National Wildlife Federation Comments on Devils Lake outlet

Corps of Engineers Draft Environmental Impact Statement

Page 3

-bracket the potential effects for the two moderate lake scenarios [emphasis added] selected for analysis…

The outlet plan preliminarily selected for design does not originate in West Bay and falls somewhat outside the bounds for this analysis [emphasis added]. The water quality effects on aquatic resources would likely be [emphasis added] very similar to those identified with the West Bay 300 cfs outlet, constrained by water quality and channel capacity. However, since a Pelican Lake outlet captures the fresh water flowing into Devils Lake, the outlet would have substantially higher flows, and the effects of increased flow on aquatic habitat in the Sheyenne River would likely be [emphasis added] closer to the effects identified with the West Bay 480 cfs outlet. In lieu of additional modeling, the water quality effects of the 300 cfs constrained operation and the flow effects of the 480 cfs unconstrained operation were used to evaluate the potential effects of the Pelican Lake outlet on aquatic resources.” (DEIS p. 5-45)

In discussing the impacts of the operation of the proposed Pelican Lake 300 cfs outlet on the Sheyenne River under the more “moderate” 1450 feet lake future scenario, the DEIS shows a “typical operation year” that imposes 300 cfs flows from the outlet on Sheyenne River base flows that peak at 200 cfs in July and average less than 100 cfs from May 1 through September 1, with flows from the outlet dropping to an average of perhaps 50 cfs from September 1 through November 30 (DEIS Figure 35, p. 5-50). Therefore, in a “typical operation year” under the 1450 “moderate” scenario, it appears that the Pelican Lake 300 cfs outlet would be expected to discharge about 80,000 acre-feet of water from Devils Lake to the Sheyenne River. Under these “moderate” conditions, the DEIS states that:

“Operation of the Pelican Lake outlet would result in a substantial change in the flow regime of the Sheyenne River. Discharges of up to 300 cfs over a major portion of the summer would represent a 5- to 10-fold increase in summer/fall flows along the Sheyenne River.” (DEIS p. 5-48)

“…the outlet could result in up and down flows with sudden and extreme fluctuations in flow. These are the types of situations that made it difficult for species to adapt to habitat conditions.” (DEIS p. 5-48)

“The changes in flow duration, stage and frequency could result in an increase in erosion and sedimentation on Sheyenne River.” (DEIS p. 5-52)

“The changes on the Sheyenne River in water quality, hydrology, geomorphology and habitat could result in substantial changes in aquatic biota.” (DEIS p. 5-53)

“Even under a constrained operation approach, the levels of many water quality constituents are increased by two to three times to concentrations just below the established water quality standards.” (DEIS p. 5-53)

“…although water quality standards on the Sheyenne River are not violated, the percent of time any particular concentration is exceeded increases dramatically. For example, sulfate exceedences go from zero to 42 percent for the 250 mg/l sulfate level.” (DEIS p. 5-53)

“The loss of habitat due to increased flows, changes in channel geometry, loss of overbank cover and sedimentation, coupled with changes in water quality and algal growth, would all contribute to a substantial change in the aquatic community present in the Sheyenne River. Projected water quality changes associated with outlet operation may adversely influence fish reproduction and result in lost-year classes. The cumulative result of all these changes would be a decrease in diversity and density of aquatic species in the Sheyenne River. The threshold chloride levels of some aquatic species, such as mussels, would be approached with operation of an outlet; however, no effects are anticipated.” (DEIS p. 5-53)

“Many of the effects associated with the operation of an outlet cannot readily be quantified.” (DEIS p. 5-96)

“Some of the aquatic losses would not be mitigated; for example, loss of invertebrates, loss of fish year classes, loss of wetted usable area due to increased channel width, and changed channel morphology.” (DEIS 5-97)

“Changes in the aquatic community would persist for many years after outlet operation ceased, especially on the Sheyenne River above Lake Ashtabula.” (DEIS Appendix D, p. D-31)

“… the 300 cfs [West Bay] constrained pumping alternative would cause much less damage than the 480 cfs [West Bay] unconstrained pumping alternative [which approximates the flow impacts of a 300 cfs Pelican Lake outlet] under either the moderate or wet climatic scenario.” (DEIS Appendix A, p. A-254)

“The flow impacts due to a Pelican Lake alternative could be dramatic, particularly in the upper Sheyenne, which is essentially isolated from recolonization. Water quality changes would be devastating to unionids.” (DEIS p. 5-102)

“Substantial to significant adverse impacts on aquatic habitat availability and suitability can be expected under most if not all of the Devils Lake outlet options. The most flow sensitive habitat types, such as riffles where shallow, fast habitats predominate, would be almost entirely eliminated for a majority of the year. The largest adverse impacts on habitat would likely occur in the Sheyenne River above Lake Ashtabula, where stages are projected to increase up to 3 feet.” (DEIS Appendix C, p. C-38)

“Downstream interests would bear most of the negative impacts of this [480 cfs] plan [which reflect the water quantity impacts of a Pelican Lake 300 cfs outlet]. Flooding may increase, primarily on agricultural lands along the Sheyenne River. Higher flows may exacerbate streambank erosion that may threaten farmstead structures and residences along the river. The added flow translates into stage increases, resulting in additional damage to structural property from direct flooding. Under these circumstances, flood easements would be purchased to compensate landowners for future expected losses to their properties. The potential for bearing these adverse impacts of an outlet is a source of controversy with downstream interests and has produced conflict with their upstream neighbors.” (DEIS p. 4-10)

“As in the case of an overflow, farms that withdraw water from the Sheyenne River or the Red River for irrigation could suffer reduced crop yields from the lower river water quality associated with an outlet. Exacerbated flooding in the Sheyenne River could damage agricultural property, including lands, equipment, and structures. Also, higher flows in the river could affect some farms that straddle the river… These river crossings may be impeded or prohibited by additional river flow associated with an outlet.” (DEIS p. 5-42)

“In rare instances, there could be overbank flooding due to unforecasted rainstorms and the inability to turn the outlet off in time.” (DEIS p. 5-56)

“Using a _ mile area of influence, groundwater changes could potentially affect about 112,000 acres of riparian lands along the Sheyenne River and 76,000 acres along the Red River.” (DEIS p. 5-57)

“Although the Sheyenne River channel appears currently stable, channel instability may be onset if the flows are increase[d] due to the operation of an outlet… The process of channel adjustment may take 50 to 100 years or more.” (DEIS Appendix C, p. C-69)

“There is an increased risk of transfer of biota or the increase in the distribution of existing organisms associated with any feature that improves the connectivity between systems that have been segregated for many centuries.” (DEIS 5-56)

As noted above, the DEIS shows that, in a “typical operation year” under the more “moderate” 1450 feet future lake level scenario, the proposed Pelican Lake 300 cfs outlet would discharge approximately 80,000 acre-feet of water from Devils Lake to the Sheyenne River, primarily from May through August. Although the DEIS does not show a “typical operation year” for the Pelican Lake 300 cfs outlet under the “wet future scenario,” in order to prevent an overflow, it appears that the outlet would have to operate at its 300 cfs maximum capacity for the full seven months from May 1 to November 30 every year. For example, with the lake reaching 1457 feet even with the outlet in operation (DEIS p. 5-86), it would have a surface area of approximately 230,000 acres (DEIS Figure 7, p. 2-26). The average annual 21 inches of precipitation in the Devils Lake area during the 1993-1999 period on which the “wet future scenario” is based (DEIS p. 4-12) would contribute 402,500 acre-feet of precipitation directly to the surface of the lake each year. With the additional average 317,000 acre-feet of inflows during that period (DEIS p. 1-5), total annual accruals would average 719,000 acre-feet through the first 21 years of the “wet future scenario.” The average annual 29 inches of evaporation through the 1993-1999 period (WEST Consultants, Inc., 2001) would be expected to remove 556,000 acre-feet per year from the lake, leaving an average annual net accrual of 162,000 acre-feet that would have to be removed by the outlet to prevent the lake from continuing to rise above 1457 feet. A 300 cfs outlet operating at maximum capacity for seven months would remove 126,000 acre-feet per year, so it appears that the Pelican Lake 300 cfs outlet would have to operate at maximum capacity from the fifth through the 21st year (DEIS Appendix A, p. A-110) of the a “wet future scenario” in order to prevent the lake from overflowing to the Sheyenne River and justify its construction.

Because the downstream impacts of the operation of the proposed Pelican Lake 300 cfs outlet have not been modeled, the DEIS attempts to interpret the possible impacts—examples of which are cited above—based on the water quality impacts of a 300 cfs constrained West Bay outlet and the water quantity impacts of a 480 cfs unconstrained West Bay outlet modeled under “moderate” future lake conditions of 1450 and 1455 feet. However:

“A wet future in the Devils Lake basin would also probably result in a wet future in other basins.” (DEIS p. 5-81)

including the Sheyenne River Basin, and the statements that:

“The primary downstream area affected would be those areas flooded when the flow on the upper and lower Sheyenne River reach 1,000 and 1,500 cfs, respectively.” (DEIS Appendix C, p. C-138)

and:

“Operation of an outlet at 300 cfs would have limited effect on the extent or duration of flooded area along the upper or lower Sheyenne River with flows not exceeding 1,000 or 1,500 cfs, respectively.” (DEIS Appendix C, p. C-138)

indicate that the operation of the outlet would not, in fact, be constrained to the 600 cfs capacity of the Sheyenne River channel during a “wet future scenario” as claimed (DEIS p. 3-14, 4-18), so the impacts could be expected to be substantially greater and more severe than those described under the moderate future scenarios discussed in the DEIS.

It is instructive, therefore, to consider how the DEIS describes the downstream impacts associated with the more than 50 percent increase in discharges from these “moderate” conditions (from 80,000 acre feet to 126,000 acre-feet per year) of a Pelican Lake 300 cfs outlet operating under “wet future scenario” conditions where the Sheyenne River would already be experiencing unusually high flows:

“Because the scenario is based on a wet climate, the pumping may [emphasis added] last longer and greater quantities may [emphasis added] may be pumped out. Therefore, the impacts described for the stochastic analysis would last longer and the flow effects would be greater. For example, erosion would be more, aquatic effects from flow would be the same type but would be of a greater magnitude, soil salinity effects would also be of the same type but irrigators and land users would be subject to those effects for a longer period.” (DEIS 5-86)

“In summary, changes in hydrology would be significant with a Pelican Lake alternative because large amounts of water could be discharged during wet periods in the Devils Lake Basin due to improved water quality. Erosion will be greater, summer nursery habitat will be less, unproductive habitat will increase in summer and fall, and change in flow magnitude between fall and winter will be greater. Therefore, aquatic communities may survive the water quality changes of the alternative, only to be affected by the change in habitat and hydrology. The changes in the aquatic community would persist for many years after outlet operation has ceased.” (DEIS p. 5-55)

That’s it! These two paragraphs are the sum and substance of what the public, the Congress and other decision-makers are told about the specific environmental impacts of the operation of the proposed Pelican Lake 300 cfs outlet in the “wet future scenario” under which outlet proponents such as the North Dakota congressional delegation, Ramsey County elected officials and Lake Emergency Management Committee representatives are advocating that the outlet be justified (Associated Press, 2002a).

Of course, the reader is told that more detailed discussion of the impacts under the scenario future is presented in the Technical Appendices (DEIS p. 5-66), but examination of Appendix C, which addresses “Environmental Resources,” reveals only the same kinds of abstract and ambiguous generalizations that are used in the DEIS itself to minimize and obfuscate the downstream impacts of the operation of the proposed Pelican Lake 300 cfs outlet under the “wet future scenario” necessary to rationalize its construction.

The failure of the DEIS to provide the detailed statement of the qualitative and quantitative environmental impacts of the construction and operation of the proposed Pelican Lake 300 cfs outlet required by NEPA renders the DEIS technically inadequate and legally deficient on its face.

Devils Lake Outlets – Technically Unsound and Economically Unjustified

The DEIS concludes that the proposed Pelican Lake 300 cfs outlet only:

“Minimally reduces flood damages around the lake and moderately reduces the potential for a natural overflow event.” (DEIS p. 4-38)

However:

“When balancing the project needs and objectives, including cost effectiveness, downstream water quality impacts, and other considerations, the Pelican Lake 300 cfs outlet alternative is the best overall outlet plan. Additionally, it is moderately effective in controlling future lake levels” (DEIS 1-S-7).

Under a conventional stochastic analysis, the proposed Pelican Lake 300 cfs outlet would reduce the expected lake stage from 1450 feet without the outlet to 1449.5 feet with the outlet—a half foot reduction (DEIS p. 1-S-4). Without the outlet, there is a 50.6 percent chance that the lake would reach or exceed 1450 feet and a 20.8 percent chance the lake would reach or exceed 1454 feet (DEIS p. 1-S-4-5). The outlet would reduce the chance that Devils Lake would reach elevation 1459 feet where it would begin to overflow to the Sheyenne River from 9.4 percent to 4.1 percent (DEIS p. 5-71). “Devils Lake would have to rise to 1460.6 before there would be a significant flow (at least 300 cfs) to the Sheyenne River” (DEIS p. 2-9), and the proposed Pelican Lake 300 cfs outlet would reduce the chance of that occurring by 2 percent, from 4 percent without the outlet to 2 percent with the outlet (DEIS Appendix B, Table II.ST-2, p. B-195). However, the 1 percent chance that Devils Lake would reach elevation 1463 feet where the damages would be the greatest (DEIS p. 2-9, 5-71-84; Appendix C, p. C-124) still remains at 1 percent even if the Pelican Lake 300 cfs outlet is built (DEIS Appendix B, Table II.ST-2, p. B-195). Thus, the outlet would do virtually nothing to prevent the most serious damages resulting from an overflow of Devils Lake at 1463 feet.

Under the “wet future scenario,” the lake would continue to rise another 10 feet from the January 2002 elevation of 1447.1 feet to 1457 feet even with the outlet in operation (DEIS p. 5-89), and with any significant increase in precipitation from the 1993 to 1999 average, it also would overflow to the Sheyenne River (see The Wet Future Scenario – Fantasizing Feasibility below). Moreover, as pointed out above, during a “wet future scenario” when the Sheyenne River already has high flows, the operation of the outlet would have to be constrained below its maximum capacity, in which case it would be even less effective in preventing the lake from continuing to rise above 1457 feet, or, if operated at maximum capacity, it would result in even more severe downstream impacts on the Sheyenne River. Consequently, the proposed Pelican Lake 300 cfs outlet is technically unsound on its face.

According to the DEIS:

“Therefore, there is about a 75 percent chance that if an outlet were built it would not be economically beneficial.” (DEIS p. 1-S-5)

“The outlet plan that has been preliminarily selected for design is not economically justified using methods that would determine expected net benefits by producing probability-weighted benefits and costs.” (DEIS p. 1-S-7)

“The outlet alternative under the stochastic analysis with the highest benefit-cost ratio (although it is not shown to be economically justified) is the Pelican lake 300 cfs outlet.” (DEIS p. 4-3)

The benefit-cost ratio for the proposed Pelican Lake 300 cfs outlet under the stochastic analysis is 0.37 (DEIS Table 4, p. 4-2). This is even less than the 0.69 benefit-cost ratio of taking no additional action whatsoever in the Devils Lake Basin to protect the local infrastructure (DEIS p. 3-24, Table 4, p. 4-2). The benefit-cost ratios for the other outlet alternatives considered are: West Bay 300 cfs outlet = 0.28, West Bay 480 cfs outlet = 0.01, Pelican Lake 480 cfs outlet = 0.10, Pelican Lake Bypass 480 cfs-PL 2 = 0.14, Pelican Lake Bypass 480 cfs-PL3 = 0.21, and East End Outlet = 0.02 (DEIS Table 4, p. 4-2)

The Energy and Water Development Appropriations Acts for Fiscal Years 1998, 1999, 2000 and 2001 specify:

“That the economic justification for the emergency outlet shall be prepared in accordance with the principles and guidelines for economic evaluation as required by regulations and procedures for the Army Corps of Engineers for all flood control projects, and that the economic justification be fully described, including the analysis of the benefits and costs, in the project plan documents.” (DEIS p. 1-2)

The DEIS states that:

“The Corps of Engineers traditionally recommends plans that show the greatest expected net benefits, where benefits exceed costs based on the probability of events. As a standard process under the Principles and Guidelines, this is referred to as the National Economic Development, or NED, plan. A stochastic approach was used for economic evaluation. The benefit-cost ratio of the best outlet plan incorporating probabilities of occurrence is 0.37.” (DEIS Abstract)

The proposed Pelican Lake 300 cfs outlet, therefore, is without economic justification under the law, as well as under the Corps’ own Principles and Guidelines. Consequently, the Corps has no alternative under the law except to recommend that the outlet not be built.

Hidden Costs

The DEIS lists the Total First Cost of the proposed Pelican Lake 300 cfs outlet as $97,651,000 (DEIS Table 3, p. 3-23) and the Total Costs at $117,000,000 (DEIS Table 4, p. 4-2) to $125,000,000 (DEIS Table 6, p. 4-13). However, because the lake would continue to rise under the “wet future scenario” even with the outlet (DEIS. p. 5-86), it still would be necessary to incur the additional costs of implementing infrastructure protection measures (DEIS p. 5-89), including raising the levees protecting the City of Devils Lake, relocating homes, building temporary levees, raising selected roads and railroads, and protecting or relocating utilities (DEIS p. 3-9).

The DEIS estimates these additional infrastructure protection costs under the “wet future scenario” without the outlet and the lake reaching 1460.6 feet (DEIS Table B, p. 1-S-4) at $585 million (DEIS Table 6, p. 4-13). With the outlet in operation and the lake reaching 1457 feet, (DEIS p. 5-86)—just two feet below overflow elevation, it might be assumed that these infrastructure protection costs still could reach $300 to $400 million. Therefore, the total cost of implementing the Pelican Lake 300 cfs outlet plus the associated infrastructure protection for a lake level of 1457 feet required with this alternative is not the $125 million shown in the DEIS, but likely is in the range of $425 to $525 million.

The Wet Future Scenario – Fantasizing Feasibility

In outlining the rationale for evaluating alternatives under a “wet future scenario,” the DEIS explains that:

“The stochastic modeling was based on an assumption of the stationarity of the climate. Because of the uncertainty of and the differing scientific opinions regarding future climatic conditions in the Devils Lake basin, a scenario based analysis was also performed. In situations of uncertainty, the Principles and Guidelines allow for development of alternative future conditions, or scenarios. This scenario based analysis was used to specifically address potential solutions to the problems in the basin if the recent wet conditions continue.” (DEIS Abstract)

“The scenarios for Devils Lake include the WET future, the moderate trace 1445, an even more moderate trace 1450, and a DRY future. The WET future assumes that the years 1993 to 1999 would occur for two cycles. At this point the lake would reach the overflow elevation of 1459 in the year 2014. The period 1993 to 1999 is repeated again to generate overflow and then the years 1980 to 1990 to finish out 50-yrs. The WET future was necessary to assess the impacts of a natural overflow from Stump Lake to the Sheyenne River.” (DEIS Appendix A, p. A-21).

“The wet future scenario analysis evaluated one set of 50-year lake levels that is based on very recent climatic conditions for the years 1993-1999. The wet future scenario repeats the climatic and hydrologic conditions for the seven highest inflow years in recent history (1993-1999) for three cycles, causing the lake to overflow. The remaining years of the 50-year cycle were defined assuming climatic and hydrologic conditions similar to 1980 through 1999, and then 1980 through 1990, to complete the 50-trace.” (DEIS p. 3-5)

The DEIS offers no evidence and makes no claim that the “wet future scenario” provides a more reliable—or even remotely more realistic—analysis of future lake conditions than the stochastic analysis. On the contrary, the DEIS points out that:

“The duration of the recent wet conditions cannot be determined definitely because of the complex interactions between global weather factors.” (DEIS Appendix A, p. 1-18)

“As indicated by the regional Weather Information Center, climatic conditions during 2000-15 are expected to be similar to conditions during 1980-99.” (DEIS Appendix A, p. 1-18)

“No one can know or predict with confidence climate 50 years into the future. The National Academy of Sciences (NAS) provided guidance for another study (citation omitted) on analysis when the future is uncertain. They warn that, ‘Failure to deal explicitly with uncertainty leads the unwary to have far too much confidence in the resulting forecast and analysis, which can lead to bad public decisions [emphasis added]…’” (DEIS Appendix A, A-20)

“While the use of a wet future scenario may provide insight into potential benefits of the outlet alternatives, such an analysis provides little assurance as to the soundness of such an investment, since it is tied to the unlikely assumption that a particular scenario will ever occur.” (DEIS p. 4-40)

“The probability of the scenario future occurring is practically zero because it is an artificial scenario.” (DEIS p. 5-88)

“The alternatives were evaluated using an alternate future without conditions, which assumes a continued wet climate scenario based on the climate sequence from 1993 through 1999 repeated until a natural overflow to the Sheyenne River occurred. The probability that the lake will rise exactly in this way is zero.” (DEIS p. 5-71)

Thus, the “wet future scenario” has nothing to do with reality, but is simply a set of manufactured conditions specifically created to result in just enough precipitation over a 21-year period to cause the lake to overflow without the Pelican Lake 300 cfs outlet, but not so much that the lake would still overflow even with the outlet. But, of course, “The probability that the lake will rise exactly in this way is zero” (DEIS p. 5-71). Nevertheless, proponents of the outlet cite this artificially contrived scenario as justification for building the outlet. For example:

“The key to getting a Devils Lake outlet, one official says, is to persuade the Army Corps of Engineers [to] accept a so-called ‘wet-cycle scenario.’

Ramsey County Commissioner Joe Belford said that if the corps accepts the premise that the wet cycle of the last eight years will continue for another 10 years or more, the project easily would meet federal benefit-cost requirements.” (Associated Press, 2002b)

Of course, the Corps cannot accept a premise that the wet cycle of the last eight years (2001 was not a wet year in the Devils Lake Basin) will continue for another 10 years because it is without valid scientific foundation. However, rather than dealing with the matter on a rational, factual basis:

“Mike Connor, manager of the Devils Lake Basin Joint Water Board said… ‘I think it’s time for people to hollar a little bit… Well, maybe not a little bit, maybe a whole lot.” (Associated Press, 2002b)

Unfortunately, this has been the approach universally employed by proponents of an outlet from Devils Lake since the lake began its rapid rise in 1993. The Corps, however, is obligated to take a more responsible approach, and it is required under NEPA to recognize and respond substantively to the National Academy of Sciences’ admonition that failure to deal explicitly with uncertainty leads the unwary to have far too much confidence in the resulting forecast and analysis, which can lead to bad public decisions. The proposed outlet from Devils Lake reflects precisely such a failure to deal explicitly with uncertainty leading the North Dakota congressional delegation, the Governor, the State Water Commission and other unwary proponents of the outlet to have far too much confidence in the “wet future scenario” and, therefore, to advocate a bad public decision.

According to the DEIS:

“To better understand the sensitivity of assumptions used for future lake conditions, both with and without project, the alternatives were evaluated in comparison to other possible conditions.” (DEIS p. 3-24).

Those conditions were (1) No Action Protection Strategy, (2) Moderate Future Scenarios, (4) Erosion of Natural Outlet, and (5) Proposed Temporary Outlet As Part of Future Conditions (DEIS pp. 3-24-25). However, the DEIS does not provide a sensitivity analysis of the proposed Pelican Lake 300 cfs outlet itself under a “wet future scenario.” As noted above, the “wet future scenario” is a manufactured set of conditions specifically contrived to result in just enough precipitation over the next 21 years to cause the lake to overflow without the outlet, but not so much that it would still overflow even with the outlet. Therefore, it would be helpful to the public and to decision-makes in understanding the tenuous nature and dubious relevance of the “wet future scenario” for the Corps to perform a sensitivity analysis of the outlet itself to show the effect on the efficacy and benefits of the proposed outlet of variations from the specific “wet future scenario” conditions outlined in the DEIS. For example, at elevation 1457 feet, the “expected lake stage” with the proposed Pelican Lake 300 cfs outlet after the first 14 years of the “wet future scenario” (DEIS Table B, p. 1-S-4; Appendix A p. A-21), the lake would have a surface area of approximately 230,000 acres (interpolated from DEIS Figure 7, p. 2-6). Annual inflows to the lake from 1993 to 1999 averaged 317,000 acre-feet (DEIS p. 1-5) and precipitation, which averaged 21.0 inches from 1993 to 1999 (WEST Consultants, Inc., 2001) would contribute another 402,500 acre-feet to the 230,000 acre lake, for average total annual accruals of 719,000 acre-feet. Evaporation, which averaged 29.0 inches, or 2.42 feet, during the period (WEST Consultants, Inc, 2001), would remove 319,440 acre-feet, and the outlet, operating at maximum capacity for seven months would remove another 126,000 acre-feet, leaving a net gain of 36,900 acre-feet per year under the “wet future scenario.”

If average annual precipitation in the Devils Lake Basin under the “wet future scenario” were to increase by one inch (5 percent) above the 1993-1999 level, average annual inflows might be expected to increase from 317,000 acre-feet to 332,850 acre-feet and direct precipitation on the lake would increase from 402,500 acre-feet to 420,900 acre-feet, for an increase in total average annual accruals to 753,750 acre-feet. Evaporation would remove a little more than 319,440 acre-feet because the surface area of the lake would be a little larger, but the outlet still would remove only 126,000 acre-feet, leaving a net gain of about 71,000 acre-feet, or about 3.7 inches, per year, bringing the lake dangerously close to the overflow elevation of 1459 feet by the end of the third seven years of the “wet future scenario.” An increase in average annual precipitation under the “wet future scenario” of two inches (10

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