12 January 2012

No Further NET Funding for Carter Lake Project

The following comments were submitted via email to the Nebraska Environmental Trust for consideration by members of the board.

The Nebraska Environmental Trust should not provide any further funding for the Carter Lake Restoration and Rehabilitation Project, project number 11-174-2.

This project though it is expressed as a water quality/fisheries project is primarily a fisheries project, to the exclusion of other uses of the lake, as has become apparent after closely following this project during the past few months. Numerous documents have also been reviewed to provide additional specifics used to develop this conclusion.

Particular pertinent items to convey, include one item or another, and indicate a common thread of a single purpose project with only just one purpose, despite what additional empty words were submitted in the grant application.

The Omaha City Council accepted and approved a bid for the project. The council would not have approved a bid unless sufficient funding was available. Thus, there is no need for the NET to provide any further dollars as the bid would not have been approved if sufficient funds were not available to cover the expected cost.

If this is a water quality project, why has nothing been done to address runoff from Eppley Airfield at the east side of the lake. There are several drains from this site, yet the project does not include any features to address its runoff which could include oil, gasoline and other transportation-related things.

The inclusion of bank stabilization, dredging to increase water depth, dumping rip-rap to create groins, removal of unwanted fish and placing breakwaters are conveyed as being beneficial for improving the fishing resource. Yet, there has been no evaluation of how these features will impact current values of the lake.

Placing more than 12,000 tons of rock — based upon bid specifications — in Carter Lake is not an improvement. It is a focused effort that will degrade the quality of this oxbow lake — with a history dating to 1877 — and create an unsightly lake of an industrial sort. Rather than finding environmentally benign options, the project proponents accepted the use of rip-rap which is in no manner conducive to a naturalistic setting.

This project appears to be nothing more than an effort to subsidize fishing, to the exclusion of other values.

Funds provided by the Nebraska Environmental Trust should reflect a holistic view, rather than providing a subsidy to two state agencies so they might be able to sell some more fishing licenses.

The primary runoff feature is in the northwest corner of Levi Carter Park. The pond will be dramatically altered because of this focus. The pond is now an important micro-habitat for birds but will cut-apart, once bisected by four fill structures of an immense extent of rock meant to impede water flows. Work associated with the placement of the necessary rock riprap will also clear vegetative growth along the pond's shore, causing further degradation. During many bird surveys in the area, the fowl like the pond setting and swim along freely, and massive amounts of rock will create a changed habit. There was no consideration presented in the planning documents as to how this alteration would impact the avifauna associated with the pond.

The in-lake breakwaters to be dumped into the lake will negatively impact use of the lake by waterfowl. The birds will no longer be able to swim to these portions of the lake, so the habitat important to their survival has been constricted.

These communications have included concerns regarding just one groin at the northeast part of the lake. This one bunch of rock is among the more than twenty to be placed in the lake waters, and for the inane reason given by the state agency staff: people do not like to fish from the bank.

Most of the project proponents have not been interested in any sort of compromise to exclude one groin to provide a setting conducive for signage that would recognize the Sandy Griswold Bird Sanctuary, established in the latter 1920s - then forgotten and unknown for decades — until newly expressed in an editorial published in the Omaha World-Herald. Numerous discussions have occurred with staff of the NGPC about one groin and birdlife of the lake. One discussion in this regard - concerning one unnecessary groin — occurred with an senior administrator of the NGPC occurred on November 17, 2011. Even after nearly two months, he did not respond, despite expressive comments that he would. Subsequent inquiries as to the status of this met with no reply other than a decision had not been made.

The reality of bird use has been derived from more than fifty bird surveys done about Carter Lake since late March, 2011. Even though staff with NGPC has been told of this effort, they have continually ignored these facts.

Use of the lake by birds has not been considered in any manner by project proponents. Based upon numerous communications, this is readily apparent, especially based upon comments from staff at the Nebraska Game and Parks Commission. Staff have said — again and again — that the lake is not important for birds. This is an erroneous opinion.

How incorrect they are, since when it comes to bird use they have no current information and have not shown any interest in considering the known aspects of fowl at the lake in the past few months.

It is now obvious that the NGPC staff have made a decision based upon a focus on fisheries, and have no interest in considering other values and uses that can be derived from the waters of Carter Lake.

The history of this cutoff lake date to origins in 1877. Changes again and again have altered this oxbow, and reduced its value to migratory birds. Least terns and piping plover formerly raised young here. Bird enthusiasts conducted numerous surveys in the latter 1920s and subsequent years to document bird use. None of this history has been considered in the current, short-sided planning for a project designed to reduce the value of the lake for birds, which is a perspective derived from three decades of studies of birds and the habitats where they occur.

Carter Lake has had a greater extent of bird use by some species during the past few months. This is based upon an evaluation of details from Missouri River valley sites from Desoto NWR and southward to Lake Contrary, near St. Joseph, Missouri.

Also worth considering is the response due to the removal of the unwanted fish from the lake. There was a "great bloom of growth" by aquatic vegetation. Then boaters complained, so a boat was used to clear away the plants. Yet this is an essential reason for the ongoing occurrence of many sorts of waterfowl.

This is disingenuous. The project proponents wanted to improve water quality, and when it happened and water flora flourished, they did not like the results. This indicates, again, a weak plan which deserves not further funding from the NET.

Considering bank stabilization, this is another questionable project feature. Carter Lake has a very consistent water level, as maintained by a pump. During bicycle rides along the lake shore, there have been no problematic bank erosion noted. The plan calls for placing tons of ugly rock along the bank, without any consideration given to how the currently sufficient situation is foraging habitat for birds and more aesthetic than glaring piles of rock! An option was given to where the rock would not get covered by earth which would at least make it have an appearance more suitable for the park setting.

The number of groins proposed is excessive. More than twenty of these will be built, with most along the east shore of the lake, and a spaced just a short distance apart. The extent of these intrusive constructs is another indication that this is primarily a project with an intent to promote fishing, i.e., a subsidy for selling fishing licenses. The reason for these is that apparently people do not like fishing from the bank. So a massive amount of rock riprap will be dumped into a lake to make it easier to fish, but without any consideration of how these intrusions will change the lake's condition.

Quarterly reports provided by the entity which has already received money are incomplete. There is nothing given in the two most recent reports which indicate a number of email communications which expressed concerns or provided up-to-date options for project modifications. The response was that the project was already designed and would not be changed, no matter what might have changed. This indicates a blatant disregard to public input and any interest in utilizing the best possible design.

There was no public meeting for the final project design where the proposed options could be presented, discussed and suitably considered. This is another obvious disregard of public involvement. A public meeting to discuss project goals and a timeline is being held in mid-January, but none was held to receive final comments on project options, or to accept plan improvements. There should have been such a meeting for project planners to hear comments regarding the massive changes to occur to the lake and adjacent Levi Carter Park, an appreciated public green space.

The project website also has not given details of any significance. Any details presented have been trite and lacking in detail. So there has obviously been an ineffective effort to inform the public. Yet this project relies upon millions of public dollars!

This project does not convey any effort to consider all aspects of the project environment about Carter Lake. It is instead focused upon one particular intent — fishing — with additional inadequate measures for another project purpose thrown to convey benefits which are dubious or only partially implemented.

The results will establish an industrial lake — changed from a Missouri river oxbow to a setting created by engineers sitting at their desks — which does not reflect a multiuse project beneficial to the environment.

It would be wrong for the Nebraska Environmental Trust to provide any additional funds for this project. Site plans convey a design which will degrade the lake environs. The NET promotes project which benefit the environment and are done in a thoughtful manner. The Carter Lake project does not — in many ways — conform with the standards of broad-based and multi-purpose projects which are beneficial to the general populace which provide the NET its funds.

There are a multitude of other proposals which could derive a greater benefit if funded. The Nebraska Environmental Trust should not be involved with any project that has an obvious bias, which misrepresents project purposes, which avoids public scrutiny, and that will result in an overall negative impact to a unique oxbow lake of Missouri River valley.