The IFA has recently noted that the work scope for the Phase II feasibility study has not been finalized and that it is open to public input. Hence the concerns noted below.
The task of supplying input is made more difficult by our inability to obtain the Corporation for Economic Development’s application for funding and the IFA’s evaluation of the application, or more accurately, the IFA’s non-disclosure of these requested public records. We do not know what was actually applied for and upon what basis the application was considered and approved. If the application (and the draft scope of work for the grant agreement) is not disclosed to the public, the task of supplying input becomes problematic. Nevertheless, our comments follow.
1. The public consultation meetings which have been referenced in the media should be free of uniformed police presence and intimidation. In the three “public sessions” conducted earlier this year by the CED, the police presence has been visible and intimidating to the public. This is an inappropriate use of the police power of the state.
These meetings themselves should be structured in a way that actually encourages open input, perhaps even pointed criticism of the plan, and avoids the usual techniques of control and suppression often employed by the proponents of the issue, who also have control of the meeting format.
2. A feasibility study should include a detailed dam removal plan, because a reservoir can be expected to fill with sediment, lose capacity, and present a public safety hazard as its useful life and function come to an end.
3. A feasibility study should fully evaluate the potential impacts associated with such a high-hazard dam, and identify an adequate protection plan for downstream residents.
4. We cannot speak for Citizens Water (Indianapolis utility). However, we can relay statements and apparent facts which should weigh, or should have weighed, in the decision about whether to fund the proposed feasibility study:
According to a Citizens Water corporate communications officer, no one from the State contacted Citizens’ management before the grant was announced concerning either the proposed study or the need/process for planning for future water supply. Yet the Governor, in announcing the grant, emphasized a purported need for additional water supply for central Indiana as a principal publicly-stated rationale for committing the funds.
Considering, among other things, the increasing costs (rate increases) of water supply and treatment in central Indiana, and resultant affordability issues, it is possible that per capita consumption will continue to fall over time, as it has steadily over the past seven years, according to a company consultant.
Soon, the IURC will likely approve a new irrigation rate structure for Citizens Water customers which will substantially increase the costs of lawn watering (by eliminating the current volume discounts). Thus it’s foreseeable that dry-weather draw downs from the various surface and ground water sources could decrease, thereby possibly reducing or even obviating the need for some new sources of supply.
5. The case statement in opposition, dated October 17, 2013, by the Heart of the River coalition has previously been supplied to IFA. It contains many additional concerns and potential impacts affecting feasibility and viability. These should also be incorporated into the scope of work.
Submitted to the IFA by:
Heart of the River Coalition
December 13, 2013