Dear Mr. Clark,

I am submitting comments to the proposed ROPE plan on behalf of the Whitefish Chain Yacht Club (WCYC). We are a non-profit association whose mission is to promote boating and water safety on the Whitefish Chain of Lakes. As part of our mission, we install and maintain more than 100 buoys throughout the Whitefish Chain without financial support from any government sources. The purpose of our buoy program is to assure that as individuals navigate the lakes, they do so safely by marking channels, shallow areas and underwater hazards and slow/no wake zones. The buoys are placed at the direction of the Crow Wing County Sheriff Water patrol.

We are very concerned that the proposed plan will negatively impact the Chain in many respects, including boating safety. The proposed ROPE plan will not only result in an adverse affect on boat access and navigation, as your study recognizes, but it will render our buoy system less effective in maintaining a safe boating environment. Lower lake levels will increase the number of shallow water hazards and require more buoys to define areas of safe boating depths. The seasonal boating activity remains very active well into October, so our concerns about lower levels reflect the expected levels called for during half of our boating season.

On it’s face, the proposal does not include dramatic changes to the current plan, until the effects of the proposed lower target, increased outflow and dry conditions are combined. As a point of reference I can state from recent personal experience that with the pool at 1228.91 on Sept 20, 2008 traffic through the channel between Lower Whitefish and Big Trout Lake was drastically impeded. This level is what one would expect during the month of August under the new plan and the same deficit inflow that we experienced in 2008. The channel itself was barely passable, and the approach areas on either side were so shallow that all boats I observed had to raise their motors to the point that steerage and headway were significantly reduced. If this condition existed on a busy August afternoon or worse evening, the congestion of boats would present a real safety concern.

We believe your study is misleading in characterizing the changes represented by the proposed plan. The plan indicates the changes would result in lake levels 3 inches “lower than normal” on September 1st and October 1st. Similarly, your study also compares the additional reductions to the drought years of 2006 and 2007. Revised lake levels should be compared to “normal” levels represented by the summer targets, which safe boating and navigational expectations are based upon. Your study states “The summer band represents the range of water levels that are most beneficial to the majority of the users during summer months.” The proposed plan would start reducing the “beneficial” summer levels in mid-summer and result in lake levels approximately 5 inches below the normal summer target elevation by mid-September, when boating is still very active. With the proposed plan, lake levels would be over 7 inches below “normal” on October 1st or worse if drought conditions exist. The current operating plan already causes navigational and boat access issues when drought conditions result in levels at the lower end of the operating band.

The conclusions on Table 1 of the economic impact study reflect no impact on public safety, business activity and property values, which we believe is understated. There are several channels that would become un-navigable at these levels, such as the channels in and out of Island Lake, Trout Lake, Lower Hay Lake, Bertha Lake, the channels between Whitefish and Rush Lake, as well as access to residences around the island in Little Pine. These residents may be unable to navigate to useable boat launches or marinas once the lake levels drop this significantly. The COE’s economic impact study acknowledges the fact that “Minnesota lakes are extremely important to the state’s recreation and tourism, as well as many local economies.” Many other restaurants and retail businesses rely on boaters navigating the chain for their livelihood and will also see economic impacts from a reduction in boating caused by the proposed changes. Crow Wing County has the highest direct economic impact from recreational boating and tourism of all counties affected by the ROPE.

The property values on the chain are significantly higher than those on nearby lakes due to the appeal of safe, recreational boating on the chain. As that is impacted, so will property values. This will not only affect the individual property owners but will also affect the property tax base that sustains the local schools and cities.

We are supportive of positive changes to the existing operating plan. Our primary concerns stem from reduced lake levels that will have serious negative consequences. A revised operating plan that keeps levels at or above the existing target levels through mid-October would be supported by our organization. Increasing the summer target would actually improve boating safety.

If the primary objecting is to achieve seasonal changes in reservoir levels to foster positive effects on the natural resources, we recommend a plan that achieves that objective without sacrificing boating safety or negatively impacting property values and local economic health. If a revised plan increased summer targets as does the proposed plan for Gull Lake and implemented a mid-August drawdown at the proposed rate, we believe the same objectives could be achieved without the negative consequences of the proposed plan

We do not believe that the unquantified benefit are justified when measured against the real, predictable and know problems that it will cause.

Thank you for your consideration of our concerns.

Sincerely,
J. Robert Nelson
Commodore
Whitefish Chain Yacht Club