Ms. Helen Rucker
Tennessee Valley Authority
400 West Summit Hill Drive
Knoxville, Tennessee 37902
Dear Ms. Rucker:
I appreciate the opportunity to comment on the “Draft Environment
Assessment of TVA on the Elk River Resort Proposed Recreational
Easement and Marina Facilities, Wheeler Reservoir, Lauderdale
County, Alabama".
As a published terrestrial and behavioral ecologist, I am dismayed by
some of the methods and findings reported in the
assessment. Below I list some of my concerns:
1. I could find no description of the methods used by TVA
personnel to assess the vertebrates located on the proposed
project area. For example, how many pit traps, drift fences,
cover boards, PVC pipes, etc. were used on the proposed area to
sample for amphibians and reptiles? How many man-hours were
used to turn over logs and litter looking for amphibians and
reptiles? How many hours were used to walk transects through the study
area listening for birds? What methods were used to sample
for bats and other mammals? When was the sampling done for
the terrestrial vertebrates? Was it done during the spring,
middle of the summer, late in the summer? The only time
period that I could find in the assessment was August, which is a
completely inappropriate time to sample for terrestrial
vertebrates. Methods used in the study are of course needed
so the reader can make the appropriate inferences about the
findings of the survey work. For example, did a TVA worker
go into the proposed area for an afternoon in August, wander
around, turn over a few logs, listen for a few hours and come to
the conclusions published in the assessment, or were many hours spent
in the appropriate habitats, using appropriate surveying
methodology for a particular terrestrial group? It is not
clear what methods were used in your assessment and it calls into
question the kind of science TVA uses to manage the public's
land.
2. In 3.1.3, it is reported that "Wood frogs" were seen on the
property. I assume that the authors are referring of Rana
sylvatica, which is not found in this area of Alabama, and which
is rare and local in the state. Is the "eastern tufted
titmouse" the same species as the Tufted Titmouse (Baelophus
bicolor) or have TVA personnel discovered a new species? These
errors and the very short list of terrestrial vertebrates that
were noted as being on the proposed site indicates to me that no
serious survey work was done on the site and calls into question
the qualifications of the people doing the survey
work. Also, why is there relatively thorough plant
list but not a thorough vertebrate list? Is it because no serious
survey work was done?
3. The birds listed in the assessment are primarily those that
are year-round residents. Since the property is wooded, I
am sure that the area serves as an important breeding and
stop-over site for numerous migrant species. Apparently,
very little survey work was done during the migratory or breeding
period and therefore we can only assume what bird species will
be affected by the proposed project. Is this good
science?
4. It is not clear what documents TVA personnel used to create
Table 3-1. It appears that TVA biologists are not familiar
with some of the new publications concerning wildlife and
conservation in Alabama (i.e., "Alabama Wildlife Vol. 1, A Checklist of
Vertebrates and Selected Invertebrates: Aquatic Mollusks, Fishes,
Amphibians, Reptiles, Birds, and Mammals" edited R. E. Mirarachi;
"Alabama Wildlife Vol. 2, Imperiled Aquatic Mollusks and Fishes" edited
by R. E. Mirarchi et al., "Alabama Wildlife Vol. 3, Imperiled
Amphibians, Reptiles, Birds, and Mammals" edited by R. E.
Mirarchi et al.; "Alabama Wildlife Vol. 4: Conservation and
Management Recommendations for Imperiled Wildlife", edited and
written by Mirarchi et al.). This is especially disturbing
to me since I volunteered many hours to research, to write, and to
edit these publications. Many wildlife experts were
involved in the preparation of these publications and it was
hoped that they would help organizations like TVA make good
management decisions. Again, this calls into question the
kind of science TVA does to manage the public land that it is
responsible for.
These comments provide evidence that the EA that was done in the
proposed area needs further work. The section of the EA
that deals with terrestrial vertebrates (my area of expertise)
appears to have been "thrown together" quickly and reflects very poorly
on the professional scientists that work for TVA. I
recommend that TVA go back and reassess the environmental effects
of the proposed area on terrestrial vertebrates in a more scientific
and responsible way. The public is depending on TVA to take
its responsibility of managing its property seriously and expects
that TVA will not alter natural ecosystems without a serious scientific
environmental assessment. To do less, jeopardizes the
credibility and respect that TVA officials will obtain from the
public, from professional scientists, and even from professionals
within TVA’s own ranks; but even worse, it could lead to
the blind destruction of valuable natural resources.
Thank you again for this opportunity to comment on the EA draft.
Sincerely,
Thomas M. Haggerty, Ph.D.
Professor of Biology
University of North Alabama
Florence, AL 35632
