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Date ____________________
* Deadline:
August 6,
2009
Ms. Erin Hanson
Wisconsin Dept. of Natural Resources
2984 Shawano Avenue
Green Bay, WI 54311
Dear Ms. Hanson,
I object to the
proposed
“Delisting Criteria” for the Lower Fox River
and Green Bay Area of Concern (AOC). When
“beneficial uses” are impaired, they should be listed as impaired. The plain meaning of words should not be
redefined to allow the government to declare these problems solved when
they
are not. All communities around the
Great Lakes should be required to measure themselves against true
definitions
of impairment, rather than weakening definitions at the worst Great
Lakes sites
so the worst sites strive only for average (but still unacceptable)
levels of
pollution and degradation. All
communities should be lifted to a healthy standard, instead of lowering
standards
at the worst.
I urge the DNR and EPA to
make the following underlined changes, at a minimum:
1. The Beach Closings /
Recreational Restrictions Beneficial Use Impairment (BUI) should be
delisted
when all waters of the AOC are safe for swimming for 98%
of the swimming season (between May 1 and October 1) for any 5
year
period based on Wisconsin Coastal Beach monitoring protocols for E. Coli monitoring and meet the
blue-green algae target for 98% of the swimming season.”
2. The Restrictions on Fish
and Wildlife Consumption BUI should be delisted when fish and
wildlife
consumption advisories are no longer needed in our AOC. (It would be extremely dishonest for our
government to delist our site for this measure while advisories are
still in
place.)
3. The Restrictions on
Dredging Activities BUI should be delisted when dredging for
shipping and
boating channels, marinas, transportation projects, utilities,
recreation,
wildlife habitat improvements or other purposes is no longer restricted
or more
expensive due to sediment contaminants or artificial obstructions
placed on the
river or bay bed.
4. The Bird or Animal
Deformities or Reproductive Problems BUI should be delisted when
bird or
animal deformities or reproductive problems are no longer found in
river and
bay wildlife. (Studies should continue until causes are found and
addressed.)
5. The Restrictions on
Drinking Water or Taste/Odor Problems BUI should be delisted when
river and
bay waters in our AOC can be safely used as public drinking water
supplies
after standard treatment methods and average treatment costs.
6. The Degraded Fish and
Wildlife Populations BUI should be delisted when recovery plans
have been
written and successfully implemented to establish sustainable
populations of
rare listed species which were historically present in our AOC. (Adequate habitat must be provided.
Additional management and intervention may also be needed.)
7. The Degradation of
Aesthetics BUI should be delisted when a professional survey of a
random,
representative sample of 1,000 people living within the AOC community
and who
come in contact with the waterway finds that at least 90% of the
respondents
feel river and bay waters are aesthetically acceptable.
8.
The Fish Tumors and Other Deformities BUI should be delisted when
studies of
fish in our AOC prove that they no longer have tumors or other
deformities
above natural background levels. (This
BUI must not be dropped as only a “suspected”
impairment because
it is not honest. U.S. Fish & Wildlife Service and DNR studies have
confirmed that elevated levels of fish tumors are present.)
9.
The Tainted Fish and Wildlife Flavor BUI should be delisted when a
professional survey (as in #7 above) of hunters and anglers finds no
tainting
of wildlife flavor. (This BUI must
not be dropped as only a “suspected” impairment.)
10. Local human health studies must be conducted,
related to river
and bay
quality, as measures of whether several of these BUI’s can be delisted. Items #1, 2 and 5 are based on the health of
humans exposed to those uses. Our local
health exposures are unique and complex, which makes simplistic fish
advisories
and minimal government pollution limits inadequate for determining our
community’s
true health risks. Our AOC listing must
not be dropped until human health studies are complete and show no
risks.
11. Better evidence is needed before
delisting - Many of the
proposed criteria fail to specify how much measuring must be done, and
for how
long, before an impairment could be delisted. Permanent
delisting must not happen after just one
favorable year or one
favorable measurement. All criteria must ensure that adequate
monitoring is
done and all improvements persist at least 5 years before delisting. It would be better to stay listed a few years
longer than to delist when serious problems are still present.
I do not want my community
to
lose its mandate, funding and sense of direction regarding our river
and bay
ecosystem restoration because the DNR and EPA have defined the problems
away.
Name (Print) _________________________________________________
Signature ____________________________________________________
Address _____________________________________________________
City _____________________________State________Zip ____________
Phone ______________________________________________________
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