Address Your Letter to MDEQ: Points to Consider
To write a letter to MDEQ you may want to be clear on what wetlands do. Next week will be a review of those facts. If you want to address the current proposal, CPA suggests that you concentrate on one or more things.
(Check the blog: March 16th: details the new plan; other listings include quotes from State law, etc. March 17th’s aerial picture shows how narrow the channel is near and around the bend of the river where the plan is proposed. Check the JJR harbor study on the 11.12.06 blog for understanding the density of the marina slips, although this fact does not necessarily factor into the MDEQ decision.)
The following points are things you could address in your letter:
1. Identify the problems.
- Real problems are biological concerns and the concerns of the wetland operation itself. How would a wetland be affected by a marina of 155 slips? If the wetland were reconfigured into the new plan that the City, J&B Landing and 1st Choice Marina propose, the normalcy of the wetland would be changed. Celery Pond would not operate with its current efficiency with excavation and dreding. A wetland filters pollutants. The contained water body of contaminants that Celery Pond naturally dissolves would be an open field. (Remember the environmental reports handed into the MDEQ by the developers were inconclusive; they were done on frozen ground conditions, and more study was recommended on water contaminants. Nothing further was done.) Celery Pond is a a Great Lakes coastal marsh with an ecosystem that is important. It is unique in that it is close to the Lake and important for the migration/breeding of many birds.
- Another problem that has been discussed by officials/developers is the blocked culvert from Dunkley Avenue to the Pond. We won’t speculate on what is blocking it, but it is advertised to create a “death trap.” Fish (carp) migrate into the pond when stormwater flushes into/out of the pond, creating a higher water level which in turn opens up a flowing stream from the Pond to Black River (such as a quick winter melt which we had a week ago). But once the runoff flush recedes, the pond returns to its normal, ie. shallow, state, and the fish meet their death because they cannot get out. With their numbers, the dissolved (DO) of the shallow waters can’t accomodate their needs and they die.
2. Identify solutions.
- Is there a solution to the carp dying? Apparently. A state official wrote, in his report last April, that 2 aluminium poles and wire mesh could alleviate the problem for $20. This information was given the City Manager and developers but, to date, none have taken any action, that we know of, to test to a solution. Head and heart would dictate it, wouldn’t they? You could write about this suggested solution, and make note that nothing has been done. A blocked culvert is no reason to carve out a 60 foot channel for $9+million as the plan suggests. A channel of 60 feet would affect populations of aquatic, bird and plant life way beyond the problem cited, and more life would be killed or dislodged than the carp population that comes into the Pond under flooded conditions. There is a potential solution. Why wasn’t it tested this spring, with that professional clue have been given a year ago?
3. Consider the new mitigation site.
- The first mitigation plan was very poor because it was 5 miles away and landlocked. This new mitigation plan, however, is even further away from the Pond, over 5 miles straight out on Phoenix Road, on the private residence of the Barner farm. While it complies with mitigation 2:1 ratio, there are certain facts to look at. Having seen the site last October with another CPA member, we can verify that land is full of clay. (We had just had lots of rain and water stood around, pooling in puddles that stood on top of the ground. They were not being absorbed quickly. The earth was solid mud, full clay adhesions. We got stuck twice.) There are no apparent natural filtration of waters, such as those of Celery Pond, which takes excess waters automatically into its sandy bottom, near the river and Lake Michigan. This fact could affect life in a proposed mitigated site, again, in a more major way than the carp problem, if waters were not properly adjusted.
- This new mitigation site is advertised to be near a creek within the watershed, and a storm drain nearby, which we saw in our visit. At more than 5 miles inland distance, no fish or wildlife from Celery Pond would likely find it, by narrow creek stream or by storm drain! Mitigation sites are usually required to be near the wetland, and near the source of the river/lake to which it sources from. The natural breathing process of Celery Pond, at one with the Lake and the River and the seasons, the water saturations and the filtrating process that it provides for those waters and its wildlife, would be lost in such a plan. This is not a good plan for mitigation, clear and simple. It would also demand a tremendous budget to try to duplicate the porous land near Celery Pond. The wetland gives us free service of water quality, but with this plan, your tax dollars will once again be raised, undoubtedly, to accomodate yet another man-made plan to reconfigure nature’s balances. The plan could potentially add pollutants to the River and Lake as well.
4. Address the question of what a MDEQ official might have to ask himself in his evaluation: Are there ways that to alter the proposal to minimize impact? Is the any other alternate solution? What would be its feasibility?
- Underline the fact that any impact on the natural processes of a wetland, in the climate of enviromental awareness, is reason enough to say no to a permit application. The MDEQ official at Lake Michigan College told us last week that wetlands are so important to life that he wished that the state law would not even consider issuing permits for a wetland take-over. No private, commercial interest should rank above what is nature’s balance, so needed by us. A marina would impact the wetland, which might cause more problems in the future. Wetlands that were filled in by agriculture one hundred years are needed, and being actively sought to restore by the State, at great time and expense. It is also a proven global fact that the decreasing bird population is related to loss of wetlands. That impact is reason enough to write a letter now.
More facts on what wetlands do, will be on the blog next week, if you want to refer to these things before you address your letter. But you may already have that letter in your mind, so please pass it along to MDEQ. The February public hearing needed more input on the reasons why not to approve a permit. This is your last chance to really state your reasons. We encourage you to write.
Be sure your letter has re: Celery Pond, File # 05-80-0061-P, on it. Direct it to Michelle DeLong, File Manager and Kameron Jordan, District Supervisor, MDEQ-Land and Water Mgt. Division, 7953 Adobe Road, Kalamazoo, MI 49009-5026.
Include a cc: to your ward representative, the whole Council and the City Manager to affect the local level. Celery Pond’s fish and wildlife, and your children, will thank you for thinking of them and their future!