"I am commenting on behalf of the Lake Hartwell Association, and its 2000 member businesses and families, regarding the relicensing of the Augusta, Georgia Canal, Project P-11810. The Lake Hartwell Association strongly supports adaptive management to control the Savannah River Basin. By adaptive management we mean using inline, real-time monitoring of basin conditions to regulate stream flows and optimize water resources for all users. We believe such an approach would not only have a significant mitigating effect during the current regional drought, but is the only viable option to adequately allocate resources in the future.

When we have discussed this concept with the U.S. Army Corps of Engineers personnel, we typically get a favorable response to the concept, but the first roadblock thrown up is the demands of the city of Augusta due to its proximity to the Thurmond Dam. As an example, when there was considerable rainfall this past year in the lower basin to satisfy both supply and water quality needs, the demands of Augusta and the shoals were used to justify the need for continued high releases from the lakes.

In taking a closer look at what's happening at Augusta, it appears that the real problem is the operation of the Augusta Canal. The flows are diverted from the prized shoals to supply water to what appear to be unnecessary or little justified purposes. The largest demand of canal flow is for driving the city water pumps in a very inefficient and antiquated system. Granted it would cost a bit more to use diesel or electric pumps as every other major city does, but we are dealing with a critically short resource here. Likewise, the small hydropower plants (only one actually serving its original purpose) seem hard to justify in today's environment. There appears to be plenty of water available to supply the critical needs of the shoals, users downstream, and the lakes in time of drought if the operation of the canal system were optimized.

We understand that a new federal license for operation of the canal is imminent, and will lock in required minimum flows for decades to come. It does not seem to make much sense to merely accept what is the current user demands, and go forward with a new licensing agreement. We now have grown to better understand the effects of climate change and the needs of future economic growth, and their respective impact on our scarce water supplies. We are also just at the start of developing a Georgia Statewide Water Plan, which will include a Regional/Basin component. We also expect South Carolina to follow suit with a similar approach. Doesn't it make sense to take a clean slate approach to how the entire basin is managed, and allow basin users the opportunity to share in decision-making over how their resources are shared?

We strongly recommend that before entering into any new licensing agreement for the Augusta Canal system, the Regional Water Planning Councils should be given an opportunity to weigh in on how effectively these resources are being utilized. And the Corps should be given the tools and flexibility to optimize water management throughout the basin without being locked into fixed flow targets under a license agreement for an antiquated and inefficient operation."