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Great Lakes


EPA RAP Liaison
John Perrecone

Lower Green Bay and Fox River Area of Concern

Lake Michigan

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September 2012 — The U.S. Army Corps of Engineers will begin work on a long-planned restoration project involving the Cat Islands Chain in lower Green Bay, Wis.

The Corps is partnering with EPA, U.S. Fish and Wildlife Service, Brown County and the state of Wisconsin, using a variety of funding sources, to restore the barrier island chain washed away in the 1970s by high water levels, waves and ice.

The project involves constructing 4.3 miles of stone dike ranging from four to eight feet high on Green Bay lake bed and installing concrete culverts for circulation between islands. This will constitute a dredged material disposal facility, DMDF, with 20 years of capacity for the sediments from the lower portion of the navigation channel. Contaminated material from the upper portion of the bay channel will continue to be placed in the nearby Bay Port facility.

Dredged materials deposited in the Cat Island DMDF over the coming years will gradually build three islands, expected to foster vegetation and habitat for fish and wildlife.

The goal of restoring the islands is to provide beneficial use for dredged materials removed from Green Bay and strengthen the lower Green Bay ecosystem while fostering the diversity of habitat for migratory birds and various fish species. Additional expected benefits include enhancing spawning grounds for fish, creating fishing and wildlife viewing opportunities for the public.

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The Lower Green Bay and Fox River Area of Concern consists of the lower 11.2 km of the Fox River below DePere Dam and a 55 km2 area of southern Green Bay out to Point au Sable and Long Tail Point. The drainage area encompasses portions of eighteen counties in Wisconsin and 40 watersheds of the Upper Fox River, Wolf River and the Fox River Basins, including the largest inland lake in Wisconsin, Lake Winnebago and its pool lakes. While water quality problems and public use restrictions are most severe in the AOC, water resources of the entire basin are affected by runoff pollution from urban and rural areas, municipal and industrial wastewater discharges and degraded habitats. Eleven use impairments have been documented and two are suspected of being impaired.

Reversing the hypereutrophic conditions in the river and bay is a top priority for the AOC. The LGB/Fox Science and Technical Advisory Committee (STAC) has formed a Strategic Data Acquisition Task Force to begin assembling information needed to develop a TMDL for the Fox-Wolf River Basin.

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Beneficial Use Impairments More information

  • Restrictions on fish and wildlife consumption
  • Tainting of fish and wildlife flavor
  • Degradation of fish and wildlife populations
  • Fish tumors or other deformities
  • Degradation of aesthetics
  • Degradation of benthos
  • Restriction on dredging activities
  • Loss of fish and wildlife habitat
  • Bird or animal deformities or reproductive problems
  • Eutrophication or undesirable algae
  • Restrictions on drinking water consumption, or taste and odor
  • Beach closings
  • Degradation of phytoplankton and zooplankton populations
  • Added cost to agriculture and industry

The two main impaired desired uses of the AOC are shore and water use. Fishing, boating, swimming, hunting and passive recreation have been restricted. Fish and fish-eating bird reproduction are impaired. Consumption advisories warn against eating mallard ducks and fish of twelve species. Shipping and navigation in the harbor and channel have been impaired due to the high cost of dredging and contaminated sediment disposal. The harbor must be dredged to a depth of 24 feet to allow deep-draft navigation.

Restrictions on Fish & Wildlife Consumption
Consumption advisories warn against eating mallard ducks and fish of twelve species.

Degradation of Fish & Wildlife Populations
There have been population declines in waterfowl, furbearers and endangered colonial-nesting water birds.

Bird or Animal Deformities or Reproductive Problems
Fish and fish-eating bird reproduction are impaired.

Restrictions on Dredging Activities
Shipping and navigation in the harbor and channel have been impaired due to the high cost of dredging and contaminated sediment disposal. The harbor must be dredged to a depth of 24 feet to allow deep-draft navigation.

Beach Closings
The two main impaired desired uses of the AOC are shore and water use. Fishing, boating, swimming, hunting and passive recreation have been restricted.

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RAP Development and Status More information

The Lower Green Bay RAP was developed by the Wisconsin Department of Natural Resources (WDNR) using a multi-stakeholder partnership with other agencies, local governments, scientists, citizens, industries and environmental groups. More than 75 people participated for two years on four technical advisory committees and a citizen's advisory committee for development of this community-based plan. The technical advisory committees developed reports identifying the problems, goals and objectives for management and technical solutions to restore the bay and river. The citizen's advisory committee identified the ten most pressing problems that should be addressed in the RAP, defined a "desired future state" for lower Green Bay and the Fox River and advised on recommended remedial actions. The RAP was completed in 1987 and adopted as part of Wisconsin's Water Quality Management Plan in 1988. Nearly two-thirds of the RAP's 120 recommended actions have been initiated. The RAP is viewed as a "living" document and will be updated regularly. Implementation and updating of the RAP is facilitated by WDNR using a Green Bay RAP Public Advisory Committee, a Science and Technical Advisory Committee and a Public Education and Participation Advisory Committee. In addition, two nonprofit organizations have been established by community leaders to promote implementation of nonpoint source pollution controls (Great Lakes Nonpoint Abatement Coalition) and to determine the most cost-effective actions to meet the goals of the RAP (Northeast Wisconsin Waters for Tomorrow, Inc.)

Significant RAP Milestones

  • Since 1988: 38 of the 120 recommended remedial actions have been implemented
  • 1988: RAP was adopted as part of Wisconsin's Water Quality Management Plan
  • 1987: RAP was completed in 1987

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RAP Implementation

Since 1988, 38 of the 120 recommended remedial actions have been implemented. Another 57 remedial actions have been initiated, but need more effort and 25 actions have had little or no progress. Many of the actions completed have been short-term, lower cost projects that demonstrate an immediate environmental result or institutional commitment to the RAP. Presented below are highlights of RAP implementation and resource improvements.

Fox River Damage Assessment

EPA has proposed to list the area as a superfund site. Remediation will take place under a $10 million agreement with the 7 paper mills in the area. Under the agreement, work is progressing to finish a PCB risk assessment and whole river clean up plan, an evaluation of the PCB transport and fate models and two sediment deposit cleanup projects. Pre-design studies have been completed, feasibility studies are underway and cleanup is scheduled for next year under the cleanup projects. One of the demonstration cleanups is being funded under the agreement and another with a combination of U.S. EPA, state and industry money.

Dredge Soil Disposal Plan

The RAP is working cooperatively with the port of Green Bay on a dredge soil disposal plan for disposal and beneficial reuse of dredged material. The U.S. Army Corps of Engineers is conducting a feasibility study on use of clean dredged materials for habitat island construction in southern Green Bay. The RAP's Biota and Habitat Committee proposed this project to the port and is working with the port and the Corps on the feasibility study and engineering designs. The Biota and Habitat Committee has also designed a habitat enhancement project for a new marina at the mouth of the Fox River. The RAP committee is working cooperatively with the marina developers to design and cost-share the work.

Nonpoint Source Pollution Abatement

Work is progressing on nonpoint source pollution abatement in the large drainage basin (6,400 mi2) within the AOC. There are thirteen priority watershed projects in the basin addressing nutrient, soil, pesticide and urban runoff pollution.

Actions to Reduce Toxicity

  • EPA, WDNR and others completed the $13 million Green Bay and Fox River Mass Balance Studies in 1993 to determine the extent of PCB contamination from Lake Winnebago to Green Bay and model the fate and transport of PCBs in the river and bay system.
  • Wisconsin Legislature passed the Harbors and Bays Act funding for sediment remediation in 1990.
  • WDNR formed a Sediment Management and Remedial Techniques Program in 1989 to inventory statewide contaminated sediment and demonstrate effective remedial techniques.
  • WDNR completed the Little Lake Butte des Morts demonstration project feasibility study for evaluating remedial options for a sediment deposit containing 716 kg PCBs in 1993.
  • WDNR entered into a cooperative effort with 30 representatives of industry, county and municipal government and municipal publicly-owned treatment works in the Fox Valley to develop a cost effective remediation schedule for contaminated sediments in the 60 km (37 miles) of lower Fox River. In 1993-94, the group prioritized sites in 60 km of the river and initiated remedial investigations and feasibility studies on four sites.
  • WDNR and the state adopted new water quality standards for toxic substances in 1990 to protect human health, fish and aquatic life and wild and domestic animals. The state anti-degradation policy for new discharges to Great Lakes waters was also revised.
  • Green Bay Metropolitan Sewerage District ($69 million), the city of Appleton ($69 million), the Heart of the Valley Metropolitan Sewerage District, the city of Oshkosh ($15 million) and the Village of Pulaski ($4.5 million) have completed facility upgrades to reduce pollutant loadings.
  • Further reductions in air emissions are expected with implementation of the Clean Air Act.
  • WDNR is developing new rules for stormwater permits for industries and municipalities to address urban nonpoint source pollution. East River Priority Watershed project has an urban stormwater component. City of Appleton is developing a stormwater management plan.
  • 262 chemical spills have been cleaned up in the Fox River Basin.
  • Cleanup of 582 leaking underground storage tank cases in the lower Fox River Basin is ongoing.

Actions to Reduce Phosphorus and Suspended Solids

In September 1999, the Nutrient and Sediment Management Work Group of the Science and Technical Advisory Committee (STAC) met to review the original Lower Fox River/Green Bay RAP recommendations regarding proposed reductions in phosphorus (P) and total suspended solids (TSS, including sediments) for current applicability. Of primary interest was the technical basis for the original recommendations of 1988 (and subsequent recommendations in the 1993 RAP update in order to sanction their use in a Total Maximum Daily Load (TMDL) process for the Lower Fox River Geographic Management Unit (GMU, or Basin).

  • Progress has been made in reductions of external phosphorus loads to the AOC. Since the late 1970s, point source loads in the Lower Fox River drainage basin have been reduced by 84%. However, average summer total P concentrations in the AOC have decreased over the same period by only 32% (from 206 µg/l in the 1970s to 141 µg/l in the 1990s). Summer averages of chlorophyll a decreased in this period by about 38%, but Secci disc values have remained steady at around 0.5 m since the 1970s. (Source: Nutrient and Sediment Management in the Fox-Wolf Basin - White Paper, Science and Technical Advisory Committee)
  • Between 1970 and 1990, municipal point source control efforts (discharge permits) decreased total phosphorus loadings from 370,000 kg/yr to 60,000 kg/yr.
  • Publicly-owned treatment works for Green Bay, DePere and Neenah-Menasha have voluntarily reduced total phosphorus discharges and have evaluated capabilities to achieve a 0.5 mg/l effluent phosphorus concentration.
  • In 1992, an administrative rule was adopted which extends the 1 mg/l phosphorus limit for large municipalities to many industries and small municipalities.
  • Comprehensive nonpoint source pollution abatement projects have been initiated in four of the twelve highest priority watersheds and in two of the moderate priority watersheds. Landowners, local governments and WDNR cooperate to achieve project objectives which include protection of Big Green Lake (completed $1.1 million project); reduction of phosphorus loading from East River Watershed by 70% and sediment loading by 50% ($23.8 million); reduction of phosphorus loading from Lake Winnebago-East by 40% and sediment by 50% ($2.6 million); reduction of phosphorus and sediment loadings by 50% from Arrowhead-Daggets Creeks ($2-3 million); and development of inventories for Neenah Creek and Waupaca-Tomorrow Rivers to determine potential load reductions.
  • Fifty landowners cut phosphorus fertilizer use by 36,360 kg in 1992 through the Soil Conservation Service East River Water Quality Demonstration Project.
  • A state model ordinance has been developed for construction site erosion control. A model ordinance for stormwater runoff is under development. As of 1993, six local governments are considering or have adopted ordinances. New state legislation requires local erosion control ordinances for 1-2 family developments.
  • Brown County has expanded its shoreland/floodplain zoning ordinance to require agricultural setbacks from perennial streams.
  • As of February 1993, 33,120 m of stream shoreline in Brown County were protected from livestock with the cooperation of 76 property owners. An estimated 36,290 metric tons of soil erosion was prevented, correcting 65% of the problems caused by livestock along those streams.
  • All counties in the Fox/Wolf Basin, except Waushara, have adopted animal waste management ordinances (58 animal waste management applications processed; 68 waste management plans prepared from 1990-1993).
  • 52,300 ha have been enrolled in a Farmland Preservation program for Brown County. The amount of land enrolled in the Federal Conservation Reserve Program as a result of expanding the eligibility to croplands adjacent to streams includes: Brown County (526 ha); Calumet County (2,023 ha); Fond du Lac County (283 ha); Outagamie County (2,023 ha) and Winnebago County (4,210 ha).

Actions to Enhance Fish, Wildlife and Habitat

  • Muskellunge have been reintroduced to increase predator fish and control problem fish (fingerlings stocked: 10,000 in 1989; 1,283 in 1990; 2,624 in 1991 and 2,259 in 1992).
  • 335 m of walleye spawning habitat was created at three Fox River sites in 1990.
  • A permanent barrier to sea lamprey migration was constructed in 1988 by U.S. Army Corps of Engineers and WDNR at Rapide Croche Dam.
  • 68 ha of wetlands have been acquired within the West Shore Wildlife Area and 46 ha north of Duck Creek.
  • U.S. EPA, U.S. Fish and Wildlife Service and the RAP Biota and Habitat Committee used wetland inventories to identify critical wetlands and habitats for protection and enhancement (completed in 1993).
  • 20 private pothole wetlands have been restored in the Fox River Basin (4.2 ha).

Actions to Monitor Ecosystem Changes

Considerable resources are expended on an annual basis to monitor contaminant levels, trophic status, fish population trends and harvests, macroinvertebrates, waterfowl use, public attitudes, human uses, etc.

Actions to Improve Public Access and Recreational Opportunities

  • The Green Bay Metropolitan Boat Launch expansion was completed in 1993.
  • The Duck Creek access site was improved in 1993 (boat launch, handicapped-accessible fishing pier, picnic area, boardwalk).
  • A new boat launch was built on the east side of Fox River in DePere in 1991.
  • Access was also improved at Fox River Walkway, East River Parkway, Ashwaubenon Creek, Sauamico and Bay Beach Park.
  • Improvements to Voyageur Park in DePere include shoreline fishing facilities with handicapped-accessible areas, expanded park trails and construction of two fish spawning reefs.

Actions to Improve Public Awareness and Participation

Considerable, on-going efforts are underway. Examples include a "Water Action Volunteers" monitoring project in the Green Bay School System; the annual "Clean Bay Backer" awards; RAP and water quality education exhibits at the Green Bay Metropolitan Boat Launch and Neville Public Museum; a RAP exhibit at area expositions like the Home and Garden Show and Sports Fishing Show; an annual River/Bay Cleanup Day and development of a mass media campaign for nonpoint source pollution prevention using an animated team of characters called the "Clean Bay Backers."

Actions to Further Pollution Prevention

In the Green Bay AOC, local efforts are underway by the WDNR, citizen advisors, University of Wisconsin Extension, Lake Michigan Federation and the County Land Conservation agencies. Federal efforts are underway through the Pollution Prevention Act of 1990 and EPA's 33/50 program. State efforts are underway through Wisconsin Act 325, including pollution prevention audits and the resources of a number of offices and centers set up to promote pollution prevention.

Actions to Evaluate Environmental Risks

An environmental risk assessment was performed in 1991-1992 to determine which problems or stressors posed the greatest potential to harm human health, the ecosystem, the economic system and/or the quality of life. Those stressors judged to pose the greatest risk were, in descending order: wetland/shoreland filling; exotic species invasions; persistent bioaccumulative organic substances; heavy metals; phosphorus loadings; suspended solids loadings; BOD loadings and nonpersistent toxic substances. This information will be used to set priorities and target resources for most effective risk reduction. In addition, a cost-effectiveness analysis is also being performed by Northeast Wisconsin Waters for Tomorrow, Inc. to help achieve the greatest risk reduction and meet the appropriate phosphorus and suspended solids objectives for the least cost.

Current projects and outlook

Substantial progress has been made in developing the RAP and implementing recommended actions. However, despite incremental improvements to prevent water pollution, restore habitats, improve public access and further define the causes of impaired uses, none of the problems in the AOC have been completely solved. Recommendations are being implemented sequentially - the easiest have been started, the more difficult have yet to be implemented. Full RAP implementation will be well beyond the year 2000.

Reversing the hypereutrophic conditions in the river and bay is a top priority for the AOC. The LGB/Fox Science and Technical Advisory Committee (STAC) has formed a Strategic Data Acquisition Task Force to begin assembling information needed to develop a TMDL for the Fox-Wolf River Basin.

The following information is extracted from the STAC White Paper referenced above in "Progress and Achievements".

To effect further, more significant reductions in P levels, management strategies to control nonpoint sources must be implemented throughout the Fox-Wolf watershed. As a consequence, both Lake Winnebago, which also suffers effects of excessive P stimulation of algal growth and reduced water quality, and the AOC would benefit from the P controls.

A coordinated monitoring effort is essential to enhance knowledge of the dynamic relationships between P loads, water clarity and water resource conditions. Coordinated monitoring is also important for evaluating the results of P and Total Suspended Solids (TSS) reduction efforts in the Fox-Wolf Basin.

The revised recommendations should also be considered in the Upper Fox, Wolf and Lower Fox River geographic management units (GMUs). It is counterproductive and counter-intuitive to expect to achieve the desired future state for the Lower Fox River/Green Bay AOC without including these GMUs in P and TSS reduction efforts. Of particular interest should be the Lake Winnebago pool of lakes.

Revised ambient targets for P and TSS can be expected to achieve the following:

  • Reductions in algal abundance and abiotic suspended solids will lead to increased water clarity (Secchi disc of 1.5m).
  • The littoral community can be expected to increase in biological production, diversity and area of development, including fish and waterfowl.
  • Beneficial uses such as swimming and fishing can be expected to increase.
  • Increased development of aquatic plants will reduce water turbulence and facilitate further reductions of suspended solids, and may impact boating in shallow water areas.
  • Frequency and intensity of nuisance blue-green algae blooms will decrease.

The RAP recommendations, as revised in the STAC White Paper for ambient concentrations of P, TSS and chlorphyll-a should continue to serve as the goal for achieving the desired future state as it relates to nutrients and suspended solids in the watershed. In order to meet these targets, the 50% reductions from the 1981-1983 average estimated loads of P (just over 1 million pounds) and TSS (200 million pounds) stand. In other words, P loads should cut to 500,000 pounds and TSS to 100 million pounds annually.

The STAC recommends this information be used to achieve a total maximum daily load (TMDL) in the Lower Fox, Upper Fox and Wolf GMUs so that the development and implementation of watershed restoration strategies may begin as soon as possible.

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What is a beneficial use impairment?

Impairment of beneficial use is a change in the chemical, physical, or biological integrity of the Great Lakes system sufficient to cause any of the following 14 use impairments:

  • restrictions on fish and wildlife consumption
  • tainted fish and wildlife flavor
  • loss of fish or wildlife habitat
  • degraded fish and wildlife populations
  • fish tumors or other deformities
  • bird or animal deformities or reproductive problems
  • degradation of benthic macroinvertebrate communities
  • restrictions on dredging activities
  • eutrophication or undesirable algae
  • restrictions on drinking water consumption or taste and odor problems
  • beach closings
  • degradation of aesthetics
  • added costs to agriculture and industry
  • degradation of phytoplankton and zooplankton

What is a remedial action plan?

The remedial action plan, or RAP, is a process to clean up the waterfront, rivers, habitats and waters. The United States and Canada, as part of the Great Lake Water Quality Agreement, committed to cooperate with State and Provincial Governments to ensure that RAPs are developed and implemented for all Areas of Concern in the Great Lakes basin. Forty-three AOCs have been identified: 26 located entirely within the United States; 12 located entirely within Canada; and five that are shared by both countries. RAPs address impairments to any one of 14 beneficial uses (e.g., restrictions on fish and wildlife consumption, dredging activities, or drinking water consumption) associated with these areas.

What is a delisting target?

In order to move towards formal delisting, RAPs need delisting targets to gauge their success:

  • Delisting targets should be premised on local goals and related environmental objectives for the watershed; they should be consistent with the applicable federal and state regulations, objectives, guidelines, standards and policies, when available, and the principles and objectives embodied in Annex 2 and supporting parts of the GLWQA.
  • Delisting targets should have measurable indicators.
  • Delisting targets should be developed and periodically reviewed on a site specific basis (allowing for flexibility in addressing local conditions) by the respective state agencies, in consultation with local stakeholder groups. This is particularly important if new information becomes available.

More information about the delisting process>>

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