Appendix 17

Transcription

Appendix 17

Appendix 17
Comment Response Matrix and Record of Consultation
Grand River Dam Authority, Pensacola Project No. 1494
Permanent Rule Curve Amendment Request – Response to Comments Received
No. Commenter(s)
Date
Comments
Response
1
Delaware County
Floodplain
Administration
March 17, 2016
GRDA appreciates the response of the Delaware County
Floodplain Administration. Its comment is noted.
2
Oklahoma Water
Resources Board
March 29, 2016
3
Oklahoma
Department of
Wildlife
Conservation
March 29, 2016
The Delaware County Floodplain has reviewed the draft Application to
the Federal Energy Regulatory Commission for Non-Capacity Related
Amendment of License for the Pensacola Project and has no comment
on, nor any objections.
We have reviewed the Application for a Rule Curve Amendment and
support the proposed request. We would like to encourage GRDA to
continue to look toward managing Grand, Hudson, and Holloway as a
“system” instead of as individual reservoirs. This would enhance
GRDA’s ability to adaptively provide a better balance for the myriad
stakeholder needs in the area.
The Oklahoma Department of Wildlife Conservation (ODWC) fully
supports the application requested by the Grand River Dam Authority
(GRDA) to amend Article 401 of its license for the Pensacola Project,
and agrees that no additional mitigation for fish and wildlife resources
be required through the remainder of the license to account for the
amendment. This support is a result of a recently finalized Interagency
Agreement between ODWC and GRDA in which mitigation for
wildlife resources (Article 411) will be addressed through adjacent-site
restoration and management, thereby negating the need to lower the
lake level to seed mudflats with millet.
4
Modoc Tribe of
Oklahoma
March 31, 2016
GRDA has elevated the level and frequency of flooding by continuing
to raise the lake elevation over the years, with FERC’s approval. The
FERC license allows GRDA to place water upon lands up to 760 feet;
the Tribe has lands above 760 feet and GRDA does not own easements
on tribal lands. The Tribe does not support even a small increase in
lake elevation when it is already being impacted on its lands on which
GRDA does not hold easements.
GRDA appreciates the response of the Oklahoma Water
Resources Board (OWRB), particularly the comment
regarding system integration among its three hydropower
projects. This is an issue that GRDA intends to explore
further in the upcoming FERC relicensing of the Pensacola
Project. ORWB’s comment is noted.
GRDA appreciates the work and engagement of ODWC
and the U.S. Fish and Wildlife Service (USFWS) in
cooperative efforts to resolve this long-standing challenge
at Grand Lake. GRDA expects this compromise to
enhance wildlife conditions in support of this permanent
amendment of the existing license. See Environmental
Report § 8.1 (Appendix 4). Although GRDA has not yet
formally presented the offsite mitigation agreement to
FERC, with a request to make several license changes
needed to implement the agreement, GRDA expects to
make this filing with FERC in the near future.
GRDA appreciates the Modoc Tribe of Oklahoma’s
review of the draft amendment application.
GRDA is seeking a license amendment that would only
allow the reservoir to be maintained at 743 feet Pensacola
Datum (PD) for a period of 1 month. This elevation is 2
feet below the flood pool, which begins at elevation 745
feet PD. The proposed amendment does not seek to raise
targeted levels of Grand Lake beyond elevation 743 feet
PD.
While GRDA does not agree with the Tribe’s belief that
implementing the amendment would result in the
placement of water on lands above GRDA’s flowage
easements, it understands the Tribe’s flooding concerns
during high-precipitation events. For this reason, GRDA
is proposing to permanently implement a Storm Adaptive
Management Plan (SAMP) as part of this amendment.
This Plan would apply whenever a significant storm event
occurs throughout the year—not merely during the August
Page 1 of 12
No. Commenter(s)
5
Modoc Tribe of
Oklahoma
Date
March 31, 2016
Comments
The Modoc Tribe does not support to operational criteria GRDA is
using to justify raising the rule curve. The Tribe has no respect for the
conclusion of the Dennis study, which “suffer from unscientific
limitations that command little confidence in this incomplete
‘academic exercise.’” The Tribe urges FERC to instead rely on the
Tetra Tech study for a realistic model of water surface elevations in
Ottawa County.
Response
through October period for which GRDA seeks to change
the rule curve. Based on the successful implementation of
a similar adaptive management plan during the variance
period of 2015, as well as during the near historical
flooding events this past December, GRDA believes that
the proposed amendment will be implemented without
adversely affecting upstream communities. See
Environmental Report §§ 3.2-3.3 (Appendix 4); Appendix
5; Appendix 10.
All three models that have been developed to analyze the
potential changes in surface water elevations due to
implementation of the requested amendment reached
substantially identical conclusions. The results of all
models indicate that the change from 741 feet PD to 743
feet PD for a four-week during the August-September
period will result in negligible changes in surface water
elevations and durations upstream of Grand Lake. The
TetraTech model, in fact, predicted the smallest change of
all the models—and certainly within the margin of error of
the model itself.
While the TetraTech model had different assumptions of
the water-surface elevations beginning at the Twin Bridges
area than the Dennis and FERC models, the assumptions
in the TetraTech model have not been substantiated. See
Appendix 5; Appendix 10.
Moreover, the events simulated in the February 2016
TetraTech report are some of the most severe highprecipitation events ever recorded in the basin. Under
such extreme (and rare) occurrences, GRDA has no
control over Project operations, as the U.S. Army Corps of
Engineers (USACE)—pursuant to its exclusive
jurisdiction under section 7 of the Flood Control Act of
1944—assumes full control of spillway releases during
flood events.
Finally, the different assumptions in the models regarding
water-surface elevations beginning at the Twin Bridges are
irrelevant during normal, day-to-day Project operations.
When GRDA operates the Project within the normal
Page 2 of 12
No. Commenter(s)
6
City of Miami
Date
April 12, 2016
Comments
The City strongly recommends that GRDA’s final application rely on
two new flood routing studies that the City commissioned from Tetra
Tech and provided to GRDA. Based on the results of the Tetra Tech
studies, it is now clear to the City that the FERC Study (and the 2014
Dennis Study) are unreliable, because they utilize faulty methodologies
and have significant data limitations.
Response
operating range of 741-44 feet PD, upstream water levels
are well within GRDA’s flowage easements upstream of
Grand Lake. The extreme events simulated in the
February 2016 TetraTech distort reality by failing to
acknowledge that during normal, everyday conditions at
Grand Lake, upstream areas are not flooded. Instead, the
TetraTech report presents a highly skewed sample of
extreme, rare events—and events in which USACE would
be spillway releases at the Project. See Environmental
Report §§ 3.2, 3.4 (Appendix 4).
The City of Miami’s position conflicts with the consensus
reached in the December 16, 2015 technical conference by
all participants—including the City, FERC staff, GRDA,
and other participants. The whole purpose of the technical
conference was to address any concerns related to the
modeling work needed to support a permanent amendment
to the Project’s rule curve. Despite being supported by
TetraTech during the technical conference, the City
adopted the consensus decision that the Dennis and
independent FERC staff models would suffice.
And yet, all along, it appears that the City has been
planning to leverage its modeling effort to block GRDA’s
amendment application. The TetraTech report at issue is
dated February 3, 2016—over 3 months ago. Although
GRDA reached out to the City numerous times since
February (including consultation regarding GRDA’s report
on the December 2015 technical report and this
amendment application), the City never apprised GRDA
that it had commissioned the TetraTech report, and it
never alerted GRDA that its consultant had reached a
different conclusion than the independent FERC staff and
Dennis models. Instead, the City ostensibly held this
report back—waiting until the last possible time to
distribute its report and announce a complete change of
position than it agreed to during the technical conference,
in a transparent attempt to disrupt this process.
GRDA believes that the Commission should not tolerate
the City’s tactics. Many parties devoted substantial time
and resources to make the December 2015 technical
Page 3 of 12
No. Commenter(s)
Date
Comments
Response
conference a success. Commission staff from both
Washington, DC and Atlanta attended the conference, as
did many other parties. For its part, GRDA’s CEO and
many members of its management and consulting teams
were present for the entire day. USACE attended to help
the parties understand the overlay of flood operations
throughout the Arkansas River Basin. Many experts were
around the table to discuss and agree upon the proper
course of action. The City’s last-minute effort to upend
the process with a “new” study report attempts to
undermine the integrity of this process and waste
significant resources that were exerted by all to make the
technical conference a successful, collaborative effort.
GRDA has worked very hard over the last several years to
build a positive working relationship with the City, and to
address issues of mutual interest in a collaborative and
cooperative manner—and to build on those successes by
addressing the more challenging and complex issues that
have caused mistrust and concerns of both parties over a
period of many years. Given the recent progress we have
made to work together, it is both disappointing and
surprising that the City would elect to engage in in this
manner to address a very important issue that is intended
to benefit the public throughout the entire region—
including the City of Miami.
Nonetheless, contrary to the City’s comment letter, the
February 2016 TetraTech report does nothing to question
the reliability of the independent FERC staff and Dennis
models. To the contrary, the TetraTech report confirms
the single most important technical question at issue in this
amendment proceeding: that changing the target level
elevation of Grand Lake from 741 feet PD to 743 feet PD
during a four-week period in August-September would
have negligible effects to water-surface elevations
upstream of Grand Lake. All three models are exactly
consistent in that conclusion—and in fact, the TetraTech
model calculates an even smaller effect than the other two
models.
Page 4 of 12
No. Commenter(s)
7
City of Miami
Date
April 12, 2016
Comments
The 2015 Tetra Tech study confirms Project-related flooding of over
12,900 acres, which are not subject to easements, and on which GRDA
has no right to increase the elevation and duration of flooding and
FERC has no right to grant a license allowing it to do so.
Response
See also GRDA’s response to Comment 5; Environmental
Report §§ 3.2, 3.4 (Appendix 4); Appendix 5; Appendix
10.
While it is true that large precipitation events have resulted
in flooding in the City of Miami and other areas upstream
of Grand Lake, the City inaccurately claims that such
flooding is attributable to the Project. In fact, the 2015
TetraTech study itself concludes that factors that have
nothing to do with the Project—such as a decrease in
agricultural operations and increases in forest and other
vegetation along the river channel—have likely
contributed to upstream flooding. The Dennis model
concluded that the numerous piers and other in-water
structures supporting roads and railroad crossings also
have contributed to such flooding. Again, these are
unrelated to the Project.
In any event, the fact that flooding does occur in upstream
areas during significant precipitation events is not relevant
in this narrow amendment proceeding. GRDA is simply
requesting that the rule curve be changed during a 10week period each summer/fall. During approximately 4
weeks of this period, target reservoir elevations for Grand
Lake will be increased from current levels of 741 feet PD
to 743 feet PD. All the models used to assess effects of
this 2-foot increase have uniformly concluded that the
change will result in negligible changes in upstream
surface water elevations, and maintaining a target
elevation of 743 feet PD will not result in flooding in
upstream areas beyond GRDA’s flowage easements.
Moreover, the acreage figure cited by the City is extreme,
having been generated by a simulation of one of the most
significant precipitation events ever experienced in the
basin—when stream stages were very high and when
reservoir levels at Grand Lake were much higher than the
target elevation of 743 feet PD, which is what GRDA is
seeking in this application. Simply stated, GRDA is not
seeking to increase even reservoir levels beyond the
normal maximum level of 744 feet PD, and the City
cannot accurately claim that any upstream flooding occurs
Page 5 of 12
No. Commenter(s)
Date
Comments
Response
when the Grand Lake targeted surface elevation is 743 feet
PD.
Finally, GRDA believes that implementation of the
proposed SAMP will go far to help manage reservoir
levels during flood operations, when USACE assumes
control of Project spillway operations. This adaptive
management and communications strategy proved very
useful during the variance period of 2015 and the near
historical flooding during December 2015.
8
City of Miami
April 12, 2016
9
City of Miami
April 12, 2016
10
City of Miami
April 12, 2016
11
Plaintiffs in City of
Miami v. GRDA and
Asbell v. GRDA
April 13, 2016
12
Miami v. GRDA and
Asbell v. GRDA
April 13, 2016
The 2016 Tetra Tech study concluded that actual water surface
elevations at the Miami gage are up to 2.9 feet higher than those
predicted in FERC’s analysis, indicating that FERC’s estimate of the
number of structures which would be subject to increased or new
flooding is based upon assumed backwater elevations that are too low
and may be incorrect. The 2016 Tetra Tech study estimates that the
Proposed Amendment would increase the area of unauthorized
flooding by up to 102 acres.
The City believes that increasing the extent of unauthorized flooding,
even by a small amount, is inequitable and inappropriate in the absence
of adequate mitigation.
Any position the City may adopt regarding the Proposed Amendment
is without prejudice to its positions in the forthcoming relicensing
proceeding on the use of comprehensive flood routing studies to assess
impacts of continued Project operations and mitigation measures to
address any flood-related impacts.
The operation and presence of Pensacola Dam is causing a backwater
effect in the area of the City of Miami, which impacts the elevation and
duration of flooding on the property for which GRDA has no flowage
easements. Therefore, the lake elevation should not be increased, as
that further increases the risk of flooding, even if just a little bit.
The requested rule curve changes the lake elevation from August 15 to
November 1, not just August 15 to September 15.
See also GRDA’s response to Comment 4 and 5;
5; Appendix 10.
See GRDA’s response to Comments 4, 5, 6 and 7; see also
5; Appendix 10.
See GRDA’s response to Comments 4, 5, 6, and 7; see
also Environmental Report §§ 3.2-3.4 (Appendix 4);
GRDA’s application recognizes that comprehensive issues
related to Project operations and management will be
addressed during the upcoming relicensing of the Project.
See GRDA’s response to Comments 4, 5, 6, and 7; see
Plaintiffs are correct, and GRDA’s application is very
clear on this point. However, comments on GRDA’s
proposal have focused on the August 15 to September 15
time period for two reasons: 1) that time frame is when the
largest variance in the rule curve occurs; and 2) that is also
the time frame when the proposed rule curve change
Page 6 of 12
No. Commenter(s)
Date
Comments
13
Miami v. GRDA and
Asbell v. GRDA
April 13, 2016
The documentation presented, a thesis prepared by Mr. Dennis, and the
subsequent study performed by FERC, are not using the latest
technology available.
14
Miami v. GRDA and
Asbell v. GRDA
April 13, 2016
The thesis and study use bathymetric data that is old and very likely
does not recognize or consider the sedimentation that has undoubtedly
occurred at the head of the reservoir. It is physically probable that this
sedimentation hump occurs at the head of the reservoir, and that
sedimentation impacts the backwater effect in Miami. Therefore, a
study which does not consider that sedimentation is not probable to be
accurate. Yet, GRDA presents it as the equivalent of a flood routing
study.
15
493 Ottawa County
citizens and
businesses
April 14, 2016
There have not been adequate easements purchased for the operation of
Pensacola Dam.
16
493 Ottawa County
citizens and
businesses
493 Ottawa County
citizens and
businesses
April 14, 2016
Any increase in the rule curve increases the risk of invasion into the
flood pool, causing a backwater effect in Ottawa County.
April 14, 2016
To date, all Courts have been consistent in rulings and opinions issued:
GRDA is responsible for the flooding due to the existence and
operation of Pensacola Dam, it has caused a quantifiable increase in
the magnitude and duration of flooding, and lands without an easement
have been flooded because of the backwater effect of Pensacola Dam.
FERC Staff
April 18, 2016
In Appendix 4: Information Supporting Amendment Application, the
ninth bullet on the list refers to a document as “FERC staff modeling
17
18
Response
would result in the highest water level at the dam (for the
period under consideration by the proposed amendment).
See Appendix 9.
GRDA notes that all three models reached the exact same
conclusion—that the proposed change in the targeted
surface elevation from 741 to 743 feet PD, during a 4week period each August-September, will have negligible
effects to upstream water levels. See GRDA’s response to
Comments 5 and 6; see also Environmental Report §§ 3.2,
3.4 (Appendix 4); Appendix 5; Appendix 10.
Mr. Dennis used the most current bathymetric and
topographic information that was available; the sources
and dates of the data sets are well-documented in Section
3.2.1 of the thesis. In particular, the lake bathymetry is
based on data collected by the OWRB in 2009, so it would
certainly represent any sedimentation that may have
occurred between construction of the dam and 2009. See
GRDA’s response to Comments 5, 6, and 13; see also
Environmental Report §§ 3.2, 3.4 (Appendix 4); Appendix
5; Appendix 9 at 3; Appendix 10.
See response to Comments 4 and 7. The variance request
does not seek to raise targeted levels of Grand Lake
beyond elevation 743 feet PD. GRDA has all rights
necessary to legally operate the project in accordance with
the proposed license amendment.
See GRDA’s response to Comments 4, 5, 6, 7, and 15; see
See GRDA’s response to Comments 4, 5, 6, 7, and 15; see
Appendix 5; Appendix 10. Resolution of alleged property
damages claims are beyond the scope of FERC’s
jurisdiction and will not be addressed in this proceeding.
As explained in GRDA’s amendment application,
however, should any major precipitation occur during the
variance period, its proposed SAMP would help address
concerns related to high water conditions upstream of
Grand Lake.
GRDA has revised its final application consistent with this
comment.
Page 7 of 12
No. Commenter(s)
Date
19
FERC Staff
April 18, 2016
20
FERC Staff
April 18, 2016
21
FERC Staff
April 18, 2016
22
FERC Staff
April 18, 2016
Comments
analysis.” That document should be referred to as “FERC staff
independent analysis.”
FERC staff has provided comments on GRDA’s proposed SAMP in
track changes.
As approved in the 2015 order, GRDA would implement the Drought
Adaptive Management Plan (DAMP) if water levels in Grand Lake fall
below the elevations on the temporary rule curve as the result of a
severe to exceptional regional drought as identified using information
from the U.S. Drought Monitor. In the draft application, GRDA
appears to implement the DAMP by a determination of a severe to
significant drought alone, without reference to water levels. This
change might cause actions under the DAMP to be taken prematurely.
Please explain why GRDA is not using water levels, in part, to trigger
implementation of the DAMP or add water levels as a trigger for
implementing the DAMP. Also, please explain the use of the term
“significant drought” when referring to the Drought Monitor. It
appears you should be using the term “exceptional” which is the
highest Drought Monitor category.
As approved in the 2015 order, once the DAMP was implemented,
GRDA would make decisions on hourly and daily release rates using
input from the same entities participating in the weekly
teleconferences. In the draft application, it is not clear that GRDA
would use input from these entities. Please address this difference, or
modify the relevant text to clarify that input from the listed entities
would be used in decisions regarding release rates under the DAMP.
Section IV: The environmental analysis in the draft application
indicates that the scope of the application is the same as GRDA’s 2015
temporary variance. GRDA then says no further studies are necessary
and that relevant existing information including materials prepared by
GRDA for the 2015 application appears in Appendix 4. In Appendix 4
of the draft application, GRDA lists the information that would be
included in that appendix of its final application. GRDA needs to
include in its final application a discussion and analysis of the
Response
GRDA has adopted all of the proposed changes submitted
by Commission staff, with one exception. One change
seemed to suggest that GRDA controls reservoir
operations during a flood event, and that USACE’s role is
only advisory. Under section 7 of the Flood Control Act
of 1944, USACE has exclusive jurisdiction for flood
control operations at the Project. For this reason, GRDA
retained language in the SAMP that recognized USACE’s
exclusive jurisdiction to manage reservoir levels and
operations during flood events.
GRDA believes it prudent to implement the DAMP
whenever a severe to exceptional regional drought occurs
in the Project basin, even before Grand Lake levels may be
approaching the target elevations. Bringing the parties
together to discuss drought issues—early in the drought—
may help identify strategies to prepare for (and possibly
minimize) changes in Project operations as the drought
intensifies.
With regard to the proper drought category, GRDA has
changed the DAMP to clarify that it applies during any
drought in the range of severe (D2) to exceptional (D4),
consistent with the Commission’s 2015 variance order.
The DAMP in the final application has been revised to
clarify that releases will be based upon input received
during the weekly teleconferences.
In response to Commission staff’s comment, GRDA has
prepared an entirely new Environmental Report supporting
this amendment application, and which includes the
additional information requested by staff. The new
Environmental Report appears in Appendix 4.
Page 8 of 12
No. Commenter(s)
Date
23
FERC Staff
April 18, 2016
24
FERC Staff
April 18, 2016
Comments
differences in possible environmental effects between last year’s
temporary variance and GRDA’s proposed permanent, multi-year
change. GRDA should discuss and analyze any such differences for
each major resource area including differences that could occur in
individual years and identification, discussion, and analysis of
cumulative effects.
In your draft application, you say a new water quality certificate is not
needed for the proposed rule curve change. Please consult with the
Oklahoma Department of Environmental Quality to determine whether
or not a new water quality certificate is needed for this amendment
application.
In the 2015 order, staff found that a temporary amendment of the rule
curve would not cause any significant effects to cultural/historic
resources. However, in support of a request for a permanent
amendment and under the requirements of Section 106 of the National
Historic Preservation Act, GRDA should consult with Oklahoma
SHPO to obtain their concurrence with the proposed amendment’s
Area of Potential Effect and any potential effects to historic properties.
Also, GRDA should consult with any Native American tribes to obtain
their comments on the proposed amendment’s effects. We note that
the Modoc tribe has already raised objections to the permanent rule
curve amendment. If needed, GRDA can ask to be designated the
Commission’s non-federal representative for the purposes of
conducting initial consultation with the Oklahoma SHPO and tribes for
this amendment.
Response
After consulting with the Oklahoma Department of
Environmental Quality (ODEQ) on this matter, GRDA
filed an application for a water quality certificate with
ODEQ on April 14, 2016. GRDA has requested expedited
consideration of its application. ODEQ issued public
notice of the application, which establishes a 30-day
public comment period ending June 8, 2016. See
Appendix 15. GRDA has updated its FERC application to
note these recent developments.
GRDA has consulted with the Oklahoma State Historic
Preservation Office (SHPO) as requested by Commission
staff. As explained in Comment 31 below, SHPO
requested that the SAMP and DAMP be expanded to
include SHPO as a consulting agency, and to include a
provision to address historic properties and burial sites that
may be affected during implementation of the plans. The
final plans included in this application contain the
provisions requested by SHPO.
As to consultation with federally recognized tribes, GRDA
notes that it provided a draft application for review and
comment to the following:
•
•
•
•
•
•
•
•
•
•
Eastern Shawnee Tribe of Oklahoma
Miami Tribe of Oklahoma
Modoc Tribe of Oklahoma
Peoria Tribe of Oklahoma
Ottawa Tribe of Oklahoma
Quapaw Tribe of Oklahoma
Shawnee Tribe
Wyandotte Tribe of Oklahoma
Delaware Tribe of Indians
Wichita and Affiliated Tribes
Page 9 of 12
No. Commenter(s)
Date
25
FERC Staff
April 18, 2016
26
FERC Staff
April 18, 2016
27
FERC Staff
April 18, 2016
28
U.S. Fish and
Wildlife Service
(USFWS)
April 21, 2016
29
USFWS
April 21, 2016
30
USFWS
April 21, 2016
Comments
Please include documentation of consultation with the U.S. Fish and
Wildlife Service identifying specific actions that may be required
under the Endangered Species Act in the processing of a permanent
change to the project rule curve. Federally-listed species in the project
area that should be considered include the Neosho mucket, Neosho
madtom, Ozark cavefish, and gray bat. In addition, please discuss
whether any new endangered or threatened species have been
identified in the project area and the results of your discussions with
FWS regarding those species.
The Vessel Aground log submitted in the 2015 application should be
updated to include all vessel groundings since that filing (i.e., all vessel
groundings from 2013 until the date of the application).
Section 2.1.1 of the 2015 Environmental Report Supplement should be
updated to reflect new vessel grounding information collected since it
was filed on August 10, 2015 (i.e., the Supplement should discuss any
patterns in vessel groundings during the 2015 variance period in
comparison to prior years).
The Service supports the proposed rule curve change, but has concerns
about the related effects of the rule curve change for mitigation
incorporated in Article 411, compliance with Article 411 and
accomplishing the mitigation that was intended for that license article.
The proposed change would limit or reduce mitigation for an article
that has achieved very limited mitigation. We strongly support the
proposed adjacent site mitigation restoring upland and wetland habitat
near the upstream portion of Grand Lake. We suggest that additional
mitigation be incorporated into the next license to compensate for the
limited mitigation implemented in the current license.
We are pleased to see the agreement between GRDA and ODWC
signed earlier this year and support the proposed development and
management of wetlands and wildlife habitat on GRDA lands. We
have some concerns related to the GRDA/ODWC agreement. We do
not believe that the Article 411 funds were intended to fund staff or
positions and such use of funds may not comply with conditions in the
article. We believe the funds were intended to maximize on the
ground mitigation and management of the created habitat should be
considered a long term obligation funded by GRDA.
We previously provided comments for the potential effects on listed
Response
GRDA has included documentation of this consultation in
Appendix 17. Only the Modoc Tribe of Oklahoma has
objected to this application.
GRDA has included documentation of its consultation
with the U.S. Fish and Wildlife Service (USFWS) in
Appendix 17 to its amendment application. USFWS has
concluded that the amendment “would not adversely affect
any listed species.” Please see GRDA’s response to
Comment 30.
Please see GRDA’s response to Comment 22. The new
Environmental Report contains an updated vessel aground
log. The new Environmental Report appears in Appendix
4.
Please see GRDA’s response to Comment 26.
USFWS’s suggestion is noted. With regard to USFWS’s
comments on Article 411, please see GRDA’s response to
Comment 3.
Please see GRDA’s response to Comment 3.
GRDA appreciates the USFWS’s support for the
Page 10 of 12
No. Commenter(s)
31
32
SHPO
SHPO
Date
April 22, 2016
May 2, 2016
Comments
Response
species related to the temporary variance last summer. The proposed
rule curve raises water levels in August-October and any additional
risk of flooding Beaver Dam Cave is not an issue because the listed
bats are not using the cave at that time. We agreed that the variance
would not adversely affect any listed species and that would also apply
for extending that variance through the end of the current license.
The SAMP and DAMP do not include provisions for the management
of historic properties (including archaeological sites) located along
shorelines and in the vicinity of shorelines and are thus impacted by
the changes in reservoir elevations. Not only are historic properties
affected by fluctuations in the water levels but archaeological survey
reports that have been prepared for GRDA projects and submitted to
SHPO have documented looting and vandalism of shoreline
archaeological sites associated with reservoir recreation activities.
amendment request and supports its conclusion that the
amendment is not likely to adversely affect any federally
listed species.
We are unable to complete review of your project without the
following additional information:
(1) Inclusion of a historic properties management plan for the
protection and mitigation of historic resources in the application to
amend the rule curve, SAMP, and DAMP.
(2) Contact list: SHPO should be included in the contact list for the
SAMP and DAMP.
After reviewing the information from the 2015 GRDA Environmental
Assessment on archaeological and historical properties, we have
concerns that the State Archaeologist/OAS was left out in paragraph
one. The OAS is the main repository for all the archaeological site
records and reports. The issue of the potential for burials to be
discovered and the state laws protecting them was not mentioned in
paragraph one or in sections 11.2 and 11.3 where the idea that
archaeological sites are protected when inundated is incorrect. Higher
levels of water do not protect archaeological sites or other historic
resources, it damages and destroys them. That’s why GRDA needs to
have a historic properties management plan (HPMP) in place to
address how they mitigate these adverse effects to the historic
properties when the water levels change.
GRDA has revised its SAMP and DAMP to include
provisions for consulting with the SHPO when the plans
are in effect to protect known burial sites and
archaeological sites or other cultural resources that are
listed in or eligible for listing in the National Register of
Historic Places. GRDA has added SHPO to the contact
list for these plans.
GRDA has revised the DAMP and SAMP to address
SHPO’s comments.
GRDA will be preparing an HPMP as part of the
upcoming relicensing and looks forward to working with
the SHPO in that effort. In the event consultation is
needed as provided in the DAMP or SAMP, the HPMP
currently in place for GRDA’s Markham Ferry Project will
provide a framework for SHPO and GRDA to address any
effects to historic properties.
This brings me to the revisions submitted for the storm and drought
adaptive management plans. It would be difficult and stressful to craft
a HPMP in the middle of an event or after some sort of storm or
drought event occurs. So, I recommend that GRDA develop an HPMP
to have in place for the final storm and drought plans instead of
Page 11 of 12
No. Commenter(s)
Date
Comments
Response
waiting until an event happens and it’s too late to do anything. Below
are my comments on the draft revisions:
Storm Plan
Page 2-1, Background, include the State Archaeologist/OAS as a
consulting party with the SHPO.
Page 2-2, Historic Properties, please include the State
Archaeologist/OAS as a consulting party with the SHPO.
Include a provision for the potential of burials to be discovered and the
state laws protecting burials and GRDA’s plan for when this happens.
Drought Plan
Please include the State Archaeologist/OAS as a consulting party with
the SHPO
Include a provision for the potential of burials to be discovered and the
state laws protecting burials and GRDAs plan for when this happens.
In the contact list, please include “Oklahoma” with State Historic
Preservation Office.
Page 12 of 12
Draft Application Distributed for Comment
(with Appendices 1-3 only)
20160315-5161 FERC PDF (Unofficial) 3/15/2016 4:32:29 PM
Daniel S. Sullivan
General Manager/Chief Executive Officer
March 15, 2016
Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Re:
Pensacola Project No. 1494;
Draft Application for Non-Capacity Related Amendment of License
and Request for Waiver of 60-day Comment Period
Dear Secretary Bose:
The Grand River Dam Authority (GRDA) is pleased to file with the Federal Energy Regulatory
Commission (Commission) the enclosed draft Application for Non-Capacity Related
Amendment of License (Draft Application) for the Pensacola Project, No. 1494 (Project). As
detailed in the Draft Application, GRDA seeks to change the rule curve requirement under
Article 401 during the August 15 through October 31 period each year through the remaining
license term, for purposes of promoting public safety, water quality, and recreational
enhancement through a peak public recreation period of the year. This Draft Application seeks a
permanent change to the Article 401 rule curve, and eliminates the need for GRDA to seek
yearly variance requests to rule curve requirements for the duration of the license.
Section 4.38(a)(7) of the Commission’s regulations, 18 C.F.R. § 4.38(a)(7), requires that before
filing a non-capacity related amendment application, an applicant must provide copies of the
draft application to federal and state resource agencies, Indian tribes, local governmental
authorities, and interested members of the public and allow them at least 60 days to comment on
the proposed amendment. Concurrent with today’s filing, GRDA is circulating this Draft
Application to stakeholders listed on the attached Distribution List. With this letter, GRDA
requests that the Commission waive the 60-day comment period required under Section
4.38(a)(7) and instead allow a 30-day comment period on the Draft Application. Under GRDA’s
proposal, all written comments on the Draft Application would be due by April 14, 2016.
This requested reduction in the comment period is warranted for several reasons. GRDA has
sought temporary variances to the Article 401 rule curve many times in prior years, and the
Commission analyzed and granted a variance as recently as last year. Thus, Commission staff,
resource agencies, tribes and stakeholders are all very familiar with the scope of GRDA’s
request, as GRDA has consulted extensively with all parties on this issue many times over the
years. As recently as December 2015, GRDA, Commission staff, resource agencies, local
governmental entities, and Indian tribes held a technical conference on modeling needs to sustain
this proposal.
Moreover, the environmental scope of this Draft Application is well established in the record.
The proposed changes sought in the Draft Application are essentially identical to GRDA’s
temporary variance request from 2015. Thus, the same environmental studies, technical
modeling work, and other information that supported last year’s variance are relevant here, and
all parties are very familiar with this record.
Finally, a 30-day comment period will promote administrative economy in resolving a longstanding issue at the Project. Because the requested amendment to Article 401 would affect
levels at Grand Lake O’ the Cherokees each year beginning on August 16, a 30-day comment
period increases the likelihood of Commission action before August 16, 2016—thus obviating
the need for a separate temporary variance for 2016.
GRDA greatly appreciates the time and effort of Commission staff, resource agencies, Indian
tribes, local governmental authorities, and other stakeholders in participating in consultation for
the many variance requests to rule curve requirements over the years. The technical conference
held in December 2015 on this matter was particularly helpful in resolving issues and helping to
identify a path forward that would resolve the Article 401 requirements during the remaining
years of the existing license. GRDA believes that if granted by the Commission, the change in
the rule curve under this Draft Application will result in significant improvements to public
recreation and safety during the peak recreation period each year, and eliminate the need for
stakeholders to consult yearly on temporary variances to the rule curve for the remainder of the
license term.
Should you have any questions related to this Application, please contact Nathan Reese on my
staff at 918-610-9726 or by email at [email protected].
Sincerely,
Daniel S. Sullivan
CEO and General Manager
cc: Attached Distribution List
Attachments
Distribution List
Bureau of Indian Affairs
Cherokee Nation
P.O. Box 948
Tahlequah, Oklahoma 74465
Eastern Shawnee Tribe of Oklahoma
P.O. Box 350
Seneca, Mo 64865
Miami Tribe of Oklahoma
P.O. Box 1326
Miami, OK 74354
505 G Southeast
Miami, OK 74354
Mr. Josh Johnston
N.E. Regional Fisheries Biologists
Oklahoma Department of Wildlife Conservation
P.O. Box 1201
Jenks, OK 74037
Mosby Halterman
Bureau of Indian Affairs
2100 W Peak Blvd
Muskogee , OK 74401
Mr. Terry Hallaeuer
Delaware County Department of Environmental Quality
2096 South Main Street
Grove, Oklahoma 74344
Ms. Cynthia Stacy
Peoria Tribe of Oklahoma
P.O. Box 1527
Miami, OK 74355
Ms. Melvena Heisch
Deputy State Historic Preservation Officer
Oklahoma Historical Society
800 Nazih Zuhdi Drive
Oklahoma City, Oklahoma 73105-7917
Ms. Rosanna Sheppard
Ottawa Tribe of Oklahoma
13 South 69A
P.O. Box 110
Miami , OK 74355
Ms. Kathleen A. Welch
Environmental Assistant
Wyandotte Tribe of OK
64700 E Hwy 60
Wyandotte, Ok 74370
Mr. Everett Bandy
Quapaw Tribe of Oklahoma
P.O. Box 765
Quapaw, OK 74363
Michael Payton
Ottawa County Floodplain Administrator
102 East Central – Suite 202
Miami, Ok 74354
Shawnee Tribe
P.O. Box 189
Miami, OK 74355
Mr. Jeff Southwick
Oklahoma Corporation Commission
2101 North Lincoln Boulevard
Oklahoma City OK 73105
Mr. Kevin Stubbs
Field Supervisor
U. S. Fish and Wildlife Service
9014 E 21st Street
Tulsa, Oklahoma 74129-1428
Dr. Robert Brooks
State Archeologist
Oklahoma Archeological Survey
111 East Chesapeake - Bldg. 134
Norman, Oklahoma 73019-0575
Mr. Andrew Commer
Chief
U. S. Army Corps of Engineers, Tulsa District
Attn: CESWT - PE -R (Regulatory Branch)
1645 S 101 East Ave
Tulsa, Oklahoma 74128-4609
Mr. Robert Real
Delaware County Floodplain Administrator
P.O. Drawer 550
Jay, Ok 74346-0550
Distribution List
Mr. Luke Tallant
Office of State Fire Marshal
2401 N W 23rd Street, Suite 4
Oklahoma City, OK 73107
Mr. Morris Bluejacket
Craig County Flood Plain Manager
P.O. Box 397
Vinita, OK 74301
Flood Plain Manager
Mayes County
1 Court Place Suite 140
Pryor, OK 74361
Oklahoma Tourism & Recreation Dept.
120 N. Robinson 6th Floor
Ms. Kris Marek
Oklahoma Tourism and Recreation Dept.
State Parks & Resorts
120 N. Robinson 6th Floor
Mr. Derek Smithee
Water Quality Division
Oklahoma Water Resources Board
3800 North Classen Boulevard
Ms. Elena Jigoulina
Oklahoma Department of Environmental Quality
P.O. Box 1677
Oklahoma City , OK 73101-1677
Caddo Nation
P.O. Box 487
Binger, OK 73009
Seneca-Cayuga Nation
P.O. Box 453220
Grove, OK 74345-3220
Muscogee Nation
P.O. Box 580
Okmulgee, OK 74447
Ms. Lisa Stopp
Preservation Office
United Keetoowah Band of Cherokees
P.O. Box 746
Tahlequah, OK 74665
Wichita and Affiliated Tribes
P.O. Box 729
Anadarko, OK 73005
U.S. Bureau of Indian Affairs
Eastern Oklahoma Regional Office
101 North 5th St.
Muskogee, OK 74401-6206
Mr. Barry Bolton
Chief of Fisheries Division
P O Box 53465
Honorable Chief Chester Brooks
Delaware Tribe of Indians
170 N. E. Barbara
Bartlesville, OK 74006
Mr. Farris Barker
Osage Nation Historic Preservation Office
1449 Main Street
Pawhuska, OK 74056
Mr. Brian Forrester
Council Member
NE Ward 1
P.O. Box 1288
Miami, OK 74355-1288
Mr. Doug Weston
Council Member
NE Ward 2
P.O. Box 1288
Miami, OK 74355-1288
Mr. Neal Johnson
Council Member
SW Ward 3
P.O. Box 1288
Miami, OK 74355-1288
Joe Sharbutt
Council Member
SE Ward 4
P.O. Box 1288
Miami, OK 74355-1288
Distribution List
Chairman John Clark
Ottawa County Commissioners
102 E Central Ave Suite 202
Miami, OK 74354
Mayor Rudy Schultz
City of Miami
P.O. Box 1288
Miami, OK 74355
Gary Wyrick
Ottawa County Commissioner
District #2
Miami, OK 74354
The Honorable Ben Sherrer
House of Representatives
2300 N Lincoln Blvd Room 500
Russell Earls
Ottawa County Commissioner
District #3
Miami, OK 74354
The Honorable James Mountain Inhofe
United States Senate
205 Russell Senate Office Building
Washington, DC 20515
The Honorable Charles Wyrick
Oklahoma State Senate
Dr. J. Mark Osborn, MD
301 2nd Ave SW
Miami, OK 74354
The Honorable Doug Cox
The Honorable Chuck Hoskin
2300 North Lincoln Boulevard
Room 509
Director Michele Bolton
Miami Area Chamber of Commerce
103 East Central Ave Suite 100
Miami, OK 74354
Mr. Dean Kruithof
City Manager
City Of Miami
P.O. Box 1288
Miami, OK 74355
The Honorable Mary Fallin
Governor of Oklahoma
2300 N Lincoln Blvd Suite 212
The Honorable James Lankford
United States Senate
B40C Dirksen Senate Office Building
The Honorable Michael Teague
Secretary of Energy and Environment
100 N. Broadway, Suite 2350
The Honorable Marty Quinn
2300 N Lincoln Blvd. Room 528B
The Honorable Wayne Shaw
2300 N Lincoln Blvd Rm 325
The Honorable Jim Bridenstine
216 Cannon House Office Building
The Honorable Markwayne Mullin
1113 Longworth House Office Building
The Honorable Frank Lucas
2405 Rayburn HOB
Distribution List
The Honorable Ben Loring
2300 N Lincoln Blvd
Mr. Lance Phillips
Mr. Richard Hatcher
Director
P O Box 53465
Mr. Monty Porter
Ms. Jonna Polk
U. S. Fish and Wildlife Service
9014 E 21st Street
Tulsa, OK 74129-1428
Ms. Beth Wilhelm
Mr. William Cauthron
Mr. Johny Jantzen
County Floodplain Administrator
Mayes County
1 Court Place, Suite 140
Pryor, OK 74361
Mr. William Chatron
U. S. Army Corps of Engineers
1645 S 101 East Ave
Tulsa, OK 74128-4609
Mr. Chuck Childs
Director of Community Development
P.O. Box 1288
Miami, OK 74355
Mr. Ed Rossman
1645 S 101 East Ave
Tulsa, OK 74128-4609
Mr. Greg Estep
1645 S 101 East Ave
Tulsa, OK 74128-4609
Mr. Jack Dalrymple
54297 E 75 Rd
Miami, OK 74354-3020
Ms. Jennifer Aranda
1645 S 101 East Ave
Tulsa, OK 74128-4609
Mr. Matt Rollins
Mr. Scott Henderson
U.S. Army Corps of Engineers
1645 S 101 East Ave
Tulsa, OK 74128-4609
Mr. Steve Nolan
1645 S 101 East Ave
Tulsa, OK 74128-4609
Mr. Terry Rupe
1645 S 101 East Ave
Tulsa, OK 74128-4609
Ms. Tonya Dunn
1645 S 101 East Ave
Tulsa, OK 74128-4609
Mr. David Williams
1645 S 101 East Ave
Tulsa, OK 74128-4609
Distribution List
Mr. Brad Johnston
P.O. Box 53465
Mr. Miroslav Kurka
Mead & Hunt
1616 East 15th Street
Tulsa, OK 74120
Mr. Charles Kerns
Oklahoma Office of Emergency Management
P.O. Box 53365
Oklahoma City, OK 73152-3365
Mr. Shawn Puzen
Mead & Hunt
1616 East 15th Street
Tulsa, OK 74120
Ms. Glenda Longan
Director of Emergency
City of Miami
P.O. Box 1288
Miami, OK 74355
Ms. Nicole McGavock
National Weather Service
10159 E 11th St. Suite 300
Tulsa, OK 74128
Ms. Judy Francisco
City of Miami
P.O. Box 1288
Miami, OK 74355
Mr. Ronnie Cline
City of Miami
P.O. Box 1288
Miami, OK 74355
Mr. Doug Weston
Ward 2
City of Miami
P.O. Box 1288
Miami, OK 74355
Mr. Joe Dan Morgan
Ottawa County Floodplain Administrator
102 E Central, Suite 104b
Miami, OK 74354
Mr. Mike Abate
1645 S 101 East Ave
Tulsa, OK 74128-4609
Ms. Eva Zaki-Delitt
1645 S 101st East Ave
Tulsa, OK 74128-4609
Mr. Larry Bork
Goodell, Stratton, Edmonds & Palmer
515 South Kansas Avenue
Topeka, KS 66003-3999
Mr. James Paul
National Weather Service
10159 E 11th St Suite 300
Tulsa, OK 74128
Mr. Dai Thomas
Tetra Tech
3801 Automation Way Suite 100
Fort Collins, CO 80525
Mr. Bob Mussetter
Tetra Tech
3801 Automation Way Suite 100
Grand River Dam Authority
Pensacola Project
FERC Project No. 1494
Comment Draft
Application for Non-Capacity Related
Amendment of License
March 15, 2016
Pensacola Project
FERC No. 1494
TABLE OF CONTENTS
Initial Statement ...............................................................................................................................1
Subscription and Verification ..........................................................................................................8
Appendix 1: Detailed Description of Proposed License Amendment
Appendix 2: Storm Adaptive Management Plan
Appendix 3: Drought Adaptive Management Plan
Appendix 4: Information Supporting Amendment Application
Appendix 5: Grand River Dam Authority Enabling Act
Appendix 6: Request to Reduce Public Comment Period for Draft Amendment Application
BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Application for Non-Capacity Related Amendment of License
18 C.F.R. §§ 4.32, 4.201
(a) Initial Statement
1.
The Grand River Dam Authority (GRDA) applies to the Federal Energy
Regulatory Commission (Commission) for a non-capacity related amendment for
the Pensacola Project No. 1494 (Project).
2.
The exact name, business address, and telephone number of the applicant are:
Administrative Headquarters
226 W Dwain Willis Avenue
P.O. Box 409
Vinita, OK 74301
918-256-5545
3.
The applicant is an agency of the State of Oklahoma and a municipality within the
meaning of Section 3(7) of the Federal Power Act, 16 U.S.C. § 796(7), and
licensee for the water power project, designated as Project No. 1494 in the records
of the Federal Energy Regulatory Commission, issued on the 24th day of April,
1992. Grand River Dam Auth., 59 FERC ¶ 62,073 (1992) (issuing a new 30-year
license to GRDA for the Project).
4.
The amendments of license proposed and the reasons why the proposed are
necessary, are:
With this amendment application, GRDA seeks to change the rule curve
applicable to the Project under Article 401 of the license. The current rule curve
requirements were established by Commission order dated December 3, 1996.
1
Grand River Dam Auth., 77 FERC ¶ 61,251 (1992). Specifically, GRDA
proposes to change the rule curve for the period August 15 through October 31
each year, consistent with the Commission’s temporary variance approval order
dated August 14, 2015. Grand River Dam Auth., 152 FERC ¶ 61,129 (2015). As
part of this proposed amendment, GRDA also seeks the Commission’s approval
of a Storm Adaptive Management Plan and Drought Adaptive Management Plan.
GRDA seeks to amend Article 401 to read as follows:
Article 401. The Licensee shall operate the Pensacola Project to
control fluctuations of the reservoir surface elevation for the
protection of fish, wildlife, and recreational resources associated
with the Grand Lake O’ the Cherokees (Grand Lake) reservoir.
The Licensee shall act, to the extent practicable (except as
provided by the Storm Adaptive Management Plan or the Drought
Adaptive Management Plan, or as necessary for the Department of
the Army, Tulsa District, Corps of Engineers to provide flood
protection in the Grand (Neosho) River), to maintain the reservoir
surface elevations, as measured immediately upstream of the
project dam. These target reservoir surface elevations are as
follows:
Reservoir Elevation, feet
Period
(Pensacola Datum)
May 01 – May 31 .........................Raise elevation from 742 to 744
Jun 01 – Jul 31 .............................Maintain elevation at 744
Aug 01 – Aug 15 ..........................Lower elevation from 744 to 743
Aug 16 – Sep 15...........................Maintain elevation at 743
Sep 16 – Sep 30............................Lower elevation from 743 to 742
Oct 1 – Apr 30..............................Maintain elevation at 742
Upon the forecast of any major precipitation event within the
Grand/Neosho River basin that may result in high water conditions
upstream or downstream of Grand Lake, the Licensee shall
implement the Storm Adaptive Management Plan through the
duration of the event. The Licensee shall institute the Drought
Adaptive Management Plan during any period in which the
National Drought Mitigation Center’s U.S. Drought Monitor has
identified a severe or exceptional drought within the Grand/Neosho
River basin.
2
A complete explanation of GRDA’s proposed amendment appears in
Appendix 1 to this Application. The proposed Storm Adaptive Management Plan
appears in Appendix 2, and the proposed Drought Adaptive Management Plan
appears in Appendix 3.
GRDA seeks this application to reduce the risk of vessel groundings at
Grand Lake in late summer, improve recreation during a peak recreation period,
better balance competing stakeholder interests, and provide for additional storage
that can assist in managing dissolved oxygen levels in the Grand River
downstream of the Project (as well as downstream of GRDA’s Markham Ferry
Project No. 2183), which is directly downstream of the Project. Existing studies
and other information that analyze the effects of this proposal appear in Appendix
4 to this Application.
GRDA recognizes that this application is being filed only a few months
before the proposed changes to the Article 401 rule curve would take effect
beginning August 16, 2016. In the event that the Federal Energy Regulatory
Commission’s (Commission or FERC) determination of this application extends
beyond that date, GRDA seeks herein a temporary variance to the Article 401 rule
curve requirements during the period August 16, 2016 through October 31, 2016.
This temporary variance would consist of the following elements:
1.
Maintain Grand Lake levels as proposed in this application (which
is identical to what the Commission approved as a temporary variance in 2015);
2.
Implement the Storm Adaptive Management Plan in Appendix 2
during the variance period; and
3
3.
Implement the Drought Adaptive Management Plan in Appendix 3
during the variance period.
5.
(i) The statutory or regulatory requirements of the state in which the project
would be located that affect the project as proposed with respect to bed and banks
and to the appropriation, diversion, and use of water for power purposes are:

GRDA’s Enabling Act, 82 O.S. § 861 et seq. provides GRDA the right,
privilege, and authority to control, store, preserve, and distribute the
waters of the Grand River and its tributaries for such purposes as
hydropower, irrigation, raw water supply, and other useful purposes. It
further allows GRDA to make rules and regulations governing the use of
the shoreline and lakes created by the hydropower facilities. With respect
to the right to the appropriation, diversion, and use of water for power
purposes, the Enabling Act expressly grants GRDA statutory authority
“[t]o control, store and preserve . . . the waters of Grand River and its
tributaries, for any useful purpose, and to use, distribute and sell the same
within the boundaries of the district.” A copy of GRDA’s Enabling Act is
included as Appendix 5 to this Application.

Under section 401 of the Clean Water Act (CWA), a federal license or
permit “which may result in any discharge into the navigable waters”
triggers water quality certification by the State of Oklahoma. 33 U.S.C.
§ 1341(a).
(ii) The steps which the applicant has taken or plans to take to comply with each
of the laws cited above are:
4

GRDA maintains compliance with its Enabling Act by operating and
maintaining the Project in accordance with the Commission-issued
license. As a means to protect public safety, promote public recreation
during a peak period of the year, and address water quality downstream,
GRDA has concluded that the instant Application is necessary to meet its
statutory obligations under the Enabling Act.

With regard to water quality certification under CWA section 401, the
State of Oklahoma issued its certification as part of the most recent
relicensing of the Project. Grand River Dam Auth., 59 FERC ¶ 62,073, at
p. 63,235 (1992). Because the instant Application will not result in “a new
or greater discharge” from the Project as previously certified by the State,
water quality certification is not applicable. S.C. Elec. & Gas Co., 109
FERC ¶ 61,099 at PP 16-17 (2004); see also North Carolina. v. FERC,
112 F.3d 1175 (D.C. Cir. 1997) (holding that state water quality
certification is not required for a water withdrawal); Idaho Power Co., 96
FERC ¶ 61,303 (2001) (holding that a suspension of flow requirements
does not require state water quality certification). In the instant
Application, GRDA does not seek changes to releases of flows beyond the
normal operating range of the Project.
(b) Required exhibits for capacity related amendments.
Because this Application is for a non-capacity related amendment, this section does not
apply.
5
(c) Required exhibits for non-capacity related amendments.
This Application seeks only to amend Article 401 of the license; no exhibits to the
Project license require revision in light of the changes proposed herein.
(d) Consultation and waiver.
As required under section 4.38(a)(7) of the Commission’s regulations, 18 C.F.R.
§ 4.38(a)(7), GRDA distributed a draft application to federal and state resource agencies,
Indian tribes, local governmental authorities, and interested members of the public on
March 15, 2016. Although section 4.38(a)(7) affords a 60-day public comment period for
non-capacity related amendment applications such as this, GRDA has asked the
Commission to waive this requirement, and instead approve a 30-day comment period.
As explained in GRDA’s request to the Commission (which appears in Appendix 6),
issues related to the Article 401 rule curve requirements have been analyzed and
addressed by the Commission, resource agencies and stakeholders many times in the past.
As such, the public comment period is not expected to produce any significant new issue
relevant to this application. Moreover, an abbreviated comment period will promote
administrative economy by giving the Commission more time to rule on this application
before the new rule curve requirements would begin on August 16, 2016—thus avoiding
the need for the Commission to rule on a separate variance request for 2016. For these
reasons, GRDA seeks written comments from agencies and stakeholders by April 14,
2016. In the event the Commission does not grant GRDA’s request for an abbreviated
comment period, GRDA will notify all entities on the Distribution List that comments are
due within 60-days, i.e., by May 16, 2016. Once the comment period expires, GRDA
will prepare its final amendment application, incorporating commenters’
6
recommendations, as appropriate. The final application will contain a complete record of
consultation, including GRDA’s response to each comment received.
7
Subscription and Verification
This Application for Non-Capacity Related Amendment of License is executed in the
STATE OF:
Oklahoma
COUNTY OF: Tulsa
by: Daniel S. Sullivan
CEO and General Manager
9933 E. 16th Street
Tulsa, OK 74128
Daniel S. Sullivan, being duly sworn, deposes and says that the contents of this
application are true to the best of his knowledge or belief. The undersigned applicant has
signed this application this ______ day of ____, 2016.
GRAND RIVER DAM AUTHORITY
By:
_________________________
Daniel S. Sullivan
Subscribed and sworn to before me, a Notary Public of the State of Oklahoma this _____
day of ____, 2016.
/SEAL/
________________________
Notary Public No. ______________
My Commission expires: _______________
8
Appendix 1
Detailed Description of Proposed License Amendment
Pensacola Project, FERC No. 1494
Detailed Description of Proposed License Amendment
I.
Background
Currently, Article 401 of the Federal Energy Regulatory Commission (Commission or FERC)
license for the Pensacola Project No. 1494 (Project) provides seasonal target elevations for
Grand Lake O’ the Cherokees, the reservoir associated with the Project and created by Pensacola
Dam, and which Grand River Dam Authority (GRDA) manages pursuant to the FERC license.
As amended by the Commission most recently in 1996, Article 401 presently provides:
Article 401. The Licensee shall operate the Pensacola Project to control
fluctuations of the reservoir surface elevation for the protection of fish, wildlife,
and recreational resources associated with the Grand Lake O’ the Cherokees
(Grand Lake) reservoir. The Licensee shall act, to the extent practicable (except as
necessary for the Department of the Army, Tulsa District, Corps of Engineers to
provide flood protection in the Grand (Neosho) River), to maintain the reservoir
surface elevations, as measured immediately upstream of the project dam. These
target reservoir surface elevations are as follows:
Period
(Pensacola Datum)
May 01 – May 31 ............................................... Raise elevation from 742 to 744
Jun 01 – Jul 31 ................................................... Maintain elevation at 744
Aug 01 – Aug 15 ................................................ Lower elevation from 744 to 743
Aug 16 – Sep 15 ................................................. Lower elevation from 743 to 741
Sep 01 – Oct 15 .................................................. Maintain elevation at 741
Oct 16 – Oct 31 .................................................. Raise elevation from 741 to 742
Nov 01 – Apr 30 ................................................ Maintain elevation at 742
Grand River Dam Auth., 59 FERC ¶ 62,073, at p. 63,227 (1992) (including Article 401 in the
new license); Grand River Dam Auth., 77 FERC ¶ 61,251, at p. 61,2005 (1996) (amending
Article 401).
When implementing Article 401 in previous years, GRDA on a number of occasions has
requested a temporary variance of the Article 401 rule curve target elevations, to maintain higher
reservoir levels during the August through October time period—primarily for the purpose of
retaining water during drought conditions. While the Commission, depending on the
circumstances each year, has both denied and granted these variance requests,1 in each instance
GRDA reached out to, and consulted with, federal and state resource agencies, Indian tribes, and
other stakeholders.
1
The Commission granted GRDA’s variance request in 2012 and 2015, but denied the requests submitted in
2006, 2011 and 2013.
1-1
II.
Temporary Variance in 2015
In 2015, GRDA again sought a temporary variance from the Article 401 rule curve target
elevations. Recognizing the need to balance the many additional competing interests of the
Project, such as projected drought conditions, water quality requirements, and support for public
recreation and safety, GRDA proposed a different solution—that a slightly modified rule curve
be instituted during late summer and early fall as follows: maintain Grand Lake elevation at 743’
Pensacola Datum (PD) through the Labor Day holiday, and then on September 16 begin
lowering the reservoir to reach 742’ PD by September 30, where it would remain for the balance
of the modified period. Recognizing the uncertainty of weather patterns during this period of the
year, GRDA also proposed, as part of the variance request, to implement a Storm Adaptive
Management Plan in the event that a high precipitation event in the basin affects water levels
upstream or downstream of the Project. GRDA also proposed to implement a Drought Adaptive
Management Plan, in the event that drought conditions prevail during the variance period—
consistent with weather patterns in prior years.
On August 14, 2015, the Commission granted GRDA’s temporary variance. Grand River Dam
Auth., 152 FERC ¶ 61,129 (2015). The Commission found that the proposed rule curve variance
would result in minimal incremental changes to upstream and downstream water levels in the
Grand/Neosho River basin. Id. at PP 28-30. The Commission also conducted an analysis of the
increased physical danger to residents upstream of the Project due to the incremental increase in
Grand Lake levels sought by the variance request. Based on this analysis, the Commission
concluded that “[s]ince many inundated structures are located at the edge of the inundated area
where flood depths are minor and the incremental flooding impacts are minimal, the increase in
the probability for risk to human life is negligible at Miami,” the community immediately
upstream of Grand Lake. Id. at P 31.
As to downstream effects, the Commission found “some increased danger for various
structures,” but concluded that the changes in releases as a result of the variance would not
change the hazard classification of such structures under the U.S. Bureau of Reclamation’s
Engineering and Research Technical Memorandum No. 11, Downstream Hazard Classification
Guidelines. Id. at P 32. Moreover, the Commission concluded that any increased risk “would be
mitigated by the existing Emergency Action Plan (EAP) procedures” implemented by GRDA.
Id. Thus, consistent with its analysis of upstream areas, the Commission concluded that
implementation of the variance would result in “little increase in the probability of human risk”
downstream of the Project. Id.
With regard to other effects of the proposed 2015 variance, the Commission found numerous
other beneficial effects:

The variance “would allow [GRDA] to store more water in the reservoir during the late
summer and early fall period. This would provide GRDA with more water for making
releases to maintain downstream [dissolved oxygen (DO)] during this period.” Id. at P
39.
1-2

The variance “would allow GRDA to retain additional drinking water in reserve for the
City of Tulsa. The city uses the Markham Ferry Project’s Lake Hudson as its sole backup water supply in the event of an emergency.” Id.

“[GRDA’s] proposal would not have any significant effects on water quality in Grand
Lake, and may provide minor benefits to lake water quality through reducing shoreline
erosion that may be associated with the normal elevation changes and exposure of
shallow areas. Any reduction in such erosion would reduce turbidity in near-shore areas,
and could reduce exposure and suspension of pollutants in sediment, such as heavy
metals.” Id. at P 41.

“GRDA’s proposed Drought Adaptive Management Plan would help to maintain
downstream DO concentrations in the event that drought conditions cause reservoir
elevations to fall below the rule curve during the variance. Under the Drought Adaptive
Management Plan, the licensee would make releases equivalent to between 0.03 and 0.06
foot of reservoir elevation per day. These releases would be equivalent to approximately
175 to 837 cfs per hour over a 24-hour period.” Id. at P 43.

The temporary variance would allow GRDA to “maintain lake elevations [at the
downstream Lake Hudson] necessary for the reliable operation of its Salina Pumped
Storage facility.” Id.

The variance “could have minor positive effects on shallow-water fish and waterfowl
habitat [in Grand Lake], in part by protecting emergent and aquatic plants that become
established in such areas.” Id. at P 47.

GRDA’s variance proposal, “including its proposed Drought Adaptive Management Plan
for maintaining downstream DO in the event of a severe to exceptional drought that
causes the reservoir to fall below the proposed rule curve, would further provide
protection of downstream fisheries.” Id. at P 48.

“Implementation of the temporary variance in 2015 would not affect any terrestrial or
wildlife resources located above normal reservoir rule curve elevations. The variance
would not likely cause any negative impacts to wetland or wildlife resources located at
and below normal reservoir rule curve elevations, because water levels would remain
within the range of the current rule curve and may provide minor, short-term benefits by
reducing the water level fluctuations that occur under the current rule curve, allowing
some degree of increased growth and establishment of riparian and shallow-water
vegetation, which could benefit both fish and wildlife that utilize these areas.” Id. at P
52.

The variance would not affect the federally listed endangered species of gray bat (Myotis
grisescens) or Neosho mucket (Lampsilis rafinesqueana), nor would it affect the
federally listed threatened species of Ozark cavefish (Amblyopsis rosae) or Neosho
madtom (Noturus placidus). Id. at PP 53-60.
1-3

The variance would allow GRDA “to maintain reservoir elevations 2 feet higher from
August 15 to September 15, and up to 1 foot higher from September 15 to October 31.
These higher reservoir elevations would increase the amount of area available for
boating in the reservoir, and would likely allow for easier public and private access at the
numerous boat ramps and boat docks located at the project. Because the increase in area
available for boating and improved recreational access would occur during the
recreational boating season, the proposed rule curve amendment would result in benefits
to recreation at the project.” Id. at P 63.

“The higher reservoir elevation [under the variance] would also likely decrease boating
hazards in the reservoir. Based on the licensee’s provided data, the vast majority of boat
groundings during the high recreation season occur during the tail end of the season
when recreational boating use is still high but the reservoir level is being lowered to or is
at 741. Thus, we expect the proposed rule curve to contribute to a decrease in boat
groundings at the project.” Id. at P 64.

“The proposed temporary variance would not result in a substantial change to generation
at Pensacola.” Id. at 67. The shift in energy generation energy from August (under the
Article 401 rule curve implementation) to late September (under the variance) would
result in a net loss of $132,000 to GRDA, as “energy generated in late August is more
valuable than energy generated in late September.” Id. At the downstream Markham
Ferry Project, implementation of the variance “would result in an estimated loss of about
123 MWh in generation, which has a value of about $58,000.” Id. at P 68.
Following the Commission’s order, GRDA implemented the temporary variance in 2015. The
effort was a marked success for Grand Lake, and resulted in a successful collaborative effort
among GRDA, federal and state resource agencies, and local governmental entities with regard
to lake level management. Recreation during the Labor Day holiday and the remainder of the
high-recreation season, and the correlating benefits to the local economy, far exceeded past
years. Information describing these benefits appears in Appendix 4. GRDA held weekly
conference calls to discuss current and forecasted water levels in the Grand/Neosho River basin.
While the basin did not encounter any significant event during the variance period, the
experience gained through this coordinated effort helped tremendously later in the year, when the
basin experienced a near-record precipitation event in December 2015, and GRDA consulted
closely with federal, state, and local authorities in safely passing the significant flows through the
system.
III.
Proposed Amendment to License Article 401
Building on the successful implementation of the 2015 temporary variance, this Application for
Non-Capacity Related Amendment of the Project license seeks to adopt the change in the Article
401 rule curve for the remaining term of the existing license (including any annual license
period). The proposed rule curve change is depicted in Figure 1.
1-4
Figure 1. Depiction of Proposed Rule Curve Amendment
In terms of the changes to the language of Article 401, GRDA seeks the following:
Article 401. The Licensee shall operate the Pensacola Project to control
fluctuations of the reservoir surface elevation for the protection of fish, wildlife,
and recreational resources associated with the Grand Lake O’ the Cherokees
(Grand Lake) reservoir. The Licensee shall act, to the extent practicable (except as
provided by the Storm Adaptive Management Plan or the Drought Adaptive
Management Plan, or as necessary for the Department of the Army, Tulsa
District, Corps of Engineers to provide flood protection in the Grand (Neosho)
River), to maintain the reservoir surface elevations, as measured immediately
upstream of the project dam. These target reservoir surface elevations are as
follows:
Period
(Pensacola Datum)
May 01 – May 31 ............................................... Raise elevation from 742 to 744
Jun 01 – Jul 31 ................................................... Maintain elevation at 744
Aug 01 – Aug 15 ................................................ Lower elevation from 744 to 743
Aug 16 – Sep 15 ................................................. Lower elevation from 743 to 741
Sep 01 – Oct 15 .................................................. Maintain elevation at 741
Oct 16 – Oct 31 .................................................. Raise elevation from 741 to 742
Nov 01 – Apr 30 ................................................ Maintain elevation at 742
Aug 16 – Sep 15 ................................................. Maintain elevation at 743
Sep 16 – Sep 30.................................................. Lower elevation from 743 to 742
Oct 1 – Apr 30.................................................... Maintain elevation at 742
1-5
Upon the forecast of any major precipitation event within the Grand/Neosho
River basin that may result in high water conditions upstream or downstream of
Grand Lake, the Licensee shall implement the Storm Adaptive Management Plan
through the duration of the event. The Licensee shall institute the Drought
Adaptive Management Plan during any period in which the National Drought
Mitigation Center’s U.S. Drought Monitor has identified a severe or exceptional
drought within the Grand/Neosho River basin.
The Storm Adaptive Management Plan is set forth in Appendix 2 to this Application, and the
Drought Adaptive Management Plan appears in Appendix 3. GRDA proposes that the
Commission approve these plans for implementation as part of its order granting this
Application.
IV.
Environmental Analysis
The environmental scope of this Application is the same as GRDA’s temporary variance request
from 2015, the same studies, modeling work, and assessments that supported the Commission’s
favorable environmental analysis, summarized above. Accordingly, GRDA has concluded that
no additional studies are necessary to sustain this Application. Relevant existing information,
including the materials prepared by GRDA last year and relied upon by the Commission in its
2015 order approving the temporary variance, appears in Appendix 4.
V.
Conclusion
For the reasons explained above, GRDA believes that this Application is in the public interest. If
granted by the Commission, the change in the rule curve will result in significant improvements
to public recreation and safety during a peak recreation period each year and assist GRDA in
meeting water quality and water supply obligations—all without exacerbating upstream or
downstream water levels. As part of this Application, GRDA is committed to continued
cooperation and collaboration with the U.S. Army Corps of Engineers, Commission staff, and
local governmental authorities in addressing high flow events in the Grand/Neosho River basin.
While GRDA has concluded that the changes to Article 401 proposed in this Application meet
public interest requirements through the remainder of the existing license term, it recognizes that
the relicensing process for the Project is scheduled to begin within the next year or so, as the
current license expires in 2022. The relicensing process will involve a comprehensive review of
all license obligations, including rule curve requirements. As such, the Commission’s approval
of this Application will not determine GRDA’s management obligations under a new license
issued following the upcoming relicensing process.
1-6
Appendix 2
Storm Adaptive Management Plan
Background
As part of this Application for Non-Capacity Related Amendment to the license for the
Pensacola Project No. 1494 (Project), GRDA proposes under an amended Article 401 to
implement a Storm Adaptive Management Plan (Plan) “[u]pon the forecast of any major
precipitation event within the Grand/Neosho River basin that may result in high water conditions
upstream or downstream of Grand Lake.” This Plan sets forth rules and protocols for the
adaptive management process to meet this requirement of the amended Article 401.
Description
This Plan sets forth protocols for managing GRDA’s Grand Lake during major precipitation
events. GRDA will work with resource agencies and local governments to address concerns
related to high water conditions upstream of Grand Lake during any major precipitation event
that may occur in the Grand/Neosho River basin.
GRDA will review, on a daily basis, weather forecasts in the watershed, Grand Lake surface
elevation data, U.S. Geological Service gauges upstream of the Project, surface elevations at the
U.S. Army Corps of Engineers’ (USACE) upstream John Redmond Reservoir, and other relevant
information affecting surface elevations at Grand Lake during the potential flood period.
Based on GRDA’s daily review of the above-referenced information, if the weather forecast
indicates a high probability of high water conditions in the Grand/Neosho River basin in the
immediate vicinity of the Project, GRDA will take the following actions:

Notification and Data Distribution. Immediately provide all above-referenced data to
the USACE; Federal Energy Regulatory Commission (FERC) staff in Washington, DC
(Division of Hydropower Administration and Compliance) and Atlanta Regional Office
(Division of Dam Safety and Inspections); U.S. Fish and Wildlife Service; Oklahoma
Department of Environmental Quality; City of Miami, Oklahoma; and interested Indian
tribes. A listing of all entities to receive this information is provided below, and each
entity is expected to keep GRDA informed of any changes in personnel or contact
information on the list.

Schedule Teleconference. In conjunction with the notification and data distribution,
GRDA will schedule a conference call at the earliest practicable time, and notify all
entities listed below of the time for the call and instructions on how to participate in the
call.

Consultation with USACE. Prior to convening the conference call, GRDA will consult
with the USACE, Tulsa District, regarding the forecasted event. USACE, Tulsa District,
will determine whether any actions can be taken to prevent, minimize, or mitigate water
levels upstream or downstream of the Project—recognizing USACE’s over-arching flood
2-1
risk management responsibilities within the Arkansas River basin under the Flood
Control Act of 1944, and to balance all reservoirs within the basin under its jurisdiction.
GRDA expects USACE, Tulsa District, to consider factors such as pre-existing watershed
conditions, soil moisture content, and storm event composition (e.g., path, intensity, and
duration).

Convene Teleconference. During the teleconference, GRDA will report USACE’s
decision on any actions at the Project to prevent, minimize, or mitigate water levels
upstream or downstream of the Project. Participants will have an opportunity during the
teleconference to explore alternative potential solutions to respond to the forecasted highflow event, recognizing the USACE’s jurisdiction to manage the Project for purposes of
flood risk management.

Subsequent Communications. As necessary and appropriate in each high-flow event,
GRDA will continue regular communications with all entities listed below, to keep them
informed of prevailing conditions at the Project during the event. Such communications
may entail conference calls, email messages, or other forms of communication
appropriate under the circumstances.
Relationship to Emergency Action Plan
The requirements of this Plan are separate and distinct from any obligations under GRDA’s
FERC-approved Emergency Action Plan (EAP) for the Project. Once the EAP is triggered,
however, the communication protocols contained in the EAP supersede those included in this
Plan until the emergency is resolved.
CONTACT LIST
Division of Hydropower Administration & Compliance
Division of Dam Safety and Inspections
U.S. Army Corps of Engineers, Tulsa District
National Weather Service, Tulsa Forecast Office
Oklahoma Secretary of Energy and Environment
2-2
U.S. Fish and Wildlife Service
City of Miami
Ottawa County Office of the County Commissioner
Ottawa County Emergency Management
Modoc Tribe
Quapaw Tribe of Indians
2-3
Appendix 3
Drought Adaptive Management Plan
Background
Under its existing Federal Energy Regulatory Commission (FERC) license for the Pensacola
Project No. 1494 (Project), the Grand River Dam Authority (GRDA) is required to ensure
maintenance of dissolved oxygen (DO) concentrations in the tailrace area downstream of the
Project. It also is required under Article 401 of its downstream Markham Ferry Project to
mitigate for low DO levels to meet state water quality standards.
During periods of drought, however, strict adherence to the Project’s rule curve under Article
401 can result in an inadequate supply of water to meet these water quality requirements—as
well as potential water supply needs downstream. For these reasons, the amended Article 401 of
the license requires GRDA to implement this Drought Adaptive Management Plan (Plan)
“during any period in which the National Drought Mitigation Center’s U.S. Drought Monitor has
identified a severe or exceptional drought within the Grand/Neosho River basin.”
This Plan provides for certain deviations from the Article 401 target elevations to allow GRDA
to meet other obligations during drought conditions. It is intended to help GRDA to have
sufficient water to maintain flow releases to meet downstream DO requirements at the Pensacola
and Markham Ferry projects, while maintaining lake elevations necessary for the reliable
operation of its downstream Salina Pumped Storage Project.
Description
In the event that the National Drought Mitigation Center’s U.S. Drought Monitor has identified a
severe or exceptional drought within the Grand/Neosho River basin, GRDA will continue to
make releases at the Project to meet downstream obligations, regardless of the prevailing levels
at Grand Lake O’ the Cherokees (Grand Lake) and Article 401 rule curve target elevations. Such
releases are limited to up to 0.06 feet of reservoir elevation per day—up to approximately 837
cubic feet per second per hour over a 24-hour period.
The daily release allowances under this Plan are designed to allow short-duration pulsed releases
to simultaneously conserve water in Grand Lake while maintaining downstream DO
requirements. These release allowances are expected to provide enough flow to maintain gate
releases downstream at the Markham Ferry Project while maintaining an elevation of 619 feet
mean sea level at Lake Hudson, which is necessary to meet general daily operations and North
American Electric Reliability Corporation reliability standards associated with the Salina
Pumped Storage Project.
In the unusual event that the allowances authorized under this Plan are insufficient to meet its
objectives, GRDA may seek further authorization from FERC to release additional flows from
Grand Lake to meet downstream requirements during a severe or exceptional drought.
3-1
Procedures

Monitoring. GRDA will monitor drought conditions in the Grand/Neosho River basin
using the U.S. Drought Monitor, available at http://droughtmonitor.unl.edu, as well as
other generally accepted sources of drought information applicable to the basin.

Weekly Teleconferences. When these sources indicate that a severe or exceptional
drought is imminent in the Grand/Neosho River basin, GRDA will commence weekly
teleconferences to keep federal and state resource agencies informed of prevailing
conditions and GRDA’s plans to begin additional releases in the event a severe or
exceptional drought is declared. These weekly conference calls will continue until the
threat of a severe or exceptional drought subsides. Entities invited to participate in this
weekly teleconference include the U.S. Army Corps of Engineers, U.S. Fish and Wildlife
Service, Oklahoma Water Resources Board, Oklahoma Department of Wildlife
Conservation, the City of Miami, and FERC staff. A listing of all entities to receive
notification of GRDA’s weekly conference calls is provided below, and each entity is
expected to keep GRDA informed of any changes in personnel or contact information on
the list.

Commencement of Additional Releases. Upon the declaration of a severe or exceptional
drought in the Grand/Neosho River basin, GRDA at its discretion may commence
additional releases of up to 0.06 feet of reservoir elevation per day—up to approximately
837 cubic feet per second per hour over a 24-hour period. At each weekly teleconference
during the duration of a severe or exceptional drought, GRDA will address the following
issues: (1) current and forecasted drought conditions and planned project operation; (2)
maintenance of water levels and flows sufficient to maintain downstream DO
concentrations for water quality and the prevention of fish kills; and (3) maintenance of
reservoir elevations at Markham Ferry sufficient to operate the Salina Pumped Storage
Project for system reliability; and (4) based on available information, when the severe or
exceptional drought period is expected to end.

Cessation of Additional Releases. Upon the end of the declared severe or exceptional
drought condition in the Grand/Neosho River basin, GRDA will cease the additional
releases authorized under this Plan. GRDA will notify the entities on the Contact List
below of the end of the severe or exceptional drought and its cessation of additional
releases.
CONTACT LIST
3-2
City of Miami
Modoc Tribe
3-3
Agency and Stakeholder Comments
•
Delaware County Floodplain Administration
•
•
•
•
City of Miami
•
Plaintiffs in City of Miami v. GRDA and Asbell v. GRDA
•
493 Ottawa County citizens and businesses
•
FERC staff
•
•
State Historic Preservation Office
From: Robert Real [mailto:[email protected]]
Sent: Thursday, March 17, 2016 1:15 PM
To: Hicks, Teresa
Subject: Re: Pensacola Project No. 1494 - Draft Application For GRDA Rule Curve Amendment
Ms. Hicks:
The Delaware County Floodplain has reviewed the draft Application to the Federal Energy
Regulatory Commission (FERC) for Non-Capacity Related Amendment of License
(Application) for the Pensacola Project, No. 1494 (Project).
The Delaware County Floodplain has no comment on, nor any objections.
If you have any questions please do not hesitate to contact my office at the numbers listed above.
Robert G. Real, CFM, OCEM
Delaware County/City of Grove
Emergency Management
Safety Coordinator
Floodplain Administrator
Offfice/EOC 918-787-4357
Fax: 918-787-2228
CONFIDENTIALITY NOTE:
This e-mail and any attachments are confidential. If you are not the intended recipient, be aware
that any disclosure, copying, distribution or use of this e-mail or any attachment is prohibited. If
you have received this e-mail in error, please notify us immediately by returning it to the sender
and delete this copy from your system. Thank you for your cooperation.
________________________________
From: "Hicks, Teresa" <[email protected]<mailto:[email protected]>>
To: "Hicks, Teresa" <[email protected]<mailto:[email protected]>>
Cc: "Sullivan, Daniel" <[email protected]<mailto:[email protected]>>; "Reese, Nathan"
<[email protected]<mailto:[email protected]>>; "Chuck Sensiba
([email protected]<mailto:[email protected]>)" <[email protected]<mailto:[email protected]>>; Steve Hocking
<[email protected]<mailto:[email protected]>>; Pete Yarrington
<[email protected]<mailto:[email protected]>>
Sent: Tuesday, March 15, 2016 4:01 PM
Subject: Pensacola Project No. 1494 - Draft Application For GRDA Rule Curve Amendment
March 15, 2016
To:
Attached Distribution List
Re:
Dear Interested Party:
The Grand River Dam Authority (GRDA) is enclosing, for your review and comment, a draft
Application to the Federal Energy Regulatory Commission (FERC) for Non-Capacity Related
Amendment of License (Application) for the Pensacola Project, No. 1494 (Project).
As detailed in the draft Application, GRDA seeks to change the rule curve requirement under
Article 401 of the Project license during the August 15 through October 31 period each year, for
purposes of promoting public safety, water quality, and recreational enhancement through a peak
public recreation period of the year. GRDA also seeks to implement a Storm Adaptive
Management Plan and Drought Adaptive Management Plan in conjunction with the requested
changes to the rule curve.
GRDA requests that all comments on the draft Application be submitted in writing within 30
days of this letter—i.e., by April 14, 2016. Although FERC’s regulations, 18 C.F.R. §
4.38(a)(7), establish a 60-day comment period for non-capacity related amendment applications,
GRDA has asked FERC to waive this requirement and instead allow a 30-day comment period,
given the long-history of consultation, environmental review, modeling, and FERC actions
related to the rule curve at this Project.
GRDA’s request for an abbreviated comment period appears at Appendix 6 of the attached draft
Application. If any party has concerns about this request, GRDA anticipates that FERC will
issue a public notice of the request and provide an opportunity for public comment.
In the event FERC does not grant GRDA’s request for an abbreviated comment period, all
written comments on this draft Application will be due within 60 days of this letter—i.e., by May
16, 2016. GRDA will keep those listed in the attached Distribution List informed of FERC’s
decision.
Please send comments on the draft Application to GRDA at the following address:
Legal Department
P.O. Box 409
226 West Dwain Willis Avenue
Vinita OK 74301
You may also provide comments via email to [email protected]<mailto:[email protected]>.
If you have any questions related to this letter or the draft Application, please contact Nathan
Reese at 918-610-9726 or via email at [email protected]<mailto:[email protected]>.
Sincerely,
Teresa Hicks
Administrative Assistant
P O Box 409
Vinita OK 74301
918-256-0632
From: Smithee, Derek [mailto:[email protected]]
Sent: Tuesday, March 29, 2016 10:57 AM
To: Hicks, Teresa
Cc: Townsend, Darrell; Jahnke, Tamara
Subject: RE: Pensacola Project No. 1494 - Draft Application For GRDA Rule Curve Amendment
Teresa,
I have reviewed this Application for a Rule Curve Amendment for the Pensacola Project No. 1494 and
support the proposed request.
I would also like to encourage GRDA to continue to look toward managing Grand, Hudson and Holloway
as a “system” instead of as individual reservoirs. This would enhance GRDA’s ability to adaptively
provide a better balance for the myriad stakeholder needs in the area.
Feel free to contact me if you have any questions.
Derek Smithee
Derek Smithee, Chief
Water Quality Programs Division
3800 N. Classen Blvd.
OKC, OK 73118
(405) 530-8800 (office)
(405) 388-2805 (cell)
From: Hicks, Teresa [mailto:[email protected]]
Sent: Tuesday, March 15, 2016 4:01 PM
To: Hicks, Teresa
Cc: Sullivan, Daniel; Reese, Nathan; Chuck Sensiba ([email protected]); Steve Hocking; Pete Yarrington
Subject: Pensacola Project No. 1494 - Draft Application For GRDA Rule Curve Amendment
March 15, 2016
To:
Re:
Attached Distribution List
Dear Interested Party:
The Grand River Dam Authority (GRDA) is enclosing, for your review and comment, a draft Application to
the Federal Energy Regulatory Commission (FERC) for Non-Capacity Related Amendment of License
(Application) for the Pensacola Project, No. 1494 (Project).
As detailed in the draft Application, GRDA seeks to change the rule curve requirement under Article 401
of the Project license during the August 15 through October 31 period each year, for purposes of
promoting public safety, water quality, and recreational enhancement through a peak public recreation
period of the year. GRDA also seeks to implement a Storm Adaptive Management Plan and Drought
Adaptive Management Plan in conjunction with the requested changes to the rule curve.
GRDA requests that all comments on the draft Application be submitted in writing within 30 days of this
letter—i.e., by April 14, 2016. Although FERC’s regulations, 18 C.F.R. § 4.38(a)(7), establish a 60-day
comment period for non-capacity related amendment applications, GRDA has asked FERC to waive this
requirement and instead allow a 30-day comment period, given the long-history of consultation,
environmental review, modeling, and FERC actions related to the rule curve at this Project.
GRDA’s request for an abbreviated comment period appears at Appendix 6 of the attached draft
Application. If any party has concerns about this request, GRDA anticipates that FERC will issue a public
notice of the request and provide an opportunity for public comment.
In the event FERC does not grant GRDA’s request for an abbreviated comment period, all written
comments on this draft Application will be due within 60 days of this letter—i.e., by May 16,
2016. GRDA will keep those listed in the attached Distribution List informed of FERC’s decision.
Please send comments on the draft Application to GRDA at the following address:
Legal Department
P.O. Box 409
226 West Dwain Willis Avenue
Vinita OK 74301
You may also provide comments via email to [email protected].
If you have any questions related to this letter or the draft Application, please contact Nathan Reese at
918-610-9726 or via email at [email protected].
Sincerely,
Teresa Hicks
Administrative Assistant
P O Box 409
Vinita OK 74301
918-256-0632
Hydraulic Analysis to Evaluate Impacts of the
Rule Curve Change at Pensacola Dam on
Neosho River Flooding In the Vicinity of Miami,
Oklahoma
Submitted to:
Submitted by:
City of Miami, Oklahoma
126 Fifth Avenue NW
Miami, OK 74354
3801 Automation Way, Suite 100
February 3, 2016
Hydraulic Analysis to Evaluate the Impacts of the Rule Curve
Change at Pensacola Dam on Neosho River Flooding
In the Vicinity of Miami, Oklahoma
TABLE OF CONTENTS
EXECUTIVE SUMMARY .......................................................................................................... vii
Study Objectives and Methods .............................................................................................. vii
Summary of Findings............................................................................................................ viii
1
2
3
INTRODUCTION .................................................................................................................1
1.1
Study Objectives and Tasks......................................................................................... 2
1.2
Authorization ................................................................................................................ 3
Evaluation of the OU (2014) and FERC (2015) Studies .......................................................6
2.1
OU (2014) Study .......................................................................................................... 6
2.2
FERC (2015) Study...................................................................................................... 7
FLOW AND STAGE DATA ..................................................................................................9
3.1
Flood Hydrographs .....................................................................................................10
October 1996 .......................................................................................................11
September 1993 ..................................................................................................11
May 1995 (Flood 11) ............................................................................................12
June 1995 (Flood 13) ...........................................................................................12
June-July 2007 ....................................................................................................12
April-May 2009.....................................................................................................12
October 2009 .......................................................................................................13
May-June 2013 ....................................................................................................13
December 2015 ...................................................................................................13
3.2
Development of 741 feet PD and 743 feet PD Flood Hydrographs..............................14
October 1986 .......................................................................................................14
September 1993 ..................................................................................................15
October 2009 .......................................................................................................15
December 2015 ...................................................................................................15
4
5
TOPOGRAPHIC DATA ......................................................................................................35
4.1
2008 Grand Lake Survey ............................................................................................35
4.2
2011 LiDAR Data ........................................................................................................35
4.3
2015 Tetra Tech Survey..............................................................................................35
4.4
Comparison of Bed Elevation Changes.......................................................................37
HYDRAULIC MODELING ..................................................................................................45
5.1
Model Development ....................................................................................................45
i
Model Geometry ..................................................................................................46
Manning’s n Roughness Values ...........................................................................46
5.2
Model Calibration ........................................................................................................47
5.3
Rule Curve Evaluation Model Results .........................................................................51
October 1986 .......................................................................................................57
September 1993 ..................................................................................................59
October 2009 .......................................................................................................60
December 2015 ...................................................................................................60
Comparison with FERC Results ...........................................................................60
6
REFERENCES ..................................................................................................................92
LIST OF FIGURES
Figure 1.1.
Proposed temporary variance from the Article 401 reservoir elevation rule
curve requirements for the Pensacola Project (copied from FERC, 2015) ........... 4
Figure 1.2.
Map of study area showing limits of the HEC-RAS model. .................................. 5
Figure 3.1.
Map showing location of stream gages in the vicinity of the study area. .............16
Figure 3.2.
Discharge and water-surface elevation hydrographs used in the simulations
for the October 1986 flood. ................................................................................17
Figure 3.3.
for the September 1993 flood. ............................................................................18
Figure 3.4.
for the May 1995 flood. ......................................................................................19
Figure 3.5.
for the June 1995 flood. .....................................................................................20
Figure 3.6.
for the June-July 2007 flood. ..............................................................................21
Figure 3.7.
Reported hourly stages from the recording gage at Commerce and stages
corresponding to USGS field-measured discharges during the June-July
2007 flood. .........................................................................................................22
Figure 3.8.
for the April-May 2009 flood. .............................................................................23
Figure 3.9.
Figure 3.10.
for the June 2013 flood. .....................................................................................25
Figure 3.11.
for the December 2015 flood. .............................................................................26
Figure 3.12.
Comparison of the measured and predicted stage hydrograph at Pensacola
Dam, and predicted stage hydrographs for the 741 feet PD and 743 feet PD
ii
starting water-surface elevations for the October 1986 flood. The data were
obtained from the FERC (2015) analysis. ..........................................................27
Figure 3.13.
Comparison of the measured and predicted stage hydrograph at Pensacola
Dam, and predicted stage hydrographs for the 741 feet PD and 743 feet PD
starting water-surface elevations for the September 1993 flood. The data
were obtained from the FERC (2015) analysis. ..................................................28
Figure 3.14.
Storage versus Water-surface elevation curve for Pensacola Dam based on
the 2008 hydrographic survey of Grand Lake (OWRB, 2009). ...........................29
Figure 3.15.
Water-surface elevation versus discharge rating curves for a main gate and
auxiliary spillway at Pensacola Dam. .................................................................30
Figure 3.16.
Comparison of the measured and routed stage hydrograph at Pensacola Dam
Figure 3.17.
Comparison of the routed stage hydrographs at Pensacola Dam for the
measured, 741 feet PD and 743 feet PD starting water-surface elevations for
the October 2009 flood.......................................................................................32
Figure 3.18.
Comparison of the recorded and routed stage hydrograph at Pensacola Dam
for the December 2015 flood. .............................................................................33
Figure 3.19.
Comparison of the routed stage hydrographs at Pensacola Dam for the
existing, 741 feet PD and 743 feet PD starting water-surface elevations fo
the December 2015 flood. ..................................................................................34
Figure 4.1.
Storage-Elevation curves for Grand Lake. 1992 Water Control Manual same
as original 1940 storage-elevation curve; USACE>Jan 28, 2012 from post Jan
28, 2012 data published on USACE Water Control website. ..............................38
Figure 4.2.
Flow hydrograph measured at the Commerce gage. The discharge during the
hydrographic survey from ranged from approximately 1,350 cfs on April 24, to
approximately 730 cfs on April 27, 2015. ...........................................................39
Figure 4.3.
Location of the benchmarks used for the 2015 hydrographic survey. .................40
Figure 4.4.
Location of the survey transects. ........................................................................41
Figure 4.5.
Comparison of the thalweg profile developed from the 2015 bathymetric
survey, with survey measurements collected by Settle Engineering Co. in
1995 and 1998. The red lines show the location of the interpolated channel
profile. ................................................................................................................42
Figure 4.6.
Comparison of the 1940 and 2015 thalweg profiles............................................43
Figure 4.7.
Comparison of the 1998 thalweg profile from the Simons HEC-2 model and
2015 thalweg profile. ..........................................................................................44
Figure 5.1.
Aerial photograph showing the vegetation in the vicinity of Tar Creek in 2015. ..62
Figure 5.2.
Aerial photograph showing the vegetation in the vicinity of Commerce Gage
(Stepps Ford Bridge) in 2015. ............................................................................63
Figure 5.3.
Aerial photograph showing the vegetation in the vicinity of Twin Bridges
(Stepps Ford Bridge) in 2015. ............................................................................64
Figure 5.4.
Roughness zones used to assign Manning’s n-values to the with-dam
conditions model. ...............................................................................................65
Figure 5.5.
Map showing location of available high-water marks for the May 1995 flood......66
iii
Figure 5.6.
Map showing location of available high-water marks for the June 1995 flood.....67
Figure 5.7.
Map showing location of available high-water marks for the June-July
2007 flood. .........................................................................................................68
Figure 5.8.
Map showing location of available high-water marks for the May 2009 flood......69
Figure 5.9.
Map showing location of available high-water marks for the October 2009
flood. ..................................................................................................................70
Figure 5.10.
Map showing location of available high-water marks for the May-June 2013
flood. ..................................................................................................................71
Figure 5.11.
Map showing location of available high-water marks for the December 2015
flood. ..................................................................................................................72
Figure 5.12.
Comparison of the predicted maximum water-surface profile along the channel
stationline compared to the measured high-water marks and peak gage
measurements for the May 1995 flood. ..............................................................73
Figure 5.13.
measurements for the June 1995 flood. .............................................................74
Figure 5.14.
measurements for the May-June 2007 flood. .....................................................75
Figure 5.15.
measurements for the October 2009 flood. ........................................................76
Figure 5.16.
measurements for the October 2009 flood. ........................................................77
Figure 5.17.
measurements for the May 2013 flood. ..............................................................78
Figure 5.18.
measurements for the December 2015 flood. ....................................................79
Figure 5.19.
Predicted and measured stage hydrographs at the Commerce and Miami
gages for the May 1995 flood. ............................................................................80
Figure 5.20.
gages for the June 1995 flood. ...........................................................................81
Figure 5.21.
gages for the 2007 flood. ...................................................................................82
Figure 5.22.
Figure 5.23.
gages for the October 2009 flood. ......................................................................84
Figure 5.24.
iv
Figure 5.25.
gages for the December 2015 flood. ..................................................................86
Figure 5.26.
Predicted inundation area for the existing (with-dam) conditions June-July
2007 flood compared to the 760-foot contour line. .............................................87
Figure 5.27.
Predicted maximum water-surface profiles for October 1986 flood under
741 feet PD and 743 feet PD conditions. ...........................................................88
Figure 5.28.
Predicted maximum water-surface profiles for September 1993 flood under
Figure 5.29.
Predicted maximum water-surface profiles for October 2009 flood under
Figure 5.30.
Predicted maximum water-surface profiles for December 2015 flood under
LIST OF TABLES
Table 1.1.
Named flood events and associated peak discharge. ......................................... 1
Table 3.1.
Stationing of key features along the project reach. .............................................. 9
Table 3.2.
Peak discharge and duration of flow exceeding bankfull discharge
(21,000 cfs) at the Commerce Gage. .................................................................11
Table 3.3.
Starting and maximum lake level elevation over the duration of the floods. ........11
Table 3.4.
Comparison of the measured and predicted maximum lake level elevation
for the existing conditions, the maximum lake elevation with starting watersurface elevations of 741 feet PD and 743 feet PD, and difference in
maximum lake elevation between the 741 feet PD and 743 feet PD
conditions for the October 1986 flood.................................................................14
Table 4.1.
USACE survey control points. ............................................................................36
Table 4.2.
Temporary survey control set by Tetra Tech. .....................................................36
Table 5.1.
Extents of the 1- and 2-dimensional areas in the HEC-RAS model. ...................45
Table 5.2.
Summary of Manning's n-values applied to the channel for model calibration. ...47
Table 5.3.
Overbank Manning’s n-values (Arcement and Schneider, 1989). .......................48
Table 5.4.
Summary of high-water marks and modeled maximum water-surface
elevations for the May and June 1995 floods. ....................................................49
Table 5.5.
elevations for 2007 flood. ...................................................................................52
Table 5.6.
elevations for the May 2009 flood. .....................................................................53
Table 5.7.
Comparison of measured high-water marks for the October 2009 flood. ............54
Table 5.8.
Comparison of measured high-water marks for the May 2013 flood. ..................55
Table 5.9.
Comparison of measured high-water marks for the December 2015 flood. ........56
Table 5.10.
Summary of Manning's n-values applied to the main channel for the rule
curve simulations. ..............................................................................................57
v
Table 5.11.
Extents of the subreaches used in the area calculations. ...................................57
Table 5.12.
Maximum predicted water-surface elevation at three locations in the study
reach for 741 feet PD and 743 feet PD starting water-surface elevations,
and the difference between the 760-foot NGVD29 flood easements. .................58
Table 5.13.
Duration above 760-foot flood easement at Miami Gage for the 741 feet PD
and 743 feet PD conditions (hours). ...................................................................59
Table 5.14.
Comparison of predicted inundation under the 741 feet PD and 743 feet PD
conditions (acres)...............................................................................................59
Table 5.15.
Predicted Maximum water-surface elevation from the Tetra Tech and FERC
analyses at the Pensacola Dam and Twin Bridges (feet, NGVD29). ..................61
Table 5.16.
analyses at the Miami Gage (feet, NGVD29). ....................................................61
vi
EXECUTIVE SUMMARY
Study Objectives and Methods
The City of Miami, Oklahoma and surrounding area has been subjected to several floods over at
least the past three decades that have caused extensive property damage. The flooding in the
vicinity of Miami has been exacerbated by the construction of Pensacola Dam. Flooding above
the 760-foot NGVD easement elevation occurs relatively frequently, indicating that the existing
flowage easements are inadequate. The City is concerned that the recent rule curve change could
further exacerbate flooding conditions within the city. In addition, it is recognized that additional
flooding created by rule curve change would also impact tribal sovereign land within the project
reach.
Tetra Tech was retained by the City to perform additional model runs to specifically evaluate the
effects of the temporary seasonal rule curve change on flooding along in the vicinity of City.
Seasonal rule curves specify the target maximum water-surface elevation of each reservoir in the
water control system throughout the year. The seasonal rule curve that was in effect for Pensacola
Dam from 1996 through August 2015 established target maximum water-surface elevations that
vary from 741 feet Pensacola Datum (PD) between September 1 and October 15 to 744 feet PD
from June 1 through July 31 (Figure 1.1). In August 2015, the Federal Energy Regulatory
Commission (FERC) issued a temporary variance that raises the target elevation to 743 feet PD
from August 15 through September 15 and to 742 feet PD from October 1 through October 15. In
2016, it is expected that the Grand River Dam Authority, who own and operate the dam, will apply
to FERC for a permanent change to the rule curve. Two previous studies have been conducted
to evaluate the effects of the rule curve change, both of which suffer from limitations that reduce
the reliability of the results with respect to flood impacts associated with Pensacola Dam on
flooding in the City of Miami. One of the studies was a Master of Science thesis at the University
of Oklahoma (OU) (Dennis, 2014) and the other was performed by FERC Division of Dam Safety
and Inspections (D2SI-Atlanta) as an independent evaluation of the OU thesis.
The OU thesis included development of a HEC-RAS model of the Neosho River system and major
tributaries from Pensacola Dam to the Commerce gage. The OU results for the 25-year peak
discharge (50,750 cfs) indicated that the water-surface elevations in the Miami area would only
be about 0.04 feet higher with the lake level held at 743 feet PD than they would if the lake level
was held at 741 feet PD. The OU analysis suffered from a number of significant limitations. The
bathymetry data for the reach between Twin Bridges and Commerce gage was developed from
a 1996 U.S. Army Corps of Engineers hydraulic model, and these data do not account for the
deposition that has occurred at the head of Grand Lake over the past two to three decades. The
model was calibrated using unsteady-flow simulations for known floods, but the actual runs that
were used to evaluate the rule curve changes were made in steady-state mode with constant
water-surface elevations at the dam throughout the flood of 741 feet PD, 742 feet PD and 743
feet PD. The assumption of constant lake levels at the three relatively low elevations and the
assumption of steady-state backwater conditions are not realistic. The lake levels rose
significantly above the indicated level during all of the actual floods that were used in the
calibration; the dynamic effects of hydrograph movement through the reach also affect the watersurface elevations. The FERC study recognized some of the limitations of the OU Study, and as
a result, FERC performed their own analysis using unsteady-flow modeling with Grand Lake stage
hydrographs that were developed from recorded pool elevations and dam releases. FERC made
some minor modifications to the OU model, but the bathymetry and overbank topography are
essentially the same. While the OU model extends from Pensacola Dam to the Commerce Gage,
the FERC model eliminated the portion of Grand Lake between Pensacola Dam and Twin
Bridges, assuming that the lake elevation at Twin Bridges would be the same as the elevation at
vii
the dam. Modeling by Tetra Tech, with confirmation from the available high-water marks, indicates
that the water-surface elevation at Twin Bridges is typically several feet higher than at the dam.
FERC concluded that the differences in water-surface elevation resulting from the rule-curve
changes would be relatively small and in the same general range at the OU study. FERC’s underestimation of the water-surface elevation at the Twin Bridges, however, results in unrealisticallylow water-surface elevations and flood inundation levels in the vicinity of Miami
In 2015, Tetra Tech conducted a study to evaluate the impacts of Pensacola Dam on flooding
along the Neosho River between Twin Bridges and the Commerce Gage, focusing on the
adequacy of the existing flood easements. The study included collection of new bathymetry data
and calibration of the with-dam (i.e., existing conditions) model to known floods. The modeling
was performed using the HEC-RAS 5.0 Beta software that includes both 1-dimensional (1-D) and
2-dimensional (2-D) capabilities. A second pre-dam conditions model was also developed using
the available pre-dam topographic and bathymetric data. Among other key finding, the Tetra Tech
(2005) study showed that the currently-held flowage easements are approximately 12,900 acres
less than needed to account for the backwater effects associated with Pensacola Dam in the area
between Twin Bridges and the Commerce Gage. The current study that is the subject of this
report was performed using the Tetra Tech (2015) 1-D/2-D, existing conditions model to evaluate
the rule curve changes.
Four specific floods were evaluated in the analysis, three of which were the same as floods
considered by FERC [October 1996 (peak discharge = 101,000 cfs), September 1993 (peak
discharge = 74,200 cfs), October 2009 (peak discharge = 46,300 cfs)] and the fourth flood
occurred in December 2015 (peak discharge = 44,000 cfs). Similar to the approach used by
FERC, water-surface elevation hydrographs at Pensacola Dam were developed using ModifiedPuls routing with known inflows and Pensacola Dam gate operations, with a range of lake levels
at the beginning of the flood, including the actual elevation and alternative scenarios with the
starting elevation at 741 feet PD and 743 feet PD.
Summary of Findings
Results from the study indicate the following with respect to flooding effects along the Neosho
River in the vicinity of Miami associated with the proposed rule curve change at Pensacola Dam:
1. The difference in maximum water-surface elevation at the Miami gage, located on the State
Highway 125 Bridge on the southwest side of Miami, between the 741 feet PD and 743 feet
PD starting lake levels range from 0.02 feet for the October 1986 flood to 0.17 feet for the
December 2015 flood.
2. The predicted maximum water-surface elevation (WSE) at the Miami gage exceeded the flood
easement elevation of 760 feet for each of the four modeled floods for both the 741 feet PD
and 743 feet PD starting lake levels. The depth of flooding above the 760-foot elevation
ranged from approximately 1.2 feet for the October 2009 flood to 12.3 feet for the October
1986 flood.
3. The duration of flooding above the 760-foot easement elevation at the Miami gage increased
by up to 3 hours (October 2009 flood) under the 743 feet PD condition compared to the 741
feet PD condition.
4. The increase in flood inundation area between the 741 feet PD and 743 feet PD conditions
ranged from 18 acres for the October 1996 event to 102 acres for the December 2015 flood
event.
5. A comparison with the FERC results indicated the magnitude of the difference in water-surface
elevations between the 741 feet PD and 743 feet PD conditions was very similar for the 3
concurrent floods; however, this study indicates that the water-surface elevations at the Miami
gage would be 0.5 feet to 2.9 feet higher than those predicted by FERC.
viii
1
INTRODUCTION
The City of Miami, Oklahoma, and surrounding area has been subjected to several floods over at
least the past three decades that have caused extensive property damage (Table 1.1). The
flooding in the vicinity of Miami has been exacerbated by the construction of Pensacola Dam.
Table 1.1. Named flood events and associated peak discharge.
Flood
Date
1986
1
2
3
4
1993
5
6
7
8
9
10
11
12
13
14
2007
2009-1
2009-2
2013
2015-1
2015-2
9 September - 11 October, 1986
18-19 November, 1992
9-21 December, 1992
18-30 March, 1993
6-23 April, 1993
8-26 May, 1993
29 June – 14 July, 1993
7-20 April, 1994
26 April - 11 May, 1994
17-28 November, 1994
5-16 May, 1995
17 May - 2 June, 1995
7-20 June, 1995
23 June - 7 July, 1995
28 June - 8 July, 2007
27 April - 5 May, 2009
7-14 October, 2009
30 May – 5 June, 2013
23 May – 4 June, 2015
27 December – 1 January 2016
Peak Flow at Commerce Gage
(cfs)1
101,000
33,700
45,600
14,700
19,500
74,200
40,000
21,700
81,700
106,000
43,800
34,3700
35,900
33,700
70,500
22,200
141,000
64,500
46,300
57,800
46,100
44,000
1
All values are published USGS peak hourly flows, except for the 1986 and 1993 floods, which are the
mean daily values.
In August 2015, the Federal Energy Regulatory Commission (FERC) issued a temporary variance
to the seasonal rule curve. Seasonal rule curves specify the target maximum water-surface
elevation of each reservoir throughout the year. The seasonal rule curve that was in effect for
Pensacola Dam from 1996 through August 2015 established target maximum water-surface
elevations that vary from 741 feet Pensacola Datum (PD) from September 1 through October 15
to 744 feet PD from June 1 through July 31 (Figure 1.1). The recently issued temporary variance
raises the target elevation to 743 feet PD from August 15 through September 15 and to 742 feet
PD from October 1 through October 15. In 2016, it is expected that the Grand River Dam Authority,
who own and operate the dam, will apply to FERC for a permanent change of the rule curve.
1
Construction of Pensacola Dam that created Grand Lake was completed by the Grand River Dam
Authority (GRDA) in 1940. Acquisition of flood easements between elevations 750 and 760 feet
NGVD29, encompassing a total area of 11,700 acres, was completed in 1947.
A Preliminary Planning Report by the Corps of Engineers (USACE) in 1948 indicated that an
additional 11,750 acres of lands extending up to elevation 769 feet NGVD29 should be acquired
for operation of the project for flood control; however, for a variety of reasons, including lack of
complaints from people in the affected area in the 1950s, the acquisition was not completed.
Following the September 1986 flood, public concern and frustration about Grand (Neosho) River
flooding and the Grand Lake easement issue were elevated (USACE, 1998), and this eventually
led to completion of the USACE (1998) Real Estate Adequacy Study. The technical analysis that
was performed for USACE (1998) based on a Land Acquisition Flood (LAF) with an average
recurrence interval of once in 50 years concluded that using current criteria and based on current
lake operations, additional flowage easements would be recommended if Grand Lake was a “new”
project.
In 2015, Tetra Tech conducted a study to evaluate the impacts of Pensacola Dam on flooding
along the Neosho River between Twin Bridges and Pensacola Dam. Two different hydraulic
models were developed for the 2015 study to represent (1) with-dam (i.e., existing) conditions
(Figure 1.2) and (2) pre-dam conditions (i.e., before construction of the dam). The significant
results of the 2015 study included the following:
1. Based on the USGS gage data and the with-dam model results, the maximum water-surface
elevation (WSE) at the Miami gage that is located on the State Highway 125 Bridge on the
southwest side of Miami exceeded the flood easement elevation of 760 feet during five of the
six modeled floods: June 1995, June-July 2007, April-May 2009, October 2009, May-June
2013. Under pre-dam conditions, the water-surface elevations at the Miami gage would have
exceeded the flood easement elevation during only three of the six modeled floods: June
1995, June-July 2007, and April-May 2009. The water-surface elevations at the Miami gage
under with-dam conditions are 3.5 feet (May 2013) to 5.9 feet (June-July 2007) higher than
they would have been under pre-dam conditions.
2. The duration of overbank inundation in the Miami area is significantly longer under with-dam
conditions than it would have been under pre-dam conditions.
3. Based on the model results and the USACE guidance for reservoirs, the Guide Take Line
would be set at an elevation of approximately 778 feet if Pensacola dam were considered a
new Federal project. This is approximately 18 feet higher than the existing easement line at
760 feet.
4. Using the USACE real estate and reservoir criteria, the currently-held flowage easements are
approximately 12,900 acres less than needed to account for the backwater effects associated
with Pensacola Dam in the area between Twin Bridges and the Commerce Gage.
Due to the inadequate flowage easements and because flooding regularly exceeds the 760-foot
easement elevation, the City of Miami is concerned that the rule curve change will further
exacerbate flooding conditions in and near the City.
1.1
Study Objectives and Tasks
At the request of the City of Miami, Tetra Tech, Inc. used the previously-discussed 2015 model to
assess the reasonableness of the analyses that were performed by Alan Dennis at the University
of Oklahoma [subsequently referred to as the OU (2014) study], and by the Federal Energy
Regulatory Commission (FERC) of the recent change in the Pensacola Dam rule curve.
For completeness, the description of the available data, model development and calibration that
was included in the Tetra Tech (2015) report are in this report.
2
The work performed for this study included the following tasks:
1. Review of the OU (2014) and FERC studies.
2. Validation of the previously-calibrated hydraulic model for the December 2015 flood using
measured water-surface elevations at the Miami and Commerce Gages, reported operations
at Pensacola Dam, and high-water marks collected at various locations in the vicinity of Miami
near the flood peak.
3. Development of lake elevation hydrographs at Pensacola Dam for starting water-surface
elevations of 741 feet PD and 743 feet PD.
4. Model runs using the 741 feet PD and 743 feet PD starting lake elevations for the four floods,
including three floods that were specifically analyzed by FERC (October 1986, September
1993, and October 2009) and the December 2015 flood.
Comparison of the model output was conducted to assess the effects of the rule-curve change on
flood inundation boundaries, depths and durations.
1.2
Authorization
This study was performed by Tetra Tech Inc. under a contract with the City of Miami, OK. Mr.
Dean Kruithof was the Project Manager for the City. Tetra Tech technical staff who contributed to
the work included:



Dr. Robert A. Mussetter, PE, Principal Engineer, Project Manager
Dr. Dai B. Thomas, PE (Colorado), Senior Engineer
Mr. Ted Bender, PE (Colorado), Staff Engineer
3
Figure 1.1.
Proposed temporary variance from the Article 401 reservoir elevation rule curve
requirements for the Pensacola Project (copied from FERC, 2015)
4
Figure 1.2. Map of study area showing limits of the HEC-RAS model.
5
2 EVALUATION OF THE OU (2014) AND FERC (2015)
STUDIES
Both the OU (2014) and FERC (2015) studies suffer from limitations that reduce the reliability of
the results with respect to potential flood in the City of Miami associated with the rule-curve
changes.
2.1
OU (2014) Study
The OU (2014) study was performed by Mr. Alan Dennis for his M.S. Thesis. Mr. Dennis
developed a HEC-RAS model of the Neosho River system and major tributaries from Pensacola
Dam to Commerce gage to answer the following basic question:
What effect would a proposed rule curve adjustment at Pensacola Dam have on
upstream water surface elevations during extreme streamflow events in the Grand
Lake region?
The bathymetry data for the Neosho River between Twin Bridges and the Commerce gage were
developed from a 1996 U.S. Army Corps of Engineers hydraulic model. The reservoir bathymetry
was based on the 2008 hydrographic survey conducted by the Oklahoma Water Resources Board
(2009), and the overbank topography was based on a LiDAR survey conducted by the U.S.
Geological Survey by Dewberry (2011).
The OU model was calibrated in unsteady mode (i.e., by simulating the hydrograph) for the
September 2009 flood (peak discharge of 44,600 cfs) so that the magnitude and timing of the
predicted water-surface elevations during the hydrograph at the Miami gage matched the
recorded water-surface elevations. Input to the OU model included recorded flows at the
Commerce gage as well as the recorded flows at the Tar Creek at 22nd Street Bridge at Miami,
OK (USGS Gage No. 07185095), Spring River near Quapaw, OK (USGS Gage No. 07188000)
and Elk River near Tiff City, MO (USGS Gage No. 07189000).
The OU study included a flood-frequency analysis of the maximum discharges that have been
recorded at the Commerce gage during the period of the year that would be affected by the rule
curve adjustment (i.e., August 15 through October 15). This analysis provided estimates of the
peak flows for a range of flood events with average recurrence intervals ranging from 2 years to
500 years. In spite of the unsteady flow “calibration”, the portion of the analysis on which the
conclusions were based was performed by assuming steady flows with a constant lake level set
at either 741 feet PD or 743 feet PD, and held constant throughout the flood.
The OU results for the 25-year peak discharge (50,750 cfs during the period of the year affected
by the rule curve) indicated that the water-surface elevations in the Miami area would only be
about 0.04 feet lower with the lake level at 741 feet PD than they would if the lake level was at
743 feet PD.
Limitations of the OU (2014) Study include the following:
1. The modeling was performed using the 1-D, HEC-RAS model. While this is a standard model
for conducting flood inundation analyses, the 1-D flow formulation is not well suited to
analyzing flooding in the Neosho River because of the large floodplain area and complex flow
patterns. A 2-D formulation is much better suited to the problem. This issue was clearly
recognized many years ago and is the primary reason that both Holly (2001) and Tetra Tech
have used 2-D modeling to evaluate flooding impacts along the Neosho River. Mr. Dennis
partially justified the one-dimensional approach by noting that HEC-RAS has been approved
for use in flood studies by the Federal Emergency Management Agency (FEMA). While this
is true, FEMA also recognizes that 1-D analysis is not always appropriate, and as a result,
has approved a number of 2-D models for use in such studies.
6
2. There is a disconnect between the unsteady-flow “calibration” and the steady-flow analysis
on which the conclusions are based. In short, showing that the unsteady model reproduces
the water-surface elevation hydrograph for a particular flood does not demonstrate that the
steady-state model is well calibrated.
3. The conclusions from the OU (2014) study state that the water-surface elevations from the
steady-state model, and therefore, the conclusions, are conservative. It may be true that the
predicted water-surface elevations for the scenarios that were considered are conservatively
high, but this does not mean that the differences between scenarios are conservative. In fact,
use of “conservatively–high” water-surface elevations for comparative scenarios likely
decreases the differences between scenarios.
4. Use of constant Grand Lake water levels for the simulations is not realistic. Based on the
configuration of the Pensacola Dam outlet works, it would be physically impossible to maintain
the lake level at the assumed elevations for the size of floods that were modeled. As a result,
the steady-state model results are not meaningful with respect to the basic question.
5. The bathymetric data for the river are nearly two decades old; thus, they do not account for
sedimentation that has occurred at the head of the reservoir that affect flood-carrying capacity
of the upstream river.
2.2
FERC (2015) Study
Information provided to support the FERC (2015) study included hydrologic and hydraulic
modeling performed by FERC D2SI-Atlanta staff.
In performing the analysis, FERC reviewed the OU (2014) HEC-RAS model, and concluded that
the model “should be assessed further because it does not account for storm composition, there
are questions with the input data of the model, and the model assumed constant downstream
boundary conditions … The study recognizes the possible benefit of further evaluation with
dynamic reservoir routing, i.e., the reservoir elevation varying due to dam outflows and upstream
tributary inflows.” Furthermore “…the use of steady flow routing, fixed downstream boundary
conditions, and HEC-RAS input discrepancies call into question the reliability of the study results.
Because of this concern, staff (FERC) completed independent analyses to confirm the
conclusions in the report”.
FERC staff used a modified version of the OU (2014) model to perform their analysis. The
modifications included removing cross sections to improve numerical stability of the model,
adjusting bridge geometry to better match actual conditions, adjusting the Manning’s n-roughness
values to improve calibration, and most significantly, reducing the length of the modeled reach to
eliminate the portion of Grand Lake downstream from U.S. Highway 60 (aka, Twin Bridges).
FERC evaluated the impacts of the rule curve change by performing unsteady flow routing of the
October 1986, September 1993 and October 2009 floods for four different starting reservoir
elevations, which represent recorded conditions and three hypothetical starting reservoir
elevations of 741 feet PD, 742 feet PD and 743 feet PD. These floods had peak flows at the
Commerce gage of 101,000 cfs, 81,700 cfs and 46,300 cfs, respectively. The modeled reservoir
elevations for the four conditions were directly applied to the downstream model boundary, which
effectively assumes no change in water-surface elevation over the approximately 52-mile reach
between Pensacola Dam and Twin Bridges. FERC staff compared the predicted water-surface
elevations at the Miami gage for each starting water-surface elevation for each of the floods, and
concluded that the largest differences of approximately 0.2 feet occurred between the 741 feet
PD and 743 feet PD starting-conditions runs for the October 2009 flood.
As will be discussed further in Section 5.3.3, the assumption of constant water-surface elevation
between the dam and Twin Bridges is not correct because both the available data and Tetra
Tech’s modeling of the full length of the reservoir indicate a significant rise in water surface
7
between these two points. While this does not have a significant effect on predictions of the
incremental increase in flooding associated with the change in rule curve, it does result in underprediction of the extent to which Pensacola Dam and Grand Lake influence the amount of flooding
in the Miami area.
8
3 FLOW AND STAGE DATA
Flow and stage data applied as input to the hydraulic models were obtained from records available
from the U.S. Geological Survey (USGS) National Water Information website
(http://waterdata.usgs.gov/nwis) and the USACE Pensacola Dam website (http://www.swtwc.usace.army.mil/PENScharts.html). The USGS operates six gages in the study reach that are
specifically relevant to this analysis (Figure 3.1):






Neosho River near Commerce, Oklahoma (USGS Gage No. 07185000)
Neosho River at Miami gage (USGS Gage No. 07185080)
Tar Creek at Miami, OK (USGS Gage No. 07185095)
Spring River near Quapaw, OK (USGS Gage No. 07188000)
Elk River near Tiff City, MO (USGS Gage No. 07189000)
Lake O’ The Cherokees at Langley, OK (USGS Gage No. 0719000)
The USACE website reports water-surface elevations, flow releases and other data for Grand
Lake O’ The Cherokees at Pensacola Dam.
To facilitate certain aspects of the analysis and to aid in identifying the location of key features
along the reach, a station line was developed to provide accurate distances along the river. The
downstream end of the station line (Sta 0) is at Pensacola Dam. Table 3.1 lists the stationing of
key features along the stationline.
Table 3.1.
Stationing of key features along the project reach.
Station
(ft)
0
124,305
143,000
Pensacola Dam
Sailboat Bridge
Elk River
228,360
Railroad Bridge
199,000
229,560
231,200
252,890
290,300
291,200
294,500
297,950
298,990
299,320
299,660
301,570
351,900
387,500
Downstream limit of pre-dam model
Spring River
Highway 60 Bridge
S 590 County Road (Connors) Bridge
Will Rodgers Bridge
Tar Creek Confluence
Abandoned Railroad Bridge
Low-water dam
Highway 125 Bridge
Miami Gage
Burlington Northern Railroad Bridge
Highway 69 Bridge
Commerce Gage
Upstream end of model
Feature
The Commerce gage is located at the Stepps Ford Bridge near the upstream end of the model
reach. Data available from the USGS NWIS website and Instantaneous-Data archive for this gage
include hourly stage and discharge values dating back to April 1990, and mean daily and annual
9
peak discharges dating back to October 1939. The stage data are reported in the National
Geodetic Vertical Datum of 1929 (NGVD29).
The Miami gage is located at the Highway 125 Bridge in the City of Miami (Sta 299,320). Due to
the backwater effects from Grand Lake, only stage values are reported at this location. Hourly
stage values are available for the entire period of record beginning in October 1994. Although the
NWIS website indicates that the datum for the Miami gage is referenced to NGVD29, field surveys
to support this and previous Tetra Tech studies indicate that the datum is actually reported in the
GRDA Pensacola Datum (PD). The reported values were, therefore, converted to NGVD29 for
use in this analysis by adding 1.07 feet so that they are consistent with the Commerce data and
the mapping and other data used for the modeling.
The USACE Grand Lake O’ The Cherokees and USGS Lake O’ The Cherokees gage is located
on Pensacola Dam approximately 44 miles downstream from U.S. Highway 60. The GRDA
website reports lake levels in PD twice daily at 8am and midnight. Lake storage, power and total
release rates and inflows, among other data, are reported once daily. Data for this gage are
available on the website back to November 1994. The USGS website for this gage reports hourly
stage (in PD) and reservoir storage values back to October 2007 and daily reservoir storages
back to March 1940. The stage values were also converted to NGVD29 by adding 1.07 feet.
The Tar Creek at Miami gage is located at the 22nd Street Bridge in Miami. Data available from
the USGS NWIS website and Instantaneous-Data archive for this gage include hourly stage
dating back to 2007 and mean daily and annual peak discharges dating back to 1984.
The Spring River gage is located approximately 12 miles upstream from the confluence with the
Neosho River. Data available from the USGS NWIS website and Instantaneous-Data archive for
this gage include hourly stage dating back to 2007 and mean daily and annual peak discharges
dating back to 1939.
The Elk River gage is located approximately 12 miles upstream from the confluence with the
Neosho River. Data available from the USGS NWIS website and Instantaneous-Data archive for
this gage include hourly stage dating back to 2007 and mean daily and annual peak discharges
dating back to 1939.
3.1
Flood Hydrographs
The model was calibrated to seven floods that represent a range of peak discharges and flood
durations: May 1995 (referred to in previous studies as Flood 11), June 1995 (Flood 13), JuneJuly 2007, April-May 2009, October 2009, May-June 2013 and December 2015 (Table 3.2).
To evaluate the change in the rule curve, the hydraulic model was run over the same 3 floods
evaluated by FERC (October 1986, September 1983 and October 2009) and December 2015
flood (Table 3.2).
The reported data at the Commerce gage for each of the modeled floods were used for the
inflowing discharge hydrograph at the upstream end of the model for all of the model runs, and
the reported stage values at this location were also used to aid in the calibration. The lake levels
at Pensacola Dam were used to represent the downstream boundary conditions. The Miami gage
only reports stages due to the confounding effects of backwater from Grand Lake; data from this
gage were used to aid in calibrating the model.
According
to
the
NOAA
Advanced
Hydrologic
Prediction
Service
website
(http://water.weather.gov/ahps2/hydrograph.php?wfo=tsa&gage=COMO2), the flood action
stage at the Commerce gage is 14 feet which corresponds to a discharge of 20,500 cfs. For
purposes of this study, the bankfull discharge was, therefore, assumed to be 21,000 cfs.
10
The following sections provide a brief description of each of the modeled floods.
Table 3.2.
Peak discharge and duration of flow exceeding bankfull discharge (21,000
cfs) at the Commerce Gage.
Peak
Days
Comment
Flood
Discharge (cfs)
>Bankfull
October 1986
101,0001
12 Rule Curve Analysis
1
September 1993
74,200
6 Rule Curve Analysis
May 1995
35,900
4.1 Calibration
June 1995
70,500
15.4 Calibration
June-July 2007
141,000
9.8 Calibration
April-May 2009
64,500
10.0 Calibration
October 2009
46,300
4.3 Calibration, Rule Curve Analysis
May-June 2013
57,800
9.6 Calibration
December 2015
44,000
2.0 Rule Curve Analysis
1
Mean Daily Flow
October 1996
The October 1986 flood had a peak mean daily discharge of 101,000 cfs that occurred on October
6, 1986 (Figure 3.2). No stage data were available at the Commerce gage or the Miami gage for
this flood. The discharge at the Commerce gage exceeded 21,000 cfs for approximately 12 days
(Table 3.2).
The peak mean daily flow discharge at Spring River was 96,400 cfs, the peak at Elk River was
28,800 cfs, and the peak inflow at Tar Creek was 3,340 cfs.
Hourly lake levels at Pensacola Dam were obtained from the FERC (2015) analysis. The
maximum reported lake level at Pensacola Dam of 756.04 feet occurred on October 6 (Table
3.3).
Table 3.3. Starting and maximum lake level elevation over the duration of the floods.
Flood
October 1986
September 1993
May 1995
June 1995
June-July 2007
April-May 2009
October 2009
May-June 2013
December 2015
Starting WSE
(ft)
743.1
744.9
747.5
748.7
746.8
746.0
742.1
745.0
743.9
Maximum WSE
(ft)
756.0
755.6
751.9
756.0
755.6
751.7
750.7
748.7
756.0
September 1993
The September 1993 flood had a peak mean daily discharge of 74,200 cfs that occurred at
September 27, 1993 (Figure 3.3). No stage data were available at the Commerce gage or the
Miami gage for this flood. The peak mean daily flow discharge at Spring River was 210,000 cfs,
the peak at Elk River was 11,000 cfs, and the peak inflow at Tar Creek was 8,200 cfs (Figure 3.3).
11
Hourly lake levels at Pensacola Dam were obtained from the FERC (2015) analysis. The
maximum reported lake level at Pensacola Dam of 755.57 feet occurred on September 27 (Table
3.3).
May 1995 (Flood 11)
The May 1995 flood had a peak discharge of 35,900 cfs and maximum stage of 768.7 feet at the
Commerce gage that occurred at 3am and 6am, respectively, on May 10 (Figure 3.4).
The discharge at the Commerce gage exceeded 21,000 cfs for approximately 99 hours
(approximately 4 days) (Table 3.1). The peak stage at the Miami gage of 758.6 feet occurred
between 3p.m. and 6p.m. on May 10. The maximum reported lake level at Pensacola Dam of
751.87 feet occurred on May 11 (Table 3.3). The unusually low reported stages at the Miami gage
for approximately 40 hours during May 8 and the early part of May 9 compared to the stages at
the Commerce gage appear to be anomalous and may indicate a problem with the stage recorder
during this period. The reported Miami stage values were used in the comparisons with the
predicted model stages. No discharge records were available at the Tar Creek gage; a constant
discharge of 10 cfs was input to the model to represent Tar Creek flows.
June 1995 (Flood 13)
The June 1995 flood had a peak discharge of 70,500 cfs, and the maximum stage of 772.2 feet
at the Commerce gage occurred at noon on June 12, 1995 (Figure 3.5). The discharge at the
Commerce gage exceeded the bankfull discharge of approximately 21,000 cfs for 370 hours
(approximately 15.4 days) during this event (Table 2.1).
The peak stage of 767.47 feet at the Miami gage occurred at 7pm on June 12, and the maximum
reported lake level at Pensacola Dam gage of 755.8 feet occurred on June 14 (Table 3.2). The
760-foot flood easement elevation was exceeded at the Miami gage for more than 6 days during
this flood. No discharge records were available at the Tar Creek gage; a constant discharge of 10
cfs was input to the model to represent Tar Creek flows.
June-July 2007
The June-July 2007 flood had a peak discharge of 141,000 cfs at the Commerce gage that
occurred at 6am on July 3; however, the maximum reported stage of 787.22 feet occurred at
midnight on July 4 (Figure 3.6). The bankfull discharge at the Commerce gage was exceeded for
approximately 235 hours (10 days) during this event (Table 3.1). The USGS data indicate that the
stages during the rising limb of the flood hydrograph were in the range of 1 to 1.5 feet lower than
on the falling limb when the Pensacola Lake levels were higher, confirming earlier findings that
backwater from Grand Lake can extend as far upstream as the Commerce gage under certain
conditions (Mussetter, 1998) (Figure 3.7). The peak stage of 774 feet at the Miami gage occurred
at 4am on July 4, and the maximum lake level at Pensacola Dam of 755.61 feet occurred on July
8 (Table 3.2). The 760-foot flood easement elevation was exceeded at the Miami gage for 40
hours during the event.
The reported 50-year peak flow event at the Commerce gage is 150,000 cfs (USACE, 1986). The
2007 flood, with a peak discharge of 141,000 cfs, approximates the 50-year peak flow event.
April-May 2009
The April-May 2009 flood had a peak discharge of 64,200 cfs and maximum stage of 771.18 feet
at the Commerce gage, both of which occurred on May 2, 2013 at 9am and 1pm, respectively
(Figure 3.8). The discharge at the Commerce gage exceeded 21,000 cfs for approximately 240
hours (approximately 10 days) (Table 3.1). The peak stage at the Miami gage of 765.0 feet
occurred at 6am on May 3, 2009, and the maximum lake level at Pensacola Dam of 751.7 feet
occurred on May 5 (Table 3.2). The 760-foot flood easement elevation at the Miami gage was
12
exceeded for over 3.6 days (87 hours) during this event. The peak flows at the Elk River and
Spring River gages was 7,170 and 22,800 cfs, respectively.
October 2009
The October 2009 flood had a peak discharge of 46,100 cfs and maximum stage of 769.46 feet
at the Commerce gage, both of which occurred at midnight on October 11, 2009 (Figure 3.9).
The discharge at the Commerce gage exceeded 21,000 cfs for approximately 107 hours
(approximately 4.5 days) (Table 3.1). The peak stage at the Miami gage of 761.09 feet occurred
at 6am on May 3, 2009, and the maximum lake level at Pensacola Dam of 751.7 feet occurred on
October 12 (Table 3.2). The 760-foot flood easement elevation at the Miami gage was exceeded
for over 1.75 days (42 hours) during this event. The peak flows at the Tar Creek gage was 4,630
cfs, at the Elk River gage the peak flow was 39,000 cfs, and the peak flow at the Spring River
gage was 66,200 cfs.
May-June 2013
The May-June 2013 flood had a peak discharge of 60,000 cfs and maximum stage of 770.97 feet
at the Commerce gage, both of which occurred at 9pm on June 2, 2013 (Figure 3.10). The
discharge at the Commerce gage exceeded 21,000 cfs for approximately 239 hours
(approximately 9.6 days) (Table 3.1). The peak stage at the Miami gage of 763.02 feet also
occurred at 10pm on June 2, 2013, and the maximum lake level at Pensacola Dam of 748.7 feet
occurred on June 4 (Table 3.2). The 760-foot flood easement elevation at the Miami gage was
exceeded for over 2 days (55 hours) during this event. The peak flows at the Tar Creek gage was
3,060 cfs, at the Elk River gage the peak flow was 2,840 cfs, and the peak flow at the Spring River
gage was 43,500 cfs.
December 2015
For the December 2015, the USGS reported stage data at the Commerce Gage over the full
duration of the flood, but did not report discharge values between noon on December 28 and 12
am on January 2 due to “backwater” at the gage (Figure 3.11). It is not clear why the USGS
reported backwater conditions for the relatively low peak flow event. Previous analyses indicated
that backwater-water conditions occur during relatively high flow events, such as the 2007 flood,
which had a peak flow of 141,000 cfs.
The peak stage of 769.27 feet at the Commerce Gage occurred at 10:30 pm on December 28,
2015, 10.5 hours after the last reported discharge measurement when the stage was 0.26 feet
lower. To facilitate the analysis, the missing discharge values were estimated by fitting a linear
regression curve through the nearest reported stage-discharge pairs. Although this method is not
strictly appropriate under backwater conditions, since the missing data occur near peak stage and
on the falling limb of the hydrograph, it is likely that errors in the predicted discharge are relatively
minor. The resulting flood hydrograph had an estimated peak discharge of 44,000 cfs at the
Commerce Gage (Figure 3.11). The discharge exceeded 21,000 cfs for approximately 94 hours
(approximately 3.9 days) (Table 3.1).
The resulting flood hydrograph had an estimated peak discharge of 44,000 cfs at the Commerce
Gage (Figure 3.11). The discharge exceeded 21,000 cfs for approximately 94 hours
(approximately 3.9 days) (Table 3.1). The peak stage at the Miami gage of 763.42 feet occurred
at 5 pm on December 29, 2015, and the maximum lake level at Pensacola Dam of 756.99 feet
occurred on December 29 (Table 3.2). The 760-foot flood easement elevation at the Miami gage
was exceeded for over 2 days (63 hours) during this event. The peak discharge at the Tar Creek
gage was 4,790 cfs. The inflows at the Elk River and Spring River were very high, with peak
inflows of 105,000 cfs and 151,000 cfs, respectively.
13
3.2
Development of 741 feet PD and 743 feet PD Flood Hydrographs
To evaluate the rule curve changes, stage hydrographs at Pensacola Dam were developed for
starting water-surface elevations of 741 feet PD and 743 feet PD for each of the four floods. The
stage hydrographs for the October 1986 and September 1993 flood events were taken from the
FERC (2015) analysis. Although FERC developed stage hydrographs for the October 2009 event,
the water-surface elevations used to represent existing conditions did not match values reported
by the USACE or GRDA. As a result, Tetra Tech developed new stage hydrographs for this flood.
Hydrographs were also developed for the December 2015 event using the reported data and
similar computational procedures.
Both FERC and Tetra Tech used similar methods to develop the 741 feet PD and 743 feet PD
hydrographs that involved a mass balance analysis (similar to the modified-Puls flow routing),
which calculates the reservoir elevations based on an initial water-surface elevation, reservoir
inflows, water-surface versus outflow rating-curves for various gate operations, and a watersurface versus reservoir storage rating curve. This method assumes that the water-surface
elevation is the same over the entire reservoir and does not take into account routing of the flood
through the reservoir. The mass-balance analysis was initially calibrated by comparing the
predicted and reported water-surface elevations at Pensacola Dam for each flood events.
A limitation of the analysis is that is not possible to predict how the gates would have been
operated under the different scenarios. As a result, the same gate operations were used for the
each of the three starting water-surface elevation conditions.
October 1986
For the October 2009 flood, the calibrated flood hydrograph from the FERC analysis matches
reasonably well to the measured values. Under existing conditions, the predicted maximum watersurface elevation of 756.0 feet matches the measured value (Table 3.4), however the timing of
the predicted hydrograph is lagged by approximately 4 hours (Figure 3.12).
The maximum lake level with starting water-surface elevations of 741 feet PD and 743 feet PD is
755.8 feet and 756.1 feet, respectively; a difference of 0.3 feet (Table 3.4).
Table 3.4.
Flood Event
Oct. 1986
Sept. 1993
Oct. 2009
Dec.2015
Comparison of the measured and predicted maximum lake level elevation for the
existing conditions, the maximum lake elevation with starting water-surface
elevations of 741 feet PD and 743 feet PD, and difference in maximum lake
elevation between the 741 feet PD and 743 feet PD conditions for the October
1986 flood.
Difference
Recorded
Predicted
Predicted
Predicted
in Peak
Peak
Peak for
Peak for
Peak WSE
Peak WSE
WSE (ft)
Discharge
Existing
Existing
with Starting with Starting
(743 feet
(cfs)
Conditions Conditions WSE at 741 WSE at 743
PD – 741
WSE (ft)
WSE (ft)
feet PD
feet PD
feet PD)
101,000*
756.0
756.0
755.8
756.1
0.3
74,200*
755.6
755.6
755.0
755.4
0.4
46,100
750.7
750.6
750.6
751.3
0.7
44,025
756.1
756.0
755.5
756.0
0.5
*Mean Daily Flow
14
September 1993
For the September 1993 flood, the predicted maximum water-surface elevation of 755.6 feet from
the FERC analysis matches the measured value (Table 3.4). Similar to the October 1986 flood,
the predicted hydrograph lags the measured hydrograph by approximately 4 hours (Figure 3.13).
The maximum lake level with starting water-surface elevations of 741 feet PD and 743 feet PD is
755.0 and 755.4 feet, respectively; a difference of 0.4 feet.
October 2009
As noted above, Tetra Tech developed new stage hydrographs for the October 2009 flood event
using the available data. The water-surface elevations and reservoir outflows, including the power
release and spill releases, were obtained from the USACE website (USACE Gage No.: PENO2).
http://www.swt-wc.usace.army.mil/webdata/gagedata/ .
An updated reservoir volume versus water-surface elevation rating curve for lake elevations up
to 745 feet NGVD was taken from Oklahoma Water Resources Board (OWRB, 2009) (Figure
3.14). The OWRB (2009) curve was extended through the flood pool based on recent data
published on the above USACE website. Discharge versus water-surface elevation rating curves
were developed for the primary and auxiliary spillways based on the Plates 7-3 and 7-4 in the
Pensacola Water Control Manual (1992) (Figure 3.15). The routing analysis was calibrated by
adjusting the number of primary and auxiliary gate openings until the predicted outflows and
reservoir elevations matched the recorded values.
The difference in maximum water-surface elevation between the recorded and routed flows is
only about 0.1 feet (Table 3.4, Figure 3.16).
The lake elevation at the start of this flood was very close to 741 feet PD; thus, it was only
necessary to develop an additional hydrograph for the 743 feet PD starting conditions. This was
accomplished by rerunning the analysis using the reservoir inflows and gate operations from the
calibration (Figure 3.17).
The difference in maximum water-surface elevation at the dam between the 741 feet PD and 743
feet PD conditions is 0.7 feet (Table 3.4).
December 2015
The stage hydrographs for the December 2015 flood were calculated using the same method that
was used for the October 2009 flood. Comparison of the measured and routed stage hydrographs
shows a very good match (Figure 3.18). The difference in maximum water-surface elevation
between the recorded and routed flows is 0.1 feet (Table 3.4). Under the 741 feet PD and 743
feet PD conditions, the difference in maximum water-surface elevation is 0.5 feet (Figure 3.19,
Table 3.4).
15
Figure 3.1. Map showing location of stream gages in the vicinity of the study area.
16
120,000
780
Spring River - Discharge
Elk River - Discharge
100,000
775
Commerce Gage - Discharge
Pensacola Dam - WSE
80,000
Discharge (cfs)
765
60,000
760
755
40,000
Pool Elevation (ft, NGVD29)
770
750
20,000
745
0
9/29/1986
Figure 3.2.
740
10/4/1986
10/9/1986
10/14/1986
Discharge and water-surface elevation hydrographs used in the simulations for
the October 1986 flood.
17
250,000
780
775
200,000
Pensacola Dam - WSE
765
150,000
760
100,000
755
Discharge (cfs)
770
750
50,000
745
0
9/24/1993
Figure 3.3.
9/26/1993
9/28/1993
9/30/1993
10/2/1993
740
10/4/1993
the September 1993 flood.
18
50,000
770
Pensacola Dam - WSE
Commerce Gage - WSE
Miami Gage - WSE
45,000
40,000
765
30,000
760
25,000
20,000
755
Discharge (cfs)
35,000
15,000
10,000
750
5,000
0
5/6/1995
Figure 3.4.
5/7/1995
5/8/1995
745
5/9/1995 5/10/1995 5/11/1995 5/12/1995 5/13/1995 5/14/1995 5/15/1995 5/16/1995
the May 1995 flood.
19
90,000
780
80,000
775
Pensacola Dam - WSE
Commerce Gage - WSE
70,000
Miami Gage - WSE
Discharge (cfs)
60,000
765
50,000
40,000
760
30,000
770
755
20,000
750
10,000
0
6/1/1995
Figure 3.5.
6/3/1995
6/5/1995
6/7/1995
745
6/9/1995 6/11/1995 6/13/1995 6/15/1995 6/17/1995 6/19/1995 6/21/1995
the June 1995 flood.
20
780
160,000
WSE - Commerce Gage
WSE - Miami
WSE - Pensacola Dam
140,000
Discharge - Commerce
Elk River (MDF)
Spring River
120,000
770
100,000
765
80,000
760
Discharge (cfs)
Water-surface Elevation (feet NGVD29)
775
60,000
755
40,000
750
745
28-Jun-07
Figure 3.6.
20,000
30-Jun-07
2-Jul-07
4-Jul-07
6-Jul-07
8-Jul-07
0
10-Jul-07
Discharge and water-surface elevation hydrographs used in the simulations for the
June-July 2007 flood.
21
7/3/2007
7/5/2007
7/6/2007
7/2/2007
7/1/2007
7/8/2007
7/9/2007
Gage Height (ft)
20
7/7/2007
30
25
7/4/2007
35
15
10
USGS Reported Hourly Q
5
Reported Discharge at noon on indicated day
USGS Gage Measurements
USGS Rating #12
0
0
25,000
50,000
75,000
100,000
125,000
150,000
Discharge (cfs)
Figure 3.7.
Reported hourly stages from the recording gage at Commerce and stages
corresponding to USGS field-measured discharges during the June-July 2007
flood.
22
70,000
780
60,000
775
Pensacola Dam - WSE
Commerce - WSE
Miami Gage - WSE
770
Discharge (cfs)
765
40,000
760
30,000
755
50,000
20,000
750
10,000
745
0
4/27/2009
Figure 3.8.
4/29/2009
5/1/2009
5/3/2009
5/5/2009
740
5/7/2009
April-May 2009 flood.
23
70,000
780
60,000
775
Pensacola Dam - WSE
Commerce - WSE
Miami Gage - WSE
770
Discharge (cfs)
765
40,000
760
30,000
755
50,000
20,000
750
10,000
745
0
10/8/2009
Figure 3.9.
10/9/2009
740
10/10/2009 10/11/2009 10/12/2009 10/13/2009 10/14/2009 10/15/2009
October 2009 flood.
24
70,000
780
60,000
775
Pensacola Dam - WSE
Commerce Gage - WSE
Miami Gage - WSE
770
Discharge (cfs)
765
40,000
760
30,000
755
50,000
20,000
750
10,000
745
0
5/28/2013 5/30/2013
Figure 3.10.
6/1/2013
6/3/2013
6/5/2013
6/7/2013
6/9/2013
740
6/11/2013 6/13/2013
June 2013 flood.
25
160,000
780
Commerce Gage - Discharge (Measured)
775
140,000
Commerce Gage - Discharge (Predicted)
Pensacola Dam - WSE
Discharge (cfs)
Miami Gage - WSE
770
100,000
765
80,000
760
60,000
755
40,000
750
20,000
745
0
12/24/2015 12/26/2015 12/28/2015 12/30/2015
Figure 3.11.
1/1/2016
1/3/2016
1/5/2016
Commerce Gage - WSE
120,000
740
1/7/2016
December 2015 flood.
26
758
756
754
752
750
748
746
744
Measured
742
Predicted
Predicted 741-PD Starting WSE
Predicted 743-PD Starting WSE
740
9/29/1986 10/1/1986 10/3/1986 10/5/1986 10/7/1986 10/9/198610/11/198610/13/198610/15/198610/17/1986
Figure 3.12.
Comparison of the measured and predicted stage hydrograph at Pensacola Dam,
and predicted stage hydrographs for the 741 feet PD and 743 feet PD starting
water-surface elevations for the October 1986 flood. The data were obtained from
the FERC (2015) analysis.
27
758
756
Pool Elevation (ft, NVGD29)
754
752
750
748
746
744
Recorded
742
Predicted
741-PD Starting WSE
743-PD Starting WSE
740
9/24/1993
Figure 3.13.
9/25/1993
9/26/1993
9/27/1993
9/28/1993
9/29/1993
9/30/1993
10/1/1993
Comparison of the measured and predicted stage hydrograph at Pensacola Dam,
and predicted stage hydrographs for the 741 feet PD and 743 feet PD starting
water-surface elevations for the September 1993 flood. The data were obtained
from the FERC (2015) analysis.
28
Pensacola Dam Water Surface Elevation (feet, NGVD29)
760
750
740
730
720
710
700
0
0.5
1
1.5
2
2.5
Millions
Grand Lake Storage (ac-ft)
Figure 3.14.
Storage versus Water-surface elevation curve for Pensacola Dam based on the
2008 hydrographic survey of Grand Lake (OWRB, 2009).
29
Pensacola Dam Water-Surface Elevation (feet, NGVD29)
760
755
750
745
740
735
1 Main Gate
730
1 Auxillary Spillway
725
0
2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
18,000
20,000
Discharge (cfs)
Figure 3.15.
Water-surface elevation versus discharge rating curves for a main gate and
auxiliary spillway at Pensacola Dam.
30
752
751
750
749
748
747
746
745
744
743
742
Recorded
741
10/8/2009
Figure 3.16.
10/9/2009
Routed
10/10/2009 10/11/2009 10/12/2009 10/13/2009 10/14/2009 10/15/2009
Comparison of the measured and routed stage hydrograph at Pensacola Dam for
the October 2009 flood.
31
752
750
748
746
744
742
Routed - Existing Conditions
741-feet PD
743-feet PD
740
10/8/2009
Figure 3.17.
10/9/2009
10/10/2009 10/11/2009 10/12/2009 10/13/2009 10/14/2009 10/15/2009
Comparison of the routed stage hydrographs at Pensacola Dam for the measured,
741 feet PD and 743 feet PD starting water-surface elevations for the October
2009 flood.
32
758
756
754
752
750
748
746
Recorded - Existing Conditions
744
742
12/25/2015 12/26/2015 12/27/2015 12/28/2015 12/29/2015 12/30/2015 12/31/2015
Figure 3.18.
1/1/2016
Comparison of the recorded and routed stage hydrograph at Pensacola Dam for
the December 2015 flood.
33
758
756
754
752
750
748
746
744
742
741-PD Starting WSE
743-PD Starting WSE
740
12/25/2015 12/26/2015 12/27/2015 12/28/2015 12/29/2015 12/30/2015 12/31/2015
Figure 3.19.
1/1/2016
Comparison of the routed stage hydrographs at Pensacola Dam for the existing,
741 feet PD and 743 feet PD starting water-surface elevations for the December
2015 flood.
34
4 TOPOGRAPHIC DATA
The HEC-RAS hydraulic model requires an input “terrain” that represents the lake bed, channel
bed and overbank topography. The terrain is a Digital Terrain Model (DTM) that consists of square
pixels that represent an area and an associated elevation. The terrain is used to assign elevations
to the grid elements in the model input files, and to map the flood inundation limits from the model
output. The terrain used for the with-dam (i.e., existing) conditions model has a 5-foot (25 ft2) pixel
resolution that was developed from four data sets that cover various parts of the reach: 2008
OWRB Grand Lake Survey, 2011 LiDAR Survey, 2015 Tetra Tech Neosho River survey, and
channel geometry from the 1997 survey of the Neosho River in areas not covered by the Tetra
Tech 2015 survey. Where applicable, all the data sets were converted to the NGVD29 datum. A
more detailed description of each of these data sets is provided in the following sections.
4.1
2008 Grand Lake Survey
The Oklahoma Water Resources Board conducted a bathymetric survey of Pensacola Reservoir
and approximately 4.5 miles of the Neosho River upstream from the confluence of the Spring
River. The survey data were collected between April 2008 and January 2009 and referenced to
the Pensacola Datum. The OWRB used the survey data to develop updated stage versus storage
rating curves for Grand Lake. The updated curves indicate that there has been a decrease in
capacity of approximately 156,588 acre-feet (9.3 percent) between 1940 and 2008/2009 (Figure
4.1). It should be noted that the lake storage values reported for the USGS Lake O’ The
Cherokees website and the storage values reported on the USACE website prior to January 28,
2012, are based on the original stage-storage curve. The USACE-reported values after January
28, 2012 are based on the updated curve.
4.2
2011 LiDAR Data
A high-accuracy Light Detection and Ranging (LiDAR) survey of the Grand lake area was
conducted for the USGS by Dewberry (2011). The survey encompassed the entire area of Grand
Lake and its tributaries, including the Neosho River and overbank areas. The survey data were
referenced to the North American Vertical Datum of 1988 (NAVD88). For purposes of this study,
these data were converted to NAVD29 datum by subtracting 0.33 feet. The LiDAR data are
reported to have a vertical accuracy of ±18.5 cm (~7.3 inches) at the 95-percent confidence level.
4.3
2015 Tetra Tech Survey
Tetra Tech conducted a hydrographic and bathymetric survey of the portion of the study reach
between Twin Bridges and the Stepps Ford Bridge in April 2015 to evaluate topographic changes
within the study reach between 2015 and the previous surveys, including pre-dam surveys
(USACE, 1940) and surveys conducted in 1995 to support earlier flood studies, and to develop
the with-dam conditions HEC-RAS model. During the hydrographic survey period, the discharge
at the Commerce City gage steadily decreased from 1,350 cfs on April 24 to 730 cfs on April 27
(Figure 4.2). Survey control was established along the reach on April 23 and 25; no hydrographic
surveying was conducted on these days.
Horizontal survey control for the project was referenced to benchmarks along the study reach
established in conjunction with USACE surveys conducted in 1998. Based on discussions with
Survey Services (personal communication, May 2015), it is understood that the USACE
benchmarks were surveyed by two different companies; one company established the horizontal
coordinates and the other company established the elevations. During the Tetra Tech survey,
static survey data were collected during each base station setup. In addition, an independent
check was done on a nearby benchmark. The static survey data was sent to Online Positioning
User Service (OPUS) to refine the horizontal coordinates and elevations based on the National
Geodetic Survey (NGS) Continuously Operating Reference Station (CORS) network.
35
The differences between the OPUS and USACE horizontal coordinates at the four USACE
benchmarks was approximately 0.03 feet, indicating very good agreement. The OPUS derived
elevations were, 0.27 feet lower than the USCAE elevations, on average. These elevation
differences are consistent with measurements made by Survey Services to support the survey
effort (personal communication, Survey Services, May 2015). The OPUS corrected survey
elevations were, therefore, used for this study (Table 4.1; Figure 4.3).
Table 4.1. USACE survey control points.
Point ID
Easting (ft)
Northing (ft)
USACE Elevation
(ft, NGVD 29)
OPUS Elevation (ft,
NGVD29)
Fairview School
MON 27 Dotyville
MON 28 Airport S
MON 32 Gravel Pt
2865246.01
2872685.49
2878795.03
2908604.89
716373.34
691133.84
706341.42
675506.51
805.97
773.48
797.90
849.25
805.74
773.11
797.72
848.95
Because the USACE benchmarks were located a significant distance from the river, thick
vegetation along the river and overbanks limited the radio range between the boat and the GPS
base station. As a result, temporary survey control was set closer to the river between Twin
Bridges and the Commerce gage (Table 4.2; Figure 4.3) to facilitate the hydrographic survey.
The temporary survey control was set from the USACE benchmarks and verified using OPUS.
The survey methodology and results were verified by Survey Solutions (personal communication,
May 2015).
Table 4.2. Temporary survey control set by Tetra Tech.
Point ID
Easting (ft)
Northing (ft)
R1 1037
R1 1037
R1 1042
R1 1048
R1 1052
R1 1062
R1 1071
R1 1181
R1 1199
R1 1213
2858087.56
2858087.57
2860285.99
2876604.12
2871094.15
2880765.07
2887806.04
2918129.61
2899522.93
2888344.71
715865.56
715865.60
705585.16
699452.49
700739.61
693071.12
688064.72
671344.39
672538.37
686359.32
Elevation (ft,
NGVD29)
785.71
785.77
763.86
775.65
757.83
770.09
795.23
829.64
765.56
813.67
The hydrographic survey was conducted using conventional surveying methods in accordance
with guidelines that meet the requirements of Class 2 Hydrographic surveys (USACE, 2002).
Depth soundings were measured using an Ohmex SonarMite sonar transducer (0.1-foot
resolution) mounted on the side of the boat. Horizontal and vertical positioning data were
measured using a Leica Viva RTK survey-grade GPS. The positioning accuracy of the GPS data
is approximately 0.05 feet both vertically and horizontally.
The hydrographic survey was conducted by surveying transects across the river. A total of 110
transects were surveyed with an average spacing of 1,000 feet along the reach (Figure 4.4). Due
to the thickness of the vegetation and limited range of the GPS radio, there were three limited
areas where data could not be collected (Figure 4.5). These included an approximately 0.8-mile
reach in the vicinity of Mud Eater Bend between Sta 252,890 and Sta 258,940, an approximately
36
2.3-mile reach in the tight bends upstream from Miami between Sta 316,000 and Sta 328,160,
and an approximately 1-mile reach upstream of the second area between Sta 332,360 and Sta
338,550. In the area of the survey gaps, the bed elevation was linearly interpolated based on the
up- and downstream surveyed cross sections. A comparison of the thalweg elevation at 10 cross
sections surveyed by Settle Engineering Co in 1995 and 1998 show a very good match except at
Station 289,220, where the thalweg elevation surveyed by Settle Engineering is approximately 5
feet above the 2015 survey. The Settle data at this location appears to be anomalously high
compared to the adjacent river profile.
4.4
Comparison of Bed Elevation Changes
Construction of Pensacola Dam was completed in March 1940. Since that time, sediment carried
by the Neosho River and other tributaries that enter Grand Lake has deposited in the reservoir,
occupying a portion of the storage space. Because the amount of sediment that can be carried
by the river is controlled by the local hydraulic energy, and the required amount of energy
increases with increasing particle size, the coarser-grained portion of the sediment load (i.e.,
sands and gravels) will typically deposit on the river bed near the head of the reservoir and the
finer grained sediment will be carried progressively farther downstream into the reservoir. At the
discharges and lake-levels that typically occur during non-flood periods, the backwater from
Grand Lake extends at least as far upstream as the Miami low-water dam that is located at Sta
297,950.
Comparison of the thalweg (i.e., minimum bed elevation) profiles from the 2015 bathymetry with
thalweg elevations measured in 1940 indicates that the bed has aggraded by an average of about
5 feet, with over 10 feet of aggradation in some locations in the 6- to 7-mile reach upstream from
Twin Bridges/U.S. Highway 60 (Figure 4.6). Based on the elevations along the tops of the channel
banks, a similar amount of aggradation has occurred in the overbanks along this portion of the
reach.
In general, the top of bank elevations upstream from Highway 69 from the 1940 and current
mapping match reasonably well and are approximately parallel with the channel profile. The 1940
top-of-bank profile downstream from Highway 69 is also roughly parallel with the channel bed
profile, and the slope of the profile is consistent with the slope upstream from Highway 69. The
2015 top of bank elevations in the vicinity of Twin Bridges are at an elevation of approximately
750 feet, which coincides with reservoir elevation that often occur during flood periods when outof-bank flows are occurring. Based on the bank elevations, there has been approximately 15 feet
of overbank deposition in the vicinity of Twin Bridges between 1940 and 2015.
A comparison of the channel profile from the Simons (1998) HEC-2 model that was based
primarily on data collected in 1995 shows the channel is approximately 2.4 feet lower than the
2015 channel profile and the 1995/1998 Settle Survey between Twin Bridges and Highway 69
(Figure 4.7).
37
760
Pensacola Dam Water Surface (feet, NGVD29)
755
750
745
740
735
1992 Water Control Manual
730
OWRB (2009)
725
USACE >Jan 28, 2012
Extrapolated from USACE Data
720
715
710
0.6
Figure 4.1.
0.8
1
1.2
1.4
1.6
1.8
Grand Lake Storage (ac-ft)
2
2.2
2.4
Millions
Storage-Elevation curves for Grand Lake. 1992 Water Control Manual same as
original 1940 storage-elevation curve; USACE>Jan 28, 2012 from post Jan 28,
2012 data published on USACE Water Control website.
38
16,000
Commerce - Discharge
14,000
Hydrographic Survey Period
12,000
Discharge (cfs)
10,000
8,000
6,000
4,000
2,000
0
16-Apr-15
Figure 4.2.
18-Apr-15
20-Apr-15
22-Apr-15
24-Apr-15
26-Apr-15
28-Apr-15
30-Apr-15
Flow hydrograph measured at the Commerce gage. The discharge during the
hydrographic survey from ranged from approximately 1,350 cfs on April 24, to
approximately 730 cfs on April 27, 2015.
39
Figure 4.3. Location of the benchmarks used for the 2015 hydrographic survey.
40
Figure 4.4. Location of the survey transects.
41
Commerce Gage
770
Miami Gage
County Rd. Br.
Twin Bridges
780
Abandonded RR Br.
790
760
Elevation (ft)
750
740
730
720
710
Settle Survey (1995,1998)
Bed Eevation - With-Dam
700
Interpolated Section
690
230000
250000
270000
290000
310000
330000
350000
Station (ft)
Figure 4.5.
Comparison of the thalweg profile developed from the 2015 bathymetric survey,
with survey measurements collected by Settle Engineering Co. in 1995 and 1998.
The red lines show the location of the interpolated channel profile.
42
Miami Gage
Commerce Gage
770
Abandonded RR Br.
780
County Rd. Br.
Twin Bridges
790
760
Elevation (ft)
750
740
730
720
Bank Profile 2015-DS of HWY69
Bank Profile 2015 - u/s of HWY69
710
Bank Profile (GNR 1941)
700
1941 Profile
Linear (Bank Profile 2015 - u/s of HWY69)
690
160000
180000
200000
220000
240000
260000
280000
300000
320000
Station (ft)
Figure 4.6. Comparison of the 1940 and 2015 thalweg profiles.
43
340000
360000
Commerce Gage
770
Miami Gage
County Rd. Br.
Twin Bridges
780
Abandonded RR Br.
790
760
Elevation (ft)
750
740
730
720
710
1998 HEC-RAS Model
700
Settle Surveys
690
160000
180000
200000
220000
240000
260000
280000
300000
320000
340000
360000
Station (ft)
Figure 4.7.
Comparison of the 1998 thalweg profile from the Simons HEC-2 model and 2015
thalweg profile.
44
5 HYDRAULIC MODELING
The modeling was conducted using HEC-RAS 5.0.0 (Beta August 2015) with available
topographic, bathymetric, flow and stage data. HEC-RAS 5.0 is used to simulate movement of a
flood hydrograph over a system of 2-D grid elements and 1-D cross sections (Figure 1.1). The
model was calibrated to seven floods that represent a range of peak discharges and flood
durations: May 1995 (referred to in previous studies as Flood 11), June 1995 (Flood 13), JuneJuly 2007, April-May 2009, October 2009, May-June 2013 and December 2015 (Table 3.2).
To evaluate the rule curve change, the hydraulic model was run over the same 3 floods evaluated
by FERC (October 1986, September 1983 and October 2009) as well as the December 2015
flood (Table 3.2).
5.1
Model Development
The current version of HEC-RAS 5.0 does not have the ability to calculate energy losses at
bridges in 2-D model areas. As a result, 1-D reaches were included in appropriate locations,
including the reach between the abandoned railroad bridge at Sta 294,420 and Highway 69, within
the City of Miami, to insure that the bridge losses are properly accounted for. In addition, the
complexity of the 2-D algorithm requires substantial computing resources that can result in long
model execution times. Since the primary focus of the study is on flooding in the Miami area and
the downstream conditions primarily provide boundary conditions for the focus area, the entire
modeled reach from Pensacola Dam to Sta 275,605 (approximately 2.8 miles downstream from
I-44) was also modeled one-dimensionally (Table 5.1). The 1-D approach is appropriate for the
reach between Twin Bridges and Station 275,605 because the channel relatively confined, and
the resulting flow patterns for the majority of the flow are essentially parallel to the channel.
Table 5.1. Extents of the 1- and 2-dimensional areas in the HEC-RAS model.
Type
1-D
2-D
1-D
2-D
Downstream
Limit
0
275,605
294,420
301,645
Upstream
Limit
275,605
294,420
301,645
407,300
Reach Length
(mi)
52.2
3.6
1.4
20.0
The 1-D area from the abandoned railroad bridge to Highway 69, the most northern bridge in the
City of Miami, includes four bridges: the abandoned railroad bridge (Sta 294,505), Highway 125
bridge (Sta 298,990), Burlington Northern Railroad Bridge (Sta 299,660) and the Highway 69
Bridge (Sta 301,570). The Miami gage is located in this reach and the average cross-section
spacing along the reach is 250 feet.
Initial model simulations indicated that, at flows greater than approximately 30,000 cfs there is
significant flooding across the western portion of the floodplain in the vicinity of the Commerce
gage. It was determined after several trial runs that locating the upstream model boundary where
the Neosho River inflow is specified in the vicinity of Sta 387,550, approximately 6.7 miles
upstream from the Commerce gage, produced the most reasonable model results at flows greater
than about 30,000 cfs. The floodplain is relatively confined in this area; thus, the flow distribution
across the upstream model boundary can be specified with more certainty, providing an accurate
prediction of the flow distribution in the overbanks at and downstream from the Commerce gage.
The trial runs indicate that little or no discharge attenuation occurs in the reach between the inflow
point and the Commerce gage, but the flows are offset by about 4 hours. As a result, the recorded
flows at the Commerce gage for each flood were shifted back in time by four hours for input to
the model. The inflows for the Spring River and Elk River were input at the confluence of the
45
Neosho River and were both set forward 6 hours to account for the travel time. The inflows from
Tar Creek were applied at the gage with no adjustment to the timing. The recorded stage at the
Pensacola Dam was directly applied to the downstream boundary of the model.
Model Geometry
As noted above, a digital terrain model (DTM) was developed to represent the reservoir, channel
and overbank area, and this terrain was used to develop the geometry for the 1-D cross sections
and 2-D areas in the hydraulic model.
An initial terrain was developed from the 2008 bathymetry and the 2011 LiDAR data that extend
lengthwise from approximately 6 miles upstream of Commerce gage to the dam and extends
laterally across the floodplain.
Data from the 2015 bathymetric data were then inserted into the DTM using the “RAS Mapper”
tool in HEC-RAS 5.0 for the reach from approximately Twin bridges to the Commerce Gage. This
tool was also used to incorporate the cross-sections from the Simons & Associates (1996) HEC2 model from approximately the Commerce gage to the upstream end of the model, as these are
the most recently surveyed cross sections that are available for this part of the reach.
The cross-section geometry for the 1-D portion of the model was developed from the terrain
surface using geoHEC-RAS. The terrain was also applied to the 2-D areas to compute the “2-D
hydraulic flow area tables” using the RAS mapper tools in HEC-RAS. The bridge geometry was
primarily obtained from the Simons & Associates (1996) HEC-2 model from bridge
measurements.
Previous modeling indicates that the Miami low-water dam has little or no impact on hydraulic
conditions at the high flows that are the focus of this study. Since the topographic discontinuity
created by the dam in the DTM causes model instability, the dam was not included in the model.
Manning’s n Roughness Values
The HEC-RAS model uses Manning’s n roughness values to quantify the energy losses at the
cross sections and in the 2-D areas. Manning’s n-values for the main channel were initially
selected based on the local channel characteristics, standard references and previous modeling
of the project reach, and the initial values were then adjusted within physically reasonable limits
to achieve agreement between modeled and observed water-surface elevations, and flood timing
(Table 5.3). The resulting n-values in the reaches of primary interest to this study tend to increase
with increasing discharge, particularly when there is substantial overbank flow. This result if
physically reasonable because significant turbulence and energy losses occur along the boundary
of the riparian vegetation that propagates into the channel, increasing the effective roughness of
the overall main-channel cross section.
46
Table 5.2.
Description
Reservoir to
approximately
Twin Bridges
Twin Bridges
to bend
downstream
of Tar Creek
Bend
downstream
of Tar Creek
to Abandoned
RR bridge
Abandoned
RR bridge to
HWY69
HWY69 to
upstream end
of model
Summary of Manning's n-values applied to the channel for model calibration.
Station
May
1995
(35900cfs)
Dec.
2015
Oct
2009
May
2013
(44000cfs)
(46300cfs)
(57800cfs)
AprilMay
2009
(64500cfs)
Jun
1995
(70500cfs)
Flood
2007
(JuneJuly)
(141000cfs)
0 to
231262
0.02
0.02
0.02
0.02
0.02
0.02
0.02
231262
to
282500
0.027
0.027
0.027
0.027
0.027
0.027
0.037
282500
to
297360
0.032
0.034
0.035
0.037
0.045
0.049
0.083
0.03
0.03
0.03
0.03
0.03
0.03
0.035
0.043
0.043
0.043
0.043
0.043
0.043
0.043
297360
to
301645
301645
to
387500
The overbank n-values were established by delineating polygons from the 2015 aerial
photography that represent zones with similar roughness characteristics (Figures 5.1 through
5.3) using ArcGIS. The specific values were assigned based on guidance from Arcement and
Schneider (1989) and previous modeling of the project reach (Table 5.4). The individual zones
were visually identified based on vegetation type and density and land-use that includes
agricultural fields, orchards and urbanized areas (Figure 5.4). The roughness zones are generally
consistent with the areas of woody vegetation that were delineated by Mussetter (1998) using the
1995 aerial photographs; thus, overbank roughness conditions at the time of the 2007 and 2013
floods appear to be similar to conditions during the mid-1990s floods. The n-values assigned to
these areas ranged from 0.04 for ponded water and bare sand-and-gravel substrate to 0.15 for
dense vegetation.
5.2
Model Calibration
The model was calibrated by comparing the predicted stage hydrographs at the Miami and
Commerce gages with the recorded hydrographs, and by comparing the available, measured
high-water marks with the predicted maximum water-surface elevation at the location of the highwater mark.
The high-water marks for May 1995 (Flood 11) and June 1995 (Flood 13) were taken from Holly
(2001). Since the specific locations of these high-water marks were not recorded, it was assumed
for purposes of comparison with the predicted water-surface elevations that the points are near
the main river channel, and the location of the points on the channel station line (i.e., approximate
centerline of the main river channel) was determined by interpolating between the river miles
reported by Holly (2001) (Figures 5.5 and 5.6). A more extensive set of high-water marks was
collected throughout the Miami area after the 2007 flood by the City of Miami and Survey Service
(Figure 5.7), following the May 2009 (Figure 5.8), October 2009 (Figure 5.9), during the
recession of the 2013 flood by Survey Service (Figure 5.10) and near the peak of the December
2015 flood by Survey Service (Figure 5.11). The data for 2007 and later floods includes the
horizontal location of the point, as well as the elevation.
47
Table 5.3. Overbank Manning’s n-values (Arcement and Schneider, 1989).
Developed
Dense
Light
Farmland Urban
Vegetation Vegetation
Bare
Ponded
SandWater
Gravel
nb
0.04
0.04
0.04
0.04
0.03
0.04
0.04
n1
0.01
0.01
0.01
0.01
0.02
0
0
n2
0
0
0
0
0
0
0
n3
0.01
0.02
0.02
0.01
0.01
0
0
n4
0.01
0.08
0.03
0.02
0.01
0
0
m
1
1
1
1
1
1
1
n
0.07
0.15
0.1
0.08
0.07
0.04
0.04
Description
Base value for the floodplains
with bare surface
Correction for the effect of
surface irregularities
Correction for shape and size
of the floodplain cross section
(assumed 0.0 for this analysis)
Correction for obstructions
Correction for floodplain
vegetation
Multiplication factor for
floodplain sinuosity (assumed
equal to 1.0 for this analysis)
Composite overbank n-value n
= (nb+n1+ n 2+ n 3+ n 4)*m
Table 5.4.
Flood
May-95
Summary of high-water marks and modeled maximum water-surface elevations
for the May and June 1995 floods.
Model
Model
Model
Reported
Under (-)
Peak
Obs.
Station
HWM
or Over
Remarks
WSEL
(ft)
Elev. (ft)
(+)
(ft)
Prediction
Commerce
351,850
768.7
768.1
-0.6
Gage
May-95
9
301,415
760.6
762.3
1.7
May-95
May-95
10
11
Miami
Gage
12
13
14
301,267
298,684
759.4
758.7
759.1
758.8
-0.3
0.1
298,928
758.9
759.1
0.2
280,165
253,013
230,916
755.9
753.4
752.83
755.8
753.8
752.9
-0.1
0.4
0.1
351,850
772.2
771.7
-0.5
318,333
298,684
770
767.6
769.3
767.6
-0.7
0.0
298,928
767.7
767.6
-0.1
May-95
May-95
May-95
May-95
Jun-95
Jun-95
Jun-95
Jun-95
Commerce
Gage
16
17
Miami
Gage
High-water mark seems
unusually low1
Jun-95
18
280,165
763.8
762.4
-1.4
unusually high1
Jun-95
19
253,013
760.5
759.5
-1.0
unusually high1
1Adapter
from Holly (2001)
49
The predicted maximum water-surface elevations along the station line are very consistent with
the elevations of the available high-water marks for each of the seven floods used to calibrate the
model (Figures 5.12 through 5.18, Table 5.5 through 5.9). To provide a more specific
comparison for the 2007, 2009, 2013 high-water marks for which horizontal locations were
available, the predicted water-surface elevation at the location of each mark was determined from
the 2-D model grid (Tables 5.5 through 5.9). In comparing the predicted profiles with the highwater marks, it is important to note that many of the points are located in the overbanks well away
from the main river channel; thus, some of the differences seen in the plots are likely due to
changes in the water-surface between the main channel and the specific location of the mark. It
is also important to note that some of the high-water marks were collected after the floods had
receded; thus, there is some uncertainty as to whether all of the marks precisely represent the
maximum water surface at that location.
The predicted stage hydrographs at the Commerce and Miami gages are also in reasonable
agreement with the measured hydrographs (Figures 5.19 through 5.25). The model results
shown in these figures for the indicated floods in which the model input parameters, including
input hydrograph timing and roughness coefficients, have been adjusted to obtain the best overall
fit to the available data across all the floods.
In general, the comparisons for all seven floods indicate good agreement between the watersurface elevations predicted by the HEC-RAS model and the measured values over the relatively
large model area and large range of floods considered in the analysis. For the May and June
1995 floods, the difference between the predicted and measured values is less than one foot over
most of the reach, particularly through the City of Miami (Figures 5.12 and 5.13; Table 5.4). The
maximum stage at the Miami gage during the May 1995 flood was 758.9 feet, which is 1.1 feet
lower than the 760-foot easement elevation. The June 1995 flood exceeded the 760-foot
easement elevation by 7.7 feet.
Comparison of the predicted stage hydrographs at the Commerce and Miami gages with the
reported stages for these flows also indicates reasonable agreement (Figures 5.19 and 5.20). The
timing of the predicted stage hydrograph for the June 1995 flood is shifted somewhat later than
the measured hydrographs, but the maximum stage at the Miami gage is very consistent with the
measured value.
The average difference between the 24 measured high-water marks and the corresponding
predicted maximum water surface for the June-July 2007 flood is -0.1 feet, with individual values
ranging from -2.0 to +1.2 feet (Table 5.5). The maximum recorded water-surface elevation at the
Miami gage was 775 feet, which exceeds the easement elevation by 15 feet.
For the May 2009 flood, the average difference between the 27 measured high-water marks and
the corresponding predicted maximum water surface is -0.2 feet, with individual values ranging
from -0.9 to +0.3 feet (Figure 5.15, Table 5.6). Similar to the May 1995 and June-July 2007 floods,
the timing of the predicted stage hydrograph for the May-June 2013 flood is shifted somewhat
later than the measured hydrographs, but the maximum stage at the Miami gage (764.9 feet) is
very consistent with the measured value (765.0) (Figure 5.22). At the Commerce Gage, the
predicted water-surface elevation is 770.8 feet compared to the measured value of 771.2 feet, a
difference of 0.4 feet. The maximum recorded water-surface elevation at the Miami gage exceeds
the easement elevation by 5 feet.
For the October 2009 flood, the average difference between the 29 measured high-water marks
and the corresponding predicted maximum water surface is 0.3 feet, with individual values ranging
from -0.9 to +1.3 feet (Table 5.7). The timing of the predicted stage hydrograph at the Miami and
Commerce gages looks very good. The maximum stage at the Miami gage (761.0 feet) is very
consistent with the measured value (761.1) (Figure 5.23). At the Commerce Gage, the predicted
water-surface elevation is 769.2 feet compared to the measured value of 769.5 feet, a difference
50
of 0.3 feet. The maximum recorded water-surface elevation at the Miami gage exceeds the
For the May-June 2013 flood, the average difference between the 20 measured high-water marks
and the corresponding predicted maximum water surface is +0.2 feet, with individual values
ranging from -1.1 to +2.4 feet (Table 5.8). The timing of the predicted stage hydrograph for the
May-June 2013 flood is shifted somewhat later than the measured hydrographs, but the maximum
stage at the Miami gage (763.0 feet) is the same as the measured value (763.0) (Figure 5.24). At
the Commerce Gage, the predicted water-surface elevation is 771.0 feet compared to the
measured value of 770.4 feet, a difference of 0.6 feet. Approximately 500 feet upstream of the
Commerce Gage at Point 910, the difference between the measured and predicted values is only
0.1 feet. The maximum recorded water-surface elevation at the Miami gage exceeds the
For the December 2015 flood, all the high-water marks were collected close to the peak watersurface elevation, except for the measurement near the Commerce Gage which was collected
approximately 1 day before the peak. The average difference between the 22 measured highwater marks and the corresponding predicted maximum water surface is -0.2 feet, with individual
values ranging from -0.6 to +0.5 feet (Table 5.9). Similar to the May 1995 and June-July 2007
floods, the timing of the predicted stage hydrograph for the May-June 2013 flood is shifted
somewhat later than the measured hydrographs, but the maximum stage at the Miami gage
(763.8 feet) is 0.4 feet higher than the measured value. Two high-water marks (Obs. 10 and 11)
were surveyed close the Miami Gage near the peak of the flood (Table 5.9). The predicted
maximum water-surface elevation is 0.4 feet lower than the measured value at Obs. 10 and is 0.6
feet lower at Obs. 11. It is not known why there is a discrepancy between the gage recordings
and measured high-water mark. Since the predicted water-surface elevation is approximately
midway between the gage and high water marks, no further adjustments were made to the model
and it was deemed calibrated.
The comparison at the Commerce Gage is not shown since the high-water mark was collected
approximately 1 day before the peak.
5.3
Rule Curve Evaluation Model Results
The calibrated models were re-run for the four floods selected for the rule curve analysis (Table
3.2) with the 741 feet PD and 743 feet PD stage hydrographs applied at Pensacola Dam. During
model calibration, the Manning’s n-values varied with discharge, most notably in the reach from
the bend downstream of Tar Creek to the abandoned railroad bridge (Sta 282,500 to Sta 297,360)
(Table 5.2). For the rule curve runs, the Manning’s n-values in this reach were interpolated based
on discharge and the calibrated n-values (Table 5.10).
51
Table 5.5.
for 2007 flood.
Obs.
Easting
(ft)
2
40
42
44
45
46
47
49
50
51
52
54
56
60
62
63
64
66
72
73
74
76
77
80
Miami
Commerce
2,859,731
2,893,266
2,892,354
2,884,670
2,884,193
2,884,816
2,884,815
2,885,115
2,885,359
2,885,498
2,885,425
2,887,155
2,872,654
2,880,243
2,881,748
2,882,417
2,881,761
2,876,683
2,876,475
2,879,010
2,879,063
2,897,530
2,897,368
2,893,488
2,881,386
2,857,838
Approx.
Reported Model
Northing
HWM
Peak
(ft)
Elev. (ft) WSEL
(ft)
718,764
696,272
695,892
691,741
694,691
696,110
696,151
696,497
697,250
697,337
699,732
699,460
691,248
692,291
694,205
693,655
694,628
699,997
700,084
697,008
697,089
687,294
687,591
693,006
693,292
716,040
778.4
771.3
771.3
773.3
773.3
773.3
773.2
773.2
773.2
773.2
773.2
773.2
777.2
775.2
775.5
775.3
775.6
776.8
776.8
776.3
776.3
769.1
769.2
771.3
775
778.22
52
777.5
771.5
771.5
773.6
774.5
773.5
773.5
773.5
773.5
773.5
773.5
773.5
776.2
775.0
775.2
775.0
775.3
776.1
776.1
775.7
775.7
769.1
769.2
771.5
775.0
777.4
Model under
(-) or over
(+)
prediction
(ft)
-0.9
0.2
0.2
0.3
1.2
0.2
0.3
0.3
0.3
0.3
0.3
0.3
-1.0
-0.2
-0.3
-0.3
-0.3
-0.7
-0.7
-0.6
-0.6
0.0
0.0
0.2
0.0
-0.8
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Table 5.6.
for the May 2009 flood.
Model
Report
under (-)
ed
Approx. Model
Easting
Northing
or over
Obs.
HWM
Peak WSEL
Remark
(ft)
(ft)
(+)
Elev.
(ft)
prediction
(ft)
(ft)
300
2,872,193 708,429
768
767.5
-0.5
301
2,876,232 703,143
768
767.3
-0.7
302
2,875,516 700,748 767.54
767.0
-0.5
Shown on profile
303
2,877,834 698,440 766.56
766.2
-0.3
Shown on profile
304
2,878,757 697,347 766.43
765.9
-0.5
Shown on profile
305
2,880,327 691,396
764.8
764.9
0.1
306
2,872,119 691,146 768.23
767.3
-0.9
307
2,880,057 695,665 765.78
765.5
-0.3
308
2,880,302 695,536 765.69
765.3
-0.4
Shown on profile
309
2,880,795 694,837
765.2
765.2
0.0
Shown on profile
310
2,881,300 694,814 765.24
765.1
-0.1
Shown on profile
311
2,881,601 694,015 764.85
765.1
0.3
Shown on profile
313
2,881,837 693,581 764.77
764.9
0.2
Shown on profile
314
2,883,485 692,669 764.69
764.7
0.0
316
2,885,567 697,200 762.72
762.9
0.2
317
2,885,625 699,126
762.8
762.9
0.1
318
2,886,059 699,972 763.03
762.9
-0.1
319
2,886,865 699,490 762.99
762.9
-0.1
320
2,886,767 696,044
762.7
762.9
0.2
321
2,886,906 695,845 762.76
762.9
0.1
322
2,886,933 694,636 762.78
762.9
0.1
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323
2,893,353 690,945
761.4
761.0
-0.4
Shown on profile
324
2,892,694 694,102 761.39
761.4
0.0
325
2,892,223 695,277 761.35
761.4
0.0
336
2,886,037 700,033 763.27
763.1
-0.2
Miami
2,881,386 693,292
765
764.9
-0.1
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Commerce 2,857,838 716,040 771.18
770.8
-0.4
Shown on profile
53
Table 5.7. Comparison of measured high-water marks for the October 2009 flood.
Obs.
Easting
(ft)
Northing
(ft)
Reported
HWM
Elev. (ft)
Approx.
Model
Peak
WSEL
(ft)
501
502
503
504
507
508
509
510
512
513
514
515
516
518
519
520
521
522
523
524
525
526
533
527
528
529
530
531
532
Miami
716,103
707,807
707,253
700,697
695,687
695,496
694,769
694,785
692,706
692,598
692,082
691,090
692,217
694,057
693,581
693,537
691,269
691,253
695,862
696,056
694,307
687,229
688,690
670,685
670,505
670,703
670,880
690,636
690,684
2,881,386
2,858,584
2,870,802
2,872,506
2,875,491
2,880,021
2,880,143
2,880,771
2,881,091
2,882,803
2,883,384
2,885,134
2,869,751
2,880,462
2,881,168
2,881,591
2,881,810
2,884,484
2,884,537
2,886,878
2,886,734
2,886,904
2,897,633
2,896,337
2,899,569
2,899,668
2,918,410
2,918,255
2,888,911
2,888,688
693,292
770.1
764.3
764.1
763.5
761.7
761.5
761.2
761.3
760.7
760.6
759.0
764.2
760.9
761.0
761.0
760.8
760.0
759.8
758.8
759.0
758.9
756.5
756.7
754.7
754.5
752.6
752.7
758.2
758.3
761.1
769.2
764.5
764.3
763.5
761.6
761.4
761.3
761.3
760.9
760.8
759.7
764.0
761.1
761.3
761.1
761.0
760.3
760.3
758.5
759.7
759.7
757.6
758.0
755.1
755.1
753.9
753.9
759.3
759.6
761.0
Model
under (-)
or over
(+)
prediction
(ft)
-0.9
0.1
0.2
0.0
-0.1
-0.1
0.1
0.0
0.2
0.1
0.7
-0.2
0.1
0.2
0.1
0.3
0.2
0.4
-0.4
0.7
0.8
1.2
1.3
0.4
0.6
1.3
1.3
1.0
1.3
0.0
Commerce
2,857,838
716,040
769.5
769.2
-0.3
54
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Table 5.8. Comparison of measured high-water marks for the May 2013 flood.
Obs.
Easting
(ft)
901
903
906
910
911
912
913
914
915
916
917
919
921
922
923
924
926
927
928
929
Miami
Commerce
2,858,647
2,870,785
2,872,474
2,876,136
2,876,146
2,876,150
2,875,522
2,877,345
2,876,579
2,871,879
2,880,321
2,881,950
2,882,414
2,887,167
2,892,202
2,893,920
2,885,688
2,885,605
2,885,905
2,886,838
2,881,386
2,857,838
Model
Approx.
under (-)
Reported Model
Northing
or over
HWM
Peak
(ft)
(+)
Elev. (ft) WSEL
prediction
(ft)
(ft)
716,110
708,601
707,516
705,131
704,905
704,880
700,678
698,584
694,208
691,140
692,037
693,429
693,007
695,905
695,165
690,941
697,201
697,308
699,899
698,966
693,292
716,040
771.5
766.4
766.1
766.1
765.9
765.8
765.7
764.8
764.6
766.3
762.8
762.7
762.7
760.6
759.5
759.1
760.5
760.6
760.6
760.6
763.0
771.0
55
770.4
766.5
766.2
766.0
766.0
766.0
765.5
764.9
764.0
766.0
763.0
763.0
763.0
761.4
760.2
759.6
761.4
761.4
763.0
761.4
763.0
770.4
-1.1
0.1
0.1
-0.1
0.1
0.2
-0.1
0.1
-0.6
-0.4
0.2
0.3
0.2
0.7
0.7
0.5
0.8
0.8
2.4
0.8
0.0
-0.6
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Table 5.9. Comparison of measured high-water marks for the December 2015 flood.
Obs.
Easting (ft)
Northing
(ft)
Reported
HWM
Elev. (ft)
Approx.
Model
Peak
WSEL
(ft)
1
2
3
4
5
6
7
8
9
10
11
13
14
15
16
17
18
19
20
21
22
Miami Gage
2858527
2860115
2870770
2876112
2877325
2880000
2880259
2869791
2880460
2881772
2881679
2885259
2885037
2885419
2886827
2886923
2892735
2893560
2897531
2899647
2918500
2881386
716096
710553
707987
705012
698582
695713
695498
691075
691409
693577
693897
690955
695889
697247
696034
695907
694102
690946
687322
670425
670803
693292
769.6
766.3
765.8
765.8
765.2
764.7
764.4
766.2
764.2
764.2
764.5
763.7
763.4
763.4
763.4
763.4
762.9
762.9
762.3
761.1
760.3
763.4
769.4
766.2
765.7
765.6
764.8
764.1
764.0
765.5
763.8
763.8
763.9
763.4
763.1
763.1
763.1
763.1
762.7
762.5
762.2
761.2
760.8
763.8
56
Model
under (-)
or over
(+)
prediction
(ft)
-0.2
-0.1
-0.1
-0.2
-0.4
-0.5
-0.4
-0.6
-0.5
-0.4
-0.6
-0.3
-0.3
-0.3
-0.3
-0.3
-0.3
-0.4
-0.1
0.2
0.5
0.4
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Table 5.10.
Summary of Manning's n-values applied to the main channel for the rule
simulations.
Oct
Sep
Oct
Description
Station
1986
1993
2009
Reservoir to approximately Twin
0 to 231262
0.02
0.02
0.02
Bridges
Twin Bridges to bend downstream
231262-282500
0.027
0.027
0.027
of Tar Creek
Bend downstream of Tar Creek to
282500-297360
0.064
0.051
0.035
Abandoned RR bridge
Abandoned RR bridge to HWY69
297360-301645
0.030
0.030
0.030
HWY69 to upstream end of model 301645 to 387500
0.043
0.043
0.043
curve
Dec
2015
0.02
0.027
0.034
0.030
0.043
The HEC-RAS model output was used to develop maximum water-surface elevation profiles for
each model flood to assess the impact of the rule curve change on water-surface elevations and
inundation area outside the 760-foot easement. Area calculations were made for four subreaches
located between Twin Bridges and the upstream end of the model (Figure 5.26; Table 5.11).
Table 5.11. Extents of the subreaches used in the area calculations.
Subreach
Lower Reach - from Twin Bridges to Will Rodgers (I-44)
Miami Reach - Will Rodgers to HWY 69 Bridge
Commerce Reach 0 HWY 69 to Commerce gage
Upper Reach - Commerce gage to u/s end of model.
Station
231200 to 301500
301,500 to 301,570
301,570 to 351,900
351,900 to 387,500
To aid in assessing the impacts of the rule curve change with regard to the existing flood
easements, the area within the 760-foot contour was quantified using the terrain surface. The
resulting area, including the channel and overbanks, ranges from 2,646 acres in the Lower
subreach to 1,793 acres in the Miami subreach, 3,291 acres in the Commerce subreach and 226
acres in the Upper subreach, for a total area of 7,655 acres (Table 5.11). A terrain surface was
then developed from the maximum predicted water-surface elevations using the mapper tool in
HEC-RAS and the underlying terrain, and inundated area calculations were made for each of the
four subreaches.
October 1986
For the October 1986 flood, the predicted water-surface elevation at the Miami gage under the
741 feet PD condition is 772.29 feet, and this increases to 772.31 feet under the 743 feet PD
conditions, a difference of 0.02 feet (Figure 5.27, Table 5.12). The differences in water-surface
elevation are about 0.03 feet at the Will Rodgers Bridge and 0.01 feet at the Commerce Gage.
The flood easement elevation of 760 feet is exceeded at the Miami gage by approximately 12.3
feet and for the same duration of approximately 103 hours (4.3 days) under both scenarios (Table
5.13).
The extents of flooding in the Miami Reach are approximately 4 acres greater under the 743 feet
PD condition compared to the 741 feet PD condition (Table 5.14). The difference in the Lower
reach and the Commerce reach are 11 acres and 3 acres, respectively. There is no difference in
flooding extent in the upper reach.
57
Table 5.12.
Maximum predicted water-surface elevation at three locations in the study reach
for 741 feet PD and 743 feet PD starting water-surface elevations, and the
difference between the 760-foot NGVD29 flood easements.
Flood Event
Location
Station
(ft)
October
1986
Will Rodgers Br.
290,300
Qpeak=
Miami Gage
101,000
cfs*
Commerce Gage
September
1993
Will Rodgers Br.
Qpeak=
77,200 cfs*
October
2009
Qpeak=
46,100 cfs
December
2015
Qpeak=
44,025 cfs
Miami Gage
Commerce Gage
299,320
351,900
290,300
299,320
351,900
741 feet PD Starting
WSE
Predicted
Height
Waterabove
surface
flood
Elevation easement
(feet
(760 feet
NGVD29) NGVD29)
743 feet PD Starting
WSE
Predicted
Height
Waterabove
surface
flood
Elevation easement
(feet
(760 feet
NGVD29) NGVD29)
769.22
9.22
769.25
9.25
772.29
12.29
772.31
12.31
774.97
14.97
774.98
14.98
766.87
6.87
766.95
6.95
769.77
9.77
769.82
9.82
773.09
13.09
773.11
13.11
Difference
between
741 feet
PD and
743 feet
PD
starting
WSE
0.03
0.02
0.01
0.08
0.05
0.02
Will Rodgers Br.
290,300
759.48
-0.52
759.65
-0.35
Miami Gage
Commerce Gage
299,320
351,900
761.22
769.18
1.22
9.18
761.35
769.19
1.35
9.19
Will Rodgers Br.
290,300
762.79
2.79
762.98
2.98
299,320
763.71
3.71
763.88
3.88
0.17
351,900
769.26
9.26
769.28
9.28
0.03
Miami Gage
Commerce Gage
*Mean Daily Flow
58
0.17
0.12
0.01
0.19
Table 5.13.
Duration above 760-foot flood easement at Miami Gage for the 741 feet PD and
743 feet PD conditions (hours).
Flood Event
October 1986
September 1993
October 2009
December 2015
Table 5.14.
741 feet PD
103
100
48
68
743 feet PD
103
100
51
69
Difference
0
0
3
1
Comparison of predicted inundation under the 741 feet PD and 743 feet PD
conditions (acres).
Subreach
Ground
Surface
Lower
Miami Commerce Upper
Total
Area <= 760
2,646
1,493
3,291
226
7,655
feet
741 feet PD
743 feet PD
Difference
October 1996
2,070 3,178
12,879
2,081 3,182
12,882
11
4
3
5,903
5,903
0
24,030
24,048
18
741 feet PD
743 feet PD
Difference
September 1993
2,152 2,829
12,142
2,160 2,842
12,153
8
13
11
5,703
5,704
1
22,826
22,860
34
741 feet PD
743 feet PD
Difference
1,525
1,548
23
October 2009
1,705
9,368
1,720
9,388
15
20
4,638
4,640
2
17,236
17,297
61
741 feet PD
743 feet PD
Difference
December 2015
1,976 2,082
9,749
1,998 2,109
9,796
22
27
47
4,489
4,493
4
18,295
18,397
102
September 1993
For the September 1993 flood, the predicted water-surface elevation at the Miami gage under the
741 feet PD condition is 769.77 feet, and this increases to 769.82 feet under 743 PD conditions,
a difference of 0.05 feet (Figure 5.28, Table 5.12). The differences at the Will Rodgers Bridge
and the Commerce Gage are about 0.08 feet and 0.02 feet, respectively (Table 5.12).
The flood easement elevation is exceeded at the Miami gage by approximately 9.8 feet under
both scenarios and for the same duration of approximately 100 hours (4.2 days) (Table 5.13).
59
The extents of flooding in the Miami Reach are approximately 13 acres greater under the 743 feet
PD condition compared to the 741 feet PD condition (Table 5.14). The differences in the Lower
reach is 8 acres, in the Commerce reach is 3 acres and in the Upper Reach is 1 acre (Table 5.14).
October 2009
For the October 2009 flood, the predicted water-surface elevation at the Miami gage under the
741 feet PD condition is 761.22 feet, increasing to 761.35 feet under 743 feet PD conditions, a
difference of 0.12 feet (Figure 5.29, Table 5.12). The differences at the Will Rodgers Bridge are
about 0.17 and at the Commerce Gage are about 0.01 feet (Table 5.12).
The flood easement elevation of 760 feet is exceeded at the Miami gage under the 741 feet PD
conditions by 1.2 feet and for 48 hours, and 1.4 feet and 51 hours under the 743 feet PD condition
(Table 5.13).
The increase in the flooding extents between the 741 feet PD and 743 feet PD conditions are
approximately 23 acres in the Lower Reach 15 acres in the Miami Reach is 20 acres in the
Commerce reach and about 1 acre in the upper reach (Figure 5.14).
December 2015
For the December 2015 flood, the predicted water-surface elevation at the Miami gage under the
741 feet PD condition is 763.71 feet, increasing to 763.88 feet under the 743 feet PD condition, a
difference of 0.17 feet (Figure 5.30, Table 5.12). The differences are about 0.19 feet at the Will
Rodgers Bridge and 0.03 feet at the Commerce Gage (Table 5.12).
The flood easement elevation of 760 feet is exceeded at the Miami gage under the 741 feet PD
conditions by 3.7 feet for 68 hours and by about 3.9 feet for 69 hours under the 743 feet PD
condition (Table 5.13).
The increase in the flooding extents between the 741 feet PD and 743 feet PD conditions are
about 22 acres in the Lower Reach, 27 acres, in the Miami Reach, 47 acres in the Commerce
reach and 4 acres in the Upper Reach (Figure 5.14).
Comparison with FERC Results
As discussed above, the FERC hydraulic extends from just upstream of Twin Bridges to
Commerce gage, and they assumed that the water-surface elevation at Twin Bridges is the same
as the elevation at the lake. The Tetra Tech model predicts maximum differences between
Pensacola Dam and Twin Bridges ranging from 1.8 feet (757.6-755.8=1.8 feet) for the October
1996 flood to 7.4 feet (762.5 to 755 feet) for the September 1993 flood (Table 5.15). These
results are supported by high-water marks that were surveyed in October 2009 and December
2015 that show differences in water-surface elevations between Pensacola Dam and Twin
Bridges of 1.9 feet and 4.3 feet, respectively.
Although the differences between maximum water-surface elevation in the Miami area for the two
starting lake-level scenarios from the FERC and Tetra Tech analysis are similar (Table 5.16),
FERC’s analysis that neglects the increase in water-surface elevation from the dam to Twin
Bridges significantly under-predicts the actual water-surface elevations. For example, for the
September 1993 flood under the 743 feet PD condition, the Tetra Tech model predicts a water
surface elevation of 769.8 feet compared 766.9 feet from the FERC model, a difference of 2.9
feet. As a result, the FERC model also significantly under-estimates the flood inundation areas
for each of the modeled floods.
60
Table 5.15.
analyses at the Pensacola Dam and Twin Bridges (feet, NGVD29).
741 feet PD
743 feet PD
October 1986
September
1993
October 2009
755.8
757.6
FERC
Twin
Bridges
755.8
755.0
762.5
754.8
755.4
762.6
755.2
750.6
753.9
751.8
751.3
754.4
752.5
December 2015
755.5
760.6
756.0
760.8
Flood Event
Tetra Tech
Pensacola
Twin
Dam
Bridges
Table 5.16.
Tetra Tech
Pensacola
Twin
Dam
Bridges
758.0
756.1
FERC
Twin
Bridges
756.1
analyses at the Miami Gage (feet, NGVD29).
FERC
Tetra Tech
Flood Event
741
743
Difference
741 feet
743 feet
Difference
feet PD feet PD
(ft)
PD
PD
(ft)
772.29 772.31
769.49
769.53
0.04
October 1986
0.02
September
769.77 769.82
0.05
766.83
766.91
0.08
1993
October 2009
761.22 761.35
760.69
760.85
0.16
0.12
61
Figure 5.1. Aerial photograph showing the vegetation in the vicinity of Tar Creek in 2015.
62
Figure 5.2. Aerial photograph showing the vegetation in the vicinity of Commerce Gage (Stepps Ford Bridge) in 2015.
63
Figure 5.3. Aerial photograph showing the vegetation in the vicinity of Twin Bridges (Stepps Ford Bridge) in 2015.
64
Figure 5.4. Roughness zones used to assign Manning’s n-values to the with-dam conditions model.
65
Figure 5.5. Map showing location of available high-water marks for the May 1995 flood.
66
Figure 5.6.
Map showing location of available high-water marks for the June 1995 flood.
67
Figure 5.7. Map showing location of available high-water marks for the June-July 2007 flood.
68
Figure 5.8. Map showing location of available high-water marks for the May 2009 flood.
69
Figure 5.9. Map showing location of available high-water marks for the October 2009 flood.
70
Figure 5.10. Map showing location of available high-water marks for the May-June 2013 flood.
71
Figure 5.11. Map showing location of available high-water marks for the December 2015 flood.
72
770
Miami Gage
County Rd. Br.
Twin Bridges
780
Abandonded RR. Br.
790
750
740
Commerce Gage
Elevation (ft)
760
730
720
710
WSE -With-Dam
700
HWM
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
400000
Station (ft)
Figure 5.12.
Comparison of the predicted maximum water-surface profile along the channel stationline compared to the measured
high-water marks and peak gage measurements for the May 1995 flood.
73
770
Miami Gage
County Rd. Br.
Twin Bridges
780
Abandonded RR. Br.
790
750
740
Commerce Gage
Elevation (ft)
760
730
720
710
WSE - With-Dam
Bed Eevation- With-Dam
700
HWM
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
400000
Station (ft)
Figure 5.13.
high-water marks and peak gage measurements for the June 1995 flood.
74
Elevation (ft)
750
740
Commerce Gage
760
Commerce Gage
Abandonded RR. Br.
770
Miami Gage
780
Miami Gage
Twin Bridges
County Rd. Br.
790
730
720
710
WSE - With-Dam
700
HWM
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
400000
Station (ft)
Figure 5.14.
high-water marks and peak gage measurements for the May-June 2007 flood.
75
Commerce Gage
770
Miami Gage
County Rd. Br.
Twin Bridges
780
Abandonded RR. Br.
790
750
740
Commerce Gage
Elevation (ft)
760
730
720
WSE -With-Dam
710
700
HWM
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
400000
Station (ft)
Figure 5.15.
high-water marks and peak gage measurements for the October 2009 flood.
76
770
Commerce Gage
County Rd. Br.
Twin Bridges
780
Abandonded RR. Br.
790
Miami Gage
Elevation (ft)
760
750
740
730
720
WSE - With-Dam
710
Bed Eevation (With-Dam)
HWM
700
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
400000
Station (ft)
Figure 5.16.
high-water marks and peak gage measurements for the October 2009 flood.
77
Commerce Gage
770
Miami Gage
County Rd. Br.
Twin Bridges
780
Abandonded RR. Br.
790
Elevation (ft)
760
750
740
730
720
WSE - With-Dam
Bed Elevation - With-Dam
710
HWM
700
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
400000
Station (ft)
Figure 5.17.
high-water marks and peak gage measurements for the May 2013 flood.
78
Abandonded RR. Br.
760
Elevation (ft)
750
740
Commerce Gage
770
Miami Gage
Twin Bridges
County Rd. Br.
780
730
720
710
HWM
700
Water-Surface Elevation
Bed Elevation
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
400000
Station (ft)
Figure 5.18.
high-water marks and peak gage measurements for the December 2015 flood.
79
770
40,000
765
30,000
25,000
760
20,000
Discharge (cfs)
35,000
755
15,000
Commerce - Measured
Commerce - Predicted
750
10,000
Miami -Measured
Miami - Predicted
5,000
745
5-May-95
6-May-95
7-May-95
8-May-95
0
9-May-95 10-May-95 11-May-95 12-May-95 13-May-95 14-May-95 15-May-95
Figure 5.19. Predicted and measured stage hydrographs at the Commerce and Miami gages for the May 1995 flood.
80
775
80,000
770
60,000
50,000
765
40,000
Discharge (cfs)
70,000
760
30,000
Commerce - Measured
755
20,000
Miami -Measured
10,000
Miami - Predicted
750
31-May-95
2-Jun-95
4-Jun-95
6-Jun-95
8-Jun-95
10-Jun-95
12-Jun-95
14-Jun-95
16-Jun-95
0
18-Jun-95
Figure 5.20. Predicted and measured stage hydrographs at the Commerce and Miami gages for the June 1995 flood.
81
780
160,000
140,000
120,000
770
100,000
765
80,000
760
60,000
755
Discharge (cfs)
775
Commerce - Measured
40,000
Miami - Measured
Miami - Predicted
750
20,000
745
28-Jun-07
Figure 5.21.
0
30-Jun-07
2-Jul-07
4-Jul-07
6-Jul-07
8-Jul-07
10-Jul-07
Predicted and measured stage hydrographs at the Commerce and Miami gages for the 2007 flood.
82
775
70,000
60,000
50,000
765
40,000
760
30,000
Discharge (cfs)
770
755
20,000
Commerce - Measured
Commerce - Measured
750
Miami - Measured
10,000
Miami - Predicted
745
25-Apr-09
Figure 5.22.
27-Apr-09
29-Apr-09
1-May-09
3-May-09
5-May-09
7-May-09
0
9-May-09
Predicted and measured stage hydrographs at the Commerce and Miami gages for the May 2009 flood.
83
775
50,000
45,000
40,000
765
35,000
30,000
760
25,000
755
Discharge (cfs)
770
20,000
Commerce - Measured
15,000
750
10,000
Miami -Measured
745
Miami - Predicted
5,000
740
7-Oct-09
8-Oct-09
9-Oct-09
10-Oct-09
11-Oct-09
12-Oct-09
13-Oct-09
14-Oct-09
15-Oct-09
0
16-Oct-09
Figure 5.23. Predicted and measured stage hydrographs at the Commerce and Miami gages for the October 2009 flood.
84
775
70,000
Commerce - Measured
770
60,000
Miami - Predicted
765
50,000
760
40,000
755
30,000
Discharge (cfs)
Miami - Measured
750
20,000
745
10,000
740
735
28-May-13
30-May-13
1-Jun-13
3-Jun-13
5-Jun-13
7-Jun-13
9-Jun-13
11-Jun-13
0
13-Jun-13
Figure 5.24. Predicted and measured stage hydrographs at the Commerce and Miami gages for the May 2013 flood.
85
775
50000
Commerce - Measured
Miami Gage - Measured
Miami - Predicted
40000
765
35000
30000
760
25000
755
20000
Discharge (cfs)
Water Surface Elevation (feet, NGVD29)
770
45000
15000
750
10000
745
5000
740
12/24/2015 12/26/2015 12/28/2015 12/30/2015
1/1/2016
1/3/2016
1/5/2016
0
1/7/2016
Figure 5.25. Predicted and measured stage hydrographs at the Commerce and Miami gages for the December 2015 flood.
86
Figure 5.26.
Predicted inundation area for the existing (with-dam) conditions June-July 2007 flood compared to the 760-foot
contour line.
87
0.5
770
Abandonded RR. Br.
Elevation (ft)
760
750
740
0.4
Commerce Gage
780
Miami Gage
Twin Bridges
County Rd. Br.
790
0.3
730
0.2
720
WSE - 741' PD
710
WSE - 743' PD
0.1
Bed Eevation
700
Difference in WSE
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
0
400000
Difference in Predicted Water-Surface Elevation (743'PD - 741'PD) (ft)
Station (ft)
Figure 5.27.
Predicted maximum water-surface profiles for October 1986 flood under 741 feet PD and 743 feet PD conditions.
88
0.5
Abandonded RR. Br.
770
Elevation (ft)
760
750
740
0.4
Commerce Gage
780
Miami Gage
Twin Bridges
County Rd. Br.
790
0.3
730
0.2
720
710
WSE - 741' PD
0.1
WSE - 743' PD
700
Difference in WSE
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
Difference in Predicted Water-surface Elevation (743'PD - 741'PD) (ft)
0
400000
Station (ft)
Figure 5.28.
Predicted maximum water-surface profiles for September 1993 flood under 741 feet PD and 743 feet PD conditions.
89
0.9
760
Elevation (ft)
0.8
Commerce Gage
770
1
Miami Gage
County Rd. Br.
Twin Bridges
780
Abandonded RR. Br.
790
750
0.7
0.6
740
0.5
730
0.4
720
0.3
WSE - 741' PD
710
0.2
WSE - 743' PD
Bed Eevation (With-Dam)
700
0.1
Difference in WSE
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
0
400000
Station (ft)
Figure 5.29.
Predicted maximum water-surface profiles for October 2009 flood under 741 feet PD and 743 feet PD conditions.
90
Miami Gage
Twin Bridges
770
0.4
760
740
730
Commerce Gage
Abandonded RR. Br.
Elevation (ft)
750
0.3
0.2
WSE -741' PD
720
WSE - 743' PD
710
0.1
Difference in WSE
700
690
200000
220000
240000
260000
280000
300000
320000
340000
360000
380000
0.5
County Rd. Br.
780
0
400000
Station (ft)
Figure 5.30.
Predicted maximum water-surface profiles for December 2015 flood under 741 feet PD and 743 feet PD conditions.
91
6
REFERENCES
Arcement, G.K. and Schneider, V.R., 1989. Guide for Selecting Manning's Roughness
Coefficients for Natural Channels and Floodplains. U.S. Geological Survey Water Supply
Paper 2339.
Dewberry, 2011. USGS Grand Lake, OK LiDAR Project. Prepared for the U.S. geological Survey.
November, 63 p.
Federal Energy Regulatory Commission (FERC), 2015. Supporting information from Commission
staff’s independent analysis of GRDA’s request for expedited approval of a temporary
variance from Article 401. Technical Memorandum. August 31.
Holly, F.M., 2001. Flood Level and Duration Determination Neosho River below Commerce Gage.
Prepared for Dalrymple et al v. Grande River Dam, Case No. CJ-94-444, Miami,
Oklahoma, April.
Mussetter, R.A., 1998. Evaluation of the Roughness Characteristics of the Neosho River in the
Vicinity of Miami, Oklahoma. August 7.
OWRB, 2009. Hydrographic Survey of Grand Lake. August. 26 p.
Simons & Associates, Inc., 1996. Backwater Analysis of Pensacola Reservoir on the Neosho
River, Miami, Oklahoma. Statement of Opinions by Daryl B. Simons, March.
Tetra Tech, 2015. Hydraulic Analysis of the Effects of the Rule Curve Change at Pensacola Dam
on Flooding In the Vicinity of Miami, Oklahoma. Prepared for the City of Miami, Oklahoma.
December. 107p.
University of Oklahoma (OU), 2014. Floodplain Analysis of the Neosho River Associated with
Proposed Rule Curve Modifications for Grand Lake O’ the Cherokees. Master’s Thesis
submitted by Alan C. Dennis. Norman, Oklahoma
U.S. Army Corps of Engineers (USACE), 1940. Pensacola Reservoir topographic mapping.
36”x48” sheets.
USACE, 1942. Pensacola Reservoir Computation Folder for the revised envelope curve of water
surface in Reservoir.
USACE, 1970.Hydrologic Criteria for Acquisition of Reservoir Lands. Southwest Division
Engineering Technical Letter 1110-2-22.
USACE, 1980. Arkansas River Basin Water Control Master Manual. Tulsa and Little Rock Districts
Corps of Engineers.
USACE, 1985. Real Estate Handbook. Engineering Regulation 405-1-12.
USACE, 1986. Miami, Oklahoma Flood Study, Technical Section 1, hydrology and Hydraulics.
USACE, 1992. Pensacola Reservoir, Grand (Neosho) River, Oklahoma. Water Control Manual,
Appendix E, Part 1 of 3 to Water Control Master Manual, Arkansas River Basin. Tulsa
District Corps of Engineers, August
USACE, 1997. Pensacola Reservoir, Survey of Lake of the Cherokees, Oklahoma. Survey
conducted for the St. Louis District Corps of Engineers. Data provided on CD.
USACE, 1998. Grand Lake, Oklahoma. Real Estate Adequacy Study. Prepared by Tulsa District.
USACE, 2015. HEC-RAS 2D Modeling User’s Manual. April. 143 p.
U.S. Dept. of Agriculture (USDA), 1939. Aerial photography in the vicinity of Miami, OK. Aerial
Photography Field Office, Washington, D.C.
92
GOODELL STRATTON
515 S Kansas Ave
Topeka, KS 66603
WWVV.GSEPLAW.COM
EDMONDS&PALMER LLP
T 785.233.0593
F 785.233.8870
E [email protected]
E-filed
April 14, 2016
Ms. Kimberly Bose, Secretary
Mr. Norman C. Bay, Chairman
Mr. Robert Fletcher
Land Resources Branch
Division of Hydropower Administration
and Compliance
Washington DC 20426
RE:
Ms. Jennifer Hill, Director
Division of Hydropower Administration and
Compliance
Mr. Jason Murphy
3800 N. Classen
Mr. Kenneth Kopocis
Deputy Assistant Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue N.W.
MC4101M
Washington D.C. 20460-0001
Project No. P-1494-433
Application for Non Capacity Related Amendment of License- Article 401 (Rule curve)
Protest and Comments
Dear Secretary Bose, Mr. Bay, Mr. Fletcher, Ms. Hill, Mr. Murphy and Mr. Kopocis:
This letter is on behalf of 493 citizens and businesses that live and/or do business in
Ottawa County, Oklahoma. It is to protest and comment on the application dated March 16,
2016, and filed by the Grand River Dam Authority (GRDA) titled Application for Non-Capacity
Related Amendment of License.
Our position is simple and straightforward: It cannot be disputed there have not been
adequate easements purchased for the operation of Pensacola Dam; any increase in the rule curve
increases the risk of invasion into the flood pool, causing a backwater effect in Ottawa County.
The backwater effect is an increase in the elevation and duration of flooding. Thus, GRDA
should not be allowed to increase the lake elevation, with its corresponding increase in the risk of
flooding on property with no easements, even a little bit.
Over the course of many years I have supplied FERC with documents, studies from the
Corps of Engineers, court rulings and hydrologist studies as supporting documentation going
back to the 1940's (exhibits), which conclude adequate easements have not been purchased to
operate the Dam, and that would be particularly true with an elevated rule curve. Yet GRDA
continues to maintain the plaintiffs I represent do not know what they are talking about. This is
after being flooded 14 times between 1993 and 1995. Then flooded again, at least 21 times,
PARTNERS
H. PHIUP ELWOOD
JOHN H. STAUFFER, JR.
N. LARRY BORES
NATHAN D. LEADSTROM
MIRANDA K. CARMONA
MARY E. CHRISTOPHER'
RICHARD J. RAMON°
TIMOTHY A. SHULTZ',
OF COUNSEL
ARTHUR E. PALMER,
GERALD J. LETOURNEAU
HAROLD S. YOUNGENTOB s
PATRICK M. SALSBURY
SPECIAL COUNSEL
WESLEY A. WEATHERS'
PATRICIA A. RILEY'
CYNTHIA J. SHEPPEARD
ASSOCIATES
ALISON J. ST. CLAIR
USA M. BROWN
SARAH A. MORSP
RETIRED
GERALD L. GOODELL
WAYNE T STRATTON
DECEASED
ROBERT E. EDMONDS H932-20011
'ALSO ADMITTED IN MO
SALAD ADMITTED IN MO & NY
3 ALSO ADMITTED IN MO, NE & OK
4 ALSO ADMITTED IN MO, NE & MN
sALSO ADMITTED IN GA
Protest and Comment
On Behalf of 493 Plaintiffs
April 14, 2016
between 2007 and 2010. If GRDA thinks they own enough easements to operate the project, as
required by the license issued by FERC, to keep raising the rule curve, they need to prove it.
As its regulatory and licensing agency, FERC should hold GRDA accountable when they
are non-compliant with its license, just as the Agency did in 2011. In 2011 GRDA was assessed
a fine for violating fifty two (52) requirements of nineteen (19) Reliability Standards by failing
to adequately perform critical functions required for the reliable operation of transmission
systems.1
PLAINTIFFS HISTORY WITH GRDA
Four hundred forty-five (445) of these citizens and/or businesses were all flooded in the
2007 flood impacting Ottawa County, and have all sued GRDA for that flooding. City of Miami,
et al., v. Grand River Dam Authority, Case CJ-08-619. The additional 48 citizens and/or
businesses, flooded in 1993, 1994, 1995 and some again in 2007, have sued GRDA for that
flooding: Asbell, etal., v. Grand River Dam Authority Case CJ-01-381, filed in 2001.
In 1994, Dalrymple, et aL, v. Grand River Dam Authority, Case CJ-94-444, was filed.
That case was not fully adjudicated until November of 2007, just five (5) months after the second
largest flood ever in the area (July 2007), costing millions of dollars in losses and displacing
hundreds.
Ottawa County District Judge Reavis has specifically found in litigation involving
GRDA: "The operation of Pensacola Dam caused increased average lake elevations in
approximately 1982 and again in approximately 1992." 2 (Exhibit 1, ¶ 20, p. 9).
The Oklahoma Court of Civil Appeals (COCA) then stated: "Indeed, it was only the
increase through the years of "normal" elevation levels of the lake that resulted in flooding
of the Landowners' property."3 (Exhibit 2, p.17).
To date, all Courts have been consistent in rulings and opinions issued: GRDA is
responsible for the flooding due to the existence and operation of Pensacola Dam, it has caused a
quantifiable increase in the magnitude and duration of flooding, and lands without an easement
have been flooded because of the backwater effect of Pensacola Dam.
The Courts have stated: "The increased elevation and duration of flooding (above 760
feet NGVD) is already on ground above the elevation to which GRDA has easements". See Ex.1,
p, 11(N); Ex.4, p.3, ¶2, f.n. [2]4. Yet, GRDA asks to increase lake elevation still more.
'Order Approving Stipulation and Consent Agreement, 136 FERC ¶ 61,132
2
Order (Dated Nov. 5, 1999): Dabymple, et al., v. GRDA. Case No.: CJ-94-444
3 Appeal From the District Court of Ottawa County, Oklahoma, Affirmed, (June 15, 2004), McCoo/ v. Grand River
Dam Authority, Case 97,020
4
A flowage easement permits GRDA to flood privately-owned property, if necessary, for the operation of the
project.
Page 2 of 10
Protest and Comment
April 14, 2016
DOCUMENTATION FOR A PERMANENT AMENDMENT TO THE RULE CURVE
The fact the request for the Amendment to permanently raise the rule curve is based on
the Dennis Thesis, the study performed by FERC's Atlanta Office of Energy Projects, (accession
# 20150831-4012), as well as the 2004 Holly report (which has a significant modeling flaw
detected in 2010), raises even more concerns. The Order5 issued by FERC, approving the
temporary variance, states: "GRDA's May 28 application also included a February 20, 2015
letter from the Corps stating that the 2014 Dennis Study is of high quality..." II 6. In the
analyses of the Dennis Thesis, the Atlanta office of FERC modeled three (3) different floods,
1986, 1993 and 2009 making many changes to the Dennis Thesis. Those necessary changes call
into question "the high quality" of the Dennis Thesis. In the FERC Order granting GRDA's
Request for the Temporary Variance from Article 401 of the License, the Rule Curve, as
Amended in December, 1996, the following was stated:
"In the HEC-RAS model for the 2014 Dennis Study, the downstream boundary
condition (reservoir elevation) was set at a static elevation of either 741 or 743
feet for all model runs. The study recognizes the possible benefit of further
evaluation with dynamic reservoir routing, i.e., the reservoir elevation varying
due to dam outflows and upstream tributary inflows." Id. at 17 (emphasis added)
"Staff's review indicates that the HEC-RAS model for the 2014 Dennis Study
contained a number of input data errors (concerning, e.g., bridge deck data, cross
section data, and improper ineffective flow areas). While these errors were
carried through for all model runs, thereby possibly negating some impact of the
input errors, the errors to some extent call into question the reliability of the
modeling results. "Id. at 18 (emphasis added)
These errors resulted in the FERC staff performing an independent analysis, resulting in
changes to the modeling used in the Dennis Thesis. FERC issued the Order allowing for a
Temporary Variance to raise the rule curve.
The increased elevation of Grand Lake 0' the Cherokees makes Ottawa County
susceptible to flooding, even when just a moderate rain occurs: the higher the Grand Lake
elevation, the greater the risk of upstream flooding.
FERC concluded:
"In addition, we note that our approval of GRDA's request for temporary variance
in no way requires GRDA to deviate from the Article 401 reservoir elevation rule
curve requirements for the project. Rather, we simply approve GRDA's request to
5 Order
Approving Request for Temporary Variance, 152 FERC1 61,129 (2015)
Page 3 of 10
Protest and Comment
April 14, 2016
deviate from the Article 401 reservoir elevation rule curve, which it does at its
own risk. Regardless of this temporary variance, section 10(c) of the Federal
Power Act (FPA) provides that GRDA is liable for damages caused by its
operation of the Pensacola Project [52].”
"En. 52. See 16 U.S.C. § 803(c) (2012) ("Each licensee hereunder shall be liable
for all damages occasioned to the property of others by the construction,
maintenance, or operation of the project works or of the works appurtenant or
accessory thereto, constructed under the license, and in no event shall the United
States be liable therefore."); also, e.g., Pacific Gas & Electric Company, 115
FERC ¶ 61,320, at P 21(2006) (observing that while Congress intended for the
Commission to ensure that hydroelectric projects were operated and maintained in
a safe manner, Congress intended for section 10(c) of the FPA to preserve
existing state laws governing the damage liability of licensees) (citing South
Carolina Public Service Authority v. FERC, 850 F. 2d 788, 795 (D.C. Cir.
1988))". Id. at 77
"Accordingly, should GRDA flood lands on which it has no flowage rights, it
may be liable for any damages that result. [53]
"En. 53. For this reason, the City of Miami's assertions that we [FERC] should
deny the proposed variation because of its belief that GRDA lacks flowage
easements for certain lands is misplaced. GRDA's right to flood property is
constrained by the extent of its legal rights to do so. If GRDA exceeds its rights,
it is subject to damages." Id. at 78
GRDA began raising the rule curve in 1982 (without consent) and formally adopted the
modification in 1984. It was after this action on GRDA's part that the flooding began as a
regular occurrence in Miami. It was then increased yet again in 1996.6 GRDA continued to
request an increase in the rule curve elevation, based on different factors, and now requests a
permanent amendment to the license.
FOOTNOTES 52 & 53 OF FERC ORDER OF 8/14/2015
A. Footnote 52
In footnote 52 of the Order, FERC cites 16 U.S.C. § 803(c) (2012) "that GRDA is liable
for damages caused by the operation of Pensacola Dam". Following is how the former and
current litigation has progressed, how the law has been applied and Grand River Dam
Authority's position as to its liability:
1. Dalrymple, et al., v. GRDA CJ-94-444
The Dalrymple case, consisted of 107 citizens and businesses, was filed in Ottawa
County District Court in 1994, removed to Federal Court by GRDA when it filed
6
Order Amending License, 77 FERC ¶ 61,251 (1996)
Page 4 of 10
Protest and Comment
April 14, 2016
suit against the United States of America ex rel, Federal Energy Regulatory
Commission and the United States Army Corps of Engineers as third party
defendants. FERC took the position that it had regulatory authority over the
entire project, including the impact of the flood pool. The federal case was
remanded back to State Court. The Tenth Circuit Court of Appeals affirmed the
third party dismissal and dismissed GRDA's appeal of the remand order. On
remand to the District Court, the Trial Court appointed a referee from the Iowa
Institute of Hydraulic Research, who concluded, "[T]he existence and operation
of Pensacola Dam has caused a quantifiable increase in the magnitude and
duration offlooding" The litigation went from 1994 to 2005, when certain claims
were settled for $9 million. Resolution of all claims took until 2007 with total
damages paid by GRDA of approximately $11.5 million. All of those damages
occurred on land above elevation 760 NGVD, above easements.
2. Asbell, et al., v. GRDA CJ-01-381
The Asbell case was filed on behalf of 48 plaintiffs for the floods of late 1992,
through much of 1995, a total of 14 floods in a three and a half (3%2) year period
of time. This case was filed as a takings case and went to the Oklahoma Court of
Civil Appeals. The Court of Civil Appeals found GRDA responsible for the
flooding7 and having taken property, but remanded the case to the District Court
for additional findings. After 15 years, the plaintiffs are still awaiting a decision
from the District Court on the type of taking, the time of the taking and the
resulting damages. The attorneys for GRDA state any decision will be appealed.
(Pending) (See Exhibit 4, pp. 11, 12,20)
3. City of Miami, et al., v. GRDA CJ-08-619
All 456 citizens and businesses were flooded in the 2007, and some also in 2009
and 2010. Every one of these plaintiffs was impacted by the increased elevation
and duration of flooding caused by the existence and operation of Pensacola Dam.
The basis for making the statement regarding the "existence and operation of the
Pensacola Dam" comes from the lawsuit filed in 1994 in Ottawa County District
Court in Dalrymple. (Pending) (Exhibit 4)
GRDA's counsel, Mr. Joseph Farris, made it clear that whatever ruling is handed down
by the District Court, in Asbell, he will appeal on behalf of GRDA. This is after 15 years in
ongoing litigation, one trip to the Appellate Court, a writ of certiorari filed with the Oklahoma
Supreme Court by GRDA, and later denied. GRDA then filed a Petition for a Rehearing with the
Oklahoma Supreme Court. This request was promptly denied. In a hearing in the Asbell matter
held on the 13th of April, 2015, even the Judge expressed an opinion on the delays: "I've always
wanted to try to get to what's fair to the landowners and what's fair to GRDA, who provides a
power source, a hydroelectric plant, all these things, and to be fair to both of you in my
decisions. But I'm getting a little bit tired of what happens in these kinds of cases in the sense
Perry v. Grand River Darn Authority, 2015 OK CIV APP 12, 344 P.3d 1 (Div. 42013)
Page 5 of 10
Protest and Comment
April 14, 2016
that every, every little issue has to be appealed, and it takes time for appeals, and then back to
the Court, then back to this ".(Exhibit 5)
And again at a hearing in the same matter held on the 24th0f September, 2015:
MR.BORK: As to the other cases, just to get it in front to talk about it, there would be some that
would say you make your substantive decision. We already know GRDA is going to appeal it.
COURT: Sure. (Exhibit 6, pg. 13)
THE COURT: -- and you [GRDA] appeal it, do you want to move forward on these other cases
in trial while that's going on appeal, or do you want to wait?
MR.FARRIS: I do, Judge, because I think those other cases are going to raise other issues that
are going to have to be dealt with, such as standing, for example, the substitution of decedents,
who has the right if you sold it, what do we get now, you know. I see all sorts of issues between
the current owners of the property, former owners of property, about who has the right to the
proceeds, if any. (Exhibit 6, pg.14)
GRDA continues to deny any responsibility for the flooding caused by the backwater
effect, found to exist by all hydrologists that have studied this issue. Even the FERC study,
performed by the Atlanta office for the purpose of granting/denying the temporary variance,
showed an impact above the 760 feet easements. GRDA takes the position that it is the aggrieved
and cooperative party, but has its attorney(s) delaying the due process that FERC suggests is the
proper venue for persons damaged by GRDA.
B. Footnote 53
FERC's Order denied the City's request, based on the City's "belief that GRDA lacks
flowage easements for certain lands is misplaced" (En 53) (emphasis added)
I have been involved in this litigation since 1993. I have been lead counsel for these
plaintiffs since 1994 and have advocated on their behalf based on facts presented to the Courts,
using documentation and scientific evidence, which supports the position that inadequate
easements exist for the operation of Pensacola Dam to continue to flood and store water on the
plaintiffs property. Easements need to be purchased; this is not just a belief, but rather a fact
found by multiple Courts and for which GRDA has paid millions of dollars, albeit many years
after the damage was done.
The lack of easements is addressed in the FERC license issued in 1939 and again in 1992:
the Court decision in Dalrymple; the Appellate Court Decision in McCoo/; and the Appellate
Court Decision in Perry, Pryor and Shaw, consolidated under Oklahoma Court of Civil Appeals
as Case 109,714. The very study commissioned by FERC and referenced in the Order, (152
FERC ¶ 61,129) is a substantial argument that the "belief" of the plaintiffs is based on science
and facts.
" bile agree that the proposed temporary variance would have some benefits, including
increased water levels, greater access for boaters and other recreationists on Grand
Lake, ... ... However, notwithstanding these benefits, the proposal could potentially
exacerbate flooding both upstream and downstream of the project during any flood
Page 6 of 10
Protest and Comment
April 14, 2016
events. As explained above, based upon Commission staff's independent analysis of three
historic storm events (October 1986; September 1993; and October 2009), the proposed
temporary variance would increase flood elevations by up to 0.2 foot in the City of Miami
and up to 0.7 foot downstream of Pensacola Dam at the Langley gage. Given the
presence of certain low lying structures at the City of Miami and near the Langley gage,
a flood event could potentially impact additional homes and businesses that would have
been unaffected absent the proposed temporary variance." 152 FERC ¶ 61,129,
Order, ¶ 70.
This statement, from the Order, allows GRDA to perform an illegal act, since the
property necessary to operate the Dam, particularly at an increased elevation, has never been
purchased and GRDA has no easement(s) on the property.
EASEMENTS
Before I go further, it is critical to reemphasize that each and every one of these plaintiffs
was impacted by the "increased elevation and duration" of flooding caused by "the existence
and operation of Pensacola Dam." above the level of the easements. (Ex.1, pp. 2;11). In other
words, every one of them had more flooding than what they otherwise would have had without
Pensacola Dam. Some of them would not have flooded at all. Since all of these properties have
no flowage easement on them, GRDA has no right to put ANY water on their property. Such
rights are necessary to operate the project pursuant to Article 401,8 for power generation as well
as "to provide flood protection". That is consistent with the position previously taken in federal
litigation by FERC when 3"1 partied in by GRDA. An increase in the rule curve should not be
allowed until the easements are purchased in accordance with the terms of the license.
The license issued to the GRDA on July 12, 1939 by the Federal Power Commission,
Article 2 states: "The project covered by and subject to this license is located in Mayes, Craig,
Delaware and Ottawa Counties, Oklahoma... Article 2§C states "... also, all other rights,
easements, or interests the ownership, use, occupancy or possession of which is necessary or
appropriate in the maintenance and operation of the project or appurtenant to the project area".
For the license issued to GRDA in 1992, FERC ¶ 62,073, B3(D): This license is subject
to the articles set forth in Form L-3 (October 1975) 9 entitled "Terms and Conditions of the
License for Constructed Major Project Affecting Navigable Waters of the United States".
(Exhibit 3). Article 5 states: "The Licensee, within five years from the date of issuance of the
license, shall acquire title in fee or the right to use in perpetuity all lands, other than lands of the
United States, necessary or appropriate for the construction, maintenance, and operation of the
8 Order Issuing New License, April 24, 1992 (59 FERC ¶ 62,073).
Article 401. The Licensee shall operate the Pensacola Project to control fluctuations of the
reservoir surface elevation for the protection of fish, wildlife, and recreational resources associated
with the Grand Lake 0' the Cherokees (Grand Lake) reservoir. The Licensee shall act,
to the extent practicable (except as necessary for the Department of the Army, Tulsa District,
Corps of Engineers to provide flood protection in the Grand (Neosho) River)).
9 Reported at 54 FPC 1817 Standardized Conditions For Inclusion in Preliminary Permits and Licenses Issued
Under Part I of the Federal Power Act (October 31, 1975)
Page 7 of 10
Protest and Comment
April 14, 2016
project. The Licensee or its successors and assigns shall, during the period of the license, retain
the possession of all project property covered by the license as issued or as later amended,
including the project area, the project works, and all franchises, easements, water rights, and
rights of occupancy and use;" (Ex. 3, Article 5).
As FERC considers this request for a permanent amendment to the license of FERC
project P-1494, based on the limited studies and reports submitted by GRDA, it is important to
differentiate the options which are legal, and those which are illegal. The flooding of property
which does not have a flowage easement on it is an illegal act, for which multiple courts have
found GRDA to be liable. This goes beyond whether a landowner can get his boat to and from
his dock; or whether a fish has significant oxygen, particularly when there is very questionable
science as to whether the increased elevation of the lake would significantly have a favorable
impact on the dissolved oxygen issue under these circumstances.
When there is a history of thirteen (13) years, fifteen (15) years and going on eight (8)
years and growing, of litigation, it is not appropriate to casually mention those so aggrieved can
just go to the courts. We are now more than twenty (20) years after the damage was to some of
these plaintiffs and they still have not been compensated for the damage done by GRDA. Why
did GRDA buy any property or easements to 755 for storage or 760 for flowage, when it can just
take the property and stall its way through years of litigation? If no easements had been
purchased, so only fee to elevation 750 feet, would FERC allow the amendment stating the
landowners can just go to the Courts? Of course not, and it should not here, either. Even GRDA
cannot take the position there are adequate easements, so it focuses on the fact it is just causing a
little more damage.
The flooding that occurred in the City of Miami and Ottawa County, Oklahoma this past
May and December, 2015 was a result of backwater. Flooding caused by a backwater effect of
1-3 feet may seem inconsequential, something that can be cleaned up quickly once the water
recedes. That is not a reflection of the reality of what is happening to these plaintiffs. With only
1-3 feet of water in a home there is impact on: electrical wiring, sheetrock, paint, flooring,
baseboard trim, doors, duct work, cabinetry, personal property; the home may have black mold;
and, the home has become devalued as flood property. Also, the homeowner is displaced. This
scenario has been repeating since 1986, multiple times, in the same area. This is not a small
amount of money we are talking about, but millions of dollars. FEMA, private insurance
companies and individuals are impacted. These costs, in addition to the damages suffered by
plaintiffs, are then magnified by way of raising the floodplain elevation and the increase in the
cost of flood insurance due to the repeated flooding that continues in this area, caused by GRDA.
Additionally, increased lake elevation causes a danger. Mr. Sullivan, General Manager
and CEO of Grand River Dam Authority, briefly touched on the rainfall received in the area, in
December of 2015, at the January 2016 GRDA Board meeting. [H]e stated: "they received a
tremendous amount of rain in a very short period of time as compared to the May 2015 event.
... he told the Board ... water was about 0.05 of an inch from the top of the flood gates at the
Pensacola Dam at one point. He stated "... at one time during this rainfall event there were 18
gates open at one time, with this being the second highest release at Pensacola Dam since
Page 8 of 10
Protest and Comment
April 14, 2016
1943..."
(Exhibit 7, pg. 7). Mr. Sullivan made no mention of the 1951, 1986, 1994 or 2007
floods, all causing widespread devastation. The Dam came very close to being breached in
December of 2015. Now GRDA is asking, once again, to store more water in the Lake.
My clients are continually portrayed as one of the impeding elements in an attempt to
raise the rule curve. They have gone to the Courts for a remedy and after receiving multiple
favorable rulings against GRDA, many still have yet to recover any damages due to the denial
and delay tactics practiced by GRDA. Plaintiffs want GRDA to purchase the flowage easements
required by the license, initially issued in 1939, and reissued in 1992. Pensacola Dam was
constructed for two (2) primary reasons: flood control and hydropower. This project
(Pensacola), was legislatively established by the 76th Congress 1st, Session, based on studies of
the area as early as the late 1920's. GRDA has known of the necessity to purchase additional
flowage easements since the 1943 flood.
There have been multiple studies done, beginning in the late 1930's and the early 1940's
by the Corps of Engineers, and other private engineering firms (i.e. Black & Veach) and more
recently by Dr. Robert Mussetter and engineers hired by GRDA, (including Forrest Holly,
special master at the Dalrymple trial) who found: "the existence and operation of Pensacola
Dam caused a quantifiable increase in the flooding and duration of flooding in the City of
Miami, Oklahoma above the elevation of the easements..." (Ex. 1, p.2) (emphasis added). The
operation of the dam is the critical component and the common denominator in the entire
unnatural flooding taking place in Ottawa County.
The plaintiffs ask that the cumulative effect of the small incremental changes made
to the rule curve since 1982 be reevaluated. Asking to raise the rule curve one-to-two feet
does not seem like a lot, when in fact the rule curve has been raised by 10 feet in this time
period since 1980. The dam originally was drawn down to 732 feet, 10 feet less than what is
currently being sought. The drawdown to 732 feet allowed for more storage of inflows due to heavy
rainfall. With weather patterns being difficult to predict, less storage translates to less time to react
in the event of an emergency. Plaintiffs also ask that the lack of storage acre per foot and the
nearly 10 feet of sediment, found to exist at Pensacola Dam, be taken into consideration.
The 493 citizens and businesses that I represent request that FERC consider the Study
performed by Tetra Tech. Dr. Robert Mussetter has been studying this area and these issues
since the middle 1990s. (Exhibit 8). The Tetra Tech Study used the latest technology and
bathymetry. That Study shows a backwater effect of a difference of 2.9 feet from the FERC
modeling for the September 1993 flood, for example. (Exhibit 8, p. 60). The Mussetter study
shows the FERC model as significantly underestimating the flood inundation area for each of the
modeled floods (p.60). Further, that study shows a backwater impact up to elevation 778 feet,
NGVD 18 feet above the existing easements at 760 feet, involving nearly 13,000 acres. (Exhibit
8,p. 2).
FERC has the authority to make changes to the Pensacola Dam operations. Flood control
is listed as one of the two purposes for building the Dam. The repeated flooding of the area
where these plaintiffs reside, the City of Miami and Ottawa County, Oklahoma, is Dam caused
Page 9 of 10
Protest and Comment
April 14, 2016
and has been found so by multiple Courts and hydrology studies. This continued flooding is in
direct opposition to the 76" Congress, 1st Session, intended purpose of approving the financing
and building of this Dam under authority of the Flood Control Act.
For the reasons stated herein, 493 citizens and businesses in Ottawa County state the
requested Amendment to the license GRDA holds to operate Pensacola Dam, to permanently
raise the rule curve, should be denied.
We appreciate your consideration of this protest and comment.
NLB:pz
Miami City Council
cc:
Ottawa County Commissioners
B. Pete Yarrington
David Anderson
Dean Kruithof
Jack Dalrymple, P.E.
Mark Osborn, M.D.
Kevin Stubbs
Derek Smithee
Barry Bolton
Senator James M. Inhofe
Senator Charles Wyrick
Senator Ron Wyden (Oregon)
Congressman Markwayne Mullin
Kenneth Kopocis, EPA
Jerry Clark, FEMA, Region IV
Page 10 of 10
April 18, 2016
FERC staff informal review comments on GRDA’s draft application for amendment of
Article 401 rule curve requirements, Pensacola Hydroelectric Project, No. 1494 Oklahoma
____________________________________________________________________
Flood Analysis
1.
In Appendix 4: Information Supporting Amendment Application, the ninth
bullet on the list refers to a document as “FERC staff modeling analysis.” That
document should be referred to as “FERC staff independent analysis.”
2.
Regarding Appendix 2, please see the attached Word document, which contains
GRDA’s proposed Storm Adaptive Management Plan, with FERC staff comments in
track changes.
3.
We compared the Drought Adaptive Management Plan (DAMP) approved in
paragraph (C) of the Commission’s August 14, 2015 order to the DAMP proposed in
the draft application. Please address the following differences in your final application:
a. As approved in the 2015 order, GRDA would implement the DAMP if water
levels in Grand Lake fall below the elevations on the temporary rule curve as the result
of a severe to exceptional regional drought as identified using information from the U.S.
Drought Monitor. In the draft application, GRDA appears to implement the DAMP by
a determination of a severe to significant drought alone, without reference to water
levels. This change might cause actions under the DAMP to be taken prematurely.
Please explain why GRDA is not using water levels, in part, to trigger implementation
of the DAMP or add water levels as a trigger for implementing the DAMP. Also,
please explain the use of the term “significant drought” when referring to the Drought
Monitor. It appears you should be using the term “exceptional” which is the highest
Drought Monitor category.
b. As approved in the 2015 order, once the DAMP was implemented, GRDA
would make decisions on hourly and daily release rates using input from the same
entities participating in the weekly teleconferences. In the draft application, it is not
clear that GRDA would use input from these entities. Please address this difference, or
modify the relevant text to clarify that input from the listed entities would be used in
decisions regarding release rates under the DAMP.
Environmental Analysis
4.
Section IV: The environmental analysis in the draft application indicates that the
scope of the application is the same as GRDA’s 2015 temporary variance. GRDA then
says no further studies are necessary and that relevant existing information including
materials prepared by GRDA for the 2015 application appears in Appendix 4. In
Appendix 4 of the draft application, GRDA lists the information that would be included
in that appendix of its final application. GRDA needs to include in its final application
a discussion and analysis of the differences in possible environmental effects between
last year’s temporary variance and GRDA’s proposed permanent, multi-year change.
GRDA should discuss and analyze any such differences for each major resource area
including differences that could occur in individual years and identification, discussion,
and analysis of cumulative effects.
5.
In your draft application, you say a new water quality certificate is not needed
for the proposed rule curve change. Please consult with the Oklahoma Department of
Environmental Quality to determine whether or not a new water quality certificate is
needed for this amendment application.
Cultural and Historic Resources
6.
In the 2015 order, staff found that a temporary amendment of the rule curve
would not cause any significant effects to cultural/historic resources. However, in
support of a request for a permanent amendment and under the requirements of Section
106 of the National Historic Preservation Act, GRDA should consult with Oklahoma
SHPO to obtain their concurrence with the proposed amendment’s Area of Potential
Effect and any potential effects to historic properties. Also, GRDA should consult with
any Native American tribes to obtain their comments on the proposed amendment’s
effects. We note that the Modoc tribe has already raised objections to the permanent
rule curve amendment. If needed, GRDA can ask to be designated the Commission’s
non-federal representative for the purposes of conducting initial consultation with the
Oklahoma SHPO and tribes for this amendment.
Threatened and Endangered Species
7.
Please include documentation of consultation with the U.S. Fish and Wildlife
Service identifying specific actions that may be required under the Endangered Species
Act in the processing of a permanent change to the project rule curve. Federally-listed
species in the project area that should be considered include the Neosho mucket,
Neosho madtom, Ozark cavefish, and gray bat. In addition, please discuss whether any
new endangered or threatened species have been identified in the project area and the
results of your discussions with FWS regarding those species.
Recreation
8.
The Vessel Aground log submitted in the 2015 application should be updated to
include all vessel groundings since that filing (i.e., all vessel groundings from 2013
until the date of the application).
9.
Section 2.1.1 of the 2015 Environmental Report Supplement should be updated
to reflect new vessel grounding information collected since it was filed on August 10,
2015 (i.e., the Supplement should discuss any patterns in vessel groundings during the
2015 variance period in comparison to prior years).
Background
As part of this Application for Non-Capacity Related Amendment to the license for the
Pensacola Project No. 1494 (Project), GRDA proposes under an amended Article 401 to
implement a Storm Adaptive Management Plan (Plan) “[u]pon the forecast of any major
precipitation event within the Grand/Neosho River basin that may result in high water
conditions upstream or downstream of Grand Lake.” This Plan sets forth rules and
protocols for the adaptive management process to meet this requirement of the amended
Article 401.
DescriptionPurpose
This Plan sets forth protocols for managing Grand Lake prior to and during major
precipitation events.
Description
GRDA will work with resource agencies and local governments to address concerns
related to high water conditions upstream and downstream of Grand Lake prior to and
during any major precipitation event that may occur in the Grand/Neosho River basin.
GRDA will review, at a minimum on a daily basis, weather forecasts in the watershed,
Grand Lake surface elevation data, U.S. Geological Service gauges upstream and
downstream of the Project, surface elevations at the Army Corps of Engineers’ (USACE)
upstream John Redmond Reservoir and downstream Lake Hudson, and other relevant
information affecting surface elevations at Grand Lake during the potential flood period.
Based on GRDA’s daily review of the above-referenced information, if the weather
forecast indicates a high probability of high water conditions in the Grand/Neosho River
basin in the immediate vicinity of the Project, GRDA will take the following actions:
•
Notification and Data Distribution. Immediately provide all above-referenced
data to the USACE; Federal Energy Regulatory Commission (FERC) staff in
Washington, DC (Division of Hydropower Administration and Compliance) and
Atlanta Regional Office (Division of Dam Safety and Inspections); U.S. Fish and
Wildlife Service; Oklahoma Department of Environmental Quality; City of Miami,
Oklahoma; and interested Indian tribes, and interested local governments. A
listing of all T h e entities to t h a t w i l l receive this information is are provided
below, and each entity is expected to keep GRDA informed of any changes in
personnel or contact information on the list. This list of entities is subject to
change, at any time, as other entities express an interest or a need for participation.
•
Schedule Teleconference. In conjunction with the notification and data
distribution, GRDA will schedule a conference call at the earliest practicable
time, and notify all entities listed below of the time for the call and instructions on
how to participate in the call.
•
Current Reservoir Operation. [ G R D A : P L E A S E A D D B R I E F
DESCRIPTION OF RESERVOIR LEVEL OPERATION
PROTOCOLS WITH THE USACE e.g.: “Dedicated flood storage
(the flood pool) is provided between elevations 745 and 755
feet PD. When reservoir elevations are within the limits of the
flood pool, the Tulsa District directs the water releases from
the dam under the terms of a 1992 Letter of Understanding and
Water Control Agreement between the USACE and GRDA that
addresses flooding both upstream and downstream of Grand
Lake. When reservoir elevations are below the limits of the
flood pool, GRDA operates the project pursuant to the terms of
its license.”
•
Consultation with USACE. Prior to convening the conference call, GRDA will
determine in consultation consult with the USACE, Tulsa District, regarding the
forecasted event. USACE, Tulsa District, will determine whether any actions,
including initiating pre-releases, can be taken to prevent, minimize, or mitigate
water levels upstream or downstream of the Project.—recognizing USACE’s overarching flood risk management responsibilities within the Arkansas River basin
under the Flood Control Act of 1944, and to balance all reservoirs within the basin
under its jurisdiction. GRDA expects USACE, Tulsa District, to consider Ffactors
such asconsidered will include pre-existing watershed conditions, soil moisture
content, and storm event composition (e.g., path, intensity, and duration).
•
Convene Teleconference. During the teleconference, GRDA will report
USACE’snotify the participants of any decision on anyto take actions at the
Project, including initiating pre-releases, to prevent, minimize, or mitigate water
levels upstream or downstream of the Project. Participants will have an opportunity
during the teleconference to explore alternative potential solutions to respond to the
forecasted high- flow event, recognizing the USACE’s jurisdiction to manage take
over spill operations at the Project for purposes of flood risk management once the
reservoir elevation reaches flood pool elevation 745 feet PD.
•
Subsequent Communications. As necessary and appropriate in each high-flow
event, GRDA will continue regular communications with all entities listed below, to
keep them informed of prevailing conditions at the Project during the event. Such
communications may entail conference calls, email messages, or other forms of
communication appropriate under the circumstances.
Relationship to Emergency Action Plan
Although tThe requirements of this Plan are separate and distinct from any obligations
under GRDA’s FERC-approved Emergency Action Plan (EAP) for the Project, the
protocols set forth in this Plan compliment the EAP and include many of the same interested
entities. Once the EAP is triggered, however, the communication protocols contained in
the EAP supersede those included in this Plan until the emergency is resolved.
CONTACT LIST
National Weather Service, Tulsa Forecast Office
City of Miami
Modoc Tribe
From: Catharine Wood [mailto:[email protected]]
Sent: Monday, May 02, 2016 2:19 PM
To: Reese, Nathan
Subject: RE: Historic Properties Addition to Pensacola License Amendment
Nathan,
We did not receive the 2015 GRDA EA for review and so I do not have the context for the
additional information you sent below.
However, after I read the three paragraphs from the EA I had concerns that the State
Archaeologist/OAS was left out in paragraph one. The OAS is the main repository for all
the archaeological site records and reports. The issue of the potential for burials to be
discovered and the state laws protecting them was not mentioned in paragraph one or in
sections 11.2 and 11.3 where the idea that archaeological sites are protected when
inundated is incorrect. Higher levels of water do not protect archaeological sites or other
historic resources, it damages and destroys them. That’s why GRDA needs to have a historic
properties management plan (HPMP) in place to address how they mitigate these adverse effects
to the historic properties when the water levels change.
This brings me to the revisions submitted for the storm and drought adaptive management plans.
It would be difficult and stressful to craft a HPMP in the middle of an event or after some sort of
storm or drought event occurs. So, I recommend that GRDA develop an HPMP to have in place
for the final storm and drought plans instead of waiting until an event happens and it’s too late to
do anything. Below are my comments on the draft revisions:
Storm Plan
Page 2-1, Background, include the State Archaeologist/OAS as a consulting party with the
SHPO.
Page 2-2, Historic Properties, please include the State Archaeologist/OAS as a consulting party
with the SHPO.
Include a provision for the potential of burials to be discovered and the state laws protecting
burials and GRDAs plan for when this happens.
Drought Plan
Please include the State Archaeologist/OAS as a consulting party with the SHPO
Include a provision for the potential of burials to be discovered and the state laws protecting
burials and GRDAs plan for when this happens.
In the contact list, please include “Oklahoma” with State Historic Preservation Office.
From: Reese, Nathan [mailto:[email protected]]
Sent: Monday, May 02, 2016 11:27 AM
To: Catharine Wood
Cate, the Environmental Assessment that was prepared for GRDA’s 2015 variance request included the
following information related to archaeological and historical properties. I would note that the
“proposed variance” from last year is identical to our request in this year’s license amendment. We will
include similar information in the EA we are currently preparing, but we can also include reference to
our HPMP.
Currently, there is risk of exposure of archeological or historical properties during drawdown and
drought. Article 409 addresses GRDA’s responsibilities related to land-clearing or land-disturbing
activities within the Project boundary and includes a provision for the protection of any unidentified
archeological or historical properties exposed or discovered during Project operations. GRDA maintains
data supplied by the State Historic Preservation Office (SHPO) and the Oklahoma Historical Society that
identified potential and significant cultural resources sites. Approximately 50 cultural sites are known to
exist within the Project area (GRDA 2008). Because of the sensitive nature of cultural or historic
resources, their locations and significance are not public information.
11.2 Potential Impacts
The proposed variance would create less disturbance of the land around the reservoir because more land
would be inundated for a longer period of time throughout the year. The risk of greater exposure occurs
during the drawdown period of the current rule curve. The proposed variance would prevent the areas
below 742 feet from being exposed to natural and human disturbance (GRDA 2015b).
11.3 Proposed Mitigation
License Article 409 provides for the protection of previously unidentified archeological or historical
properties that are discovered during Project operations, maintenance, or permitted construction. No
additional mitigation actions for this resource are recommended because the temporary change to the rule
curve would positively impact cultural and tribal resources.
From: Catharine Wood [mailto:[email protected]]
Sent: Monday, May 02, 2016 8:19 AM
To: Reese, Nathan
Nathan,
Just wanted to let you know that I received the document and that I will review it and provide my
comments before the end of the day.
Sincerely,
Catharine “Cate” M. Wood
Historical Archaeologist
Section 106 Program Coordinator
Oklahoma Historical Society
State Historic Preservation Office
Oklahoma History Center
800 Nazih Zuhdi Drive
Oklahoma City, Oklahoma 73105-7917
(405) 521-6381/fax (405) 522-0816
Upcoming Events:
May 4 & 5, 2016
Section 106 & the NRHP Workshop
BLM Oklahoma Field Office, Tulsa
www.okhistory.org/shpo/workshops.php
June 1-3, 2016
Oklahoma’s 28th Annual Statewide Preservation Conference
Enid
From: Reese, Nathan [mailto:[email protected]]
Sent: Friday, April 29, 2016 10:10 AM
To: Catharine Wood
Subject: Historic Properties Addition to Pensacola License Amendment
Catharine, attached is language that incorporates a plan to manage historic properties as part of our
license amendment application. Please let me know if this is in line with our conversation last week. We
are happy to amend if necessary.
Thank you.
Nathan Reese
Director of Public Policy
P.O. Box 409
Vinita, OK 74301-0409
918-530-8247

Appendix 17

Transcription

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