Reasons to Say NO to Ten59

The New Boston Crossing in unequivocally a bad idea and it's simply due to it's location. It will destroy over 3 acres of wetlands, destroy and impact over 50+ acres of floodplain, has been denounced by the Haskell Board of Regents due to its proximity to the historic Haskell Farm where Indigenous children were stolen from their families and often fled into the Wakarusa Wetlands (also known as the Haskell-Baker wetlands) , and will have unknown negative impacts on the Wakarusa wetlands and the future of development in the Wakarusa River Valley.

Both the City and County have affirmed multiple times the need to preserve and conserve sensitive lands, which include wetlands, floodplains, and river/stream corridors. This has been confirmed in our Comprehensive Plan 2040 which dictates the land uses and goals of our county and city. Additionally, the Douglas County Open Space plan has explicitly stated that the Wakarusa River Valley is a top priority area that is endangered directly due to development. Douglas County also recently published a pilot study of the Washington Creek watershed, which feeds into the Wakarusa River upstream of New Boston Crossing, that studied the best mitigation effects of flooding in the region. It's not surprise that the answer was conserving and protecting the wetlands and natural buffer zones (including floodplains) in the area from increases in development.

The City of Lawrence has been focusing a lot of efforts on promoting equity based solutions and closing the gap between our most marginalized citizens and those well above the living means. We applaud this but find it rather startling that the City would approve a project that could disturb children's burials from Haskell's history as a boarding school. We believe these are not truly equity based solutions and rather the City's attempt to make itself look better.

While it's easy to get caught in the details of the project and to look at the New Boston Crossing as a singular issue, we must remember that the Wakarusa River Valley is not only a place on paper. It is a thriving ecosystem, a piece of our natural world, and a living being that holds both history and the future within it. It is a place where folks gather medicines, reconnect with the history of the land, watch and interact with the flora and fauna, where folks conduct scientific research, and find a spiritual retreat from the hustle and bustle of city life. This is of utmost importance when the City is reviewing New Boston Crossing, where this land gets sequestered to simple lines on a piece of paper.

When evaluating this project, we must ask ourselves the following questions:

What ethics & morals are we willing to abandon to gain a short term economic boost?
What precedent are we setting for development not only in the Wakarusa River Valley, but in the surrounding floodplains in Douglas County?
Are we willing to continue the historical trend of ignoring Indigenous sovereignty in favor of private development or do we want to try to right historical wrongs?
In the area of climate change, are we willing to destroy our floodplains and wetlands? What is the hard-line where we say no?
Is it appropriate to develop commercial next to known nature preserves? Are green corridors a priority?

Wetland Destruction

A drone shot by our friend Eric Dyke. The drone is positioned over the field south of the stream on New Boston Crossing. Facing east, we can see that the wooded stream to the left connects directly to a channel in the Baker wetlands. Animal tracks on the New Boston Crossing parcel show how the area is utilized as green corridor despite the current intense agricultural use.

IMPACTS ON SITE

MISLEADING WORDS

We're not 100% sure how much on-site wetland will be impacted, as the developer is intentionally using language downplaying the impacts and leaving out key information. The development site has identified in total 12.6 acres of wetlands. At first the developer was impacting 5.64 acres of wetland which was later to roughly 3 acres. However, in the press release Landplan stated they only "disturb" 1.48 acres of wetlands and 1.17 acres of stream corridor. This is not an accurate picture. This number can only be generated by using a legal technicality that distinguishes "isolated" and "jurisdictional" wetlands. There is no significant ecological difference between these wetlands, it is only a legal designation in regards to what the federal government has jurisdiction over in regards to permitting. 1.48 acres is the amount of wetlands being completely filled and graded for building development. This number doesn't count the additional ~1.3 acres that will be destroyed to install "stormwater wetlands" or bioswales. We have asked for clarification on this matter, the development team has yet to respond.

Wetlands provide critical habitat for many endangered animals and plants. For this development specifically, 7 threatened or endangered species are thought to be potentially impacted by development: the northern long eared bat, the tricolored bat, the pallid sturgeon, the western prairie fringed orchid, the monarch butterfly, the western regal fritillary, and Mead's milkweed.

The following plants are considered uncommon/conservative and are going to be destroyed:

Missouri sedge (Carex missourensis)
Short-awned foxtail (Alopercurus aequalis)
Green Dragon (Arisaema draconium)
Star sedge (Carex radiata)
Marsh spike-rush (Eleocharis palustris)
Yellow fruit sedge (Carex annectans)
Purple Rocket (Iodanthus pinnatifidus)
Water willow (Justicia americana)
Shoreline sedge (Carex hyalinolepsis)
American waterleaf (Hydrophyllum virginianum)

Outlined in green, all these wetlands were officially delineated and originally determined to be under the jurisdiction of the United States Army Corp of Engineers (USACE). To fill in these wetlands, the developer needed an approved 404 permit. Total estimated wetlands: 12.6 acres.

In April 2025, the USACE determined that the wetlands outlined in orange are no longer part of their jurisdiction. Therefore, the 404 permit was dismissed and there are no longer any protections for these wetlands. These wetlands outlined in orange are slated to be filled and permanently destroyed.

IMPACTS OFF SITE

Beyond the destruction of wetlands on the actual property, we have massive concerns about New Boston Crossing affecting the current Haskell-Baker wetland complex. 288 species of birds, 98 other vertebrate species, and 492 plant species have been identified using the Haskell-Baker wetlands as permanent or temporary habitat. Species on the Species in Need of Conservation (SINC), Threatened, and Endangered list of Kansas that been found in the Haskell-Baker wetland complex include:

Least tern (Sterna antillarum ) Endangered
Eastern Narrowmouth Toad (Gastrophryne carolinensis), Threatened
Piping Plover (Charadrius melodus ) Threatened
Snowy Plover Charadrius alexandrinus) Threatened
Black Tern (Chlidonias niger ) SINC
Eastern Whip-poor-will (Antrostomas vociferus) SINC
Boblink (Dolichonyx oryzivorus) SINC
Southern Bog Lemming (Synaptomys cooperi) SINC
Short Eared Owl (Asio flammeus) SINC
Ferruginous Hawk (Buteo regalis) SINC
Golden Eagle (Aquila chrysaetos) SINC
Henslow's Sparrow (Ammodramus henslowii) SINC
Yellow-Throated Warbler (Setophaga dominica) SINC
Cerulean Warbler (Setophaga cerulean) SINC

The Baker owned portion of the Haskell-Baker wetlands was designated a National Natural Landmark in 1969. It also hosts the remaining virgin wet prairie in the Wakarusa River Valley. The Wakarusa Wetland complex is also designated a Special Aquatic Life Use Water by the Kansas Department of Health and Environment (KDHE). A Special Aquatic Life Use water is defined by Kansas State law as

"Special aquatic life use waters" means classified stream segments that contain combinations of habitat types and indigenous biota not found commonly in the state, or classified stream segments that contain representative populations of threatened or endangered species, that are listed in rules and regulations promulgated by the Kansas department of wildlife and parks or the United States fish and wildlife service.

We still have no concrete understanding of how the Haskell-Baker wetlands was altered due to the completion of the SLT, much less how this fragile and complex ecosystem will be altered due to rapid development in the region. Haskell and Baker land stewards have been hard at work the past few years trying to right mismanagement/neglect of the land and understand how the landscape can recover after the creation of the SLT. Creating a development right next to this fragile complex can destroy years of careful love and labor in a short 6 months. We have little to no information from the developer for mitigation plans, for long term conservation plans, or even how they're collaborating with Baker (the same entity that tried to sell their wet meadow for development) to mitigate harm to the Haskell-Baker wetland complex. You can read the developer's noncommittal responses to questions presented at the public meeting on 10/29 here.

Wetlands have always been important cultural sites, both for the First Peoples and for those of us here now. By destroying and degrading wetlands, we remove the ability of our children and future generations to experience the job of interacting with the complex web of life found in a wetland. We remove the ability to experience outside recreation in natural spaces, the joys of observing migratory creatures, of learning about plants and their roles in our culture.

The location of the project in proximity to the Haskell-Baker wetland complex is startling. A single 2-lane road separates the project site from the western portion of the Baker wetlands, and a stream that bisects the project site feeds runoff directly into the Baker wetland's basins. Wetlands are one of the most endangered habitats in the United States and wetland destruction has only increased in the past 10 years due to agriculture and development.

POSSIBLE IMPACTS

Increased invasive species pressure from disturbance and development. The newly established mitigation lands near the Baker University Discover Center are already battling invasive species pressure as they fight to establish. This development would introduce more non-native species and provide the necessary disturbance for invasive species propagation.
Increased chemical pollution runoff from parking lots (oil leaks, antifreeze leaks from cars)
Increased trash from sporting events and public access
Potential PFA shed from the artificial turf used for the soccer fields
Noise and light pollution from the outdoor soccer fields that can disrupt and alter migratory bird habitat
Potential child burials disturbed in the greater Wakarusa River Floodplain

As part of their JEO study (more information below), Douglas County has provided an ecological sensitivity map for the Wakarusa River Valley. Even thought this area has historically been fractured and degraded due to agriculture and expansion of the southern City limits, we can still see the entire region hosts incredibly sensitive areas.

A zoom in on the New Boston Crossing project site and the neighboring Baker portion of the Haskell-Baker wetlands. The dark green stripe is a wetland complex that is under the jurisdiction of the United States Army Corp of Engineers which surrounds a stream that flows directly into the Haskell-Baker wetlands via a culvert underneath the road.

Culturally Sensitive Lands

KansasMemory.org, Kansas Historical Society, Copy and Reuse Restrictions Apply

PRE CONTACT HISTORY

Prior to contact, the Wakarusa Valley region was an important area that was historically stewarded by the local Plains Tribes, including the Kansa, Osage, Pawnee and Wichita Peoples. Tribes would host inter-Tribal councils in the valley's upland areas and partake in hunting throughout the wetlands and the wet prairies. The Wakarusa River Valley was once a thriving, biodiverse ecosystem home to hundreds of native animal species, including bison, elk, otters, beavers, and deer. These animals provided essential sustenance and clothing to Tribes and were integral during the fur trade with colonizers. (Information provided by Courtney King, Haskell lab and field research assistant and Greenhouse manager).

Tyler Moore details the Indigenous History of the area in this paper.

The Wakarusa River Valley and wetlands have had an interconnected history with the various Indigenous groups throughout history that have called this region home. There are six sections that I would like to outline within this work, the first being traditional homelands, tribes who without any European intervention, came to call this area home. The second is the emigrant tribes, those who were forced to use the Wakarusa Valley as a point on their removal journey. The third era of the wetlands would come from the United States Indian Industrial Training School, modern-day Haskell Indian Nations University. The fourth era would be the 1968 Baker University buyout of the wetlands, which took control of the majority of the wetlands from Haskell. The fifth discernible era would be the controversial South Lawrence trafficway that cuts through the wetlands. The last era that must be discussed is our modern one, where there are individuals who want to develop the wetlands versus those who want to protect the wetlands' rich biodiversity.

GENOCIDE AND THE WAKARUSA RIVER VALLEY

Haskell Indian Nations University (HINU), formerly known as Haskell Institute, was a residential school before it became a university. If this is new or unfamiliar information we encourage you to visit the Cultural Center at HINU and read information regarding Kansas's history of Indigenous Boarding Schools. We also encourage folks to read about the Haskell Cemetery and read the names of the 110 known children who did not survive Haskell Institute.

As the website of the Haskell Cultural Center details:

Educational instruction was provided from grades one through five with special emphasis placed upon agricultural training. In an effort to provide income for the school, the crops raised by the students at the school were all sold with severe punishment administered to any child found to be stealing the produce meant for sale. They were strictly forbidden from speaking their tribal language, praying and practicing any spiritual beliefs or cultural norms, and were expected to attend church services and encouraged to convert to Christianity.

During their terms, the children were forbidden from returning home or having any family contact. Upon arrival children were removed from the train, and thus the beginning of their dramatically altered lives. Each was immediately stripped of all traditional clothing and belongings. Their hair, whether male or female, was cut into a short military-style crew cut. To these children, cutting ones’ hair would have been a mourning practice and a sign of significant trauma, such as the loss of a close relative.

There were severe physical and emotional consequences applied to the children for failing to abide by these new rules. They were often subjected to inadequate food, clothing, shelter, and medical attention. Later, in the period from 1910-1933, they would have been incarcerated in the Haskell jail, but prior to its construction, fruit storage cellars were used to punish students.

The proposed development near the historic Haskell Farm (now the Historic Baker Wetlands) and its proximity to the Wakarusa River, where Indigenous children attempted to escape severe abuse, has raised concerns among the Haskell Board of Regents, staff, and the community who demand implementation of ground penetrating radar. This demands are based on oral history and has been proven true by the fact that the Department of Interior (DOI) recently published a report verifying that there is at least one unmarked burial in the Haskell Wetland Complex. According to Professor Chuck Haines, it is estimated that over 700 children died while at Haskell Institute (Haines, 2002, p. 4). While forcibly attending Haskell Institute and enduring traumatic hardship, many children would seek connectedness to Mother Earth through the flooding in the Wakarusa Valley that the government could never control (Haines, 2002, p. 6). Children would flee to the Haskell Farm in the wetlands to play, meet their families, and pray to Mother Earth (Haines, 2002, p. 5-6). Some children would never return from the wetlands and would be laid to rest in the Wakarusa Valley. Unfortunately, this was never addressed or even considered by any of the developers or their contractors.

Haskell Institute students plowing fields. Children were forced to do manual labor as "education" and to feed themselves since the government refused to provide enough food. This led to high rates of malnutrition, rampant disease spread, and unfortunately death. KansasMemory.org, Kansas Historical Society, Copy and Reuse Restrictions Apply

Haskell students cutting corn on the historic Haskell Farm (current day Baker wetlands). KansasMemory.org, Kansas Historical Society, Copy and Reuse Restrictions Apply

As Tyler Moore details,

Many students were known to try to escape from Haskell, going directly into the wetlands to try and find their way home, and according to many people and elders,the wetlands are some of those students' final resting places.Haskell Institute was a place made to assimilate Native students, and one way of doing so was to force Western agricultural practices onto a new generation of native Americans.

During this time, Haskell Institute drained the wetlands and tilled the soil using raised earthen beds, destroying over 700 acres of wetland. Students were forced to do manual labor throughout most of the day, harvesting the crops that were then sold by the campus. This development would also spark neighboring wetlands owned by Kansas residents to become agricultural land. In 1922, three large-scale drainage ditches were constructed throughout the Haskell wetlands. It was not until Dr. Henry Roe Cloud, a citizen of the Winnebago tribe, began to oversee Haskell as it Superintendent in 1933, that the winds of change would hit the soils of Haskell. Dr. Cloud would put an emphasis on traditional practices and arts at Haskell, and by 1937, Haskell's agricultural sector would be removed.

DISREGARD BY DEVELOPERS

Archaeological contractors began invasive testing without visiting the Haskell Cultural Museum, or informing themselves of the sensitive nature of this project. Upon discovering pre-contact artifacts, they did not notify Tribes before making the findings public. Despite the Haskell Board of Regents sending a letter directly to the developers, they have shown no sensitivity or respect for the Indigenous community.

Following the precedent set by the SLT, the developer has categorically ignored Haskell and our Indigenous community members and has appealed to Baker University, the same University that put a gag order on their land stewards at the Discovery Center and tried to sell land to developers. The City of Lawrence, the entity that jump started this project by approving the illegitimate floodplain development permit, has yet to acknowledge their part in the continued systemic disregard for Indigenous sovereignty and respect for the children lost due to the government's genocidal policies. While the the Federal Government and the Nations have their own processes, we must demand a higher standard locally and reject projects that have no interest in understanding the history and current experiences of our community members.

Floodplain Destruction and Flooding Impacts

A photo showing the Wakarusa River high on it's banks in 2024. At this time, the Wakarusa entered the flood stage with a height of [insert USGS data). The photo was taken on the bridge

WHAT RISKS DOES DEVELOPMENT CREATE?

More impervious cover (buildings/streets/parking lots) means less water percolates underground and increased runoff into major waterways
Continues to fracture key habitat for sensitive plants and animal communities
- Development is DIRECTLY WEST of Baker wetlands and will impact migratory patterns, water flow into the Haskell-Baker wetland complex, and spur other developments in the river valley
Increased flooding risk due to human proximity. Houses/buildings on a floodplain means statistically humans will be closer to floodwaters when they overflow the banks of the Wakarusa

WHY WAS THE FLOODPLAIN CHOSEN?

The developer is claiming there are no other sites around town that provide the necessary acreage and visibility (traffic). The first claim is unequivocally false, Phil Bundy has been trying to develop this lot of land for over 10 years. There have been areas in comparable size for sale, notably on the western edge of town where Bob Billings intersects with K10. These areas have no regulatory floodplain encumbering them.

FILL AND BUILD AND WHY IT'S BAD

WHAT IS IT

Putting additional fill soil on top of a floodplain to raise the elevation outside of the FEMA floodplain.

WHY IT'S BAD

By adding impervious cover (parking lots, roads, buildings) we reduce the capacity of the floodplain to work as a natural buffer to flood and drought cycles. Simply adding dirt to a floodplain, known as "fill and build" doesn't remove the composition of the floodplains underground water movement, it simply blocks the surface from being able to peculate water underground and remove the ability of plants to anchor soil. This technique, condemned by FEMA's advisory board, creates issues with flood insurance, encourages development in floodplains, inflates downstream flooding impacts, and harms the environment and us humans by creating a larger flood zone. By filling in floodplains, we also harm the plant communities, the animal communities, and the aquatic communities who use the floodplain. By continuing to fracture and disconnect this floodplain, we destroy the ability of the Wakarusa River Valley to function as a connected and complex wildlife corridor and natural space.

While we can't be certain the exact amount of floodplain the developer intends to remove, we can assume any of the 100 year floodplain within the areas zoned for the development will be permanently altered. The total estimated removal of the 100 year floodplain is ~70 acres (the areas highlighted above, ~52 acres + 18 acre pond). If you account for the 500 year floodplain the total floodplain removal increases to ~82 acres. Of course, this only counts what is considered regulatory floodplain, and not what is functionally floodplain.

BENEFITS OF FLOODPLAINS

Flood control and mitigation
Often hosts wetlands which are an endangered ecosystem with unparalleled biodiversity
Water quality regulation
Preserves water table during droughts
Often sites of parks and outdoor passive recreation

The City has affirmed the value of our local floodplains yet is allowing this project to continue resulting in destruction of roughly ~70 acres of undeveloped floodplain including over 3 acres of intact wetlands.

FLOODING AND THE WAKARUSA RIVER VALLEY

The project is located downstream from Clinton Dam. Clinton is considered a high-risk hazard dam, a dam that, if it were to fail, would cause significant property damage and extensive loss of life. A 2009 Kansas Biological Survey found that the Clinton Reservoir is silting 70% faster than projected in 1977 when the dam was established, and the dam itself is approaching 50 years old, increasing its potential for failure. While currently there are no indications of dam failure, excessive rain forces the USACE to flood the Lower Wakarusa watershed to alleviate water levels in the reservoir causing flooding complications downstream of Clinton. This happened in 2019 when USACE did not shut off the spillway from Clinton Reservoir until 8 am on August 1st, 2019 despite torrential rain starting during the night. USACE says that they would not be able to get permission for overnight staff, so there is a real possibility this could happen again in the near future.

The flood data for the Wakarusa River is extremely outdated, with flood data from the 1990s and the FIRM dated 2010. While geologically floodplains can take a longer time to change and alter, climate change has made our normal rain cycles increase in frequency and intensity. This has lead to unpredictable storms and devastating floods in areas not considered part of the floodplain. This is combined with FEMA's outdated FIRMs (floodplain maps) which only indicate a 50% confidence that a flood would stay within the boundaries drawn on the FIRMs. This leads to 25% of flood claims that originate from outside the floodplain boundaries, and up to 20% of severe repetitive loss properties (5+ floods) lie outside the floodplain boundaries as currently outlines.

City and County Policies Broken

LOCAL FLOODPLAIN PERMIT ISSUED ILLEGITIMATELY

The developer has admitted both verbally and in writing that they are increasing the flood velocity, which violates our local floodplain regulations. This renders the local floodplain development permit approved on 02/16/2024 and all subsequent rezonings illegitimate. The developer claims the velocity increases are "small" but refuses to disclose any actual calculations. However, our local floodplain regulations were developed in the early 2000's to prevent all development in our floodplains. Additionally, for FEMA to approve a fill permit (required for the developer to build), the City had to sign and approve that the local permit was legitimate and followed the City's development code. This is in direct opposition to the City Commissioners claims that the permitting process will provide checks and balances. Detailed information can be found here.

As of 02/10/2026 the developer has submitted a new floodplain development permit. This might be because they submitted a new plat, but the previously floodplain development permit did not expire with the previous plat. Therefore, we believe that the developer has submitted a new floodplain development permit to avoid the scandal of the old one. Upon preliminary review, this new floodplain development permit still seems to violate the floodplain codes. This will be verified.

PLAN 2040 VIOLATED

Plan 2040, our Comprehensive Plan for development in the City and surrounding areas, is a binding document that is meant to be used as guidance for all new developments. As stated on page 6:

All development proposals must comply with the Comprehensive Plan. If a proposal does not comply with Comprehensive Plan requirements, then the applicant must pursue a plan amendment. In pursuing an amendment, the applicant must show that the proposal is reasonable within the context of the entire Comprehensive Plan.

It's important to know that the developer attempted to get an amendment to the Comprehensive Plan approved. This amendment, CPA-23-00186, wanted to alter the land use in south Lawrence. This amendment was approved by the City Commissioners but rejected by the County Commissioners due to concerns about removing the open space protections for the majority of the development that is encumbered by the 100-year floodplain. This means that 2040 was never amended and any rezonings violated the Comprehensive Plan. The City still chose to rezone the land anyways. This is absurd considering 2040 is a binding document for the City.

FIVE GUIDING SUSTAINABILITY POLICIES

This was passed by the City Commission in 2021 and directed staff to integrate the following principles into city plans:

To achieve net-zero greenhouse gas emissions through a fair and just transition for all communities and workers;
to create jobs with livable wages to ensure prosperity and economic security for all people;
to invest in the infrastructure and industry to sustainably meet the challenges of the 21st century;
to secure for all people for generations to come: clean air and water; climate and community resiliency; healthy food; access to nature; and a sustainable environment; and
to promote justice and equity by stopping current, preventing future, and repairing historic oppression of Indigenous peoples, communities of color, migrant communities, de-industrialized communities, depopulated rural communities, the working poor, women, the elderly, the unhoused, people with disabilities, and youth.

DOUGLAS COUNTY'S OPEN SPACE PLAN

While this Open Space plan has beautiful language, goals, and pathways for change, this plan has no teeth and no enforcement. It states that the Commissioners may use this plan to introduce new regulations for land use and rezoning. It can provide important framework and it can be used as a bargaining tool for Commissioners because another legal, government has validated that Open Space is important and re-affirms our community values. This only matters though with sympathetic ears and policy takes a long time to implement.

Community Values:

This Plan is built on the foundation of shared values articulated through community driven conversations. These community values were expressed during the planning process and used to inform the Conservation Criteria, implementation recommendations, and County focus areas.

Protect our natural environment through stewardship, conservation, and accountability.

Enhance important focus areas for wetlands, woodlands, prairie, wildlife habitats, prime farmland, floodplains, riparian corridors, and biodiversity.

Provide incentives, education, and collaborative partnerships to empower willing landowners in managing private lands responsibly.

Protect the continuation of local farming and ranching to support the local food system.

Embrace creative and culturally inclusive land stewardship solutions and partnerships.

Promote adaptability within human and non-human communities of Douglas County for an unpredictable climate future.

Convene and support the collaboration of open space partners and interest groups working towards a shared vision.

Preserve rural character.

Support the creation of regionally connected recreation networks where open spaces, waterways and parks are thoughtfully linked to ensure physical connectivity.

Support and encourage safe access to public spaces for all abilities, cultures, socio-economic status, and geographic areas of the County.

Promote the County’s natural beauty and sense of place.

Preserve, honor, and respect historic sites, landmarks, and cultural landscapes.

Conserve areas to provide immersion in the outdoors.

Thoughtfully consider the use of resources wisely, both financially and environmentally.

DOUGLAS COUNTY AND THE WAKARUSA RIVER VALLEY

WVP Existing Conditions Summary.pdf

This document provides a great wealth of information about the real world conditions of the Wakarusa River Valley, including land use, prime soil maps, environmental sensitivity maps, etc.

As part of the Open Space plan, the county is conducting a large scale Hydrologic and Hydrology study [H&H] study. This study looks at the amount of water during a flood event and how the water moves during a flood event. For this specific study, the County hired JEO Consulting to look at flooding events under the following parameters:

As part of the assessment, JEO plans to leverage existing flood risk modeling and refine the current available models. The corridor flood risk models, which were provided by KDA, have been reviewed as part of the scoping effort. As part of the assessment, JEO will focus on efforts utilizing the 10-year, 25- year, and 100-year model runs. This range of smaller but more frequent events with larger but less frequent events will provide an understanding of overall flood risk along with information about flooding frequency, depth, and velocity.

Another important consideration for flood risk for conservation areas is a review of both natural and regulated flows. The U.S. Army Corps of Engineers (USACE) regulates incoming flows to Clinton Lake based on a water control manual. During times of elevated natural flows, the USACE stores flood water in Clinton Lake. Flood control storage and releases (above the normal pool elevation of 875.5 ft) are dictated by a reservoir Phase based on the lake elevation with releases allowed based on maximum flows at downstream target locations such as the Wakarusa River at the US 59 highway crossing and the Kansas River at De Soto.

In conjunction with unregulated flows produced in the model, JEO intends to review and simulate Clinton Lake releases to understand the combined effects. Including the regulated flow releases is critical since impacts from these steady, controlled releases are observed for much longer periods of time than a peak of a hydrograph. Coincident timing of both flow sources or impacts of sequential rain events may cause unforeseen impact areas. Regulated releases may also contribute to higher backwater on tributaries and more significant flows and impacts downstream of the US 59 regulation point. A strategy for conservation of open space in the corridor should take these baseline potential flow scenarios into account to ensure a full range of risk assessment is considered.

Based on the results of the above model simulations, the JEO team will review model outputs including flood frequency, depth, velocity, and depth times velocity to make recommendations for conservation spaces within the river corridor. Finally, the project team will assess the benefits of open space conservation as a nature based solution in the Wakarusa River corridor by mapping differences in depths and inundation extents which occur due to open space conservation compared to development.

Comprehensive Vision and Area Plan for the Wakarusa River Valley to establish collaborative conservation priorities and strategies.
Advanced Hydrologic and Hydraulic (H&H) models, flood risk modeling and mitigation recommendations for the Wakarusa River, supported by the Kansas Department of Agriculture Division of Water Resources Technical Assistance program.

Leadership opportunities identified in the Plan include:

• In collaboration with multiple partners, complete a comprehensive study and action plan for the Wakarusa River Corridor that identifies key areas and scenarios for enhancing biodiversity, climate resilience, recreation, agriculture and other desired future land uses.

• Support and uplift staff, faculty, students, and alumni of Haskell Indian Nations University, and Indigenous community members, in leadership of conservation projects in the Wakarusa Valley.

• Identify and apply for grant funding for specific projects to support conservation initiatives that may include private land conservation, land stewardship, and public outreach, access, and education.

• In collaboration with willing landowners, explore conservation opportunities in the Wakarusa Corridor with existing and enhanced zoning tools and floodplain regulations.

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