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Marcus Larson Comments to the USACE re: Fargo Moorhead Dam and Diversion

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Marcus Larson Comments USACE FEIS Fargo Moorhead Dam and Diversion

General Grisoli
Civil Works Review Board
Headquarters, US Army Corps of Engineers
441 G. Street, NW
Washington, DC 20314-1000

Dear General Grisoli:

I respectfully request that you DO NOT release the final report of the LPP. The current LPP and SDEIS contains deficiencies that local representatives and decision makers are basing vital decisions on.

A joint letter was sent to President Barack Obama from North Dakota Sen. Kent Conrad (D), Sen. John Hoeven (R) and Rep. Rick Berg (R) and Minnesota Sen. Al Franken, Sen. Amy Klobuchar and Rep. Collin Peterson.

The joint letter states: [“The Red River of the North, which flows through the cities of Fargo, North Dakota, and Moorhead, Minnesota, has exceeded flood stage every year since 1993,”] However, there is nearly 18+ feet of difference between river flood stage level and major flooding. The entire cities of Fargo and Moorhead were not adversely threatened during each incident where the flood stage was exceeded.

The joint letter states: [“The floods of 2009, 2010, and 2011 have represented the first, seventh, and fourth highest floods on record for the region.”] The letter does not include that these event were due, in part, to relocation of water impacts from flood plain developments.

The joint letter states: [“Every year, the region must erect miles and miles of temporary protective measures, which are costly and often have to be erected quickly under adverse conditions.”] The letter not address that these temporary measures are due to negligent city planning, development of flood plains and flood prone areas along with a failure to require developers to install proper flood protection measures in areas where occupancy of the flood plain and been encouraged.

The joint letter states: [“The region has suffered some of its worst flooding in recent years, experts suggest that it is only a matter of time until the area is hit with even more catastrophic flooding.”] What these experts are not telling you is that it is directly related to irresponsible flood plain development and relocation of water impacts from flood prone areas in the region, which is augmenting flood level elevations on the Red River channel region due to direct and indirect violation of EO11988.

The U.S. Army Corps of Engineers (USACE) indicates that a 500-year event could potentially cause $6 billion in damages. However, impacts of a 100 year flood would be significantly less (5.99 billion dollars less).  A 500-year event could flood nearly the entire city of Fargo and a large portion of Moorhead because the geography of the region is the physical bottom of ancient Lake Agassiz. A catastrophic breach in temporary protection under these circumstances could likely result in hundreds of fatalities and could devastate the area economically, however, the USACE has failed to include the potential loss of life and viable evacuation routes if a permanent structure were to fail.

The region has been somewhat proactive in removing flood-threatened structures, however, has failed to achieve the adequate  green space necessary to provide a proper flood way to convey flood water via the Fargo Moorhead area.

Local leaders and specifically the project sponsor have a mission. That mission is to compel yourself and congress that one vital piece is still missing in their flood fighting arsenal, which would be comprehensive, permanent flood protection project. However, the currently proposed LPP (Fargo Dam and Diversion) has been deceptively labeled a diversion that is based upon an incomplete SDEIS.

In reality, it is a 12-15 mile wide dam and levee system that:

•  needs to cross 5 rivers,

•  will directly and indirectly encourage development of 25+ square miles of natural
   flood plain,

•  will directly and indirectly create new flood plains in Richland County (ND) and
   Wilkin County (MN),

•  will destroy the productivity of several thousand acres of prime farmland,

•  negatively impact the quality and fabric of the human environment in surrounding
   communities,

•  negatively impact 2 school districts,

•  negatively impact several churches,

•  elevate water as high as 9-12 feet behind the dam on unstable ground,

…which will pose a focused threat, similar to New Orleans during hurricane Katrina, to Fargo Moorhead for an undetermined amount of time.

The joint letter states: [“In 2008, the cities of Fargo and Moorhead requested assistance from the USACE to evaluate options for permanent flood protection.”] The USACE did not scope the project properly and quantify the effects of the entire dynamic region and contributing watersheds that exert an effect on the currently proposed LPP. After an incomplete study that analyzed only a select few flood protection measures, the city of West Fargo ND withdrew their interest when it became apparent that Fargo would be the primary beneficiary of the project in pursuit of future land development in violation of EO11988.

There are several deficient points in the current LPP and SDEIS. These
deficiencies include, but are not limited to:

•  uncalculated loss of life if a permanent structure fails,

•  an accurate cost benefit ratio reflecting permanent flood structures that have been
   constructed in Fargo and Moorhead,

•  uncalculated impacts to Richland County ND and Wilkin County MN,

•  a comprehensive environmental impact statement for Richland County ND and
   Wilkin County MN,

•  uncalculated long term impacts to areas southwest, west and northwest of the
   proposed LPP (Fargo Dam and Diversion) including the communities of
   Kindred ND, Davenport ND, Mapelton ND, Casselton ND, Prosper ND, Argusville ND

The Associated Press reported on Monday, February 1st, 2010 “The man who led efforts to protect Fargo and neighboring Moorhead, Minn. from record Red River flooding last spring said Monday he favored a plan to build a diversion channel in North Dakota over a cheaper proposal backed by the U.S. Army Corps of Engineers.”

The joint letter states: [The Assistant Secretary of the Army-Civil Works granted an exception to allow USACE to recommend the LPP in lieu of the National Economic Development (NED) plan. In granting the exception, the Assistant Secretary noted that “the locally preferred plan would significantly reduce flood damage, the risk of loss of life and the need for emergency flood fighting measures.”] However, the Assistant Secretary’s position is based on incomplete information and completely ignores the permanent flood protection structures that have been constructed since the 2009 flood which have effectively protected Fargo Moorhead. The cost benefit ratio has not been adjusted to reflect these permanent structures which negate the need for a 2+ billion dollar project that has a 99.98% chance of never being used to it’s designed capacity.

I, as well as others, understand that these are challenging for times for the United States as our country struggles to regain control of our national debt in a sustainable manner. The Fargo Moorhead Dam and Diversion project (LPP) is one area where the United States can prioritize and divert funding to the flood ravaged cities of Minot ND and Bismarck ND, where the financial rebuilding assistance it is most needed.

The currently proposed LPP (Fargo Dam and Diversion) does not meet the needs for the entire region, it is more costly than alternative plans and does not contain proper merit for final report release.

I urge you to NOT RELEASE the final LPP report and intercede on our behalf to halt further planning, engineering, and design of the Fargo Dam and Diversion and further violations to EO11988.
Thank you for your consideration,

Marcus Larson (U.S. Citizen & Taxpayer)
513 7th St
Hickson, ND 58047

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