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Dec. 16, 2005
Airport permit needs strengthening
Under Wisconsin state statute companies wishing to discharge
into public waterways are required to apply for a Wisconsin
Pollutant Discharge Elimination System (WPDES) permit issued
by the Department of Natural Resources (DNR). WPDES permits,
which are reissued every five years, allow the DNR and
public to monitor the performance of companies that
discharge wastewater. Recently, General Mitchell
International Airport has applied to have their WPDES permit
re-issued.
Friends of Milwaukee’s Rivers is concerned by the DNR’s
proposed re-issuance of the airport’s permit. Rather than
strengthening the Airport’s requirements, ensuring
compliance to federal and state water quality standards, the
DNR’s proposed permit allows the airport’s negligence to
continue. The broad language of the permit grants the
airport much leniency, which could allow volumes of toxic
glycol and other chemicals to be continued to be discharged
into Wilson Park Creek without consequence. FMR has
commented on the permit and requested a public informational
hearing.
The Kinnickinnic River downstream of Chase Avenue and the
Milwaukee Estuary are both listed as impaired waters due to
their general aquatic toxicity, elevated bacteria levels,
reduced dissolved oxygen content, and fish consumption
advisory. The proposed permit would allow discharge of storm
water pollutants such as propylene glycol and other toxic
substances that could contribute to stream impairments and
violate water quality standards.
Propylene glycol is of special concern due to its propensity
to cause high biochemical oxygen demand. An increased oxygen
demand would deplete the dissolved oxygen in our rivers,
which already suffer from low levels of dissolved oxygen.
The proposed permit does not address specific pollutants,
which limits its ability to identify problems and solutions
relevant to Wilson Park Creek.
In our comments we have encouraged the DNR to modify the
permit to require that discharges from the airport result in
absolute compliance with water quality standards for Wilson
Park Creek, the Kinnickinnic River, and Lake Michigan.
The airport, which has not been meeting its glycol recovery
goals during the last five years, should not be allowed to
continue “business as usual”. The proposed permit does not
require stricter Best Management Practices (BMP) even though
the airport’s past BMP have been inadequate. The proposed
permit should more clearly define glycol recovery limits the
airport must meet, stricter BMP the airport should
implement to increase glycol capture, and consequences for
not meeting these expectations. Without a change in the
permit it seems unlikely that glycol recovery measures will
improve.
Full comments
[PDF]
Midwest Environmental
Advocates comments, submitted on FMR's behalf
[PDF]
Dec. 15,
2005
FMR serves on Green Team
FMR Executive Director Lynn
Broaddus served on one of the committees helping to set
recommendations for the Mayor's green initiative, termed the
Milwaukee Green Team. Water has been a key part of this
initiative. Recommendations include ways to reduce pollutant
loads in stormwater. They also include suggestions for
restoring natural groundwater recharge - getting rainwater
and snowmelt to naturally soak into the ground, where it can
slowly, naturally make its way back into our streams and
rivers.
Full report
[PDF]
Milwaukee Green Team page
Dec. 13,
2005
FMR calls for Stronger State Laws in
Wisconsin to Improve Compact Agreement, Water Protections
FMR and
Wisconsin-based conservation groups said today that the
newly-signed and historic Great Lakes – St. Lawrence River
Basin Water Resources Compact contained important
safeguards, but urged Wisconsin legislators to adopt
stronger implementing legislation with regard to
conservation, bottled water regulations, and diversion
proposals, for the protection of Wisconsin waters and the
Great Lakes.
Full press release
[PDF]
Dec. 8, 2005
Citizens need information on PCB
levels
Letter to Milwaukee County
Supervisors
Dear Supervisors,
As a grassroots advocacy group
dedicated to the Milwaukee, Menomonee, and Kinnickinnic
Rivers, Friends of Milwaukee's Rivers cares about both water
quality and recreational accessibility of the Milwaukee
River. As you may know, we recently completed the "Milwaukee
Urban Water Trail", a paddling guide to our rivers. One of
our most important partnerships in that endeavor has been
Milwaukee County - the Parks Department worked closely with
us in developing the access sites for Milwaukee County
Parks.
Last fall when the DNR released its study on PCB's in the
area upstream from Estabrook Dam, we immediately begain
getting phone calls from constituents wanting to know our
position on removal of the Estabrook Dam. I told them the
same thing I will tell you - Friends of Milwaukee's Rivers
does not have a position on whether or not the dam should be
removed. However, we do want to have, and we want our
leaders to have, the best information possible on the costs
(both direct and indirect) of all options.
It is my understanding that in Tuesday's P,P,& E Committee
meeting there was sentiment that the dam removal option
should not even be considered until a responsible party for
the PCBs in the sediments behind and upstream from the dam
is identified.
However, in the long run, informed leadership is needed on
this extremely emotional issue. The public needs to know
life cycle maintenance costs for the dam, as well as removal
costs. "Costs" include not only the dollar value of the
labor and materials involved, but also recreational costs,
fisheries costs, water quality costs, etc. Only then, when
all options are fleshed out, can we make sound decisions.
As I said before, Friends of Milwaukee's Rivers truly does
not have a position on the potential removal of the
Estabrook Dam. However, in order to eventually arrive at
such a position, we and all the other citizens of Milwaukee
County will need sound information to help us formulate our
opinions.
Thank you for your
consideration.
Lynn E. Broaddus, PhD, MBA
Executive Director
FMR report on PCB
levels in Estabrook Impoundment
Dec. 1, 2005
FMR
opposes
bill
regulating piers
Friends of
Milwaukee’s Rivers opposes AB 850 pertaining to new
regulations for piers and boat slips, because of the
negative effects this legislation could have on our rivers,
riparian property rights, public access/public rights, and
safety. While the perception is that this bill would only
affect rural lakes and rivers, this is not the case.
First of
all, the proposed bill requires the DNR to prove “by a
preponderance of evidence” that existing piers present “an
imminent and substantial danger to navigation or the public
interest,” and not just interfere “with public rights.”
This language is vague and essentially unenforceable, and
does not serve either the public interest or interest of
riparian property owners. If an existing pier is dangerous
or currently damaging public waters or interfering with the
rights of adjacent property owners, this bill could
effectively “grandfather” that pier in and make it legal
forever. This is not good policy.
Secondly,
this bill will allow a boat slip for each and every
“dwelling” on a piece of property. In Milwaukee, this could
mean several things as our rivers are slowly filling up with
riverside condominiums: either huge or long piers could be
built or huge numbers of piers packed in along the
shoreline. For example, a condo with 80 units could
potentially build 40 piers to accommodate 80 boat slips.
The cumulative effect of increasing number of piers in
Milwaukee and surrounding areas is causing problems with
navigability (i.e. traffic jams on the water), safety issues
for boaters, and degradation of wildlife habitat and water
quality. In addition, as piers start lining our rivers along
both sides, non-motorized recreational users in canoes and
kayaks are pushed further into the navigable channel, where
they come into closer contact with motorized boats, coal
barges, tugs, and other craft. Allowing increased, rampant
pier development in Milwaukee could turn our urbanized
rivers into a serious safety hazard (i.e. think bumper
boats). In addition, as piers start to line all of our
riverfronts, the aesthetics of our rivers change as one can
no longer look out on the water without seeing piers in the
foreground. We also increasingly hear from local fishermen,
who are saddened and frustrated at losing their traditional
fishing spots, as they can no longer cast their lines over
20-40 foot boats lining the shores.
In
conclusion, regulation of piers is a complicated issue.
Because of that fact, the Department of Natural Resources (DNR)
has been working hard for years to revise the permitting
process for piers and the pier planner. After the Jobs
Creation Act (Act 118) was passed several years ago, the DNR
worked hard with all affected interest groups to come up
with exemption categories for piers and to clarify the
process. They were given the ability to write rules to
administer the statute, and these rules have already gone to
public hearing and have not come to the legislature yet. AB
850 is an attempt to bypass this process and the hard work
that has been put in by many stakeholders to make sure that
we have pier rules that work for everyone, in all areas of
the state, and along all our waterways. Friends of
Milwaukee’s Rivers urges you to oppose this bill on behalf
of over 350 families in the Milwaukee River Basin that are
concerned about protection of our water quality, wildlife
habitat, recreational opportunities, and quality of life.
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