The Loch Mary Reservoir holds enough water to fill about 715 Olympic-sized swimming pools.
All that stands between that wall of water and Annette Rudolph’s Earlington, Kentucky neighborhood is a 95-year-old earthen dam, deteriorating and seeping water.
Rudolph, 70, has lived in the neighborhood she calls “The Bottom” all her life, and floods are routine there. State inspectors have told the dam’s owner, the city of Earlington, that heavy rain could overtop it — “threatening the safety of the residents downstream,” according to a 2018 inspection report.
Yet local officials don’t have a crisis plan for a dam failure. The county emergency manager would have to lead a crisis response, but he doesn’t have maps showing which houses would be inundated or how far the water would travel. Officials have not practiced a response.
To Rudolph, that means if the dam breaks, “we’re on our own.”
“If you can’t swim, you’re just a damn dead pigeon.”
The Loch Mary Reservoir dam is one of 80 in Kentucky that state inspectors have deemed to be a two-fold risk: high-hazard, because a breach would threaten lives or property, and in poor or unsatisfactory condition. Only six of those dams have complete emergency plans on file with the state, according to a Kentucky Center for Investigative Reporting investigation.
State records and more than two dozen interviews with local emergency management officials show emergency responders largely lack detailed plans for responding to a crisis at those dams. Precisely how many people in Kentucky live at risk is unclear without those plans, as one of their functions is to scientifically identify where the flood waters would go during a breach.
(Interactive: Is there a high-hazard dam near you?)
But just having a plan isn’t enough: the local community also needs to practice and update it on an annual basis, said Colette Easter, a civil engineer in Louisville. Easter assessed Kentucky’s dam safety program for an analysis by the American Society of Civil Engineers.
“If a local body has not reviewed the plan, then it would be pretty challenging to implement it,” Easter said.
The Federal Emergency Management Administration recommends detailed plans for any dam that would threaten lives if it broke. Forty-three states have laws that require these plans for high-hazard dams, but Kentucky does not.
Of the 178 dams the state Division of Water considers to be high hazard — regardless of whether it’s in good or bad condition — about 89 percent don’t have complete plans on file with the state.
KyCIR interviewed emergency management staff in 25 counties where high-hazard dams are rated in poor or unsatisfactory condition, the lowest ratings respectively. The vast majority had not seen dam break plans, or didn’t know if there were any — even when state data indicated their dams had plans.
Yet those are the people who would generally have to call the state to alert officials of a problem, and take charge of responding to a dam disaster, said Glen Alexander, environmental engineer supervisor with the state Division of Water’s dam safety program.
“We try our best to communicate with emergency managers. We probably haven’t always done the best in the past and we’re trying very much to improve that,” Alexander said.
Nick Bailey, emergency management director for Hopkins County, where Rudolph lives, has six high-hazard dams that are in poor or unsatisfactory condition in his county.
All but two are privately owned, and Bailey said he didn’t know much about their condition or inspection history. He thinks the city of Earlington is working on a plan. Earlington’s mayor didn’t return requests for comment.
Bailey doubted most dam owners would make plans unless they were required to.
“How would I even know whether or not a dam owner was doing their part of the bargain if I’m not even aware of which dams are high hazard and which are not?” Bailey said.
‘Draft’ Plans Count, But Aren’t Widely Shared
The Kentucky Division of Water has oversight to inspect dams, issue violations and order repairs. But they say the dam owners are responsible for voluntarily making emergency plans. More than half of the 950-some dams regulated by the state are owned by individuals, businesses or coal companies — not governments.
Alexander said his team encourages dam owners to make plans, but they don’t have much success.
“I’ve heard it all,” he said. “A big one is the expense involved … other owners don’t have an interest in maintaining those documents.”
Data reported by the Kentucky Division of Water data say that 74 percent of Kentucky’s high-hazard dams have emergency action plans. But a state dam official in Frankfort, not the dam owners, made most of those plans.
The state officials said they’re drafts, and they have not been adopted by local officials — or necessarily even seen.
Only 20 of 178 are actually complete.
The Division of Water wouldn’t release its draft plans, citing an exemption in Kentucky’s open records law. But Alexander said they contain basic emergency contact lists and simplified maps of the area expected to flood during a breach.
If the state were to require dam owners to make these plans, Alexander said, they would have to be much more thorough.
State officials say they made these drafts to help prepare dam owners for breaks, since they can’t force dam owners to take the initiative. In theory, emergency managers could call state dam staff during a disaster, who could then get to the maps within 20 minutes and ship them out electronically, Alexander said.
Carey Johnson, assistant director for the Kentucky Division of Water, said he didn’t think it was misleading to report the draft reports in state data.
“The document is a tangible document, with inundation maps, and we’re happy to share it,” he said.
But state officials only share the plans they’ve drafted with dam owners or local emergency managers if asked, because they worry that sending them out without context would create a misunderstanding that dams were in imminent danger.
Alexander said his division regularly communicates with dam owners, but inspectors do not proactively reach out to emergency managers about specific dams or share inspection reports with them. The dam safety team has only five employees that oversee nearly 1,000 dams statewide, he said. Resources are a major barrier.
“When you do 300 to 400 inspections a year, it gets a little much to send out multiple copies,” Alexander said.
Even some state-owned dams don’t have complete plans, including three owned by the Department of Fish and Wildlife Resources in Grant, Marion and Shelby counties. Dam officials appear to have made draft plans, but a spokesperson for Fish and Wildlife didn’t know anything about them.
Alexander said his team is working on complete plans now.
More Rain Strains Dams
Of the 80 high-hazard dams rated poor or unsatisfactory across the state, records show at least 47 of them received that ranking at least partially because they wouldn’t hold enough rain during a catastrophic storm.
Inspectors rate dams low for two other reasons: structural deficiencies that threaten the integrity of the dam; or maintenance issues like animal burrows or overgrown plants that threaten to create structural problems.
Dam breaks are rare, and poor condition doesn’t mean imminent failure. Dams that can’t hold catastrophic rain could theoretically be taken down overnight, but if would take an extreme, and highly unlikely, rain event. Even dams in good condition could break given unexpected natural disasters, like an earthquake.
That’s why dam safety experts recommend that all high hazard dam owners have emergency plans. And climate change makes it more pressing, particularly for dams that can’t hold catastrophic rainfall, to have emergency action plans.
Jake Allgeier, hydraulic engineer with the Army Corps of Engineers, compared dammed bodies of water to a plugged bathtub.
“It fills up with water and the more often you have rain, the more water you have, the more quickly it fills up and the less flood storage you have to store that water and prevent downstream damage.”
Last year was one of Kentucky’s wettest years on record. And several of the Corps’ dammed lakes in Kentucky have filled to record levels in recent years. (Federally owned dams are not under state oversight; high-hazard dams owned by the U.S. Army Corps of Engineers have emergency action plans.)
All that rain puts a strain on dams.
Warmer temperatures can strain dams further by changing surrounding vegetation, which can create more sediment that builds up in streams or lake beds and cause more flooding, Allgeier said.
State Sen. Robin Webb, D-Grayson, said the increasing rainfall in Kentucky makes stronger laws even more important.
Webb has introduced bills and resolutions to require emergency action plans for high-hazard dams in past legislative sessions. She says the issue doesn’t get much traction.
“It was always deemed more regulation,” she said. “I get it. I’m not a big government type of person. But I am a public health and safety, and worker safety, advocate.”
Officials could struggle to reach vulnerable residents in areas of Eastern Kentucky without cell reception in the event of a disaster without emergency action plans, she said.
“We’ve been lucky,” Webb said.
Emergency Staff Caught Off-Guard
According to FEMA, a plan is not effective unless it’s made in close coordination with emergency management authorities and practiced regularly.
Some emergency managers interviewed by KyCIR were surprised to hear that dams in their county were considered high hazard, and they had no idea that inspectors had rated them poor. They did not have plans to practice.
Jerry Stacy, emergency management director for Perry County in Eastern Kentucky, didn’t know the state had determined three dams in poor condition in his county could threaten lives if they broke. He said he generally knew the homes that might be affected, but not based on any hydrological study.
“I’ve been here five years and this is the first time I’ve had a conversation about this,” he told KyCIR.
Chris Limpp has been Spencer County’s emergency management director for five years and worked for the county for 15. He didn’t know a dam existed in his county, let alone that state dam experts determined that it would likely kill someone or significantly damage infrastructure if it broke.
“This is eye-opening,” he said.
Jim McKinney, emergency services coordinator for Louisville Metro Emergency Services, said dam owners have not provided him with specific plans. But he does know which of the county’s dams are high hazard, and he said he’s working with dam owners in Jefferson County to address issues with their dams.
He also said he wants to present dam owners with templates for emergency action plans, in hopes that they’ll make their own. But he thinks everyone, including homeowners, shares responsibility to educate themselves.
For example, some expensive property sits downstream from a small, high-hazard dam in the Norton Commons area. Tyler Glick, a spokesperson for Norton Commons, said a property owner living downstream of the dam is aware of living downstream from a potential breach.
But McKinney says that’s not always the case.
“Many of these people that live downstream from dams, they have no idea what’s upstream from them,” he said.
Alexander of the state dam program acknowledged as much.
“If the emergency managers aren’t up to date on the information, if they don’t practice how they’re going to handle the information when the time comes, they’re going to be caught off guard and not really know what to do,” Alexander said.
State dam safety staff said they plan to ask the legislature to require dam owners to make emergency action plans within the next few sessions.
Kenny Hardin, emergency management director for Bullitt County, said supporters of reforms are likely to run into resistance from dam owners. He said owners of existing dams shouldn’t be required to make plans, although perhaps new dam owners should.
“What the landowner would say is, ‘Big Brother is interfering with this.’ There’s been no issues, so why should you come in here now and make me do something that has been no issue?” Hardin said.
Bullitt County has four high-hazard dams, three of which are in poor condition. Only one has a draft plan on file with the state, and all are owned by private individuals or businesses.
Hardin told KyCIR he wasn’t familiar with any plans and would need to look into it. Later, he said he located two plans from private dam owners, at least one of which was out of date.
Some dam owners were working on plans when KyCIR reached them.
In Nelson County, the city of Bloomfield is spending about $120,000 to improve its dam on a two-acre fishing lake in the city park.
If it were to break, the water would wash over about five or six houses, hit Bloomfield City Hall, a church, a few other buildings and then an apartment complex that houses a lot of elderly people, said Mayor Chris Dudgeon.
So the city is also drafting up emergency action plans, which meant having to hire an engineering consultant to do hydrological studies to determine where water would go if the dam broke.
In Jenkins, a border city with Virginia in Letcher County, a dam failure at Elkhorn Lake could strike 30 percent of the town’s population if it broke, said Mayor Todd DePriest. The dam has been leaking for years, and he fears a natural disaster could come along and take the dam out for good.
He used to work with people who witnessed a major coal slurry dam failure in West Virginia in the 1970s, which killed more than 100 people. And he’s heard the stories.
“It sort of gets in the back of your mind. That’s something they never thought would happen up there,” he said. “Same thing here. You can think that it may not happen. But we need to be prepared.”
The state Division of Water ordered Jenkins last summer to work on an emergency plan, and it’s in the works now. The city had already commissioned some studies, so DePriest got the data he needs to build inundation maps. He plans to share the maps with emergency planners, who will conduct regular practices.
According to state data, dam officials made a simplified plan for the dam, but DePriest had never seen it. Neither had the emergency management director, Paul Miles.
Testing emergency plans to make sure they work is key, Miles said.
“You have to practice your plan,” Miles said. “If you don’t, it’s not a good plan.”
Sydney Boles of the Ohio Valley ReSource contributed to this report. Contact reporter Caitlin McGlade at (502) 814.6541 or firstname.lastname@example.org.