Dear Ms. Pastor,

I’m writing to oppose the amendments to the Record of Decision for the Lower Fox River PCB cleanup.  In particular, I oppose any reduction in the quantity of sediments and PCBs to be removed from the river and bay, and I oppose any use of caps as a replacement for sediment removal.  Key concerns about the proposed plan:

1.  Caps are Experimental  --- Caps have never been proven to last in any large flowing river.  Caps were placed recently in a few rivers, but those caps have yet to survive the test of time or a multitude of severe floods. As Carl Sagan said, “Extraordinary claims require extraordinary evidence.”   Common sense and centuries of experience with river erosion tell us caps will not last.   Plan promoters have NOT provided evidence to the contrary.  Their claims are based on flawed mathematical predictions, not actual caps.

2.  Weak Caps  --- The plan calls for only sand layersover many partially dredged areas.  Any child who has built sand castles knows sand is washed away easily.  In other areas, thicker caps are planned, but this is still a bandaid given the force of longterm erosion.

3.  Not Built for Worst Case Scenario  --- According to this plan, caps would be built to withstand only a 100 year flood, which would be irresponsible and disastrous for future generations.  When a so-called 200 or 500 year storm hits, which could occur any year, the caps could be washed away entirely, exposing and recirculating dangerous levels of PCBs, mercury and other toxic chemicals. 

4.  100 Year Flood Improperly Calculated  --- The plan used a maximum river flow of 24,200 cfs as the basis for a 100 year flood, but studies have recorded a recent flow of 33,800 cfs on the Fox River.  Again, it is irresponsible to deliberately ignore known intense storms, especially when climate change could drastically alter rainfall, storms and river flows, making any predictions highly suspect.  Some climate change models show our region getting more water and more storms than in the past.

5.  Punch-through Strength Inadequate  --- The plan only examined the pressure resulting from human footsteps overtop the caps and ignored the obvious potential for huge wayward ships to puncture caps.  Or human mistakes involving heavy construction near, through or on the caps 100-200 years from now.  Or large tree limbs, boulders or other heavy objects rammed repeatedly into the caps during extreme flooding.  Or floods in the spring during ice break-up causing powerful ice shoves across the caps.  The planners also ignored erosion from “fractile ice” particles.   Again, the caps are not being designed responsibly to incorporate known threats.

6.  Groundwater Upwelling Ignored  --- When caps are placed over areas with significant flow from aquifers into a river, as there is in the Fox River, the pressure from upwelling groundwater can put pressure on compressed cap materials, compromising the caps’ integrity over time and forcing PCB leakage upwards into the river. The plan should have addressed this concern, but didn’t. 

7. Scattered Sites Pose Problems  --- The proposed cleanup maps show a multitude of areas considered suitable for caps.  The result is a hodgepodge of dredged, capped or unaltered sites.  Will “islands” of capped sites stick up from surrounding sediments, making them more vulnerable to erosion? How will future people remember the locations of all these sites 200 years from now?  Will our descendents be willing or able to maintain and repair the caps?  Where will they get the money, fuel and materials?

8 .  Monitoring is Too Brief  --- Only 40 years of cap monitoring is planned, but caps need to last more than 200 years.  They’ll only get weaker with time, and PCBs may migrate through the cap slowly.  If monitoring isn’t maintained, won’t people forget the caps? 

9.  Corporations Released from Liability, but Taxpayers Hooked   --- If this plan is accepted, the governments will sign a corporate release from liability when the short-term work is complete.  This means public taxpayers will be stuck with hundreds of millions of dollars in remediation costs when the caps fail.  And the bulky cap materials will make remediation much more difficult and expensive.  It would be far better to get the PCBs out of the river now, treat the sediments, and be done with the whole issue permanently.

10.  New Sources Neglected   --- The plan doesn't do enough to stop significant new river inputs of PCBs from urban stormwater run-off, leaking shoreline landfills like Arrowhead Park (a toxic PCB papermill sludge dump in Neenah on the shore of Little Lake Butte des Morts), widespread sludge landspreading from contaminated wastewater and sewage treatment plants, and other continuing PCB sources.  Until those sources are shut off, the new contaminants will just recontaminate our “clean” river.

11.  Renard Isle Ignored   --- A large mass of PCBs is contained in Renard Isle, offshore from Bay Beach Amusement Park.  This old sediment disposal island leaks like a sieve, is uncapped, and will take millions of dollars to remediate.  Brown County taxpayers should not get stuck with this remediation work.  It's clearly the polluters' responsibility, as part of this PCB cleanup plan.

12.  Bay Sediments Ignored  --- While the agencies have taken 10,000 sediment samples at more than 1,300 locations in the river, very few samples have been taken in the first 7 miles of the lower Bay, just beyond the river’s mouth.  This is a MAJOR gap in the plan that must be corrected.  At the least, a full sampling effort, comparable to that on the river, must be conducted to determine the mass of PCBs still remaining in the lower Bay, particularly in deeper areas and around Renard Isle.

13.  Lack of ANY Detoxification Treatment   --- I strongly support the use of new, proven, non-burning treatment technologies, such as soil washing by the company called Biogenesis, to detoxify contaminated sediments, rather than trucking them to distant landfills. 

The agencies are proposing a major step backwards from the proposal made just 3 years ago.  The governments seem too concerned with saving the Corporations money, and not concerned about protecting longterm public health, wildlife or taxpayer interests.

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