To: Minnesota Department of Natural Resources
Division of Ecological and Water Resources
Re: Weaver Bottoms Aquatic Habitat Restoration Project EAW.
Thank you for the opportunity to comment on the Environment Assessment Worksheet (EAW) regarding the proposed dredging of an area in Weaver Bottoms. I am writing as a concerned citizen with a general scientific background; not as a specialist in wetland ecology or wetland management.
As I understand the project goals, they are to improve boating, fishing, and waterfowl hunting from boats in a small area adjacent to one of five boat-access points in the immediate vicinity (Anderson 2009, MN DNR 2015). The project would be funded as one part of the $5.25 million project "DNR Aquatic Habitat - Phase V" funded in 2014 by the MN Outdoor Heritage Fund (MN DNR 2014).
As I understand the methods, the project would use a backhoe to dredge an average of about four feet of sediment from a twenty-acre area of Pool #5 that has been filling with sediment from the Mississippi and Zumbro rivers. The dredged material would be placed on a nearby, ten-acre area of farmland. Attempts would be made to relocate visible, mobile fauna from each day's work zone in both the dredged area and the placement area, but all other flora and fauna in and around the transported material would be killed. The upland portion would be seeded back to pasture, and the waters would be left to recover naturally (MN DNR 2015). In a departure from the approach of other conservation organizations working in the area (The Nature Conservancy 2015, USFWS 2010) , there would not be any action taken to prevent the area from refilling with sediment. Given the certainty of continued sedimentation in the area, this project would need to be repeated periodically and perpetually into the future in order to maintain the desired water depth. There is no projection for the time interval between dredgings; it might be as infrequent as 80 years, or more frequently, depending on the rate of sedimentation, other considerations, and available funding.
I see the following problems with the EAW:
Overall, I see a high cost/benefit ratio in this proposed dredging project, and I don't see a fair accounting for that in the EAW. The cost/benefit ratio of this project should be estimated in this EAW so that it can be compared by policy makers to those of alternative projects in soil-conservation, storm-water and waste-water runoff control, shoreline improvements, game and non-game wildlife conservation, game and non-game outdoor recreation, etc.
Personally and scientifically, I see the periodic creation of a 30-acre dead zone as a major drawback of the project, and I don't see a fair assessment of it in the EAW. The dredging and placement operations would be highly-destructive, and their results artificial; in contrast with the relatively harmonious, natural alternative of leaving the area to fill with sediment, and thus slowly transition to a different type of living habitat (similar to the wetlands that once surrounded historic Goose Lake).
In short, the EAW seems to be incomplete. It does not include a fair consideration of 1) alternative values and goals, 2) all environmental, financial, and energy costs, or 3) relative cost/benefit ratio.
If this EAW were complete and fair, I believe it would show that the preferred plan for areas like this along dam impoundments of the Mississippi River would be to allow sedimentation to continue, without dredging. Areas like this would continue to develop as wetlands on the food-plain, rich in wildlife, and high in environmental quality. These areas would continue to be valued by diverse interest groups, for diverse reasons. This EAW focuses only the interests of those who would boat, fish, or hunt from boats in areas like this. That's not acceptable.