FishPass (at the Union Street Dam)
Request for Public Comment on Union Street Dam/Fish Pass Project
From: Greg Reisig
Sent: Thursday, December 5, 2019 8:35 PM
To: DeFoe, Kristi M CIV USARMY CELRE (USA) <[email protected]>
Subject: File No. LRE 2018-00546-56-S18
I am writing to submit public comments on behalf of the Northern Michigan Environmental Action Council (NMEAC). We represent over 1,000 people in the Grand Traverse region. Our concerns with the FishPass project are related to the urgent need for an Environmental Impact Statement before any permit is issued. The project involves moving large amounts of dredge materials as well as large amounts of fill which will have a major impact on the Boardman River. There is also concern about toxic sediments that have flowed downstream as part of the dams removal project and have collected at the current Union St. Dam. We also have concerns about the hardening of the river shorelines with large amounts of concrete and the removal of about 63 trees.
For these reasons and the need for more local residents to become aware of the extent of the $22 million project we request an extension of the public comment period and also believe the Corps should hold a public hearing in Traverse City on the permit application. EGLE did hold a public hearing last February but did not publish advance notice of the hearing and only three people attended.
Many folks in our region are just now learning about the extent of the project and a public hearing would serve to better inform local residents on the extent of this major project. Local anglers have contacted our group and warned the FishPass project could allow non-native species upstream and greatly impact the native brook trout fishery. We have some information that future plans call for steelhead to be passed upstream to "create a more viable fishery." NMEAC's position is no non-native species should be allowed upstream. Only a few native fisheries remain in the Boardman and this should be protected. The Corps may also want to consult with US Fish & Wildlife about the impact FishPass could have on the remaining native fisheries.
Thank you for accepting this public comment.
Greg Reisig, Co-Chair
Northern Michigan Environmental Action Council, PO Box 1166, Traverse City, MI 49685
Greg Reisig writes:
"We are also asking for a complete Environmental Impact Statement on the project. We are concerned such a large $22 million project may have major impacts on the Boardman River which includes dredging, hardening river shorelines and removing about 63 trees."
Questions regarding the proposed Fish Passage in Traverse City
How well, and how wil, this FishPass work?
Will the engineering design be “patented” or “copyrighted” and available for purchase? Will an individual benefit financially?
Shareholder values apparently are a large consideration, why not city residents and taxpayer values?
Who were these shareholders and whom did they represent?
Who in the city made the decision to buy in to the project and bring it to the City commission?
Did the city accept the proposal or buy into the whole project, funding and all?
Why was the Fish Passage idea not shared with the public before it went to the City Commission and DDA ?
How much is Traverse City contributing to the Fish Passage?
Who pays for maintenance, and who manages and oversees this complicated process?
What about overall assessments of toxic sediments behind the dam, and how will that be cleaned up? Who pays for that?
If the Fish Passage is supposed to be for research who is pushing to have this first experiment here with the Boardman/Ottaway River’s trout fishery?
What about control of lighting and noise?
After the public forums will the stakeholders be able to make changes?
If the Fish Passage does not protect and deliver as projected, what is the city’s recourse?
Invasive problems will affect more than TC. It will become a multiple county problem. Why does the city get to put 287 square miles of watershed at risk?
If it fails outright, who pays for cleanup and reconstruction?
Who will be responsible for any liability issues in the future?
NMEAC Resolution regarding Fish Passage on the
Boardman (Ottaway) River
March 31, 2018
WHEREAS: The decision of any fish species chosen for passage should be decided by citizens of Grand Traverse and Kalkaska counties, not outside agencies.
WHEREAS: Sea Lampreys will likely gain entrance to the Boardman (Ottaway) River via anadromous fish, if lake-run fish gain access to the river, any toxic larvacide, (such as TFM), must not be used to treat the river, as this toxin kills more than just Sea Lampreys.
WHEREAS: If a chosen passage fish is a species currently raised in a hatchery, then passage up the Boardman River is tantamount to aiding and abetting aquaculture.
WHEREAS: Fish passage to allow _new, non-native, predatory fish species to exploit the river ecosystem will be at the expense of established fish and aquatic organisms. The Boardman river will not maintain the present status as a “Blue Ribbon Trout Stream” with the addition of exotic, predatory non-native fish.
WHEREAS: We must not ignore DEQ reports about consuming Grand Traverse Bay Lake Trout because of warnings of hazardous concentrations of PCVBs and chlordane. Lake-run Steelheads (Rainbow Trout) also have PCB concentrations that are more than twice the “No effects” limit.
WHEREAS: The adverse effects of new toxins on mink, otters, and snapping turtles may lead to deformities, reproductive failure, and sterility which could cause cascading effects throughout the land and water ecosystem (the watershed)., and documented studies have previously reported “PCBs in fish below barrier dams continue to pose a hazard to sensitive wildlife.”
WHEREAS: Many proponents of anadromous fish passage have not heeded the warning of the studies done on Kids Creek by Notre Dame University (Janetski et al. 2012) which show unacceptable levels and transport of several powerful toxins in local Brook Trout that they ascribe to the passage of lake-run salmonids and toxic TFM treatments, and these same scientists have shown similar effects below a dam on the Manistee River.
THEREFORE BE IT RESOLVED, the Northern Michigan Environmental Action Council (NMEAC) opposes allowing the passage of any species of anadromous fish above the Union Street dam in Traverse City, and only allowing passage of fish species native to Lake Michigan, Lake Huron, Lake Superior and their watershed basins.
Ann Rogers, Co-chair NMEAC __________________________________
The lower Boardman River from Boardman Lake to Lake Michigan will be the focus of study. As it travels through Traverse City it still has some natural shoreline which The Watershed Center GT Bay, NMEAC and others want to preserve.