Comment on FR Doc # 2010-02870

Public Comments Processing Attn: RIN 1018-AU88 Division of Policy and Directives Management U.S. Fish and Wildlife Service 4401 N. Fairfax Drive, Suite 222 Arlington, VA 22203 Dear Sir or Madam, This is written in response to the proposed rule and the economic analysis performed by the U.S. Fish and Wildlife Service for Endangered Listing for the Georgia Pigtoe Mussel, Interrupted Rocksnail, and Rough Hornsnail, as well as Critical Habitat for the three species. Mobile District, U.S. Army Corps of Engineers (Corps) does not object to the listing of the three species and their critical habitat. However, we have comments relating to specific sections of the economic analysis as noted below. Thank you for the opportunity to provide input into this proposed action. Page ES-2: We do not agree with the assumptions made for the baseline conditions and for the proposed Corps Water Control Manual updates. The document states that operations at Carters, Weiss and Jordan will modify operations to provide additional flows for the benefit of downstream species. Also in the next paragraph is a statement that environmental flow releases will be undertaken at Carters as a result of the Manual update. Such statements are pre-decisional as the Corps has not yet completed the Manual update and has not yet proposed any changes from current operations, nor have we completed Section 7 Consultation for the proposed actions. Paragraph 7: Same as for page ES-2. Page ES-10, Exhibit ES-8: Same as for page ES-2. Paragraph 58: Same as for page ES-2. Page 3-3, Exhibit 3-3: Same as for page ES-2. Paragraph 59: Report mentions that a project purpose is flood control, terminology has been changed to flood risk management. Page 3-5, Exhibit 3-4, second line in table, under River: “Chattahoochee” should read “Coosawattee”. Paragraph 65, Statement that 2009 Corps concerns that potential flow requirements for mussel species downstream of Carters Reregulation Dam could affect power production at the facility: This remains a comment relevant to the proposed listing since formal consultation on the species has not been concluded and environmental flow changes have not been implemented. Likewise in footnote 31 costs for study and implementation of modifications were stated to be $2 million, were stated to have been largely spent; thus, not included in the current analysis. In fact such studies are ongoing and inconclusive at this time. Paragraph 70: Note should be added that indicates a more severe drought (drought of record) occurred in 2007 and that earlier drought modeling may therefore be outdated. Paragraph 71: Report mentions a loss of revenue for hydropower. Does this value include replacement cost for generation and capacity? Paragraph 73, and footnote 36: Should be updated through communication with FERC. Additional license activities are possibly underway unknown to the Corps employee referenced. Paragraph 74: Statement of costs for environmental flows at Carters - see comment for page ES-2. Costs may be based on the earlier analysis and not reflect current costs. Last sentence in paragraph – “Whether environmental flows will be adopted…is unknown at this time.” We agree and wonder why the other references consider such flows as certain. The acronym for Water Control Manual should be corrected from ‘WQM’ to ‘WCM’. Paragraph 108: Are these annualized costs for the current construction projects (Alabama 5, Georgia 10)? Are there any values for a sensitivity analysis to look at future projects?