COMMUNITY COMMENTARY: KWD explains position on Alewives Restoration Initiative

by Jeff LaCasse
Kennebec Water District

Information and communications – ARI project, KWD, and China Lake

As third party observers, KWD staff sees some facets of the ARI project on Outlet Stream from a different perspective than many ARI members. We feel we have information and access to some resources that we can share that could aid in facilitating some planning and avoiding some potential issues – either structural or financial – in the project’s scope and implementation. We have, especially recently with the appointment of Matt Streeter, relatively good communications with ARI on ongoing project issues. We do feel, however, that there has been some misinformation being presented in discussions related to the project that is not fact based.

One issue that we have been having is that we have noticed on more and more frequent occasions that information is being disseminated in various forums that is incorrect. Some assertions have been repeated enough that they are frequently being considered factual. We feel it is a disservice to the public to put this information out there as it may lead to expectations that are unfounded and criticisms of some, including KWD, that are unwarranted. We feel we have information that can correct some of the miscommunications, increase trust, and keep all parties working cooperatively together. We also feel the information may help keep unexpected situations to a minimum.

KWD has been using China Lake as its water source since 1905 (currently serving 30,000+ people) and has collected data on the lake from 1903 to present. That data includes lake levels, water quality measurements, Outlet Dam specifications, and personal observations. We have been operating the Outlet Dam for the Town of Vassalboro since 2009. Operations are required to meet the regulatory guidelines of the China Lake water level and streamflow order of the Maine Department of Environmental Protection (DEP).

7 frequently repeated, but incorrect assertions with corrected information from KWD:

1. KWD opposes the reintroduction of alewives in China Lake.

We are actually neutral on the project, which we consider a fish restoration project. We were early proponents of trying to determine whether or not alewives would help the lake’s water quality. We lead early efforts to investigate what would be required for passage and the potential impacts of alewife restoration on the water quality of the lake. We worked through CRLA on the Seward Mills project to allow migration into Three Mile with the intent to use that as a pilot project. We reviewed impacts on both Webber and Three Mile in an attempt to extrapolate whether or not any impacts might be projected to China Lake. Our position is that we do not oppose the fish restoration and we will assist the project with technical knowledge and data sharing as appropriate, but we will not support the project financially. As a public water utility we have a massive infrastructure that needs maintenance and replacement and we do not have discretionary funds to support a project that we do not believe will provide our ratepayers with a tangible benefit. Our bottom line is we feel this is a fish restoration project, not a water quality improvement project.

2. The alewife project will result in noticeable water quality improvement in China Lake.

We have written documentation of past statements by the Department of Environmental Protection, the prior director of Maine Rivers, and several others that have brought forth the same message that alewife “most probably will not affect water quality”. This contention is also backed by many scientific publications.

The anecdotal reports of improved water quality on Webber and Three Mile Ponds are encouraging, but we feel there are other factors influencing the improved water quality in those lakes. There has been no scientific study evaluating the individual measurable impacts of alewives, annual drawdown flushing, and other nutrient control practices on the water quality in those water bodies. Many other Maine lakes with long term alewife migrations have seen no water quality improvement.

We did extensive literature review of the impacts of restoration projects on water quality in other water bodies and commissioned a study of our own to determine the potential impacts on China Lake – based on its individual characteristics. The basic conclusion of the study was “alewife does not cause water quality problems in lakes and ponds in Maine” and “there is little evidence that restoring alewife is a panacea for accelerating the recovery of eutrophic lakes.” The report did emphasize that alewife restoration will contribute to an improved ecosystem (which does not equal improved water quality), and we feel that is important.

There are multiple factors that impact water quality in lakes and multiple factors that can contribute to improving that quality. China Lake is different from other lakes. The most limiting factor in water quality improvement in China is its configuration and resultant slow flushing rate. Much of the phosphorus impacting water quality in China Lake is phosphorus that is linked to an internal recycling process within the lake. This internal phosphorus is in addition to phosphorus that comes from sources within the watershed. The fact that it takes over two years to flush the lake makes quickly removing large quantities of phosphorus from the lake impossible.

Even if there is a “net export” of phosphorus by exiting juvenile alewives as promised by some, the amount of P that needs to be removed to result in noticeable water quality improvements within the lake is substantially more than would be expected via alewife outmigration.

Although we feel the odds are very small, we certainly hope that we are wrong about the lack of positive impact on water quality from alewives which will result in a noticeable improvement in water quality. Many in the public have been convinced by ARI proponents that the restoration will reverse the eutrophication of China Lake, but we feel that to guarantee that there will be noticeable water quality improvements via the reintroduction is disingenuous. At best, we feel that a message that “it is hoped that the alewife reintroduction will be a contributor to water quality improvements in China Lake” would be more appropriate and temper public expectations.

3. The report that KWD commissioned to project impacts on China Lake’s water quality from alewife reintroduction states that the alewives will improve water quality.

This is a specific point that has been made in some forums and we feel it should be addressed separately from #2 above. The specific point of the study was to project if there would be any positive or negative impacts to the water quality of China Lake as a result of the reintroduction. As noted in #2, the study concludes “alewife does not cause water quality problems in lakes and ponds in Maine” and “there is little evidence that restoring alewife is a panacea for accelerating the recovery of eutrophic lakes.”

An “improved ecosystem” is not the same as water quality. The report concluded alewife restoration should contribute to an improved ecosystem, which relates more to a more robust top-to-bottom food chain.

4. This year’s exceptional water quality in China Lake is due to alewife introduction.

A statewide phenomenon, one that has been examined by several in the scientific community this year and in the past is that lack of precipitation is responsible for the improved water quality in almost all Maine lakes in 2016 (“Drought years led to increase in Secchi depths”). China Lake has had better water quality than in any year since 1999 (via measurable water quality parameters). Other lakes are reporting their best water quality since the 1970’s. The simple fact is that the much lower than normal amount of precipitation provided much less opportunity for runoff and movement of nutrients into China Lake. Alewives were not even exiting China Lake until early September, so any “net export” of phosphorus by out-migrating alewives in 2016 would certainly not have impacted the spring/summer/fall water quality in the lake.

5. The fall drawdown of China Lake was instituted to allow out-migration of alewives.

Alewife reintroduction played no part at all in the annual drawdown proposal. In fact, KWD was the applicant to DEP to institute the annual drawdown process. That application followed a report commissioned by KWD to determine if an annual drawdown would contribute to reducing the in-lake phosphorus level. The report detailed the expected outflow of phosphorus in kilograms and the optimal timeframe in which to conduct the drawdown. Alewives were not a consideration in this process to any degree. The drawdown was intended to be a tool to help improve water quality within the lake while not negatively impacting any of the criteria listed as essential in the Maine DEP’s Regulation of Water Levels and Minimum Flows,

(Those criteria are: a. water levels necessary to maintain public rights of access to and use of the water for navigation, fishing, fowling, recreation and other lawful public uses, b. levels necessary to protect the safety of littoral or riparian proprietors and the public, c. water levels and minimum flow requirements necessary for the maintenance of fish and wildlife habitats and water quality, d. water levels necessary to prevent excessive erosion of shorelines, e. water levels necessary to accommodate precipitation and run off of waters, f. water levels necessary to maintain public and private water supplies, g. the water levels and flows necessary for any ongoing use of the dam to generate or to enhance downstream generation of hydroelectric or hydromechanical power and h. water levels necessary to provide flows from any dam on the body of water to maintain public use and access and use, fish propagation and fish passage facilities, fish and wildlife habitat and water quality downstream of the body of water.)

6. The contention during a recent public meeting that alewife passage in and out of China Lake will supersede the DEP’s water level and streamflow order currently in place.

Water level orders are set through an extensive regulatory process that considers the potential impacts on the seven criteria listed in #5 above and the level is set to minimize the impacts Water level hearings typically receive testimony from lake and stream abutters, abutting municipalities, associated regulatory bodies, public water systems (if applicable), with input from outside expert witnesses. No one issue is valued over others. In fact, fish passage was not considered in prior lake level hearings for China Lake because it did not exist. If proponents want to get consideration for fish passage into the water level order with the intent to change the order to allow specific changes in the current regime, they will have to make its case to the DEP to hold a rehearing on the current order. Our assumption is that a specific fish passage will have to be proposed that will not greatly impact current protections in place for the other considered criteria in the order. Without going through a water level review process, the water level/streamflow order will not be adjusted.

7. The Outlet Stream dam has been dramatically modified in the past in order to raise the level of China Lake four feet (specifically in the 1960’s).

KWD actually has documentation that indicates there was a dam on the site prior to 1800, with a new dam built in 1817. Since then there have been several ownership changes. We have drawings of the dam made in 1921 by Metcalf and Eddy engineers that depict the dam and gate house structure with associated dimensions and elevations. The dam, spillway, gates and gate house have all received maintenance and rebuilds in the intervening years, but the elevations of the spillway and gates have remained the same in 2016 and they were in 1921. In addition, KWD has collected lake levels readings throughout the period from 1905-2016. Although the lake varies in elevation over the course of each year due to seasonal fluctuations, there has been no change in the structural elevations or the average lake level during that period, much less a 4 foot difference. All rebuilding processes were extremely careful to keep the spillway elevation to within a close tolerance to the original.

Jeff LaCasse
Kennebec Water District
11.22.16