Rep. Fritts:
Here is a summary of the key flaws and biases I personally found in the USGS Report. They were too egregious for me to ignore. You may see others when you read the report.
- USGS (multistakeholders) (“USGS report”) did not include an objective to control the range expansion of the Asian Carp (a stated purpose of TVA’s) and the priority of USFWS. Range expansion means carp migrating into uninvaded waters.
- USGS report incorrectly used the leading edge of the carp as Pickwick Lake based on the out-of-date USFWS report published in 2017 (two years before the official Chickamauga report that was investigated and defended by TWRA in 2019). They also ignored other UPSTREAM carp reports. [Those two errors combined would give their work an unfair bias to build downstream barriers].
- The report showed the Chickamauga carp report as an individual carp. Only one had jumped into the angler’s boat, but he observed 15-20 in the water next to his boat. That should have been a report of 15-20. [Failing to report a breeding group so far upstream would give their work unfair bias to downstream barriers].
- They admitted they had no actual barrier efficacy information from actual working locks on a river and did their simulations and modeling based on guesses and assumptions. [They had to guess a lot and made a lot of assumptions. It is too much of a reach to call the USGS work a legitimate scientific study].
- The downstream barriers being proposed will be behind an abundance of carp. Obviously, that is not going to prevent carp range expansion which was one of TVA’s objectives.
- Their simulation was also flawed. They ran a simulation assuming that carp were only found in the reservoirs downstream from Wilson dam. They manipulated hard data inputs when they set-up their simulation by ignoring four carp reports that were upstream from Wilson dam. [That would give their work a bias for downstream barriers].
- Their Decision Tree process was flawed, too. They set such narrow parameters that it was virtually impossible for participants to recommend upstream barriers. They wanted the barrier locations:
- most effective at limiting upstream migration of the leading edge but they misidentified the leading edge as Pickwick instead of Chickamauga;
- most effective at reducing migration from the Ohio River which intentionally took the four carp free lakes out of the running because they are the furthest away from the Ohio River.
Those two narrow parameters were unreasonable and never the intent of TVA’s stated purpose. They were designed to NOT give a high priority to upstream barriers.
Respectfully,
Pandora Vreeland