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Great Lakes Article:

Wisconsin Eco-Water News Briefs
08/15/2002

C.A.N.O.E
Citizen Action Network for our Environment

In This Issue

1.Alternate View on Fox Remediation Plan Click Headline
Jennifer Feyerherm of the Sierra Club's Great Lakes Program

2. Program Coordinator, Kinnickinnic River Land Trust Click Headline

3. Public Hearing on Proposed Wetland Amendments Click Headline
Postponed until September 25

1. Alternate View on Ecosystem Rehabilitation Plan
Jennifer Feyerherm of the Sierra Club's Great Lakes Program


Editor's note: C.A.N.O.E. is a way to disseminate information to those concerned with flowing waters. Views expressed in C.A.N.O.E. do not necessarily reflect the views of our funders, members, board or staff. We encourage readers to submit material for this weekly update.

As noted in last week's CANOE, an alternative view to what was proposed by a reader in last week's issue on the Fox River Remediation is provided below.


I am writing on behalf of the Midwest Office of the Sierra Club in response to the letter regarding the capping plan that has been aggressively marketed by Appleton Papers' former French parent company. This capping plan, disingenuously called the Ecosystem Rehabilitation Plan, would leave our river, our ecosystems, ourselves and our children at risk to PCBs for generations to come. We take issue with the plan in five areas:

  • First, capping itself is a much less permanent, much more risky solution than actually removing the PCBs from the waterway.

  • Second, this plan would leave the Fox River with completely unacceptable risks to humans and the environment.

  • Third, it leaves many unanswered questions about costs, liabilities, and long-term care.

  • Fourth, it completely mischaracterizes dredging, with false assertions about how long it will take and how effective it will be at reducing risk.

  • Finally, and perhaps most importantly, the constant touting of this unreasonable plan diverts money, time, and resources away from our fundamental mission: cleaning up the Fox River.

Capping provides an impermanent solution, at best. It leaves the PCBs in the river, only covering them with a thin layer of sand. The problems begin as the cap is being placed. As the cap is placed, contaminated mud at the bottom may stir up, only to resettle on top of or around the cap. Outside forces will always be working to degrade the cap. Gradual erosion, burrowing organisms, ice and boat scour, anchors, trawling, and big natural disturbances all threaten the effectiveness of caps. Even the sturdiest of caps degrades over time and becomes more susceptible to storms and floods. 100-year floods now occur much more frequently, calling the future of any Fox River cap into question. The definition of 100 year flood has not changed even though we have modified the landscape to such an extent that they are ever more common. Note that when the panel says the cap will withstand three times the force of a 100-year flood, we are not really talking about a once-a-century event. Moving water has tremendous power. No cap will be guaranteed to withstand all that nature can dish out.

Not only does capping generally provide a less ideal, less permanent solution for contaminated sediments, this specific capping plan does not adequately address PCBs in the Fox River. The plan leaves the most contaminated section of the river, below the DePere dam, to navigational dredging. Navigational dredging is a messy, inappropriate way to deal with contaminated sediments. Periodic navigational dredging in that stretch of river would only serve to stir up and spread out the bulk of the PCBs that contaminate the river, washing them into the Bay where they will persist for generations.

The panelists claim that the plan will achieve the same goal that DNR sets out to achieve, namely a given concentration of PCBs in the surface layer of sediment. What they don't explain is that in the capping plan's version, they are trying to achieve an average over the whole riverbed - something the DNR's proposed action level does not do. DNR proposes that all sediments with concentrations greater than 1 part per million (ppm) PCBs be removed from the river. This action level is then used to calculate the averages. With DNR's averages, we are assured that no sediment remains at concentrations greater than 1 ppm PCBs. On the contrary, if you go for a river-wide average such as the capping plan proposes, you end up with some areas that are much more contaminated than others. Some areas will be capped and others just left -- at concentrations many times higher than 1 ppm. PCBs left in those areas will continue to risk our health and the health of our environment by continuing to contaminate fish and continuing to wash out into the Bay.

Capping is at best an impermanent solution. If caps were used in the Fox River, we would have to monitor extensively and diligently over the long-term to ensure that the cap was not compromised. Some monitoring is built into the capping plan, but not enough. Questions remain. Who would keep up the monitoring in perpetuity? How much will indefinite monitoring end up costing? Who is going to pay for it? What kind of remedy would we use when a cap breaches? How much will additional remedies cost and who would pay for them? We cannot guarantee the cap itself over time; neither can we guarantee its stewardship, care, repair, and possible replacement.

The plan and the marketing panel completely mischaracterize dredging. Their claims of unreasonable time frames and excessive risk are unfounded. They claim that DNR will need 60 years rather than the estimated 7 to dredge the river - mainly due to overblown wastewater treatment issues. All of the "additional risks" they claim result from dredging are a result of this extra time that PCBs would supposedly be exposed to the environment. However, once we address the wastewater treatment issues, and the dredging proceeds according to schedule, this argument falls. And DNR is doing just that. Ammonia is one of the biggest problems that the panel discusses. We have industrial wastewater treatment systems that can handle treating massive quantities of ammonia. Ammonia is readily neutralized. Oxygen demand is another challenge that can be met by altering loads from other places in the river. The paper mills on the river are currently operating at a quarter of the total biological oxygen demand they are allocated by DNR. We can keep the oxygen demand within the totals already permitted by DNR. We can -- and should -- demand that DNR place stringent controls on dredging wastewater that is returned to the river. Those controls will simply not take the decades claimed by the panel.

I have outlined several of the many technical criticisms of the capping plan, but the most important problem remains to be discussed. This plan is diverting time and resources away from our fundamental mission: cleaning up the Fox River. The "alternative" capping plan not only diverts attention away from the more thorough, peer reviewed DNR assessment of all available alternatives, but it also wastes time and money that should be spent on cleaning up the Fox River. Appleton Papers' former parent company (an international, not local, firm) has hired lobbyists and other public relations folks to sell this plan to whomever will listen. The company continues to parade consultants around the state touting this capping plan for the Fox River, diverting attention from the cleanup process and getting in the way of progress on the river. Rather than giving all they can to a cleanup, they are instead spending valuable resources trying to stall the cleanup process.

DNR has spent many, many years and many millions of our dollars to thoroughly study the river and come up with the best solution. Their reports are solid, peer reviewed, scientific documents. They have studied all the options, and all point to the same conclusions: We must get the PCBs out of the river. We certainly should not be wasting our time, energy and money entertaining a hastily-written plan commissioned by a firm that has every interest in stalling cleanup. We should be devoting all our resources to cleaning up the river, removing the PCBs, and eliminating our exposure to them.

If you have more questions about the capping plan or DNRs proposed solution for the river, feel free to contact Jennifer Feyerherm at the Sierra Club's Great Lakes Program, 608/257-4994 or jennifer.feyerherm@sierraclub.org.

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2. Kinnickinnic River Land Trust Seeks Program Coordinator

The Kinnickinnic River Land Trust (KRLT) is a community land trust that works to protect the entire watershed of the Kinnickinnic River.

The KRLT's office is located in River Falls, WI, in a former mill and on the banks of the Kinnickinnic. The City has a population of about 15,000 and is home to the University of Wisconsin, River Falls.

For more information go to our web site: http://www.kinniriver.org.

Program Coordinator
The Program Coordinator is responsible for implementing and coordinating the land conservation activities and programs at the KRLT. The position responsibilities include contacting landowners, managing KRLT lands, producing land protection documents, raising project funds, working with volunteers and effectively communicating the mission of the KRLT.

Qualifications
The qualifications for this position include:

  • Bachelor's degree

  • Minimum 3 years working in conservation with preference given to land trust experience

  • Excellent verbal and written communication skills

  • Knowledge of private land conservation techniques

  • Proficiency with MS Office, Word, Power Point, Excel

  • GIS experience and Grant writing a plus

  • Salary based on experience; health insurance stipend.

To Apply: Send letter, resume and writing sample by August 19th to:
Program Coordinator Search
Kinnickinnic River Land Trust
PO Box 87
River Falls, WI 54022

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3. Upcoming Hearing on Proposed Wetland Setback Amendments Re-Scheduled

The Public Hearing to consider the Proposed Wetland Setback Amendments to the City of Franklin's Unified Development Ordinance (UDO) has been re- scheduled.

  • Wednesday, September 25 at (TBA)

  • Your attendance is greatly appreciated.

  • Your input (as well as support) on water quality protection is welcome!

  • You do not need to live in Franklin to support water quality.

Require further info? Contact me.
Kristen Wilhelm, Vice Chairman City of Franklin Environmental Commission
414-421-3087
dwilhelm@execpc.com

* Please forward.

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River Alliance of Wisconsin
306 East Wilson Street, #2W Madison, WI 53703
Tel: 608-257-2424. Fax: 608-260-9799.
Email: wisrivers@wisconsinrivers.org. Web: www.wisconsinrivers.org

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