Segret information: whitehouse.gov

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River Services T . .

Incorporated

3750 Washington Ave. N., Minneapolis, MN 55412

Tel: 612-588-8141 Fax: 612-588-6570

Mile 856.8 on the Upper Mississippi

River Services, Inc. is a subsidiary of River Trading Company, LTD and has been the operator of the Port
of Minneapolis since 1991. This terminal is a general commodity terminal and is the furthest north barge
navigable point on the Mississippi River. Annually we load or unload barges of commodities which
among other things include coal, fertilizer, pig iron, scrap metal, aggregates, baler twine and numerous
other commodities and specialty products. Our customers use and depend on the inland waterways system
because of the ability to move large volumes of products in a reliable, economical and probably the most
environmentally sound manner. We do indeed understand and support the need for clear and balanced
guidelines that will enable best water resource planning. The proposal submitted by the CEQ does not
take into account all factors that must be considered in implementing practical principals and guidelines.
It is for this reason that we share many of the same concerns as does the NWC which are outlined below.

The Council on Environmental Quality's (CEQ) proposed revisions to the Principles and Guidelines
governing the development of water resources projects (Proposal) would significantly alter our nation's
water resources planning. We find the Proposal unworkable in the real environments and commerce.

Recognizing the critical role of our water resources infrastructure to a robust economy and environmental
well-being, it is imperative that the resulting Principles establish a clear, concise, and workable framework
to guide the development of these critical projects. Vague, ambiguous, and confusing mandates and
directives must be clarified or deleted.

As drafted, the Proposal fundamentally fails to achieve this critical end and must be extensively revised to
offer a path to balanced solutions, clear and consistent guidance to planners, and replicable results that are
understandable to all stakeholders.

Unfortunately, CEQ's Proposal uses the concepts of "principles," "guidelines," "procedures," and
"standards" interchangeably so that the Proposal is confusing and impracticable.

A concise set of Principles should:

1.
Utilize cost-benefit analysis and other such recognized and proven analytical tools as a basis to
compare options,
2.
Provide for the unbiased consideration of all alternatives, and not exclude or penalize classes of
alternatives from consideration and recommendation,
3.
Require that decisions are made based on an assessment of net beneficial effects, and
4.
Establish a peer review process that is appropriate to the potential impacts of the project and
seamlessly integrated into the planning process.

The National Objectives must be clarified in order to provide for efficient water resources planning.

1.
Although it's stated in the Proposal that the National Objective is to maximize economic,
environmental and social benefits, the "modernizing" changes proposed clearly (and
inappropriately) elevate environmental goals over economic and social ones. This approach would
be especially detrimental to flood control, navigation and water supply projects.
2.
The Proposal also contemplates forcing multiple objectives in every water resources planning
study. Requiring that every study include the multiple objectives of economic, environmental, and
social benefits would lead to including features in projects where they have lesser returns than in
other projects, programs or plans. Such a requirement is impractical, does not reflect the reality of
project development, and would result in a waste of scarce resources.
The Water Resources Development Act of 2007 states that: It is the policy of the United States that all
water resources projects should reflect national priorities, encourage economic development, and protect
the environment by—

1) seeking to maximize sustainable economic development; 2) seeking to avoid the unwise use of
floodplains and flood-prone areas and minimizing adverse impacts and vulnerabilities in any case in
which a floodplain or flood-prone area must be used; and 3) protecting and restoring the functions of
natural systems and mitigating any unavoidable damage to natural systems.
WRDA 2007 contemplates water resources planning founded upon multiple national objectives:
economic, environmental, and social well-being, including a public safety objective. Additionally, WRDA
2007 emphasizes a watershed approach to planning, recognizing the importance of collaborative planning
and implementation.

CEQ's Proposal does not promote co-equal objectives in water resources planning, but instead elevates
environmental considerations at the expense of economic benefits. This framework, in apparent
contradiction of the directive in WRDA 2007, is reflected throughout the entire Proposal, starting on page
one, the statement of National Objectives: [the primary objective is to] "protect and restore natural
ecosystems and the environment while encouraging sustainable economic development." Similarly, the
Objectives are to: avoid adverse impacts "whenever possible" and avoid "unwise use" of the floodplains.
These directives are not predicated on an analysis of the net beneficial effects. Rather, they are vague and
ambiguous terms, providing no basis for measurable criteria.

In order to develop a long-term planning model, we recommend that CEQ modify its Proposal to reflect a
balanced approach to water resources planning. Recognizing the widespread public benefits of our
nation's water resources infrastructure, a balanced approach would give due regard to the economic and
human uses of water resources, along with environmental and economic considerations.


The Proposal directs the avoidance of the "unwise use" of the flood plains, flood-prone areas and other
ecologically valuable areas. However, the Proposal does not set forth criteria for determining what would
constitute "unwise use." Even more alarming, the Proposal appears to create a bias for selecting non-
structural approaches thus limiting, in practice, a full consideration of all alternatives. (K. Recommend a
Plan, page 23).

We appreciate that due consideration should be given to the risks and impacts inherent in the use of our
floodplains; we also believe that the best approach to floodplain management will continue on a course
that puts the principle of balancing economics and other factors at the center of floodplain decisions.
Floodplain decisions (including permitting and licensing decisions) should be governed by consideration
of the net beneficial effects of all feasible or practicable alternatives. This fundamentally rational approach
is consistent with longstanding national policy of balancing economic and environmental values in
decision making, and framing solutions guided by the standard of benefit-cost analysis.

As drafted, the Proposal fails to establish a clear, concise, and workable framework to guide the
development of water resources projects. It is incoherent and inconsistent - and thus cannot be utilized in a
practical sense. It substantially fails to comply with the explicit directions in Section 2031 of WRDA 2007
as well as the large body of previous law and policy related to water resources. It is written so as to not
require or even encourage use of proven analytical tools to distinguish among alternatives. It limits in a
preemptive manner certain categories of alternatives, and (even while encouraging "collaboration") seems
to assume that water resources planning decisions are the exclusive prerogative of the Federal government
thus not recognizing the keystone role played by non-Federal sponsors. Because of these critical and
extensive failings, we recommend that this effort be put aside and restarted from the beginning.