Dear Assistant Secretary Darcy,
We write to urge the U.S. Army Corps of Engineers (USACE) to complete the Tentatively Selected Plan for the Brandon Road Study in January 2017, so that the Chief's Report will remain on target to be completed by January 2019. Given the proximity of Asian carp to the Great Lakes basin and collections of juvenile and larval Asian carp further upstream than previously recorded in the Illinois River, we urge the USACE to finalize the plan as soon as possible. Completion of the plan is not only a key milestone in the process towards finalizing the Chief's Report, but it will also provide critical information for policymakers at the state and federal levels to determine the most effective measures to prevent further Asian carp movement.
On April 6, 2015, the USACE initiated the GLMRIS Brandon Road Study. While we welcomed that announcement, the 46-month projected timeframe for completing the study, including the anticipated publication of the Chief's Report in 2019, was disappointing and inconsistent with the 3x3x3 rule enacted in the Water Resources Reform and Development Act of 2014. There is no question that challenges exist to developing and implementing measures that prevent the transfer of aquatic invasive species at Brandon Road. However, it is unacceptable that the report and study take 46 months to complete.
Additionally, it has been noted that construction at Brandon Road is expected to take at least 5 to 10 years after the Chief's report is completed. This timeline is unfortunate while Asian carp continue to threaten the Great Lakes ecosystem and the economy it supports. Specifically, the Great Lakes region's world-class fishery alone is valued at more than $7 billion annually. Given the importance of the regions' ecological stability to the national economy and the proximity of Asian carp to the Great Lakes, time is of the essence to finalize this report, making it available to decision makers so that construction can begin as soon as it is authorized by the Congress.
The Brandon Road Study follows in the footsteps of the Great Lakes and Mississippi River Interbasin Study (GLMRIS) report, which took 4 years to complete and resulted in an array of potential alternatives with no specific recommended plan. Alternatively, the Brandon Road study and ultimately the Chief's Report must be done swiftly and with a focus on recommending the best method to halt and permanently prevent Asian carp from entering Lake Michigan.
There will be difficult decisions ahead regarding management of this issue, but it is imperative that the USACE complete the Tentatively Selected Plan to help inform those decisions and publish the Chief's Report in the three-year time frame as required in the Water Resources Reform and Development Act of 2014.