Robert Williams, PE

805 Des Moines Drive

Windom MN 56101

 

January 7, 2008

 

Director Kent Lokkesmoe          

500 Lafayette Road

St. Paul MN 55155-40

 

RE:  Windom Island Park Dam

 

Dear Director Lokkesmoe:

 

This is in response to your letter of November 20, 2007.  Your letter does not satisfactorily address important issues regarding the Windom dam issue that need to be reiterated.

 

Your letter stresses the “drowning machine” effect at low head dams as reason to basically deny the city permission to repair the riverbank at issue.  The DNR still calls our dam a “drowning machine” even though no one has drowned.  Based on this logic, swimming at public lakes and hunting should be banned altogether.  Your letter fails to note that a riprap retrofit that would address both safety and fish passage concerns has been used in similar situations with great success and the DNR has even commissioned a video that demonstrates it.

 

More disturbing along these lines is that the DNR acknowledges the potential for erosion to occur from the river in its natural river condition.  The DNR position is that “…should erosion jeopardize public or private property, measures can be taken to alleviate the erosion, including riprap protection of the stream bank and bridge piers.”  The willingness of the DNR to place other public employees or private contractors in the position of trying to deal with the effects of erosion during flood events is very disturbing.  I also note that in my professional opinion it appears it would be virtually impossible to safely riprap the Federally owned multistory Riverview Apartment building riverbank during a flood stage event.  The DNR’s willingness to place unsuspecting homeowners and renters in the position of attempting to riprap their riverbanks in an emergency situation without prior disclosure of the increased risks you are placing them in is also quite troubling.  The DNR’s willingness to apparently force MnDOT workers to stabilize a major bridge in flood conditions is reckless and irresponsible.

 

The claim that the dam has “already been removed” is also remarkable and contradicted by visual evidence.  The dam was perfectly capable of maintaining a reservoir if the riverbank was restored.  The following photo taken in mid October 2007 demonstrates this fact:

 

 

The DNR is in fact by all appearances attempting to force the removal of a sound dam, not an “unsafe or unsound” dam.  Your letter stated that the DNR has included cost share funds for the Windom Dam project in your 2008 capital budge request, however the fact remains that only $150,000 was shown, specifically for dam “removal”.  This makes the DNR’s statement that this situation is an “opportunity for a community dialogue” disingenuous to say the least.  All the more noteworthy is the willingness of the DNR to maintain public dams upstream of Windom, controlled by the DNR.   

 

The replacement value of our public and private property located in Windom is easily worth millions of dollars and the potential liability to the City, taxpayers and affected residents in a worst-case scenario associated with an ill-conceived dam removal would be especially serious.  Forcing others to address erosion concerns during a major flood event, as the DNR would apparently intend for others to attempt is far more dangerous and problematic than a conservative and prudent approach.  We again assert that forcing others to remedy negative consequences of a dam removal done for very marginal ecological purposes is an irresponsible abuse of regulatory authority, and we again ask the DNR to seriously and completely reconsider your position in this matter.

 

Sincerely,

 

 

 

Save the Island Park Dam Group

Robert Williams PE, Representative

 

Cc:       Governor’s Office

            Commissioner Holsten

            Senator Vickerman

             Representative Hamilton

             Mayor Tom Riordan

            Administrator Steve Nasby