigate fully and adequately for those wetland values to be lost.
You further concluded that it would be inappropriate to prepare an EIS for a
project that would be denied a 404 permit.
We do not believe that any mitigation plan could begin to compensate for the
loss of wetland values the project would cause, let alone fully replace them as
prescribed in your 1985 letter.^/ Indeed, to even attempt full replacement of
the values associated with the existing habitat would require a mitigation plan
so outlandishly complex as to be infeasible from any standpoint. We believe
the impacts cannot be mitigated either theoretically (i.e., it is not possible
to devise a plan) or practically (i.e., such a plan would in any case be unreal-
istic) . Even if it were possible to develop and implement mitigation, it
should not be relied upon to prevent significant impacts of such massive scale,
given the inherent risks associated with the practice.4/
I/
We consider in this letter the specific question of whether the significant
impacts of this project could be mitigated sufficiently to comply with 40 CFR
230.10(c). Mitigation cannot be used to achieve compliance with the require-
ment in the guidelines that a permit be denied if there exists a less environ-
mentally damaging practicable alternative. The permit application submitted
by the Water Resources Board does not clearly demonstrate that the Big River
project is the least environmentally damaging practicable alternative. Hence,
the project may not comply with 40 CPR 230.10(a). However, we need not reach a
conclusion under the alternatives provision where significant impacts would
occur, since the guidelines cannot be satisfied in any event.
I/
Arguably there is no legal basis for relying on mitigation bo overcome the
prohibition against significant impacts. Section 230.10(c) makes no reference
to using mitigation in this fashion and nowhere else do the guidelines endorse
the practice. It may be reasonable to rely on mitigation where it can prevent
significant impacts from occuring (for example, where definitive measures can
be designed into a project to avoid flood damages that would otherwise occur).
There is no reason to place the same confidence in mitigation where, as here,
significant impacts to the full spectrum of wetland values would definitely
occur.
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-5-
The literature to date indicates that wetland creation is highly speculative,
more of an experiment than a science (Larson and Neill, 1986). Since scientists
are not sure how wetlands provide all the values they do, it is hardly surpris-
ing there are 33 many unknowns in wetland mitigation (Kusler, 1987). In New
England, three recent studies have focused on wetland mitigation. One report,
entitled Wetland Mitigation Effectiveness, investigates four separate mitiga-
tion projects required by the Corps and EPA during its 404 permit decision pro-
cess (Metcalf and Eddy, Inc., 1986). The results show that none of the four
projects fully succeeded — two projects were marginal and two were ineffective.
In speculating on the reasons for failure, the report cites a lack of technical
detail, inadequate monitoring and reporting requirements, climatic changes,
lack of client incentive after the permit issuance, and the general uncertainty
inherent in wetland mitigation. The study concludes, among other things, that
because of such poor results in wetland creation, mitigation should focus on
restoration of degraded areas or enhancing less valuable systems, rather than
the uncertain process of destroying one viable habitat in an attempt to create
another one. The Corps recently contracted with IEP, a wetland consulting
firm, to review mitigation associated with 20 different permitted projects.
Five of the 20 cases involved compensatory wetland creation from upland habitat.
The results from the draft report echo the Metcalf ard Eddy findings: none of
the five creation attempts has been fully successful (M. Sheehan, Corps, pers.
comm., 1988).
The most extensive report on mitigating freshwater wetlands in the northeast
(Larson and Neill, 1986) concludes that the scientific base is too incomplete
to support assertions that artificial wetlands will provide the functions of
natural wetlands. Some wetland functions, such as flood storage, can be esti-
mated by engineering techniques and replicated successfully. Also, habitat
alteration to benefit certain species, such as manipulating water levels to
benefit waterfowl, has been practiced by some wildlife managers. However, the
report emphasizes that we have almost no knowledge of how to replicate wildlife
habitat for other species which extensively use wetlands, such as migratory and
breeding warblers, hawks, owls and small mammals. We have even less information
about replicating other wetland values like groundwater discharge ard recharge,
water quality, and nutrient transformations.
Because of the lack of information on wetland creation ard the potential impor-
tance of mitigation in making permit decisions, EPA has decided to study mitiga-
tion as one of its top research priorities in the next five years. The first
step, a literature review, should be published in the later part of 1988. Over
one-half of the wetland creation projects cited in the literature review have
failed, generally corroborating the situation in New England. All wetland
creation projects, at this point in time, involve risk of partial or complete
failure (Race, 1985).
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-6-
The majority of migitation projects reported in the literature, including many
that failed, are between one and ten acres in size. None of the projects
begins to approach in size or complexity the sort of mitigation the Big River
project would require. *K> create artificial systems to replace the values of
over 300 acres of forested wetlands, over 100 acres of shrub swamp wetlands,
over 30 acres of emergent wetlands, and 25 miles of streams and associated river-
ine habitat, is impossible.
Dr. Frank Golet, a professor at the University of Rhode Island and one of the
foremost wetland biologists in New England, agrees. In his 1984 report Wetlands
and Deepwater Habitats of the Big River Watershed; inventory and Wildlife Eval-
uation, he concludes on page 8:
There is no practical way of mitigating the losses
of wetland habitat that would result from construction
of the Big River Reservoir... subimpoundments would
simply convert existing wetland from one type to
another (e.g., forested wetland to emergent wetland);
they would not create new wetland. It is unfeasible
to even attempt to create new wetland to replace
the complex of stream systems that would be lost.
Aside from the unacceptable scientific and technical risks, attempting to miti-
gate this magnitude of loss poses practical problems as well. In 1981, the
FWS completed a Habitat Evaluation procedure (HEP) on the proposed pool area
for one of the wetland functional values (wildlife),5/ According to the FWS,
during discussions on mitigation, the Corps asserted that moving 600 acres of
hydric soil (for wetland creation) was economically unacceptable. Therefore,
FWS assessed the potential for attempting to enhance existing habitats to
replace those wildlife values lost by building the project. Based on the loss of
570 acres of high quality wetland habitat, FWS concluded that 5800 acres would
have to be acquired and intensively managed to replace the lost wildlife values.
It seems inconceivable that Rhode island could acquire, manage and monitor the
land for such a huge undertaking. Moreover, FWS based the HEP on the loss
of 570 acres of wetlands. Because we now suspect closer to 1000 acres of di-
verse wetland habitat to be at risk, further analysis would be needed to deter-
mine the additional area needed to theoretically compensate for project losses.
Substantial analysis would be needed to determine how to compensate for wetland
values other than wildlife. Obviously such compensation would further compli-
cate an already unrealistic mitigation plan.
EPA was not party to an3 does not necessarily endorse the results of this HEP
analysis. It does however illustrate the unrealistic scale of even partial
mitigation.
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To attempt to create 1000 acres of wetland or acquire and manage 5800 acres of
wetland (something the applicant has indicated no willingness to do) would
border on the preposterous, in light of the poor track record of mitigation.
The severity of impacts which would be caused by Big River Reservoir serve only
to magnify the inherent uncertainty and irreducible risk associated with miti-
gation.
III. Conclusion
In summary, the Big River Reservoir proposal would cause significant impacts to
the .aquatic ecosystem and violate the §404(b)(1) guidelines. Due to the extent
and severity of the impacts, and the uncertainty of wetland creation, we con-
clude that the adverse impacts cannot be fully or reliably mitigated. Any
serious attempt to do so would be unrealistic from a practical standpoint. Hence,
any reasonable and practical mitigation efforts which might be taken cannot alter
the fact that the project will have a significant impact on the aquatic environ-
ment and violate the §404(b)(1) guidelines.^/ The Big River project area contin-
ues to be a candidate for protection pursuant to our authority under §404(c) of
the Clean Water Act.
We hope this information will assist you in deciding how to proceed with this
project. Thank you for your attention to this important issue. My staff and
I are available to meet and discuss this matter further at your convenience.
Sincerely,
£^ u—\^Ji—L_
Ronald G. Manfredonia, Chief
Water Quality Branch
cc: Col. Thomas Rhen, DE, NED
I/
Moreover, the Corps regulations state that permit conditions (including miti-
gation) must be reasonably implementable or enforceable, or the permit must
be denied [33 CFR 325.4(c)] . In other words, unless the Corps can be confident
that the mitigation will succeed, it must deny the permit. We hope that it is
clear that the current state of mitigation does not inspire confidence—not
for a ten acre mitigation project let alone a wetland creation project that
could approach 1000 acres in size.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\
3 REGION I
*
& J.F. KENNEDY FEDERAL BUILDING. BOSTON, MASSACHUSETTS 02203-2211
X
August 24, 1988
Colonel Thomas A. Rhen, Division Engineer
U.S. Army Corps of Engineers
New England Division
424 Trapelo Road
Waltham, MA 02254-9149
Dear Colonel Rhen:
I am writing to inform you that I am beginning an action under
section 404(c) of the Clean Water Act, concerning the proposed
Big River Reservoir in West Greenwich, Rhode Island. I am taking
this step because I believe that the Big River Reservoir project
could result in unacceptable adverse effects, particularly to
fish and wildlife. This letter notifies you, pursuant to 40
C.F.R. §231.3(a), that I intend to issue a public notice of a
proposed determination to prohibit the discharge of dredged or
fill material at the Big River project site.
As you know, EPA has had longstanding concerns about this project
because it would disrupt aquatic ecosystems on a massive scale,
including a loss of wetlands unprecedented in New England. We
have conveyed our concerns in numerous meetings and written
comments during the initial EIS process and throughout the
project's history. Most recently in our letter of June 6, 1988
and our meeting of June 22, 1988, we detailed our environmental
objections to the project. EPA is initiating this 404(c) action
based on our assessment that the project would cause significant
impacts which could not be adequately mitigated. The record
developed to date indicates that the project would cause or
contribute to significant degradation of the aquatic environment,
including impacts to fish and wildlife. Apart from the sheer
impacts of the project, there is a reasonable likelihood that
practicable alternatives to the project exist.
EPA's regulations on section 404(c) procedures allow further
coordination between EPA, the Corps, and the State. According to
40 C.F.R. §231.3 (a) (2) , you have 15 days from receipt of this
notice to persuade me that no unacceptable adverse impacts would
occur from this project, or that you will take corrective action
satisfactory to EPA to prevent such adverse effects. In this
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regard, EPA believes that the Corps1 and State should abandon
this project and instead implement environmentally acceptable
alternatives. For example, the recent state report entitled
Water Supply Policies for Rhode Island (March, 1988) discusses a
number of promising approaches for effective water supply
management.
I appreciate your prompt attention to this matter. If you have
any questions or if you would like to arrange a meeting, please
call me at 565-3400.
Sincerely,
Michael R. Deland
Regional Administrator
cc: Hon. Edward D. DiPrete, Governor, Rhode Island
A.J. Mattera, RI Water Resources Board, Providence, RI
R. Lambertson, Dir., USFWS, Newton, MA
R. Hanmer, Acting AA for Water, EPA, Washington, D.C.
D. Davis, Dir., OWP, EPA, Washington, D.C.
R. Bendick, Dir., DEM, Providence, RI
1The Corps has characterized the project which the Corps
might undertake as being exempt, pursuant to section 404(r), from
the requirements of the 404(b)(l) guidelines and from EPA's
404(c) authority. Although the reservoir project was authorized
by Congress in 1986 as part of the omnibus Water Resources
Development Act, we do not believe the project qualifies for a
404(r) exemption. EPA believes the project does not comply with
several substantive and procedural requirements of section 404(r)
and is subject to EPA's §404(c) authority. Irrespective of
§404(r), I plan to proceed with the 404(c) process as it pertains
to the pending state project.
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,eo sr«,.
* UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
-• J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
-
August 24, 1988
A. Joseph Mattera, Chairman
Rhode Island Water Resources Board
265 Melrose Street
Providence., Rhode Island 02907
Dear Mr. Mattera:
I am writing to inform you that I am beginning an action under
section 404(c) of the Clean Water Act, concerning the proposed
Big River Reservoir in West Greenwich, Rhode Island. I am taking
this step because I believe that the Big River Reservoir project
could result in unacceptable adverse effects, particularly to
fish and wildlife. This letter notifies you, pursuant to 40
C.F'.R. §231.3(a), that I intend to issue a public notice of a
proposed determination to prohibit the discharge of dredged or
fill material at the Big River project site. A copy of my letter
to the Corps of Engineers is enclosed, as is a copy of the
regulations promulgated pursuant to section 404(c) of the Act.
EPA has had longstanding concerns about this project because it
would disrupt aquatic ecosystems on a massive scale, including a
loss of wetlands unprecedented in New England. We have conveyed
our concerns to both Rhode Island and the Corps in numerous
meetings and written comments during the initial EIS process and
throughout the project's history. EPA is initiating this 404(c)
action based on our assessment that the project would cause
significant impacts which could not be adequately mitigated.
The record developed to date indicates that the project would
cause or contribute to significant degradation of the aquatic
environment, including impacts to fish and wildlife. Apart from
the sheer impacts of the project, there is a reasonable
likelihood that practicable alternatives to the project exist.
EPA's regulations on section 404(c) procedures allow further
coordination between EPA, the Corps, and the State. According to
40 C.F.R. §231.3 (a) (2) , you have 15 day's from receipt of this
notice to persuade me that no unacceptable adverse impacts would
occur from this project, or that you will take corrective action
satisfactory to EPA to prevent such adverse effects. In this
-------
regard, EPA believes that the Corps1 and State should abandon
this project and instead implement environmentally acceptable
alternatives. For example, the recent state report entitled
Water Supply Policies for Rhode Island (March, 1988) discusses a
number of promising approaches for effective water supply
management.
I appreciate your prompt attention to this matter. If you have
any questions or if you would like to arrange a meeting, please
call me at 565-3400.
Sincerely,
Michael R. Deland
Regional Administrator
Enclosure
cc: Hon. Edward D. DiPrete, Governor, Rhode Island
Col. Thomas A. Rhen, P.E., NED, Waltham, MA
R. Lambertson, Dir., USFWS, Newton, MA
R. Hamner, Acting AA for Water, EPA, Washington, D.C.
D. Davis, Dir., OWP, EPA, Washington, D.C.
R. Bendick, Dir., DEM, Providence, RI
1The Corps has characterized the project which the Corps
might undertake as being exempt, pursuant to section 404(r), from
the requirements of the 404(b)(l) guidelines and from EPA's
404(c) authority. Although the reservoir project was authorized
by Congress in 1986 as part of the omnibus Water Resources
Development Act, we do not believe the project qualifies for a
404(r) .exemption. EPA believes the project does not comply with
several substantive and procedural requirements of section 404(r)
and is subject to EPA's §404(c) authority. Irrespective of
§404(r), I plan to proceed with the 404(c) process as it pertains
to the pending state project.
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August 24, 1988
FACT SHEET: 404(c) PROCESS
Under Section 404(c) of the Clean Water Act, the Env i rorimental
protection Agency has the authority to, in effect, prohibit or
restrict thy Discharge of dredged or fill material into U.S.
waters, including wetlands, where the EPA believes that such
dishcharge will have an unacceptable adverse effect on the
environment. EPA's regulations at 40 CFR 231 govern the multi-
step 404(c) process and are described briefly below.
0 The process begins with a letter of notification from EPA's
Regional Administrator to the Corps and. the permit applicant,
stating EPA's belief that an "unacceptable adverse effect" may
result from the disposal of dredged or fill material at the
site. The letter itself does not constitute a veto. How-
ever, once the notice is sent, the Corps shall not issue the
permit or proceed with construction until EPA takes final
ac t iu n .
Ren.-ii.pi-. .if the letter begins a 15 day consultation peci.o.1 la
which to satisfy the Regional Administrator that no unaccept-
able adverse inpacts will occur, or that corrective measures
will be taken to prevent such impacts.
0 If, following the 15 day consultation period, the Regional
Administrator still believes the proposed discharge could
result in an unacceptable adverse impact, EPA must publish a
proposed determination to prohibit or restrict the use of
the area as a disposal site.
0 The public notice will be published in the Federal Register
as well as local newspapers. The notice will include the
reasons for the proposed determination, a description of the
site, and the nature of the proposed discharge. The notice
will either include information regarding the right to and
procedures for requesting a public hearing, or include notice
of a scheduled public hearing.
0 Interested persons will have a period (normally between 30
and 60 days) to submit comments to EPA. If a public hearing
is held, public notice will he provided of the date, time,
and location of the hearing.
0 Following the public comment period and after careful consid-
eration of the record developed the Regional Administrator
either withdraws the proposed del;1-1 ''M.I i. ?i Hi; ion or ^orwacl-s a
determination to EPA Washington recommending that the project
be ^ r oh ib i ted or r es tr ic ted .
0 The Assistant Administrator for Water in EPA Washington makes
the Einal determination. Notice of the decision is provided
to all persons who participated in the public hearing and is
published in the Federal Register. For purposes of judicial
review, a final determination constitutes final agency action
under Section 404(c) . . ..
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August 24, 1988
FACT SHEET; BACKGROUND OF BIG RIVER RESERVOIR CASE
0 The Big River project, a $262 million water supply reservoir proposed
in Kent County Rhode Island, would directly eliminate over 600 acres of
valuable wetlands and threaten an additional 450 acres of wetland
habitat. The reservoir proposal is an outgrowth of water supply studies
completed for Rhode Island in the 1950s and 1960s; There are proposals
to construct the project either by the State alone or as a joint venture
with the Corps of Engineers.
0 Having failed several times to secure funding to complete engineering
studies, Rhode Island asked the Corps in 1978 to consider constructing
the Reservoir. The Corps completed an Environmental Impact Statement
(EIS) on Big River in 1981 and, despite conclusions in the EI3 that
environmental impacts would be significant and severe, recommended to
Congress in 1983 that it be approved. Congress authorized the project
as part of the omnibus Water Resources Development Act of 1986, but did
not appropriate any funds. As early as 1982, EPA alerted the Corps
that because of the severe wetland impacts, th'e project would not
comply with the §404(b)(l) guidelines, the primary federal regulations
that protect wetlands.
0 In 1986, the State informed the Corps that it again wished to pursue
the reservoir as a state project and subsequently applied for a federal
§404 permit. The Corps in 1987 informed the State that a supplemental
EIS would be required to address a number of unresolved issues surrounding
the project. During 1987 and 1988, EPA voiced its concerns about the
project's severe environmental impacts and alerted the State that it was
unlikely to be able to obtain a 404 permit. EPA also emphasized the
need for the State to do a thorough needs and alternatives analysis.
In June 1988, EPA informed the Corps by letter that the project would
cause significant degradation of the aquatic environment and that the
impacts could not be adequately mitigated, and urged permit denial.
0 In a July 1, 1988 letter to Governor Diprete, the Corps indicated that
the project as proposed would cause significant impacts to the aquatic
environment, would not comply with the §404(b)(l) guidelines, and
probably could not receive a federal 404 permit. However, two weeks
ago, the Corps indicated that the Big River Reservoir might be built as
a federal project. The environmental impacts of the state and federal
projects would be the same, although the federal project would include
flood control and recreation aspects in addition to water supply.
0 Because of its longstanding concerns about the environmental impacts of..
the proposed Big River Reservoir project, Region I of the Environmental
Protection Agency (EPA) today began an action under section 404 (c) of
the Clean Water Act. Section 404(c) allows SPA to prohibit or restrict
discharges of dredged or fill material into waters of the United States
to prevent unacceptable adverse impacts to,, among other things, fisheries
or wildlife. Unless convinced within 15 days that the proposed Reservoir
will not cause unacceptable adverse impacts, EPA will issue a public
notice proposing to prohibit the discharge of dredged and fill material
into waters and wetlands at the site. Following a public comment —
period, the Region will send its decision to EPA Washington, where a
final determination will be made. The 404(c) .decision could prevent
construction of the Reservoir.
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August 24, 1988
FACT SHEET; ENVIRONMENTAL IMPACTS OF THE PROPOSED BIG RIVER RESERVOIR PROJECT
If constructed, the Big River Reservoir would disrupt aquatic ecosystems on a
massive scale. The loss of wetlands would be unprecedented, more than any project
permitted in New England since the inception of the CWA in 1972. The quality of
the resources at risk and permanence of the habitat losses further underscore the
she«r: magnitude of the impacts. In summary, the environmental consequences of the
Big River project include:
0 Inundation of 570 acres of high quality wetlands;
0 Potential impacts to Mishnock Lake and 450 acres of wetland habitat at Mishnock
Swamp from groundwater starvation. Additional wetland destruction would
result from relocation of six highways, construction of the dam, and loss of
downstream flows which supply water to adjacent riverine wetlands;
0 Reduced downstream flows from the Big River: 88% less flow to the Flat River
Reservoir, 34% less flow to the South Branch Pawtuxet, and 14% less flow to
the mainstem Pawtuxet;
0 Loss of over 20 miles of fresh water streams and cold water fisheries (native
brook trout);
0 Loss of over 125 acres of fresh water ponds and lakes;
0 Probable water quality impacts on the Flat River Reservoir from reduced flows
with an increased risk of eutrophication;
0 Probable violation of water quality standards in the Pawtuxet Rivec;
0 Possible depletion of the Mishnock Aquifer.
Based on the quality and quantity of the affected aquatic ecosystem, the direct
and indirect effects and the persistence of the impacts, the Big River Reservoir
would have a significant adverse effect on the aquatic resource. The record
shows that many of the wetlands at risk are of high quality and provide a wide
spectrum of functions. In fact, the wetlands provide the complete range of wetland
values including flood control, water quality maintenance > and wildlife habitat.
Associated with a complex groundwater system, the wetlands perform important
recharge and discharge functions as well -as sediment and nutrient trapping.
These wetlands are—both legally and ecologically—special aquatic sites. There
is no practical way to mitigate the loss of the wetland habitat, especially the
complex system of streams that would be lost.
The Corps has recognized the severity of these impacts. The Corps 1981 ETS
concludes in no uncertain terms that the Big River project would result in
"significant degradation of the chemical, physical and biological integrity of
the aquatic ecosystem" as well as "significant disruption of the fool chain."
The Corps reiterated this view as recently as July 1, 1988, in a letter to the
State which warned that because of the significance of the impacts, the project
was unlikely to receive a Corps permit.
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United States
Environmental Protection
Agency
Region I
Connecticut
Maine
Office of Massachusetts
Public Affairs New Hampshire
John F. Kennedy Federal Building Rhode Island
Boston, Massachusetts 02203 Vermont
4>EPA Environmental News
August 24, 1988 For more information call
Brooke Chamberlain-Cook
Office of Public Affairs
(617) 565-3424
BOSTON The U.S. Environmental Protection Agency announced
today that, based on all the information available to date, it
has urged that the State of Rhode Island and the U.S. Army Corps
of Engineers abandon plans to construct a major reservoir in West
Greenwich/ Rhode Island.
Michael R. Deland, EPA Regional Administrator, said that he was
initiating a formal review of the project under Section 404(c) of
the federal Clean Water Act. Unless additional information is
forthcoming that would show that there would be no unacceptable
adverse impacts from the Big River Reservoir, he would proceed
with ,the process to veto the projec£. ,x The. EPA official .pointed ,.,
out the project "would result in the" destruction of 300* acfes^of
valuable wetlands.
Section 404(c) empowers EPA to protect wetlands and other water
bodies from construction projects which would cause "unacceptable
adverse effects" to, among other things, fish and wildlife.
Section 404(c) involves a multi-step process by which information
and public comments are gathered before EPA reaches a final
decision. Today's action is the first step in that process.
Deland1s letters indicate that he will proceed under section 404
(c) of the Clean Water Act to decide the fate of the project
unless the Corps or the State satisfies him within 15 days that
no unacceptable, adverse impacts will occur. Based on current
information, EPA urged that the Corps and the State abandon the
Big River project and instead implement environmentally
acceptable alternatives to meet Rhode Island's water supply
needs.
In addition to the loss of wetlands, which at 600 or more acres
would be greater than any project permitted in New England since
the inception of the federal Clean Water Act of 1972, the project
would eliminate twenty miles of streams and native trout
fisheries and would likely violate water quality standards in the
Pawtuxet River and the Flat River Reservoir.
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PUZZLING FACTS: THE BIG RIVER PROJECT
Rhode Island's Water Resources Board is planning to build Big
River Reservoir at a cost of greater than $250,000,000. The
Board estimates that it will supply 30 HGD of potable drinking
water to Rhode Island.
If the minimum downstream release from Big River is 8 cfs, as EPA
recommended in 1981, instead of the assumed 6 cfs( -2 cfs); and
If 8 cfs is needed to augument the loss of groundwater to Misnock
Lake and Swamp; then:
.30 MGD
-2 MGD
-8 MGD
20 MGD Actual Yield
But the Misnock Aquifer can supply about 10 MGD as groundwater.
By constructing the Big River Project and causing such environmental
havoc — loss of 1000 acres of wetland, and water quality impacts
to two major lakes and two rivers -- the project would only supply
a net gain of 10 MGD at a cost of >$250 million.
PUZZLE?
Is this the same state which has been fighting EPA for 10 years
to spend $2 million to upgrade its sewage treatment plants?
How can Rhode Island consider allowing a company to site a huge
landfill within five miles of three large aquifers (Upper wood,
Lower Wood, and Beaver), which have the capacity to supply 20-30
MGD of potable water?
How can desalinization be called "not cost effective", given the
price of the Big River Reservoir, and therefore not examined as
an alternative? A recent EPA report on desalinization (Beaver
Swamp Project, Virginia, March 1987), concludes that reverse
osmosis can be cost effective compared to other methods.
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Ground-Water
Reservoirs
BAIMIN4TON
.CMIPUXET
.MINK
-USEQUCPAUB-QUCE
•EAVEft
,UPPCM WOOD
.LOWEft WOOD .
AOFOND
.ASNAWAT
.WESTENLY
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ENVIRONMENTAL CONSEQUENCES DUE TO THE BIG RIVER PROJECT
1. The loss of over 600 acres of wetland habitat.
2. The likely loss of 500 acres of Misnock Swamp and Misnock
Lake due to the alteration of ground water flow.
3. A proportionally high loss of emergent wetland.
4. Reduced downstream water flows:
a) 88% less flow to Flat River Reservoir.
b) 34% less flow to the South Branch of the Pawtuxet.
c) 14% less flow to the mainstem of the Pawtuxet.
5. The likely loss of cold-water fisheries in a state which
has very few streams which are suitable for cold-water
fisheries.
6. The loss of over 20 miles of fresh water stream habitat.
7. The loss of over 125 acres of fresh water ponds.
8. The probable water quality impacts on the Flat River
Reservoir.
9. The possible violation of water quality standards on the
South Branch and the mainstem of the Pawtuxet River.
10. The possible loss of the Mishnock Aquifer which could
supply about 10 MGD to Rhode Island (Big River reportedly
will yield 30 MGD).
11. The potential need to divert water from the Wood River,
the largest cold-water fishery in Rhode Island, to
help fill and maintain the proposed Big River Project.
12. There is no practical way to mitigate the loss of wetland
habitat, especially the complex system of streams that
would be lost.
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ENVIRONMENTAL CONSEQUENCES DUE TO THE BIG RIVER PROJECT
1. The likely loss of over 1000 acres of wetland habitat.
a) direct impact to 600 acres of wetland.
b) direct impact to additional wetlands due to the need
to relocate six highways.
c) possible loss of 500 acres of Misnock Swamp and Misnock
Lake due to the alteration of ground water flow.
2. A proportionally high loss of emergent wetland, a type
which is relatively scarce in Rhode Island, and of high
value to wildlife such as waterfowl and wading birds.
3. Reduced downstream water flows.
a) 88% less flow to Flat River Reservoir.
b) 34% less flow to the South Branch of the Pawtuxet.
c) 14% less flow to the mainstem of the Pawtuxet.
4. The likely loss of cold-water fisheries in a state which
has very few streams which are suitable .for cold-water
fisheries. Cold-water fisheries may exist in four
streams which will be filled by the Big River Project:
Bear Brook; Congdon River; Nooseneck River; and Big River.
5. The loss of over 20 miles of fresh water stream habitat.
6. The loss of over 125 acres of fresh water ponds.
7. The probable water quality impacts on the Flat River"
Reservoir. Due to current water quality problems of
reduced flow and high nutrient levels, the Flat River
Reservoir frequently fails to meet its required downstream
release of 12.4 cfs to the South Branch. Big River
currently supplies about half of the water to Flat River
Reservoir and this supply will be reduced by 88%.
Current uses, including recreation, will probably be lost.
8. The possible violation of water quality standards on the
South Branch and the mainstera of the Pawtuxet River.
The best estimate calls for 14% reduction in flow to the
Pawtuxet River. Additional or better AWT plants may be
needed on the Pawtuxet River.
9. The possible loss of the Mishnock Aquifer which could
supply about 10 MOD to Rhode Island (Big River reportedly
will yield 30 MGD).
10. The potential need to divert water from the Wood River,
the largest cold-water fishery in Rhode Island, to
help fill and maintain the proposed Big River Project.
11. The lack of any practical way to mitigate the loss' of
wetland habitat, especially the complex, system of
streams that would be lost.
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September: 1, 1937
Big River Project, Rhode Island
Mark Kern ft
Doug Thompson, Acting Chief
Wetland Protection Section
OVERVIEW
On August 26, 1987, I went into the field with Dean Aibro and Brian Tefft of
RI DEM to look at some of the 550+ acres of -wetland to be flooded if the Big
River Project goes ahead as planned. Tefft indicated that this wetland and
adjacent upland habitat is the largest complex of its type in RI, a state
desperate for open space protection. Albro added that marsh habitat is
especially rare in Rhode Island, and that a large part of the 600 acres of
wetland habitat that will be lost due to the project is prime marsh ecosystem.
Both men report that the project proponents talk as if the project is only a
matter of time. Further, DEM is privately concerned that environmental
considerations will be easily swept aside by the political powers that be. I
some took photographs of the marsh which are included with this memo.
Most of the area to be flooded is just south of exit 6 on Route 95 in West
Greenwich. There are four principal wetland formations, generally running
north and south, which mostly correspond to riverine systems: Carr River,
Mud Bottom Brook, wetlands south of Capwell Mill Pond, and Big River. The
hydrology of this wetland complex drains north to join Big River and then
flows into the Flat River Reservoir in Coventry. Flat River Reservoir feeds
the South Branch of the Pawtuxet River which joins the Pawtuxet River in West
Warwick.
I hope to visit the Water Resources Board in the next six months to see what
information it has complied on the ineed for the project and alternatives it
has considered. Perhaps I can see first hand what data it has considered, or
whether it is simply operating on the mind-set that more is always better.
It will be curious to see they have considered conservation measures and how
conservation fits into their need assessment. The impression I have from
speaking with individuals from Rhode Island is that the Water Resources Board
has been planning this project for 20 years and has never considered other
alternatives. With such historical inertia, it is unlikely that the
environment will get major consideration in the final analysis.
We have commented on this proposal before. In your June 22, 1987 memo to
Betsy Higgins (copy attached), you noted the severe wetland impacts this
project poses. Indeed, the loss of nearly 600 acres of high quality wetlands
would be unprecedented in this region. This proposal clearly violates the
§404(b)(l) Guidelines [CFR 230.10(c)], which no amount of mitigation can
replace. The impacts are massive and unacceptable in my view.
ANDCONFID>
-------
Therefore, I suggest beginning a 404(c) action on the site. I believe that
this action is the only way the alternatives analysis and wetland impacts will
receive serious consideration. At a minimum, we would then have better
direct information on some of the impacts of the proposed project, regardless
of whether or not we go ahead with the action. Taking a 404(c) action on Big
River would push the environmental concerns of the project to the front of
the discussion. This action would be controversial, but it would bring the
environmental loss due to the project to an open,-public setting for all to
view. This is far better than waiting until the final project stages and
then voicing our concerns.
WATER QUALITY AND QUANTITY CONCERNS
Two obvious concerns with the project design, apart from the loss of wetland
habitat, are the lack of water reaching the Pawtuxet River and the sandy,
porous soils I observed in much of the area. An area this large, with a
relatively small flow, would probably take a few years to fill up if it ever
fills up. In the meanwhile, flow from the South Branch of the Pawtuxet
River, and in turn the Pawtuxet River, will be greatly reduced. The Pawtuxet
River is already having problems meeting water quality standards for dissolved
oxygen. A major loss of flow to this river for two or three years could
threaten aquatic life in the river, and undermine the entire the water quality
planning program for Rhode Island's sewage treatment plants on the Pawtuxet
River.
Another puzzling detail I observed in my cursory field investigation is that
there are large amounts of sandy, porous soils in the potential flood area.
It resembles the outwash plains so common near Cape Cod, with pitch pine,
white pine, and ericaeous shrubs. Such soils do a poor job of retaining
water. It would be useful to have some of our hydrogeologists take a look at
the feasibility and efficiency of such a project given the presence of these
soils.
VIOLATION
As you know, the Water Resources Board operates a gravel operation in the
area. There has clearly been a violation of the Clean Water Act by filling a
vraterbody and diverting a stream without a permit. RI DEM brought an enforce-
ment action about two years ago over this violation, and a consent agreement
was subsequently signed. The agreement called for removing the fill and
restoring the brook flow. The work has never been completed and, apparently
for political reasons, DEM has never followed through on its enforcement. We
need to consider if EPA should take an enforcement action or not, and what
implications this could have on the coming Big River Project. This may be a
good candidate for either a removal and restoration project order or an
admnist'rative penalty.
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CTHER COOTACTS
I also spoke with Dr. Frank Golet (University of Rhode Island) on the tele-
phone about the Big River Project. . His class did a project a couple of years
ago which included mapping most of the wetlands in the proposed flooding
area. lie sent us a copy of the summary report that was produced from the
work, with the caveat, that the quality of work varied, and he has not done
any careful field work himself. A copy of the discussion section is attached.
Dr. Golet gave me the number of a former student who worked on the project,
Carol McGinnis (401/331-7750), who now works for Wetland Management
Specialists, the wetland consultants for Big River. He also spoke of the
ecological significance of the region, with high quality interspersion of
wetland and upland habitat. It is impossible to mitigate for such a
staggering loss, he added.
I subsequently called Carol McGinnis for a update on the project. It turns
out she is the main field person for the Big River Project, and Paul Shea
(401/434-2430) is the spokesman for the Project with the agencies. The Corps
made a determination in February, 1987, to require a supplementary EIS for
Big River, with the wetland work to be completed first. . After speaking with
the Corps and Mr. Shea, it is clear that each party is waiting for the other
to carry out the next step.
What I believe will take place next is that the consultant will write a
proposal to Water Resources to flag wetlands in the field,, and the Corps will
determine if they have enough information to arrange a scoping meeting for
the SEIS. The Corps is not getting money for the project and therefore the
project is considered a low priority. It is unclear why Water Resources is
in a holding pattern. Neither group knows why EPA was not contacted about
these events, but both groups say that we will be notified in the near
future.
cc: Matt Schweisberg
Ron Manfredonia, Chief, WQB
Dave Fierra, Director,
Jerry Healey, Chief, WSB
Steve Silva, Chief, WQS
Eric Hall, WQS ,
Betsy Higgins, GRER
Ann Williams-Dawe, ORC
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UNITED S. .FES ENVIRONMENTAL PROTECT,.N AGENCY
June 22, 1982
•JBJECT Section 404(b)(l) Review of Final Environmental Inpact Statement (FEIS)
for the Big River Reservoir Project
FROM Douglas A. Ihorrcpscn, 404 Coorciflc^Eqr
Municipal Permits Section, >
TO Betsy Higgins, EIS Review Coordinator
Office of Intergovernmental Liaison
THRU: Clyde F. Shufelt, Chief
Municipal Permits Section
Edward K. McSweeney, Chief
Water Quality Branch
I have reviewed the U.S. Army Corps of Engineers FEIS, technical appendi-
•ces, and 404 evaluation to determine compliance with the EPA guidelines
issued under Section 404(b)(l) of the Clean Water Act (40 CFR 230). As
shown below, this project does not comply with the 'guidelines. In addi-
tion, the Corps conducted their 404 evaluation improperly.
The Big River Reservoir would inundate an area of approximately 3,400
acres (5.2 square miles) of which 570 acres are wetlands at a spillway
crest of 303 feet National Geodetic Vertical Datum (NGVD). The proposed
Dam would be located at the confluence of the Big River and the Flat
River Reservoir in Coventry, RI. The purpose of the project is to provide
drinking water, flood protection, and recreational opportunities.
This project is subject to Section 404(r) of the Act which exempts the
proposal from normal permitting procedures provided the FEIS contains
information on the effects of the discharge of fill material and considers
the 404(r) Guidelines. The Corps has prepared a 404 evaluation in
accordance with EPA's Interim Guidelines published September 5, 1975 and
concluded that the Big River Reservoir proposal complies with those
Guidelines.
In fact, this evaluation should have been organized according to EPA's
final 404(b) Guidelines published December 24, 1980. The effective date
of the new Guidelines for projects meeting the 404(r) criteria was April
1, 1981. The Corps addresses this point only briefly on page 27 of the
Supplemental Report with a statement that, "the evaluation met the intent
and requirements of these (the final) Guidelines as well". Regardless of
the issue of compliance with the Guidelines, the Corps should prepare a
404 evaluation in accordance with the legally effective and current
Guidelines rather than Guidelines which have not been in force for over a
year.
It is true that the final Guidelines are similar in general scope and
intent to the 1975 Guidelines. However, the 1980 Guidelines are organized
differently, provide different restrictions on discharges, and - reflect
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-2-
the changes brought about by the 1977 Amendments to the Clean VJater Act.
They also allow for . easier utilization during the review process and
eliminate certain ambiguities present in the 1975 Guidelines. The four
conditions that must be satisfied in order to comply with the final
Guidelines are found in Section 230.10: There must be no less environ-
mentally damaging, practicable alternative to wetland filling available;
the activity must not violate applicable State water quality standards
or jeopardize an endangered species; the activity must not cause or
contribute to significant degradation of the aquatic habitat; and all
reasonable and practicable steps must be taken to minimize adverse.envi-
ronmental effects. It is important to note that each of these restric-
tions on discharge must be satisfied; compliance with one condition
cannot be used to "balance out" or "mitigate" non-compliance with another.
The Big River Reservoir proposal fails to comply with either the general
objectives or specific provisions of the 404(b)(l) Guidelines. Section
230.1(c)(d) states a clear purpose and policy:
(a) Fundamental to these Guidelines is the precept- that dredged or fill
material should not be discharged into the aquatic ecosystem, unless
it can be demonstrated that such a discharge will not have an
unacceptable adverse impact either individually or cumulatively or in
combination with known and/or probable inpacts of other activities
affecting the ecosystems of concern.
(b) From a national perspective, the degradation or destruction of special
aquatic sites, such as filling operations in wetlands, -is considered
to be anong the nost severe environmental impacts covered by these
Guidelines. The guiding priciple should be that degradation or
destruction of special sites may represent an irreversible loss of
valuable aquatic resources.
The Big River project would result in the unprecedented destruction of
wetlands in Rhode Island (570 acres), damming of 20 miles of free flowing
stream, and loss of about 2,500 acres of supporting upland habitat. We
view this major destriction of high quality, special aquatic sites as
having significant adverse impacts both individually and cumulatively.
This is especially true in densely populated Rhode Island which has few
areas as undisturbed and diverse as the Big River watershed.
The purpose of the Clean Water Act is to "restore and maintain the
chemical, physical, and biological integrity of the Nation's waters", not
"protect vital water resources from ... irresponsible or irreversible
decisions or actions", as stated on page 1 of the 404(b) evaluation.
The proposal may not comply with Section 230.10(a) which requires
implementaion of less environmentally damaging, feasible alternatives.
During the planning phases, the Corps evaluated numerous alternatives to
meet the projected water demand. The Corps eventually discarded alterna-
tives which did not involve construction of the dam mainly because of a
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-3-
larce expected need for water. However, the Corps based their estimates
on 1975 projections; the 1979 population projections do not show the
same rate of growth and predict a lower deirand for water. Almost all
Garmenting parties urged the Corps to utilize the more recent projections,
but the Corps continues to favor the 1975 figures because they are "more
conservative" and less likely to be influenced by short-term trends
(Appendix C2 page 7). Yet there is no evidence presented to indicate
that the 1979 projects were derived from methodological flaws or otherwise
inferior to the 1975 figures. Without such evidence it would seem more
appropriate to utilize the more recent - and presumably more accurate -
data.
This is important because if the demand is reduced over earlier projec-
tions, then it may be possible to implement one of the less environ-
mentally damaging alternatives considered earlier. In particular, water
demand modification (i.e., conservation) or groundwater development might
now be feasible and should be re-evaluated. Special consideration should
be given to the feasibility of combining several compatible alternatives
such as conservation and aquifer development. For example, the FEIS
estimates that water demand modification could reduce municipal use by
as much as 11% by the year 2030 and several reviewers felt this was too
lew (cf. page 73, Appendix C2).
Based on the information in the FEIS the project will not jeopardize any
endangered species. However, this determination was based on only one
week of field work which is too short a time to do a comprehensive survey
or account for seasonal factors which might influence species presence or
distribution. RI DEM did indicate that several rare plants were extent
in the area (condradicts statement of page 24 of FEIS).
Downstream violations of State water quality standards may occur as a
result of the proposed low flow regime. The proposed flow of 6 cfs is
very low and certain to aggravate the existing water quality problems
downstream. The Corps maintains at numerous points in the FEIS that
this release is adequate for waste assimilation and protection of aquatic
life. No data or rationale is presented to justify this position.
Without information to the contrary, it seems likely that the reduced
flow would cause higher temperatures, reduced dissolved oxygen, and
increased contaminant levels which in combination would adversely effect
aquatic life.
The assertion in the supplementation report (page 14) that "poor water
quality conditions are not expected to improve appreciably in the future
..." is in contrast to the fact that lower stream segments have been
upgraded to Class C from Class D. The Corps also states that 6 cfs is
acceptable to Phode Island, yet that is certainly not reflected in the
State's comments on the DEIS (Appendix C, pages 50, 52). The Corps
repeatedly responds to concerns about the flow 'regime by stating that
studies will be undertaken to analyze these impacts during "advanced
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-4-
design stages". This response is inadequate; the information is needed
now, during the evaluation and decision process, not after final author-
ization.
Water quality may also be adversely affected by the destruction of a
large expanse of wetlands. The wetlands in the project area "do not have
significant functions in maintenance of water quality" according to the
404(b) evaluation (page 10); again I did not see any scientific information
to support this claim. The general ability of wetlands to trap water-
borne sediments, contaminants, and excess nutrients has been demonstrated
many times (see, for example. Van Der Valk et al, 1978*).
The most demonstrable non-compliance with the 404(b) Guidelines results
from the significant adverse biological impacts on the aquatic ecosystem.
Section 230.10(c) of the 404(b)(l) Guidelines prohibits discharges which
"cause or contribute to signficant degradation of waters of the U.S.".
This includes, individually or collectively, impacts on fish, wildlife,
special aquatic sites, ecosystem diversity, and recreational values.
Page 10 of the 404(b) evaluation summarizes the impacts that would result
from the Big River Reservoir project which include:
(1) Significant disruption of the chemical, physical, and biological
integrity of the aquatic ecosystem including aquatic biota and sub-
strate;
(2) Significant disruption of the food chain, including alteration or
decrease in diversity of terrestrial and plant and animal species
within the impoundment area; and
(3) Inhibition of movement of fauna including movement into and out of
feeding, spawning, breeding, and nursery areas.
The significance of the wetland impacts is correctly stated on page 3 of
the 404(b) evaluation: "wetland losses should be considered significant
due in part to the relative scarcity in the State (1.5% of total land
area) and to their important overall biological productivity and diversity
of a region". Additional impacts on the existing trout fishery and
aesthetic/recreational value of the area would occur. In short, the
proposed flooding of 3,400 acres would destroy a large expanse of diverse,
high quality stream, wetland, and forest habitat and replace it with a
deep, open water impoundment which would benefit only a few select species.
The Corps concludes that the proposal complies with the Guidelines because
the project is water-dependent and there are no alternatives. Although I
Van Der ValX, A.G. et^ alf 1978. Natural freshwater wetlands as nitrogen
and phosphorous traps Tor land runoff. National Symposium on Wetlands,
Lake Buena Vista, Florida.
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-5-
do not concur with their conclusion, it is a moot point: the new Guide-
lines restrict discharges based on the significance of inpacts and the
Corps has conceded significant, adverse impacts in the FEIS.
The Corps claims that their proposed mitigation will "offset" the proj-
ect's inpacts (page 65, Main Report). We disagree strongly. Mitigation
such as land acquisition and habitat enhancement has no effect whatsoever
on the severity of inpacts resulting from the actual project. It can be
construed as a form of "corpensation" and we have no objection to the
proposed mitigation actions themselves. Of the various mitigation plans
advanced, we favor those proposed by the U.S. Fish and Wildlife Service
and the Rhode Island Deparment of Environmental Management over the Corps
proposal. According to the Supplementation Report (page 15), the Corps
mitigation proposal is based on the assumption that the existing project
site would revert to private ownership and would eventually be developed
anyway. This is an inappropriate scenario (RI EEM does not agree either)
which bic.jes the mitigation study and ignores the regulatory protection
that the area could be afforded by the State and Federal government.
Moreover, this assumption is in apparent contradiction to statements in
the Main Report (cf, page 48).
In summary, the proposed Big River Reservoir Project does not comply with
the 404(b)(l) Guidelines because there may be practicable project alter-
natives in light of revised population projections [230.10(a)]; there
may be violations of downstream water quality [230.10(b)]; and the com-
bined biological and potential water quality impacts at.the Reservoir
site will have significant adverse effects on aquatic environment [230.
10(c)]. The FEIS is not responsive to our earlier concerns as it either
restates earlier conclusions without supporting information or simply
postpones addressing problems by promising to do studies during the
design phase. The 404(b) evaluations was improperly conducted and should
utilize the current Guidelines.
Thank you for the opportunity to comment on this FEIS. If you have any
questions or if I can be of further assistance, do not hesitate to contact
me at 223-5013.
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Connecticut
Maine
United States Office of Massachusetts
Environmental Protection Public Affairs New Hampshire
Agency John F. Kennedy Federal Building Rhode Island
Region I Boston Massachusetts 02203 Vermont
&EPA Environmental News
For more information call
Ann Williams-Dawe, legal counsel - 617/565-3334
Doug Thompson, wetlands program - 617/565-4421
for immediate release - January 25, 1989
EPA PROPOSES PROHIBITING CONSTRUCTION OF
BIG RIVER RESERVOIR; CALLS FOR PUBLIC COMMENT
BOSTON—The U.S. Environmental Protection Agency today proposed to
prohibit construction of the Dig River Reservoir in West Greenwich
and Coventry, Rhode Island because the project could cause
unacceptable environmental impacts. The 3,400 acre water supply
reservoir is proposed as a joint venture by the state of
Rhode Island and the U.S. Army Corps of Engineers.
"The Big River project would cause an unprecedented loss of at
least 600 acres of valuable wetlands and ^destroy habitat for
countless species of wildlife," said Michael R. Deland, EPA
Regional Administrator for New England, who signed the proposal.
The notice describes EPA's environmental objections to the Big
River project and opens a six month period for the public to review
and comment on the Agency's proposal. The EPA notice will be
published in the Federal Register and local papers next week. A
public hearing will be scheduled at a later date.
Today's proposal represents the next step in the formal Clean Water
Act review process that EPA began late last summer. Section 404(c)
of the Clean Water Act empowers EPA to protect wetlands and other
waterbodies from construction projects which would cause
"unacceptable adverse effects" to, among other things, fish and
wildlife. After receiving comment on today's proposal, the EPA New
England Office will decide whether or not to formally recommend to
EPA's Headquarters that construction of the project be blocked. The
Washington office of EPA makes the final decision.
(more)
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The severe impact of the Big River project on wetlands and wildlife
prompted the EPA proposal to prohibit the project. The dam would
transform a diverse ecosystem harboring a wide variety of wildlife
into a shallow lake that would benefit only a few species,
primarily warmwater fish.
The Big River site supports numerous mammals and birds including
muskrat, weasel, mink, otter, deer, fox, red-shouldered hawk, great
horned owl, great blue heron, osprey, and black duck. The direct
loss of 600 acres of wetlands would be greater than any project
permitted in New England since the inception of the Clean Water Act
in 1972.
The total impact could climb to 1,100 acres if the dam deprives
wetlands in nearby Mishnock Swamp of adequate water.
In addition, the project would eliminate 20 miles of free flowing
streams and native trout fisheries. The $282 million reservoir
would also likely cause violations of water quality standards by
reducing flows in the Pawtuxet River and Flat River Reservoir.
The EPA proposal also said that the Agency did not feel that
alternatives to the project had been adequately addressed.
"However, I should point out that I have had recent discussions
with Rhode Island Governor Edward DiPrete and his staff and have
been assured that the state will undertake an updated analyses''of
water supply needs as well as an evaluation of alternatives,
including additional water conservation measures," Deland stated.
"I welcome the governor's cooperation and believe his commitment
to undertake the studies is sensible. I ,hope this effort will
produce a plan by Rhode Island to identify and implement
environmentally acceptable alternatives to the Big River
Reservoir," he continued.
According to Deland, the six month comment period, which ends on
July 31, 1989, would provide ample opportunity for the public to
review and comment on the EPA proposal and allow the state and
others time to develop and submit any new information related to
the project. Deland indicated that his office was seeking comment
from all interested parties on any aspect of today's proposal. "I
want to assure all those involved that my staff and I intend to
evaluate carefully all the comments we receive before I decide
whether or not to recommend the project be prohibited."
To obtain a copy of the EPA proposal or for more information please
contact the wetlands office at 617/565-4421.
###
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Proposed Determination to Prohibit the Use of Big River/ Mishnock
River, their Tributaries and Adjacent Wetlands as Disposal Sites;
Kent County/ Rhode Island
AGENCY: U.S. Environmental Protection Agency (EPA).
ACTION: Notice of Proposed Section 404(c) Determination.
SUMMARY: Section 404(c) of the Clean Water Act (Act) authorizes
the Environmental Protection Agency (EPA) to prohibit or restrict
the discharge of dredged or fill material at defined sites in the
waters of the United States (including wetlands) whenever it
determines, after notice and opportunity for hearing, that use of
such sites for disposal would have an unacceptable adverse impact
on various resources, including wildlife. EPA Region I proposes
under Section 404 (c) of the Act to prohibit use of Big River,
Mishnock River, their tributaries and adjacent wetlands in Kent
County, Rhode Island, as disposal sites for dredged or fill
material in connection with construction of Big River Reservoir,
a 3400 acre water supply project. The Big River proposal would
directly eliminate approximately 550 acres of valuable wetlands and
impact an additional 500 to 600 acres of wetland habitat. There
have been proposals to construct the project either by the State
alone or as a joint venture with the U.S. Army Corps of Engineers
(Corps). EPA Region I believes that filling and inundating the
wetlands arid waters of'the site may have an unacceptable -adverse
effect on wildlife habitat and fisheries.
PURPOSE OF PUBLIC NOTICE: EPA seeks comments on this proposed
determination to prohibit the disposal of dredged or fill material
into Big River, Mishnock River, their tributaries and adjacent
wetlands. See Solicitation of Comments, at the end of this public
notice, for further details.
PUBLIC COMMENT: Comments on or requests for additional copies of
the proposed determination should be submitted to the EPA Region
I's designated Record Clerk, Virginia Laszewski, U.S. EPA, JFK
Federal Building, WWP-1900, Boston, MA 02203-2211.
EPA seeks comments concerning the issues enumerated under the
Solicitation of Comments at the end of the document. Copies of
all comments submitted in response to this notice, as well as the
administrative record for the proposed determination, will be
available for public inspection during normal working hours (9:00
a.m. to 5:00 p.m.) at the EPA Region I office.
In accordance with EPA regulations at 40 CFR 231.4, the Regional
Administrator has decided that a hearing on this proposed 404(c)
determination would be in the public interest. A separate public
notice will be published in the Federal Register and local
newspapers to announce the date, time and location of this hearing
and describe the hearing procedures. Notice will be given at least
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30 days in advance of the hearing. ' Written comments may be
submitted prior to the hearing, and both oral and written comments
may be presented at the hearing.
Because of the large scale of the proposed project, the complexity
of issues, and the large volume of information which exists about
this project, the Regional Administrator hereby determines that
good cause exists to establish a comment deadline of July 31, 1989.
This will also provide an opportunity for people to visit the site
and make their own observations if they wish to do so, and for the
State and others to submit information about project need and
alternatives. Neither the Corps nor the State plans to build this
project within the next year; therefore, the extended comment
period would not disadvantage the project proponents.
FOR FURTHER INFORMATION CONTACT: Mr. Mark J. Kern, EPA Water
Quality Branch, JFK Federal Building, WWP-1900, Boston, MA 02203-
2211. (617) 565-4421.
SUPPLEMENTARY INFORMATION AND BACKGROUND
I. Section 404(c) Procedure
The Clean Water Act, 33 U.S.C. 1251 et seq., prohibits the
discharge of pollutants, including dredged or-fill material, .into
the waters of the United States, including wetlands, except in
compliance with, among other things, section 404. Section 404
establishes a federal permit .program to regulate the discharge of
dredged or fill material subject to environmental regulations
developed by EPA in .conjunction, with ,the Department of the Army.
The Corps may issue permits authorizing dredged and fill material
discharges into waters and wetlands if they comply with, among
other things, EPA's 404(b)(l) guidelines, except as provided in
section 404(c). Section 404(c) authorizes EPA, after providing
notice and opportunity for hearing, to prohibit or restrict filling
waters of the United States where it determines that such use would
have an unacceptable adverse effect on wildlife or other specified
environmental interests. EPA can exercise 404(c) to "veto" a
permit the Corps has decided to issue or, as here, to protect
valuable aguatic areas in the absence of any specific permit
decision.
Regulations published in 40 CFR Part 231 establish the procedures
to be followed by EPA in exercising its section 404(c) authority.
Whenever the Regional Administrator has reason to believe that use
of a site may have an unacceptable adverse effect on one or more
of the pertinent resources, he may begin the process by notifying
the Corps of Engineers and the applicant that he intends to issue
a proposed determination under section 404(c). Unless the
applicant or the Corps persuades the Regional Administrator within
15 days that no unacceptable adverse effects will occur, the
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Regional Administrator publishes a notice in the Federal Register
of his proposed determination, soliciting public comment and
offering an opportunity for a public hearing. Today's notice
represents this step in the process.
Following the public hearing and the close of the comment period,
the Regional Administrator either withdraws the proposed
determination or prepares a recommended determination. (A decision
to withdraw may be reviewed at the discretion of the Assistant
Administrator for Water at EPA Headquarters.)" If the Regional
Administrator prepares a recommended determination, he then
forwards it and the complete administrative record compiled in the
Region to the Assistant Administrator for Water at EPA
Headquarters. The Assistant Administrator makes the final decision
affirming, modifying, or rescinding the recommended...determination.
II. Project Description and History
The Big River Reservoir has at different times been proposed as a
State or federal project. The State of Rhode Island has proposed
building a water supply reservoir; the Corps has proposed building
a reservoir for water supply, flood control, and recreation
purposes. The project dimensions, site characteristics, and
impacts are essentially the same for both proposals. This proposed
404 (c) action applies to both proposals. ':~ " '
The Big River reservoir project, mostly located south of exit 6 on
1-95, would involve the discharge of dredged and fill material into
Big River to construct a dam and reservoir to create a 3,400 acre
reservoir. The reservoir would produce between 27 and 36 million
gallons a day (MGD) of potable water (State versus Corps
estimates). The dam would be 70' high while the average water
depth would be about 25' deep. To contain the water within the
basin, a slurry wall would be built down to bedrock in the
northeast portion of the proposed reservoir to intercept
approximately 8 MGD of groundwater that now leaves the site and
enters Mishnock Lake and Swamp. Mishnock Lake and Swamp, which are
not part of the Big River watershed, are located approximately 1/2
mile northeast of the proposed reservoir.
A treatment plant would be built adjacent to the proposed reservoir
on 51 acres of land and a 96" diameter rock tunnel would transport
water approximately 6 miles to an existing distribution system.
Additional site preparation would destroy approximately 2,800 acres
of terrestrial forest and relocate 10 roadways, 300 structures,
numerous graveyards, and several dump sites.
According to State estimates, the project would cost at least $282
million, not including costs for environmental studies and
..mitigation. The federal government would construct less than half
of the project and fund less than 50% of the initial cost. Most
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of that expenditure would be reimbursed by the State, resulting in
a federal share of approximately 2% - 5%.
In the 1960's the State of Rhode Island acquired over 8,000 acres
of land at the Big River reservoir site in anticipation of building
a reservoir. In 1978, having failed several times to secure
funding to complete engineering studies, Rhode Island asked the
Corps to consider constructing the reservoir as part of a federal
flood control project. The Corps completed an Environmental Impact
Statement (EIS) on the reservoir project in 1981, which concluded
that environmental impacts would be significant. As early as 1982,
EPA alerted the Corps that because of the adverse wetland impacts,
EPA believes the project could not comply with the §404(b)(l)
Guidelines, the primary federal regulations that protect wetlands.
Congress authorized the project as .part of the Omnibus Water
Resources Development Act ot 1986, but ordered additional wildlife
mitigation studies to be completed no later than November 17, 1987.
These additional studies have not been completed.
In 1986, the State informed the Corps that it again wished to
pursue the reservoir as a state project and subsequently applied
for a federal §404 permit. The Corps in 1987 informed the State
that(a supplemental EIS would be required to address alternatives,
mitigation, and a number of other unresolved issues surrounding the
project. For example, the 1981 EIS indicated that 570 acres of
wetland habitat ^would be lost if the dam were constructed. New
information now suggests that the total acreage of wetlands at. risk
exceeds 1000 acres, including Mishnock Swamp and the riverine
wetlands along the South Branch of the Pawtuxet River. Moreover,
the EIS did not address downstream water quality impacts, an
important factor since the Pawtuxet River currently violates Rhode
Island's water quality standards for dissolved oxygen and toxic
chemicals.
During 1987 and 1988, EPA voiced its concerns about the adverse
environmental impacts of the reservoir proposal and alerted the
State that the project could not comply with section 404
requirements. EPA also emphasized the need for the State to
thoroughly analyze the need for and alternatives to the project.
The most recent State needs analysis for this project is over 20
years old. In a June 6, 1988 letter EPA urged the Corps .to deny
the permit because the project would cause significant degradation
of the aquatic environment which could not be adequately mitigated.
In a July 1, 1988 letter to Rhode Island's Governor DiPrete, the
Corps stated that the project as proposed would cause significant
impacts to the aquatic environment, would not comply with the
§404(b)(1) Guidelines, and probably could not receive a federal 404
permit. However, during a August 11, 1988 meeting, the Corps
indicated to Governor DiPrete that the Big River reservoir might
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again become a federal project.
In an August 24, 1988 letter, EPA's Regional Administrator informed
the Rhode Island Water Resources Board, the Governor, and the Corps
of his intention to begin a 404(c) action, based on his belief that
the project may have unacceptable adverse impacts to wildlife and
fisheries. Pursuant to 40 CFR 231.3, a 15-day opportunity for
consultation ensued, which ended on September 9, 1988. Neither the
State nor the Corps chose to consult with EPA. Instead Governor
DiPrete officially asked the Corps, on September 1, 1988, to build
the dam. The Water Resources Board withdrew its §404 permit
application to the Corps in late September, 1988.
The Corps New England Office has asserted .that if it builds the
reservoir project, it would be exempt from section 404(c) of the
Clean Water Act. Normally, Corps civil works projects, including
those authorized by Congress, must comply with the Clean Water Act
and other federal and state requirements. In the Big River
reservoir case, however, the Corps claims the project is exempt
under section 404 (r) of. the Act.
EPA has concluded that the project is not exempt because the Corps
did not follow the substantive and procedural requirements of
§404(r). The Act plainly requires an agency seeking an exemption
under §404 (r). to submit an EIS to. Congress before, .either;" project.
authorization or appropriation of funds. The,Corps failed to
submit the Big River reservoir EIS to Congress before
authorization. Even if the EIS had been submitted to Congress, the
project does not qualify for an exemption for several other
reasons. These reasons include the manner of project financing,
deficiencies in the NEPA record and an improper analysis of
compliance with the EPA 404 (b)(1) guidelines. EPA explained its
position relative to the exemption issue in a December 7, 1988
letter to the Corps New England Division.
Ill. Characteristics and Functions of the 'Site
Big River, located in central Rhode Island, is part of the 29.7
square mile Big River Watershed. On a larger scale, the water
drains to Narragansett Bay as part of the Pawtuxet River Basin.
The wetlands along Big River and the Mishnock Swamp form the
largest wetland complex in the 228-square mile Pawtuxet River
Basin. The diverse habitats associated with the Big River site
support a large number of wildlife species. According to the 1981
EIS, 221 species of birds, 55 species of mammals, and 39 species
of reptiles and amphibians can reasonably be expected to inhabit
the site.
Along Big River and its tributaries the wetland habitats are
unaltered by development or other human intrusions. As such, they
provide high quality, diverse habitat for fish and wildlife, a
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travel corridor for upland and wetland wildlife, food web
production for on-site and downstream biological communities,
nutrient and pollutant uptake and assimilation, floodwater storage,
and flow moderation. Additionally, they serve as an environment
for fishing, hunting, and other recreational activities.
The wetlands which would be lost by constructing the dam and
reservoir are part of an intact, functioning system specifically
adapted to the hydrologic regime of Big River and its tributaries.
Most of the large wetlands border finger-like stream channels
scattered throughout the site. Thus, natural topographic changes
in the landscape create a variety of interspersed wetland and
upland habitats. This mixture of vegetation types allows the
ecosystem to support a broad range of aquatic, semi-aquatic, and
terrestrial wildlife communities. Vertical' stratification of the
forest canopy, sub-canopy, and ground cover also contributes to
habitat diversity. Hence, fish and wildlife use the area as a
resting, breeding, rearing, and feeding area as well as a travel
corridor to nearby undeveloped habitat.
Leaf biomass produced by the trees and shrubs supports diverse fish
and wildlife communities both at the project site and downstream.
Numerous mammals at the site include white-tailed deer, red and
gray fox, muskrat, cottontail rabbits and snowshoe hare, woodchuck,
and raccoon. Extensive rodent populations and aquatic vertebrates
at the site provides a significant food source for numerous
predators. Thus, many valuable fur-bearing mammals such as long-
tailed weasel, mink, otter and possibly bobcat inhabit the site.
Of the 55, species of mammals cited in the EIS, the Rhode Island
Heritage Program lists bobcat as a State threatened species
(occurring at less than 5 locations in the State).
The large prey population also supports a variety of raptors, such
as red-tailed hawk, red-shouldered hawk, sparrow hawk, and great-
horned owl. Additional bird species known to inhabit the site
include osprey, belted kingfisher, flycatchers, swallows, and
woodpeckers. Populations of spring and -fall migratory birds,
especially various woodland warblers, flourish at the site. The
EIS lists 221 species of birds potentially using the site, and the
Rhode Island Heritage Program has identified 104 species of birds
which nest in the Big River area. The State classifies two
species, Cooper's hawk and upland sandpiper, as threatened species.
Extensive conifers at the site not only provide food and cover for
deer and other mammals but also supply winter food for bird
species, such as the crossbill, which feed extensively on seeds of
softwoods. The marshes of the proposed Big River site harbor
breeding waterfowl such as black duck, mallard, and wood duck,
while migratory species include green winged teal, shovelers, and
ringnecked ducks. Shore birds, rails, and coots also frequent the
marshes along with wading birds such as great-blue heron and
bittern. Other species of concern to the Rhode Island Natural
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Heritage Program at the Big River site include four-toed
salamander, eastern ribbon snake, buck moth, and barrens bluet
damselfly. Vernal pools, created during spring runoff, provide
especially productive habitat for many species of amphibians and
reptiles.
Wetlands along Big River help to maintain and/or improve water
quality, as well as regulate water quantity. Pollutants entering
the watershed are trapped, assimilated, or transformed within the
diverse substrate provided by the wetlands. During the summer, the
shading effects of the forest canopy cools water temperatures in
the river and tributaries, providing favorable conditions for
native brook trout. Wetland trees and shrubs retard floodwater,
decreasing downstream flood stages. The basal flow contribution
from Mishnock Swamp . to the South Branch of the Pawtuxet River
during summer stress conditions provides water at the most
important time of year.
Big River and itS's tributaries support self-sustaining cold water
fisheries. Over 20 miles of free flowing streams within the site
support more than 15 species of fish including brook trout, white
suckers, and redfin pickerel.
IV. Basis of the Proposed Determination •' ~. •
A. Section 404(c) Criteria
The CWA requires that exercise of the final section 404(c)
authority be based on a determination of "unacceptable adverse
effect" to municipal water supplies, shellfish beds, fisheries,
wildlife or recreational areas. EPA's regulations define
"unacceptable adverse effect" at 40 CFR 231.2(e) as:
Impact .on aquatic or wetland ecosystem which is likely to
result in significant degradation of municipal water supplies
or significant loss of or damage to fisheries, shellfishing,
or wildlife habitat or recreation areas. In evaluating the
unacceptability of such impacts, consideration should be given
to the relevant portions of the Section 404(b)(1) Guidelines
(40 CFR Part 230). ;
One of the basic functions of section 404 (c) is to police the
application of the section 404(b)(l) guidelines. Those portions
of the Guidelines relating to less environmentally damaging
practicable alternatives, water quality impacts, and significant
degradation of waters of the United States are particularly
important in the evaluation of unacceptability of environmental
impacts in this case. The guidelines forbid the discharge of
dredged or fill material into waters of the United States if there
is a less environmentally damaging practicable alternative, if it
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8
would cause or contribute to a violation of a State water quality
standard or if it would cause or contribute to significant
degradation of waters of the United States.
B. Adverse Impacts of the Proposed Project
Constructing the dam, and impounding Big River to create an
artificial lake, would inundate 3,400 acres of wildlife habitat
including 550 acres of productive wetlands. This loss represents
approximately 50% of the total wetlands in the Big River watershed.
Moreover, if Mishnock Swamp becomes dewatered because of the dam
and slurry wall, over 500 additional acres of prime wetland would
be adversely affected. Virtually all of the diverse forested
habitat that now exists in the 3,400 acre site would be destroyed.
The proposed dam would eliminate all of the forest-stream-pool
habitat and adjacent floodplain community which has adapted to
periodic flooding.
Based on the annual planned flow releases from the impoundment,
Flat River Reservoir would receive 45% less water; the South Branch
of the Pawtuxet, 34% less water; and the Pawtuxet River, 15% less
water. As a result, the dam would also partially dewater extensive
riverine wetlands along the South Branch of the Pawtuxet River,
further adding to the wetland habitat loss. Further,"reduced basal
flow contributions from Mishnock River to the South Branch of the
Pawtuxet, during summer months, could worsen the already poor water
quality of the Pawtuxet River.
The dam would transform a diverse ecosystem, harboring a wide
variety of wildlife, into a shallow lake about 25 feet deep that
benefits only a few species, primarily warm water fish and bottom
dwelling organisms. The cold water fisheries, including native
brook trout, will be destroyed. The Big River site potentially
supports over 50 species of mammals, over 35 species of reptiles
and amphibians, and over 200 species of birds, including over 100
which nest at the site. The State considers at least 13 species
which inhabit the Big River site to be threatened or of special
state interest. Another 10-20 species require large tracts of
habitat for survival.
Wildlife currently living on the site or migrating through it will
either die or be forced into adjacent upland habitat less suited
to their needs. If they survive dislocation, they will have to
compete for available food and habitat with the existing upland
animal communities. Many species of wildlife at the site either
require wetland habitat for survival, or depend upon wetlands for
a major portion of their life cycle. Thus, the dam would
drastically reduce both the total numbers of individuals, and the
diversity of species in the Big River area. In addition, the dam
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will permanently block the Big River site for use as a travel
corridor. This would disrupt movement patterns of animals forcing
them to cross highways and other exposed areas.
EPA does not believe that the Pawtuxet River, Flat River Reservoir,
and Big River would achieve state water quality standards if the
dam is built. The Pawtuxet River now violates the Class C standard
of 5 mg/1 of dissolved oxygen during summer months. In addition,
the standards require that normal seasonal and diurnal variations
of dissolved oxygen above 5 mg/1 be maintained. Impounding Big
River would likely worsen dissolved oxygen levels during all
seasons by reducing flows in the Pawtuxet River by 15%. The
Pawtuxet River historically supported large runs of anadromous fish
including shad, alewives, and Atlantic Salmon. A further reduction
in flow and increased concentration of pollutants may destroy any
future plans for restoration.
The impoundment of the Big River and its tributaries would convert
cold water fisheries to a warm water lake, and would violate anti-
degradation requirements in the Rhode Island water quality
standards. Rhode Island has very few .remaining cold water
fisheries, while warm water fisheries are common throughout the
State. The Pawtuxet River Basin, for example, has 34 ponds greater
than 10 acres in size primarily suited for warm water species, but
virtually no other'cold water fisheries. "''
Flat River Reservoir provides the best warm water fisheries in'the
Pawtuxet River Basin, but it is showing some signs of
eutrophication. Water from Big River, which provides over half of
the water budget to Flat River Reservoir, will be reduced from an
annual average flow of 60 cubic feet per second (cfs) to 6 cfs.
This loss of water would increase eutrophication and adversely
impact the fisheries and recreation of Flat River Reservoir, and
could violate anti-degradation provisions of the Rhode Island water
quality standards, which require existing water uses to be
maintained and protected.
C. Project Need and Alternatives
1. Current Information
EPA believes that environmentally acceptable alternatives to the
Big River reservoir, to supply potable water, have not adequately
addressed.1 EPA does not believe the need'for additional potable
1 Water supply is the sole purpose of the State proposal.
The Corps characterizes its project as multi-purpose; i.e., water
supply, flood control and recreation. According to the EIS,
construction of the dam would not be economically justified for
flood control or recreation alone. Therefore, EPA is focusing its
attention on alternatives to satisfy the primary purpose of water
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10
water is established, given the paucity of data about basic user
information and the lack of water conservation practices in the
State. In addition, there appears to be a variety of ways to meet
whatever need actually exists without threatening over 1000 acres
of wetlands and downstream water quality.
Despite the long history of the Big River proposal, there is a lack
of basic information regarding the supply and demand for water in
Rhode Island. There appears at present to be no method in the
state for distinguishing between industrial, commercial and
residential users. Therefore, there is no information, for
example, on how much water different types of industry use. EPA
does 'not believe that an accurate need forecast can be developed
without first conducting a thorough water audit, lacking in the
1981 EIS and other studies.
The record developed to date serves to underscore EPA's doubts
about the need for a new water supply reservoir. The State has not
completed a basic water use forecast for over 20 years. A new
reservoir is needed, according to the State, primarily because the
Scituate Reservoir is approaching its "safe yield". However,
estimates of what constitutes the Scituate's safe yield vary by up
to 15 mgd—approximately half the water that Big River could
supply. Moreover, the state Water Resources Board acknowledges
that it has no comprehensive policy to conserve water through
public education, pricing policies, leak repair, drought planning
or other such measures.,: The Corps, in £he 1981 EIS, did not
examine the State's water supply practices to determine potential
water savings,.did not gather any .user-specific information
particular to Rhode Island water users, and used population
projections which time has shown to inaccurate. Currently, the
Corps agrees that a new analysis of water supply demands should be
done.
If a need for additional water is established, EPA believes that
there are alternatives (or combinations of alternatives) to the Big
River proposal to supply potable drinking water. Management
alternatives include education, leak detection and repair, plumbing
changes for new construction, and drought planning. Conserving
drinking water from power generation, irrigation, commercial and
industrial use can also increase potable water supplies by matching
the quality of water with its intended use. Not all industrial and
commercial activities need potable water for their operations.
Similarly, existing water supplies that drop below drinking water
standards could be maintained to meet non-potable needs rather than
abandoned. In addition, a thorough analysis of alternatives would
also include investigation into groundwater supplies, less
supply. EPA believes insofar as the Big River project provides
benefits of flood control and recreation, they could be achieved
through less environmentally damaging measures;
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11
environmentally damaging surface water sources, improved protection
of existing water sources, and desalinization. Preliminary
investigations, for instance, indicate that 5-10 mgd of potable
water is available from the aquifer at the Big River site at a
fraction of the cost of a new reservoir.
2. Additional studies
In recent discussions with EPA, the State has indicated that it is
undertaking an updated analysis of water supply needs in Rhode
Island as well as an evaluation of all alternatives, including
conservation, to meet the future demand for drinking water in the
State. In order to seek an objective view of the issues involved,
the State has said it will retain an independent consultant to
conduct the studies. The State has proposed that the scoping and
oversight of the studies will be overseen by an inter-agency
committee established by the Governor and that interested parties
and EPA will be given opportunity to comment on the progress of the
work.
D. Mitigation
The State did not submit a mitigation plan with its permit
application. The Corps, in its 1981 EIS, proposed several
structural and nonstructural measures to mitigate adverse impacts
including management of forests adjacent to - the reservoir,
reclaiming a mined' area and putting'up birdhbuses. The Corps
proposed to mitigate the loss of wetlands chiefly by constructing
11 sub impoundments" in the upper reaches of the reservoir in an
attempt to enhance or create wetland habitat.'If fully successful,
these subimpoundments would contain about 90 acres of wetlands.
EPA does not believe the adverse environmental impacts of the
reservoir proposal can be mitigated. To even attempt meaningful
replacement of the full spectrum of existing wetland values would
require a mitigation plan so complex as to be infeasible from both
a scientific and practical standpoint. Even if a plan could be
devised which theoretically replaced wetland values, EPA doubts it
could be relied upon to prevent the potentially unacceptable
adverse environmental impacts of this project given the inherent
risks associated with mitigation.
Recent studies in New England and elsewhere point to a number of
scientific and practical difficulties associated with mitigation.
The scientific base is too incomplete to support assertions that
artificial wetlands will provide the functions of natural wetlands,
let'alone replace the diverse values of the 500 - 1000 acres of
wetlands that would be lost at this site. Some wetland functions,
such as flood storage, can normally be replicated successfully.
Attempts to mitigate wildlife habitat losses have met with mixed
success, and benefit only a few select species. There has been
little demonstrated ability to recreate on a broad scale other
wetland values such as groundwater" discharge and recharge or the
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12
complex interactions of water, soil and plants involved in the
uptake and transformation of nutrients and pollutants.
After considering the project's impacts, unprecedented in New
England, and the poor track record of wetland creation and
enhancement projects to compensate for projects involving much less
severe impacts, EPA Region I has concluded that the adverse effects
of the Big River project cannot be adequately mitigated. In any
case, the mitigation scheme briefly described in the 1981 EIS would
not compensate for the severe impacts to wildlife and other wetland
values which the Big River project would cause. Even if 90 acres
of subimpoundments could be successfully created and maintained,
they would largely involve manipulation of existing wetland
habitat. This would increase the value of these areas for select
wildlife species at .the expense of others. It would not begin to
balance the impacts associated with the loss of 500 to 1000 acres
of diverse, natural wetlands. Moreover, most of the wetlands
destroyed by the project are forested. The subimpoundments would
provide little or no value for the many species adapted to life in
the forested systems.
V. Proposed Determination
The Regional Administrator proposes to recommend that the discharge
of .dredged or fillomaterial 'into Big River, Mishnock River, and,
their, ^tributaries .and adjacent < wetlands be prohibited for the
purpose of ^constructing the proposed Big-River reservoir Aand
ancillary facilities. Based on current information, the Regional
Administrator has reason to believe that the adverse impacts of the
Big River reservoir would likely be unacceptable. Moreover, these
impacts may be partly or entirely unnecessary or avoidable.
This proposed determination is based primarily on the adverse
impacts to wildlife and fisheries. EPA has already concluded that
the project would cause or contribute to significant degradation
of waters of the United States and violate the §404(b)(l)
guidelines. It would directly destroy approximately 550 acres of
wetlands and has the potential to degrade an additional 500-600
acres of wetlands through groundwater starvation and reduced
downstream river flows. In addition to these impacts, EPA is
concerned about the lack of basic information about future water
supply needs and the absence of a rigorous analysis of water supply
alternatives. In light of existing information, EPA believes that
there are likely to be feasible and less environmentally damaging
alternatives to building the Big River reservoir.
VI. Solicitation of Comments
EPA solicits comments on all issues discussed in this notice. In
particular, we request information on the likely adverse impacts
to wildlife and other functional values of the rivers, streams, and
wetlands at the Big River site and at Mishnock Swamp. We also seek
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13
information pertaining to flora, fauna and hydrology of the Big
River site, Mishnock Swamp, and adjacent lands. All studies,
knowledge of studies, or informal observations is of importance for
this notice. Information on species or communities of regional and
or statewide importance would be especially useful.
i
While the significant loss of wildlife habitat serves as EPA's main
basis for this proposed 404(c) determination, EPA Region I has
additional concerns with the proposed project including water
quality impacts, fisheries, alternatives, project need and
mitigation. As discussed above in Additional Studies, the State
plans to conduct additional evaluations of the need for drinking
water and alternatives to meet that need. The State intends,
during the comment period, to submit the information compiled in
these studies for EPA's consideration during the 404(c) process.
EPA also solicits comments on the following aspects of the project:
1) The potential for violations of State water .quality
standards to occur, especially in the Pawtuxet River, the Flat
River Reservoir and Narragansett Bay;
2) Information about "fisheries at the Big River site, and
the impacts to fisheries if the reservoir is built. Also
the likelihood of maintaining cold water fisheries at the
site if the Big River reservoir were built;
3) The potential for wetland losses, and their associated
values and functions, along the South Branch of the Pawtuxet
and in Mishnock Lake, Swamp and River if the dam were built
and operated as proposed;
4) Information about recreational use of the area;
5) The need for additional drinking water and the current
data base for making projections of need and alternatives, as
well as what new information must be gathered to make
reasonably accurate projections on how much water can be saved
or produced by other alternatives;
6) Information on the availability of less environmentally
damaging practicable alternatives to satisfy the basic
project purpose — drinking water supply — taking into
account cost, technology, and logistics;
7) In the absence of the need for additional water supply,
information about environmentally acceptable alternatives for
the secondary purposes of flood control and recreation.
8) Information on the potential for mitigation to replace
the functions and values of the 500-1100 acres at risk at the
Big River site. .
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14
The record will remain open for comments until July 31, 1989. All
comments will be fully considered in reaching a decision to either
withdraw the proposed determination or forward to EPA Headquarters
a recommended determination to prohibit or restrict the use of Big
River, its tributaries, and adjacent wetlands as a disposal site
for construction of Big River Reservoir.
For further information contact: Mr. Mark J. Kern, U.S. E.P.A., JFK
Federal Building, WWP-1900, Boston, MA 02203-2211, (617) 565-4421.
/S/
Michael R. Deland,
Regional Administrator, Region I.
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, •} >1/;
C
V-
" '•""
FINAL DETERMINATION OF THE
U.S. ENVIRONMENTAL PROTECTION AGENCY'S
ASSISTANT ADMINISTRATOR FOR WATER
PURSUANT TO SECTION 404(c)-QF THE CLEAN WATER ACT
CONCERNING THE PROPOSED BIG RTVER -t
WATER SUPPLY IMPOUNDMENT
KENT COUNTY, RHODE ISLAND
March 1, 1990
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I. INTRODUCTION
Section 404(c) of the Clean Water Act (33 U.S.C. Section 1251 et seq.) provides
that, if the Administrator of the U.S. Environmental Protection Agency (EPA)
determines, after notice and opportunity for public hearing, that unacceptable adverse
effects on municipal water supplies, shellfish beds, fishery areas (including spawning and
breeding areas), wildlife, or recreational areas will result from the discharge of dredged
or fill material, he may exercise his authority to withdraw or prohibit the specification,
or deny, restrict or withdraw the use for specification, of any defined area as a disposal
site for dredged or fill material. The Section 404(c) regulations state that, before
making such a determination, the Administrator must consult with the Chief of the
Army Corps of Engineers (Corps), the property owner(s), and the applicant where
there has been an application for a Section 404 permit The procedures for
implementation of Section 404(c) are set forth in the Code of Federal Regulations, 40
CFR Part 231.
EPA's regulations for implementing Section 404(c) establish procedures to be
followed in exercising the Administrator's authority pursuant to that Section. Three
major steps in the process are: 1) the Regional Administrator's proposed decision to
withdraw, deny, restrict or prohibit the use of a site (Proposed Determination); 2) the
Regional Administrator's recommendation to the Administrator to withdraw, deny,
restrict or prohibit the use of a site (Recommended Determination); and 3) the
Administrator's final decision to affirm, modify, or rescind the Regional
recommendation (Final Determination). The Administrator has delegated the authority
to make final decisions under Section 404(c) to thev Assistant Administrator for Water,
who is EPA's national Clean Water Act Section 404 program manager.
In the instant case, this Final Determination concerns the placement of dredged
or fill material for the purpose of creating a water supply impoundment on Big River in
Kent County, Rhode Island as proposed by the Corps of Engineers and the State of
Rhode Island. The project involves construction of a dam approximately 2300 feet long
and 70 feet high to create a 3,400 acre impoundment, with an average depth of 25 feet.
The project also involves the construction of an impermeable slurry wall down to
bedrock in the Northeast portion of the proposed reservoir. The wall would be
necessary to prevent the natural flow of groundwater out of the Big River area.
Figure 1 of the Regional Recommended Determination shows the location of the
proposed project relative to the South Branch Pawtuxet River Basin and the remainder
of tiie State. Figure 2 shows the project on a regional scale relative to the Pawtuxet
River Basin and central Rhode Island. Figure 4 shows the location of the proposed
dam with respect to the proposed impoundment area, management area and the Big
River watershed.
As stated in the Regional Recommended Determination, the basic purpose of
the Big River reservoir is to satisfy future needs for drinking water in the Greater
Providence area. The Corps of Engineers evaluated the potential flood control and
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recreation benefits of the project in an Environmental Impact Statement completed in .
1981 in response to a 1978 request from the State of Rhode Island. However, in its
subsequent permit application in 1986, the State of Rhode Island stated that the
purpose of the project is to provide municipal water supply.
EPA Region Fs Acting Regional Administrator has recommended that EPA
prohibit the discharge of dredged or fill material into Big River, Mishnock River and
their tributaries and adjacent wetlands for the purpose of constructing the proposed Big
River Reservoir and its ancillary facilities. Region Fs Acting Regional Administrator
based this recommendation upon a conclusion that the project will cause unacceptable
adverse effects to wildlife habitat and recreation areas. In reaching this conclusion, the
Acting Regional Administrator found that the adverse impacts associated with the
proposed impoundment are avoidable and unnecessary.
This Final Determination is based on consideration of the administrative record
developed in this case, including public comment submitted in response to the Regional
Proposed Determination and comment received at the public hearing. This Final
Determination also reflects review and consideration of additional relevant information
that subsequently was submitted and made pan of the record.
The Section 404(c) regulations authorize the prohibition or other restriction of
the discharge of dredged of fill material at sites where it is found that "unacceptable
adverse effects on municipal water supplies, shellfish beds and fishery areas (including
spawning and breeding areas), wildlife, or recreational areas" would result The
administrative record fully supports the Regional conclusion that construction of the
proposed'Big River impoundment would result in the destruction and loss of diverse
and productive wetland and free flowing stream habitat that provides-profound and
critical ecological support to wildlife in the Big River watershed and Management Area.
Further, the administrative record supports the conclusion that the proposed
impoundment could adversely impact aquatic resources and water qualitjroutside of
both the impoundment area and the Big River watershed by impairing groundwater
movement and reducing the amount of water discharged into the south branch and
main stem of the Pawtuxet River. In addition, Regional findings concerning the overall
project purpose and need and practicable alternatives to satisfy that need are supported
by the administrative record. Accordingly, Section H, PROJECT DESCRIPTION AND
HISTORY (pages 3-9), Section m, SITE DESCRIPTION (pages 10-27), Section IV,
ADVERSE ENVIRONMENTAL IMPACTS. Sections A-D (pages 29-48), and Section
V, ALTERNATIVES (pages 49-64) of the Recommended Determination-are .hereby
adopted as part of this Final Determination.
In consideration of the Recommended Determination, the administrative record
and other material information obtained by EPA subsequent to the Recommended
Determination, EPA has determined that the discharge of dredged or fill material in
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connection with the proposed Big River water supply reservoir would result in
unacceptable adverse effects on wildlife habitat and recreation areas. This Final
Determination therefore affirms the Regional Recommended Determination and
prohibits the designation of Big Rfver, Mishnock River and their tributaries and
adjacent wetlands as discharge sites for dredged or fill material for the purpose of
creating a reservoir or impoundment as proposed by the Corps of Engineers 1981
Environmental Impact Statement and as proposed by the Rhode Island Water
Resources Board.
IL EPA HEADQUARTERS ACTIONS
Pursuant to the Section 404(c) regulations, after considering public comment on
the Proposed Determination, EPA Region I submitted the Regional Recommended
Determination to EPA Headquarters. The Recommended Determination document
was signed October 10, 1989, and the full administrative record was received by EPA
Headquarters on October 30, 1989. Pursuant to Section 231.6 of the Section 404(c)
regulations, the initial deadline for issuing the Final Determination for the proposed
action was December 29, 1989. Due to the magnitude of the record for this case and
the importance of the recommended actions under consideration, EPA determined that
there was good cause for extending the period for affirming, modifying, or denying the
Regional Recommended Determination until March 1,1990. Notice of the extension ol
time was published in the Federal Register on January 3,1990 (55 FR 171)."**
•• •;,-". = •;•' <> -;••.*:• v^;^ •-••;-.. ;.zv^'.•!<:' :" ^ ^ •-.!•'"•' '-•' "':'j: '' • ''' '
In accordance with the Section 404(c) regulations at Sectiori~231.6, EPA offered
final consultation with the Director of Civil Works of the Army Corps of Engineers
(Corps) and the Chairman of the Rhode Island Water Resources Board by letters dated
November 7, 1989. The letters provided the Corps and the Water Resources Board the
opportunity to present information which reflects an intent to take corrective action to
prevent unacceptable adverse effects from the subject activities. Further, the letters
offered an opportunity to meet with EPA representatives and discuss any issues related
to the Section 404(c) action.
The Corps responded in a letter from Brigadier General Patrick Kelly, Director
of Civil Works, dated November 29, 1989, which stated that the Corps had no
comments on the Recommended Determination at that time. The Rhode Island Water
Resources Board responded in a letter dated November 20, 1989, from A. Joseph
Mattera, Chairman. Mr. Mattera's letter suggested that because there was no permit
application pending on the project (the Board had withdrawn the Section 404 permit
application subsequent to EPA Region I's initiation of the Section 404(c) action), and
that because the State had commissioned a State-wide water supply analysis due to be
completed by mid-1990, final action on the project would be premature and EPA
should therefore defer final action on the Recommended Determination; the letter did
not indicate a specific timeframe for the deferral. Mr. Mattera's letter also raised
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issues concerning EPA's jurisdiction over the proposed Big River project and adequacy
of the proposed consultation timeframe. Mr. Mattera's letter did not request a meeting
or any other further consultation with EPA regarding the Regional Recommended
Determination or final decision.
Mr. Mattera's letter stated that there was no need for EPA Headquarters to
proceed with the Final Determination because there is no permit application pending
for the project, and the State does not intend to proceed with the application until such
time that there is a demonstrable need for additional water supplies. Moreover, Mr.
Mattera's letter also indicated that the State would consider construction of the Big
River project only if a project could be constructed without unacceptable environmental
risk. EPA notes, however, that when this Section 404(c) action was initiated, the
Rhode Island Water Resources Board had pending a Section 404 permit application
proposing the discharge of dredged or fill material in waters of the United States for
the purpose of constructing this project On April 3, 1987, the Water Resources Board
applied for a Section 404 permit for the Big River Reservoir; that application was still
pending on August 24, 1988, when EPA Region I initiated the Section 404(c) action.
The Section 404 permit application was withdrawn by the Water Resources Board on
September 8, 1988. Because specific projects have been proposed in the past, both by
the State .and the Corps, EPA determined that it would be appropriate to complete this,
Section 404(c) action rather than leave unresolved the acceptability of the adverse
effects of the proposed projects. Moreover, the Clean Water Act does not preclude
EPA from completing the.Section 404(c) process under these circumstances. In fact,
the Section 404(c) regulations explicitly recognize EPA's authority to take actions
pursuant to Section 404(c) in advance of and/or in the absence of a permit application
(40CFR §231.1(a)).
Mr. Mattera's response included discussion of an ongoing analysis of water
supply issues. The letter stated that the study would focus on the long-range need for
the Big River project and that State decisions regarding the proposed impoundment
would be assessed in light of the findings of the study. As presented in the
administrative record, the water supply analysis mentioned in Mr. Mattera's letter is
designed to address State-wide water supply issues and will not specifically address the
Big River proposal
Preliminary review of the information in the Regional administrative record, the
draft reports available from the State water supply study at that time (which have been
included in the administrative record), and the overall scope of work of that study, led
EPA to conclude that a deferral was not necessary and would not provide significantly
better information on which to base this Final Determination. EPA further determined
that the Agency had a responsibility to review the Regional Recommended
Determination and render a final Agency decision in as brief a period as reasonable.
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Based on these findings, EPA decided that deferral of final action on the
Recommended Determination would be inappropriate.
Therefore, review of Mr. Mattera's letter, in light of preliminary evaluation of
the Recommended Determination, convinced EPA Headquarters that the issues raised
by Mr. Mattera which were relevant to a Final Determination under Section 404(c)
could be adequately addressed during review of the Recommended Determination and
administrative record for the Big River project
The Conservation Law Foundation (CLF), the Audubon Society of Rhode Island
(Audubon) and the National Wildlife Federation (NWF) requested a meeting with the
Assistant Administrator for Water to discuss their concerns over EPA Headquarters'
review of the Regional Recommended Determination. This meeting was held on
December 22, 1989. Issues raised by the representatives of NWF, Audubon and CLF
included: their support for the Regional Recommended Determination; their support
for prompt completion of the Final Determination; their belief in the adequacy of the
Recommended Determination and administrative record; their doubt regarding the
project's compliance with the Section 404(b)(l) Guidelines; and consideration of the
State-wide water supply study.
HL NEW INFORMATION '
r Subsequent to transmittal of the Regional Recommended Detennination to EPA
Headquarters, information which EPA believes irrelevant: torthe^Final Determination
on the Big River project became available" to Region I arid was forwarded to EPA
Headquarters. The information contained in these reports was not available for
comment during the public review period for the Proposed Determination. However,
as discussed below, this information merely confirms the accuracy of the administrative
record supporting the Region's conclusions regarding the environmental impacts of the
Big River project, its need and the availability of alternatives. Since the new
information is not being relied upon to alter the Agency's determination but is
corroborative of other information that was subject to public review and comment
during the Regional stages of the Section 404(c) process, EPA determined that
additional pubb'c input was not necessary. The information includes: interim results of
a study reviewing measurements of the safe yield of Scituate Reservoir, new
measurements of the total wetland acreage within the area outlined by the proposed
Big River impoundment; and draft reports developed in the State's review of water
supply. A brief description of the information and its relevance to this Final
Determination is presented below.
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A. Safe yield of the Scituate Reservoir.
In evaluating the water supply capacity of existing sources in the region of
Rhode Island to be served by the proposed Big River Reservoir, previous analyses have
incorporated various estimates of the available safe yield of existing supplies in Scituate
Reservoir. In reaching particular findings contained in the Recommended
Determination, EPA Region I relied upon approximations of safe yield for Scituate
Reservoir based on estimates determined by the Providence Water Supply Board (pages
51-53 of the Recommended Determination and pages 7-9 of Appendix HI of the
Recommended Determination). The safe yield figure for the Scituate Reservoir system
used in the Recommended Determination is 89.3 million gallons per day.
Preliminary review and analysis of the safe yield measurements for the Scituate
Reservoir prepared by consultants for the Providence Water Supply Board and obtained
by EPA Region I since transmittal of the Recommended Determination to EPA
Headquarters confirms previous estimates of the Board. While inquiries by EPA
Region I found that the contractor's review has not yet been finalized, the preliminary
safe yield figure agrees with estimates in the administrative record and supports the
relevant sections of the Recommended Determination.
B. Updated information on wetland acreage.
•i i
In the preparation of the Recommended Determination, EPA Region I utilized
measurement data on general wetland acreage and type within the Big River watershed
and proposed impoundment area, concluding that 575 acres of wetlands exist within the
proposed impoundment boundaries. The data for this figure are based on evaluation of
aerial photography and field checking, both performed at the University of Rhode
Island by students under the direction of Dr. Frank Golet, Associate Professor of
Natural Resource Science, Department of Forestry and Wildlife. The acreage of
wetlands predicted by the University of Rhode Island study to be impacted by the
proposed impoundment coincides closely with earlier estimates by the Corps of
Engineers of wetlands within the impoundment area. Wetland acreage and type within
the subject area are summarized in Figure 5 of the Recommended Determination.
For the purposes of this Final Determination, EPA Headquarters relied upon the
acreage of wetland loss used in the Recommended Determination. It should be noted,
however, that in January of 1990, EPA Region I received a student report, prepared for
a class taught at the University of Rhode Island, which estimates that construction of
the proposed Big River impoundment would result in the direct loss of approximately
794 acres of wetlands. Preliminary review by EPA Region I of the data used in this
analysis predicted that the wetland loss would be somewhat larger, approximately 820
acres. The baseline acreage data used in the analysis was not available for review in
this Final Determination and as such, conclusions regarding the validity of these new
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figures would be premature and are not considered applicable for the purposes of this
Final Determination.
C. Draft Reports: Water Supply Analysis for the State of Rhode Island.
In addition to reviewing the environmental impacts of the proposed Big River
impoundment, EPA Region I examined the avoidabitity of those impacts based upon
the overall project purpose and need, as well as practicable alternatives which satisfy
the basic project purpose and need. As noted previously, the project as proposed by
the Corps had as one of its purposes construction of an impoundment which could
serve as a water supply reservoir. As proposed by the State, the Big River project
would have as its sole purpose creation of a water supply for a given region of Rhode
Island. In reviewing the avoidability of the project impacts, the Recommended
Determination evaluates factors such as legitimate need for water supply based upon
population projections and per capita consumption of water for the subject area (pages
50-53 of the Recommended Determination and Appendix HI of the Recommended
Determination). As noted in the Recommended Determination, EPA Region I
concluded that previous predictions of water supply deficits in the area which would be
served by the proposed Big River impoundment were imprecise and did not reflect
available information.
i
As noted in the Recommended Determination, the Governor of Rhode Island
has formed a special task force known as the Water Resources Coordinating Council
(WRCC) and has charged this group with ^reviewing Rhode Island's State-wide water /
supply needs and assessing various structural and non-structural alternatives which could
satisfy anticipated unmet need. In order to respond to this charge, the task force
contracted with Arthur D. Little, Inc., to prepare reports addressing baseline water use,
water demand management, water supply and supply management, forecast of water
use and unmet needs, and identification and analysis of alternatives. After
consideration of these reports the WRCC will prepare recommendations forJJtate
actions regarding water supply. Currently, draft reports are publicly available on all
topics except alternatives. It should be noted that the reports are in draft and subject
to further review and revision. Additionally, the reports are designed to address water
supply needs State-wide and therefore do not, at least in their present draft format,
specifically consider the proposed Big River impoundment
Although the available water supply analysis reports are currently in draft form,
EPA determined that it would be useful to review the information presented in the
reports for consistency with assumptions used in preparing the findings contained in the
Recommended Determination. To help accomplish this task, EPA contracted with Dr.
John Boland to examine the Arthur D. Little reports and compare them to results of
the EPA Regional analysis. Dr. Boland's February 9, 1990, letter concluded that
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overall, the draft water supply analyses available as of that date did not contradict EPA
Region I analysis or refute conclusions in the Recommended Determination.
EPA Headquarters also reviewed the draft reports independently in preparation
of this Final Determination and concluded that the draft water supply analyses were
consistent with the bases for findings presented in the Recommended Determination. In
many instances, such as population projections and water use projections, the new
analysis indicated that the Recommended Determination may have even over-estimated
the need for additional water supply.
IV. FINDINGS AND CONCLUSIONS
This Final Determination under Section 404(c) of the Clean Water Act addresses
unacceptable adverse effects to wildlife habitat and recreation areas. The Section
404(c) regulations define an unacceptable adverse effect as an impact on an aquatic or
wetland ecosystem that is likely to result in significant degradation of municipal water
supplies or significant loss of or damage to fisheries, shellfishing.jor wildlife habitat or
recreation areas. Section 231.2(e) of the Section 404(c) regulations states that the
evaluation of the unacceptability of such impacts should consider relevant portions of
the Section 404(b)(l) Guidelines. The relevant portions of the Guidelines include
consideration of practicable alternatives to the proposed project which would have less '
adverse impact on the aquatic ecosystem (40 CFR §230.10(8)). Based upon the -_
substantial environmental effects of the proposed project and the availability of less I
damaging practicable alternatives, EPA finds that the project as proposed would result I
in significant loss of wildlife habitat and recreation areas. ——
The Recommended Determination and the administrative record form the basis
for EPA Headquarters' conclusion that the area which would be directly impacted by
completion of the proposed Big River Dam and Reservoir contains exceptional and
diverse natural wetland and free flowing aquatic systems. The large, relatively
undisturbed area provides habitat for an abundant and complex assemblage of wildlife
species. The administrative record supports the findings of the Recommended
Determination that the subject area currently supports important habitat for a range of
resident and transient species of wildlife which depend upon the area's natural aquatic
systems for all or significant portions of their life cycle or which thrive in a natural
habitat composed of upland-terrestrial, open water, and emergent, scrub-shrub and
forested wetland ecosystems.
In addition to direct loss of wildlife habitat associated with implementation and
operation of the proposed impoundment, the administrative record confirms that the
proposed project would alter both surface and groundwater flow out of the Big River
system. The administrative record supports the conclusion that the Big River water
supply impoundment, if operated as proposed, would reduce substantially the quantity
8
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of water that currently flows into the Flat River Reservoir and South Pawtuxet River
and thus would adversely impact downstream aquatic habitats. Additionally, proposed
placement of a slurry wall in the area of Division Road to prevent groundwater leakage
from the proposed reservoir would interrupt normal groundwater flows that contribute
to the water levels in Mishnock lake and maintain forested wetlands in Mishnock
swamp. While these secondary, indirect impacts would adversely affect aquatic habitats
outside of the impoundment site, the effects are predicted to be of similar magnitude to
losses within the impoundment area. Finally, it should be noted that changes in
downstream flow resulting from implementation of the proposed Big River project
would have a clear potential for adversely affecting water quality in downstream areas
of Flat River Reservoir and the South Pawtuxet River.
The administrative record indicates that the Big River management area,
including the site of the proposed impoundment, is utilized by the public for a range of
consumptive recreational activities such as fishing and hunting as well as non-
consumptive uses such as hiking, bird watching, swimming and canoeing. Although the
area does not experience significant recreational use compared to some areas which
actively encourage recreational activities, such as Flat River Reservoir, the area provides
relatively unique opportunities for cold water fishing and other activities dependent
upon free flowing stream systems as well as activities dependent upon accessible large
scale environments. The proposed reservoir's area along with the remainder of the Big
River management area comprise a substantial portion of the natural open space in the
State of Rhode Island.
Under both the Corps and State proposals, the primary purpose of the Big River
project is potable water supply. Because of current State policies limiting the type of
use for water supply facilities, and the restricted access that usually accompanies a
water supply reservoir, it is likely that many if not all recreational opportunities
currently available in the proposed reservoir area would be prohibited both in the
reservoir pool and in areas surrounding the impoundment Even if restrictions were
changed to allow particular recreational activities, as proposed, construction of the Big
River -Reservoir would significantly alter the present recreational environment in the
proposed impoundment area. Because terrestrial and relatively shallow wetland and
flowing stream environments would be replaced with deeper, static reservoir waters,
recreational activities, such as stream fishing or bird watching, which are carried out on
foot, would be lost within the impoundment area. Other recreational activities within
the impoundment would be limited to those which can be accomplished from a boat or
from the reservoir shore. In addition, loss of the terrestrial and wetland wildlife habitat
would destroy or reduce the area's current capacity to support those species which are
the object of activities such as bird watching and hunting.
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EPA also evaluated the avoidability of impacts associated with the proposed
project through examination of the underlying assumptions and rationale on which the
project rests. The administrative record indicates that should the need arise for
additional water supply in the area which would be served by the Big River proposal,
practicable alternatives which are less damaging to the environment are available to
satisfy that need. The administrative record suggests that significant potential sources of
potable water, from both conventional and non-conventional sources, have not been
adequately explored. Alternatives such as improved yield of present surface water
supplies and proper use of available groundwater reserves are potential additional
sources of potable water supply which could supplement available sources. However,
the administrative record supports the conclusion that projected water demand is highly
unlikely to exceed supply in the near future and, with reasonable demand management
mechanisms, it is unlikely to exceed supply over the long term. As stated previously,
this finding is supported by preliminary reports prepared by consultants for the State
Water Resources Coordinating Council. The administrative record suggests that
population growth has stayed significantly below levels previously predicted and both
residential and industrial water consumption have exhibited declines over the recent
past. In addition, the administrative record establishes that non-structural alternatives
to construction of an impoundment, such as altered pricing policies, long-term water
conservation strategies and drought management, hold substantial promise in terms of !
demand management capable of further reducing the need for large scale impoundment
projects. - ,
Review of the Recommended Determination and the administrative record
confirms that construction of the proposed water supply dam and reservoir on Big
River would result in the direct and .significant loss of an area that provides important
wildlife habitat and recreational opportunity. Additionally, implementation of the
proposed reservoir project would adversely impact valuable aquatic systems associated
with surface and groundwater flow from the subject area and could exacerbate water
quality problems downstream of the Big River area. Further, the record confirms that
these adverse impacts are avoidable. The administrative record supports the finding in
the Recommended Determination that there are practicable, less environmentally
damaging alternatives that would address projected water supply deficits, if any, for the
area which would be served by the proposed Big River Reservoir. The record also
demonstrates that the basis for previous estimates of water supply deficit for the region
which would be served by the Big River proposal were incorrect and that water supply
deficits are not likely to occur over the long term. EPA concludes that the direct and
indirect environmental impacts associated with the proposed Big River project would be
10
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profound and are avoidable and constitute unacceptable adverse effects to wildlife
habitat and recreation areas within the meaning of Section 404(c).1
This Section 404(c) Final Determination therefore affirms the Regional
Recommended Determination and prohibits the designation of waters of the United
States including Big River, Mishnock River and their tributaries and adjacent wetlands
as discharge sites for dredged or fill material for the purpose of creating the Big River
reservoir as proposed by the Corps of Engineers 1981 Environmental Impact Statement
and as proposed by the Rhode Island Water Resources Board. EPA's Section 404(c)
action is based upon the adverse impacts associated with construction of the Big River
dam and reservoir and the avoidabflity of those impacts. Accordingly, this Final
Determination does not pertain to filling activities for purposes other than the project
as proposed, or to proposed filling activities in other waters of the United States within
the described area. Other proposals involving the discharge of dredged or fill material
in the waters of the United States at issue will be evaluated on their merits within the
Section 404 regulatory program.
March 1, 1990
HaJuajza S. Wilcher, Assistant
Administrator for Water
1 EPA Headquarters' conclusion that the adverse impacts of this project are
unacceptable rests on consideration of the significance of the impacts in the context of
their avoidabflity. Therefore, this decision need not, and does not, reach the question
of whether such impacts would still be unacceptable if there were no other practicable,
environmentally less damaging alternatives to meet legitimate public water supply needs.
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