Wisconsin Eco-Water News Briefs
Action Network for our Environment
View on Fox Remediation
the Sierra Club's Great Lakes Program
River Land Trust
Hearing on Proposed Wetland Amendments
Postponed until September 25
View on Ecosystem Rehabilitation Plan
the Sierra Club's Great Lakes Program
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.
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.
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:
capping itself is a much less permanent, much
more risky solution than actually removing the
PCBs from the waterway.
this plan would leave the Fox River with completely
unacceptable risks to humans and the environment.
it leaves many unanswered questions about costs,
liabilities, and long-term care.
it completely mischaracterizes dredging, with
false assertions about how long it will take
and how effective it will be at reducing risk.
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.
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.
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.
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.
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.
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.
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.
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.
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 firstname.lastname@example.org.
River Land Trust Seeks Program Coordinator
Kinnickinnic River Land Trust (KRLT) is a community
land trust that works to protect the entire watershed
of the Kinnickinnic River.
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.
more information go to our web site: http://www.kinniriver.org.
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 for this position include:
3 years working in conservation with preference
given to land trust experience
verbal and written communication skills
of private land conservation techniques
with MS Office, Word, Power Point, Excel
experience and Grant writing a plus
based on experience; health insurance stipend.
Apply: Send letter, resume and writing sample by
August 19th to:
River Land Trust
Falls, WI 54022