May 26, 2017
Savannah District, U.S. Army Corps of Engineers
ATTN: Mr. Nathan Dayan (PD)
100 West Oglethorpe Avenue
Savannah, Georgia 31401-3640
RE: Comments on the Savannah Harbor Expansion Project (SHEP), Modification to Fish Passage Feature at the New Savannah Bluff Lock and Dam (NSBLD)
Dear Mr. Dayan:
The Augusta Metro Chamber of Commerce represents the interests of 1,200 businesses and organizations throughout the Central Savannah River Area (CSRA) and is very interested in the ongoing planning activity with regard to the New Savannah Bluff Lock and Dam by the United States Army Corps of Engineers. The NSBLD structure has become a part of the fabric of the Augusta/North Augusta Community over the past eighty-plus years. Alterations to, or replacement of the current structure could result in changes to the Savannah River which will have meaningful impacts on the greater community and our members for many, many years to come.
Thousands of jobs as well as millions of dollars and product depend on the level and use of water from the pool for process-water. Hundreds of millions of dollars in development have been created along the banks of the Savannah River because the pool of water created by the lock and dam creates the environment that makes them attractive and viable. This development includes hotels, conference and convention space, restaurants, a golf course, housing, museums and office space. Future plans include additional housing, retail, meeting space and professional space. The State of Georgia is building its Cyber Center on the banks of the river, North Augusta is developing a new baseball stadium directly next to the pool and conceptual plans to create an Augusta visitor destination center on the banks of the river are all developments currently underway.
For over 17 years, the Augusta Metro Chamber has been a leading voice in advocating for the rehabilitation of the NSBLD structure to ensure and safeguard our community’s future dependency on the pool, especially as the structure has steadily deteriorated. As you are aware, the Water Resources Development Act of 2000 authorized the repair and conveyance of the NSBLD, and we remain committed in stating that this solution was viable and met the needs of our community. Had the project occurred as authorized, mitigation required by SHEP for the migration of endangered fish could have been accomplished with the construction of a Fish Passage/Bypass and without the need to legislatively fashion alternate projects as outlined in the Water Infrastructure Improvements for the Nation Act of 2016.
While we are encouraged that these project modifications legislate the security of the pool, it is still the opinion of the Augusta Metro Chamber that repair of the lock and dam, and the construction of a fish bypass, is an optimal solution that meets our needs while reducing possible negative impacts on the community, and accomplishes the needs of the Savannah Harbor Expansion Project.
As stated, we are greatly encouraged that a project modification as outlined in WIIN 2016 requires the structure [to maintain the pool for navigation, water supply and recreational activities, as in existence on the date of enactment of this Act;] ((C) PROJECT MODIFICATIONS (1)(A)(i)). This is a significant legislative achievement for our community but we remain rightfully concerned that the projects as described in the law may not be able to achieve the desired result for both our community and SHEP and at the same time minimize the possible impacts of both not enough water or too much water. We understand final guidance is yet to be provided to the district on how it should proceed and how the feasibility of projects will be evaluated. Given the two project descriptions currently outlined in the law, the Augusta Metro Chamber of Commerce feels that one option offers more to our community than the other.
The Chamber believes that an option that provides for continued access from above the structure to the lower half of the Savannah River via an operational lock is preferable. We believe to permanently cut off the center of our region from the lower parts of the river and the Atlantic Ocean beyond is short-sighted. While there has not been significant usage of the existing lock in recent years that need could change in the future, and by permanently blocking the river entirely we may prevent a number of important and useful developments in the future. The existing lock’s poor condition and lack of consistent operation has surely reduced demand in recent years; meanwhile our community is growing and we do not know what the future may hold. To forever seal Greater Augusta from the areas down river is not in our best interest.
The Chamber also believes that choosing an option that includes the lock has the further benefit of reusing the existing dam structure, which we view as preferable to constructing a new structure at a different location. The park at the existing lock and dam is popular with the public and a great asset to the county. We believe the value of this asset would be diminished should the dam structure move. In addition to the benefit to the park we feel that using the existing footprint for a new structure would reduce uncertainty and possible environmental impacts from construction at a new site.
For these multiple reasons, the Augusta Metro Chamber considers a project that repurposes the existing structure to include a lock more preferable over other project modifications described in WIIN 2016, if those options are the only ones currently under consideration. However, should further guidance allow for the full repair of the existing structure and construction of a bypass around the dam, we feel this option is best for the community.
The Augusta Metro Chamber of Commerce stands ready to continue to work in partnership with the USACoE to find the best way to move forward together. We believe that a solution that meets local needs as well as those of the Corps and that of the Savannah Harbor Expansion Project is an achievable goal that should be pursued.
Sincerely,
Susan E. Parr, GCCE, IOM President/CEO