September 21st, 2021

JD McLucas

489 Hackett Road

Benton, PA 17814

Jmcluca1@[Link]

Dear Representative Millard, Senator Gordner and the SEDA-COG Board of Directors,

Will we have to wait until lives are lost to effectively plan for disaster?

That question should be foremost in the minds of every public official in Columbia

County. Over the last forty years, this area has been hit by some of the worst flooding in the

entire Mid-Atlantic region. It’s foolish to think these were just one-off events or freak accidents.

As climate change accelerates and violent storms become more and more common, our area will

have to reckon with the fact that we are unprepared for a major flood. Despite efforts to protect

the bigger towns, many of the smaller communities are at risk for unchecked damage. This must

be addressed. The best way to do so, in my mind, is with strong public works projects such as

floodwalls to keep our vulnerable towns safe.

The thought that we are at high risk for flooding events isn’t an exaggeration. We have

good evidence, in fact, that this problem is just beginning. David L. Kriebel, Professor of Ocean

Engineering at the U.S. Naval Academy, explains in more detail: “Nuisance flooding, which

causes public inconveniences such as frequent road closures, overwhelmed storm drains and
compromised infrastructure (NOAA, 2017), has noticeably increased at multiple mid-Atlantic

coastal locations in recent years. Multiple factors contribute to such flooding events, however

mean sea level rise (MSLR) is a primary driver, due to its effect on increasing the exceedance

probability of a given storm leading to flooding” (2018). What this dataset tells us is that we

should expect increased storms throughout the Mid-Atlantic Region (MAR) as a consequence of

sea level rise as well as other factors, such as ground saturation. We need only to look at the

multiple flooding events that have turned our towns into rivers of their own for further proof that

we must be prepared.

What can be done, then? Knowing that MAR flooding will be a continued problem is

only half the battle. For the other half, we must take action and make sure we’re prepared when

the next major storm strikes. The question is: How? What can be done to prevent acts of nature?

One common suggestion is the planting of water-retaining plants. Soil saturation is a major cause

of flooding, as any water not absorbed by the ground will run into waterways, raising their levels

significantly. By planting specific types of vegetation, we can increase water retention and

reduce flooding. However, this requires a great deal of time and effort. Not only do you have to

make sure that the plants aren’t invasive, you also would have to send crews out regularly to

ensure that they haven’t died or been eaten by fauna. Texas’ Harris County Flood Control

District outlines just how much vegetation is needed to be effective: “The Flood Control District

typically plants 12,000 to 15,000 trees annually to replace those lost during construction, to

enhance capital improvement projects, and as part of a routine maintenance program” (HCFCD

n.d.). Given how remote some of our area is, this would be wholly impractical. Additionally,

this would require agreement from thousands of landowners, as every inch of ground that isn’t

covered by water retaining plants is an inch that can drain off into the waterways.
 Another proposed solution is to improve runoff systems from industrial areas such as

mines. Strip mining causes a steep drop in soil retention, which can make severe flooding even

worse. Digging runoff ditches and controlling where runoff goes would go a long way to

alleviating some of the stress on the local waterways, but it is only a partial solution which

comes with some of its own environmental concerns. Even with the best runoff systems and

ditches imaginable, it only takes one good storm to overwhelm their capacity and bring us right

back to square one. James Bruggers of the National Environment Reporting Network goes into

some more detail:

“…Concerns persist about the adequacy of erosion and sediment controls. ‘With the

larger and more intense storms coming, you could have those controls fail,’ leading to more

flooding, said Joe Pizarchik, a lawyer from Pennsylvania who ran U.S. Office of Surface Mining

and Reclamation, the agency that oversees enforcement of the 1977 surface mining law, during

the Obama administration. Acidic water runoff that flows from strip-mined areas into valley fills

and dissolves rock from the inside, likely weakening them, is also a potential risk that could

grow with climate change, increasing the potential for landslides during storms in the future, said

Duke University Professor Emily Bernhardt, who studies watershed biogeochemistry” (Bruggers

2019).

The best way to prevent flooding, in my view, is through our infrastructure and public

works. This is not a new idea for our area, as the Towns of Bloomsburg and Danville have

already taken steps to ensure the safety of their people. WNEP covered the completion of the

first phase of their flood wall project:

“Construction on this phase of the project started last spring. It expands on the $30

million flood wall that already went through town. ‘It's going to protect 125 homes, 30
businesses and the school district. It doesn't get any better than that,’ SEDA-COG Executive

Director John Brown said. It also includes stormwater and sewer improvements. ‘The

devastation of just getting water in your basement is a problem and yet the devastation of a flood

that would take out homes,’ Brown said” (Krize 2020).

We already have experience in building infrastructure to protect our bigger towns from

flooding. Now, we need to use that knowledge to expand those projects to protect other

municipalities and boroughs, such as the oft-devastated town of Benton. The goal of protecting

lives and livelihoods should be enough to begin work on a smaller flood wall and better storm

drainage for Fishing Creek in Benton, but the reality is that a project such as this would come

with a few key caveats.

First among those caveats is the issue of money. This would not be a cheap solution.

However, projects like these have great economic advantages. The money spent on them doesn’t

just evaporate, it lands in the pockets of workers and project leads before cycling back through

local businesses. The Center on Budget and Policy Priorities elaborates:

“Carefully targeted initiatives to maintain and improve public infrastructure boost a

state’s long-term productivity, resulting in more economic growth and higher-wage jobs. In the

short term, when conditions are right, public infrastructure investments also can create needed

jobs” (McNichol 2019). CBPP also states that “Higher-quality and more efficient infrastructure

will boost productivity in states that make the needed investments, lifting long-term economic

growth and wages. In the short term, even though overall employment has recovered, millions of

Americans are working less than they would like and making less than it takes to get by. Key

infrastructure investments would provide immediate job opportunities” (McNichols 2019).

 These projects would be expensive, granted, but self-investment through public

infrastructure packages serve to give the local economies much-needed boosts in manufacturing,

design, construction and more. If we’re not going to spend our tax dollars to make ourselves

stronger, what are we even collecting taxes for?

Another major concern is that of our local ecosystems. Fishing Creek is a vibrant

waterway, teeming with life. Whether it be trout, suckers, minnows, crayfish, salamanders or

anything else, making sure that major projects don’t harm our valuable local species should be of

the utmost importance. Thankfully, there are precautions that can be taken to ensure that we

respect the local wildlife and their homes. F. Douglas Shields, University of Mississippi,

explains: “Environmental resources in the project area can be preserved and enhanced by

avoiding critical areas and critical periods such as breeding or nesting periods, by preserving

trees and riparian vegetation wherever possible, and by overdesigning drainage ditches so that

some vegetative growth can be tolerated. Construction impacts may be reduced by employing

appropriate erosion and sediment control measures to reduce off-site impacts” (1987). We would

need to work closely with the Environmental Protection Agency (EPA) and the Pennsylvania

Department of Conservation and Natural Resources (DCNR) to ensure that we take care of our

non-human species as much as we do our human ones. Construction would likely have to take

place in the high summer months, when very few aquatic species are in their breeding season and

the creeks are low enough to work in without dredging up too much mud. We could also work

closely with the Pennsylvania Fish and Boat Commission to build flood walls and levees that can

serve as effective shelter and structure for the stocked Trout species, as well as the native Spruce

Trout, just as the old stone dams throughout Fishing Creek serve as protection for the local fish.
 A common point brought up when discussing levees and floodwalls is their safety and

effectiveness. Critics commonly refer to the events surrounding Hurricane Katrina as an example

for the unreliability and danger posed by these projects. The levee systems protecting the city

from the waters of the Gulf and Lake Pontchartrain infamously broke, destroying large swaths of

the city after the storm. However, the comparison in this case is apples to oranges. G.L. Sills

goes into further detail:

“Forty years had elapsed since New Orleans and the surrounding areas had experienced a

major storm. For this reason, it seems likely that many residents had become a little complacent

about Gulf storms. It is also likely that not many were concerned with the reports of the tropical

depression that was forming over the central Bahamas on August 23, 2005” (2008).

It should be clear, then, that the most major cause of the Katrina disaster was

complacency in upkeep and inspection of the levee system. Additionally, the massive storm

surge that Katrina created produced erosion and weakening of floodwalls. Sills explains:

“Overtopped I-type floodwalls experienced varying amounts of erosion and scour. The

extent of erosion was similar to that of levees where the soil type and degree of compaction of

the material being attacked by the overtopping waters dictated the degree of erosion. The south

breach at the IHNC, which catastrophically flooded the Lower 9th Ward, is an example of this

type of failure. The waters flowing over the top of the wall attacked the soil that provided the

passive resistance the floodwall needed for its stability. After this passive resistance was

removed, the wall was no longer stable and it breached” (2008).

 Given the proper upkeep we would provide and the impossibility of any type of storm

surge to cause erosion, the failure of New Orleans’ flood retention system can not be compared

to a potential prevention system in Northeastern Pennsylvania.

At the end of the day, we must be prepared for the worst. At any time, we are one good

storm away from a repeat of 1972, 2006, 2011 or any other destructive floods since. The

question is: Will we be ready? Will we take action to prevent the loss of life, or wait until

members of our community are killed to act? As members of the government, you are the only

ones who can make that decision. If no action is taken, the responsibility of damages and any

lives lost fall directly at your feet. Do the right thing and invest in the future of our communities.
 References

Bruggers, J. (2019, November 21). Appalachia's strip-mined mountains face a growing climate
risk: Flooding. Inside Climate News. Retrieved November 30, 2021, from
[Link]
change-coal-mining-west-virginia-extreme-rainfall-runoff-analysis/.

Harris County Flood Control District (HCFCD). (n.d.). Retrieved November 30, 2021, from
[Link]

Kriebel, D. L., & Henderson, G. R. (2018, December 30). Assessing current and future nuisance
flood frequency throughout the U.S. MID-ATLANTIC. Coastal Engineering Proceedings.
Retrieved November 16, 2021, from
[Link]

Krize, N. (2020, September 9). Bloomsburg celebrates completion of Flood Protection Project.
[Link]. Retrieved November 16, 2021, from
[Link]
protection/523-642929d0-00a6-4c7a-a0ef-778b3db544a1.

McNichol , E. (2019, March 19). It's time for states to invest in infrastructure. Center on Budget
and Policy Priorities. Retrieved November 16, 2021, from
[Link]
infrastructure.

Shields, F. D., Hynson, J., & Nunnally, N. R. (1987, March). (PDF) environmental
considerations for levees and floodwalls. Research Gate. Retrieved November 16, 2021,
from
[Link]
Levees_and_Floodwalls.

Sills, G. L., Vroman, N. D., Wahl, R. E., & Schwanz, N. T. (2008). Overview of new orleans
levee failures: Lessons learned and their impact on National Levee Design and assessment.
Journal of Geotechnical and Geoenvironmental Engineering, 134(5), 556–565. C