[BCNnet] BCN's L.Calumet Marina Letter to USACE

Sun, 9 Jun 2002 16:38:28 EDT

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Dear BCNnet,

As per my last posting, attached below is a copy of the letter I drafted on 
behalf of BCN regarding the proposed L. Calumet marina. Again, BCN members 
are welcome to draw upon it as an information source for their own original 
letters to the US Army Corps of Engineers, but please don't copy it -original 
letters are best. And don't forget, the public commentary period ends June 
14, 2002.

Good Luck!
Walter Marcisz, Chicago, Cook Co.
WJMarcisz@aol.com

June 9, 2002

Mitchell Isoe
Chief, Regulatory Branch
U.S. Army Corps of Engineers
Chicago District
111 N. Canal Street, 6th Floor
Chicago, Illinois 60606-7206

Re: Proposed construction of a 1,000 slip marina in Lake Calumet by the 
Illinois International Port District

Dear Mr. Isoe:

     I am writing on behalf of the Bird Conservation Network of Greater 
Chicago (BCN), a coalition representing sixteen bird clubs and birding 
organizations from the greater Chicagoland area. The BCN advocates for the 
protection, perpetuation, and appreciation of the native bird life of the 
Chicago region, both resident and migratory.
     The Illinois International Port District's proposed construction of a 
1,000 slip marina on Lake Calumet was first considered eligible for a Letter 
of Permission (Application No. 200200427) dated April 17, 2002, under Section 
10 of the Rivers and Harbors Act. After appreciable public opposition was 
encountered, the project is now being considered for a regular individual 
permit.

In regard to the marina proposal, the BCN requests:
1) A complete Environmental Impact Statement
2) A public hearing
3) An extension of the public comment period

WHY AN ENVIRONMENTAL IMPACT STATEMENT?
     An Environmental Assessment regarding the proposed marina, dated 
February 25, 2002, has been prepared by Kudrna & Associates, Ltd. for the 
Illinois International Port District. An environmental assessment is a 
presentation of existing data. As such, the existing assessment is inadequate 
for a project of this magnitude. A complete Environmental Impact Statement 
(EIS) exploring a range of possible options and giving consideration to all 
reasonably foreseeable consequences of the project is now needed. An EIS will 
thoroughly consider economic, environmental, and quality of life issues 
related to the proposed project.
     The potential impact of the proposed marina and its associated boat 
traffic on birds and other wildlife needs to be thoroughly investigated. A 
list of 88 bird species observed at Lake Calumet during 1998-2000 is 
presented in Table 3 of Appendix A in the existing Environmental Assessment 
(Kudrna & Assoc., 2002). The source of this bird list is included at the end 
of the table ("Data from Field Museum of Natural History as provided by Doug 
Stotz for the Calumet Area Ecological Management Strategy: Phase I Study Area 
Sites."). I personally spoke with Doug Stotz on June 8, 2002 in regard to the 
bird data presented in Table 3. Three very relevant points emerged during our 
conversation: 1) Stotz was completely unaware that his data was being used in 
this context; 2) Stotz stated that he would characterize the bird list used 
by Kudrna & Associates in Table 3 as "extremely incomplete"; and 3) Stotz 
stated "in order to obtain bird data representative of this site, an 
Environmental Impact Statement must be completed."
     In our conversation, Doug Stotz went on to say that his Lake Calumet 
bird data is largely incomplete because of severely limited access to Lake 
Calumet. A major portion of Stotz's Lake Calumet bird observations were 
obtained "by peering through the razor-wire fences erected around Lake 
Calumet by the Illinois International Port District." A far more thorough and 
contemporary study of bird life in the proposed marina site is clearly 
needed. Even given the limited nature of the bird data presented in Table 3, 
the bird list presented includes three Illinois Endangered Species 
(Black-crowned Night-Heron, Forster's Tern, and Osprey) and one Illinois 
Threatened Species (Sandhill Crane). Illinois' first confirmed Reddish Egret 
was found at Lake Calumet's middle turning basin adjacent to the proposed 
marina site in 1993 (Friscia, "Meadowlark: A Journal of Illinois Birds," 3: 
45-46) prior to the erection of the razor-wire fence around the lake.
    Even given the incomplete nature of the bird data presented in the 
existing Environmental Assessment (Kudrna & Assoc., 2002), statements made in 
that document underscores the great significance Lake Calumet has as bird 
habitat. The following statements are quoted from page 10 of the Assessment's 
introduction:

"The predominant fauna using Lake Calumet are birds, which also may serve as 
a main attraction for the many bird watchers that frequent the area. 
Waterfowl and wading birds make up the most visible component of the Lake 
Calumet fauna. The lake experiences heavy use by migratory waterfowl, wading 
birds, and shorebirds. It provides a significant area of habitat in a part of 
the Chicago Metropolitan region that is heavily urbanized. The open water of 
Lake Calumet provides an attractive resting and feeding area for a variety of 
waterbirds (e.g., Pied-billed Grebe, Canvasback, Pintail, Mallard, Canada 
Goose, Black-crowned Night-Heron, Great Blue Heron, Great Egret, Common 
Moorhen, Least Bittern, Common and Hooded Mergansers.)"

     Note that of the bird species listed in the compilation above, three are 
Illinois Threatened Species (Pied-billed Grebe, Common Moorhen, and Least 
Bittern), and one is an Illinois Endangered Species (Black-crowned 
Night-Heron).

     Potential river traffic impacts also need to be addressed by an EIS. 
Given the potential effect that the proposed marina will have on river 
traffic, I offer the following quotes:

Quoted from a May 10, 2002 letter addressed to the IDNR from Todd Hudson, 
President, Illinois River Carriers Association-
"...When you couple the commercial congestion with the bridges and bends, the 
current recreational boating traffic is an accident waiting to 
happen...Unless there is massive effort to educate the recreational boating 
community, the establishment of no wake zones, speed limits and a full time 
law enforcement presence along the Calumet River, coupled with continued 
efforts from our industry, we are not looking forward to the future accidents 
that will take place in this busy waterway."

Quoted from a May 9, 2002 letter addressed to Brent Manning, Director, Office 
of Water Resources, IDNR, from R. E. Seebald, Captain, U.S. Coast Guard-
"I have concerns with the increased number of recreational craft the marina 
would introduce into an already congested commercial port area. Also, 
security issues that could arise with gasoline offloading that has taken 
place at several locations along the Calumet River would involve a enforced 
security zone which would restrict traffic."

Quoted from a May 9, 2002 letter addressed to James Casey. Office of Water 
resources, IDNR, from Douglas Chien and Christine Williamson, Illinois 
Chapter Sierra Club representatives-
"The construction of a marina will impact the lake bottom, potentially 
disturbing and redistributing contaminated sediment into the water column and 
surface area of the lake, as power boats disrupt the entire lake. The wave 
action created by power boats will also create a significant potential for 
shoreline erosion."

Quoted from a May 7, 2002 letter addressed to Brent Manning, Director, Office 
of Water Resources, IDNR, from John H. Nikolai, Principal Consultant, Nikolai 
& Associates, Ltd.-
"Marina activity will interfere with regular commercial and industrial 
waterborne traffic on the Calumet River to the detriment of industry that is 
the lifeblood of the City of Chicago."

     Added expressway traffic in an area already congested by truck traffic 
would also appear to be a potential consequence of the proposed marina. In 
summary, a complete Environmental Impact Statement is needed to determine all 
of the potential impacts of the proposed 1,000 slip marina.

WHY A PUBLIC HEARING?
     A Public Hearing is necessary because of the widespread level of public 
concern and the presence of Endangered/Threatened Species in the Lake Calumet 
Area.

WHY AN EXTENSION OF COMMENT PERIOD?
     Although the permit notice was posted May 24, 2002, most concerned 
citizens did not see it until Friday, May 31, 2002. Based on previous 
agreements, the environmental community expected direct communication from 
the USACE on this important topic.

Thank you for the opportunity to comment on this project proposal.

Sincerely,
Walter J. Marcisz
Bird Conservation Network of Greater Chicago    

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<HTML>Dear BCNnet,
 
 As per my last posting, attached below is a copy of the letter I drafted on behalf of BCN regarding the proposed L. Calumet marina. Again, BCN members are welcome to draw upon it as an information source for their own original letters to the US Army Corps of Engineers, but please don't copy it -original letters are best. And don't forget, the public commentary period ends June 14, 2002.
 
 Good Luck!
 Walter Marcisz, Chicago, Cook Co.
 WJMarcisz@aol.com
 
 
 
 June 9, 2002
 
 Mitchell Isoe
 Chief, Regulatory Branch
 U.S. Army Corps of Engineers
 Chicago District
 111 N. Canal Street, 6th Floor
 Chicago, Illinois 60606-7206
 
 Re: Proposed construction of a 1,000 slip marina in Lake Calumet by the Illinois International Port District
 
 Dear Mr. Isoe:
 
 &nbsp;&nbsp;&nbsp;&nbsp;I am writing on behalf of the Bird Conservation Network of Greater Chicago (BCN), a coalition representing sixteen bird clubs and birding organizations from the greater Chicagoland area. The BCN advocates for the protection, perpetuation, and appreciation of the native bird life of the Chicago region, both resident and migratory.
 &nbsp;&nbsp;&nbsp;&nbsp;The Illinois International Port District's proposed construction of a 1,000 slip marina on Lake Calumet was first considered eligible for a Letter of Permission (Application No. 200200427) dated April 17, 2002, under Section 10 of the Rivers and Harbors Act. After appreciable public opposition was encountered, the project is now being considered for a regular individual permit.
 
 In regard to the marina proposal, the BCN requests:
 1) A complete Environmental Impact Statement
 2) A public hearing
 3) An extension of the public comment period
 
 WHY AN ENVIRONMENTAL IMPACT STATEMENT?
 &nbsp;&nbsp;&nbsp;&nbsp;An Environmental Assessment regarding the proposed marina, dated February 25, 2002, has been prepared by Kudrna &amp; Associates, Ltd. for the Illinois International Port District. An environmental assessment is a presentation of existing data. As such, the existing assessment is inadequate for a project of this magnitude. A complete Environmental Impact Statement (EIS) exploring a range of possible options and giving consideration to all reasonably foreseeable consequences of the project is now needed. An EIS will thoroughly consider economic, environmental, and quality of life issues related to the proposed project.
 &nbsp;&nbsp;&nbsp;&nbsp;The potential impact of the proposed marina and its associated boat traffic on birds and other wildlife needs to be thoroughly investigated. A list of 88 bird species observed at Lake Calumet during 1998-2000 is presented in Table 3 of Appendix A in the existing Environmental Assessment (Kudrna &amp; Assoc., 2002). The source of this bird list is included at the end of the table ("Data from Field Museum of Natural History as provided by Doug Stotz for the Calumet Area Ecological Management Strategy: Phase I Study Area Sites."). I personally spoke with Doug Stotz on June 8, 2002 in regard to the bird data presented in Table 3. Three very relevant points emerged during our conversation: 1) Stotz was completely unaware that his data was being used in this context; 2) Stotz stated that he would characterize the bird list used by Kudrna &amp; Associates in Table 3 as "extremely incomplete"; and 3) Stotz stated "in order to obtain bird data representative of this site, an Environmental Impact Statement must be completed."
 &nbsp;&nbsp;&nbsp;&nbsp;In our conversation, Doug Stotz went on to say that his Lake Calumet bird data is largely incomplete because of severely limited access to Lake Calumet. A major portion of Stotz's Lake Calumet bird observations were obtained "by peering through the razor-wire fences erected around Lake Calumet by the Illinois International Port District." A far more thorough and contemporary study of bird life in the proposed marina site is clearly needed. Even given the limited nature of the bird data presented in Table 3, the bird list presented includes three Illinois Endangered Species (Black-crowned Night-Heron, Forster's Tern, and Osprey) and one Illinois Threatened Species (Sandhill Crane). Illinois' first confirmed Reddish Egret was found at Lake Calumet's middle turning basin adjacent to the proposed marina site in 1993 (Friscia, "Meadowlark: A Journal of Illinois Birds," 3: 45-46) prior to the erection of the razor-wire fence around the lake.
 &nbsp;&nbsp;&nbsp;Even given the incomplete nature of the bird data presented in the existing Environmental Assessment (Kudrna &amp; Assoc., 2002), statements made in that document underscores the great significance Lake Calumet has as bird habitat. The following statements are quoted from page 10 of the Assessment's introduction:
 
 "The predominant fauna using Lake Calumet are birds, which also may serve as a main attraction for the many bird watchers that frequent the area. Waterfowl and wading birds make up the most visible component of the Lake Calumet fauna. The lake experiences heavy use by migratory waterfowl, wading birds, and shorebirds. It provides a significant area of habitat in a part of the Chicago Metropolitan region that is heavily urbanized. The open water of Lake Calumet provides an attractive resting and feeding area for a variety of waterbirds (e.g., Pied-billed Grebe, Canvasback, Pintail, Mallard, Canada Goose, Black-crowned Night-Heron, Great Blue Heron, Great Egret, Common Moorhen, Least Bittern, Common and Hooded Mergansers.)"
 
 &nbsp;&nbsp;&nbsp;&nbsp;Note that of the bird species listed in the compilation above, three are Illinois Threatened Species (Pied-billed Grebe, Common Moorhen, and Least Bittern), and one is an Illinois Endangered Species (Black-crowned Night-Heron).
 
 &nbsp;&nbsp;&nbsp;&nbsp;Potential river traffic impacts also need to be addressed by an EIS. Given the potential effect that the proposed marina will have on river traffic, I offer the following quotes:
 
 Quoted from a May 10, 2002 letter addressed to the IDNR from Todd Hudson, President, Illinois River Carriers Association-
 "...When you couple the commercial congestion with the bridges and bends, the current recreational boating traffic is an accident waiting to happen...Unless there is massive effort to educate the recreational boating community, the establishment of no wake zones, speed limits and a full time law enforcement presence along the Calumet River, coupled with continued efforts from our industry, we are not looking forward to the future accidents that will take place in this busy waterway."
 
 Quoted from a May 9, 2002 letter addressed to Brent Manning, Director, Office of Water Resources, IDNR, from R. E. Seebald, Captain, U.S. Coast Guard-
 "I have concerns with the increased number of recreational craft the marina would introduce into an already congested commercial port area. Also, security issues that could arise with gasoline offloading that has taken place at several locations along the Calumet River would involve a enforced security zone which would restrict traffic."
 
 Quoted from a May 9, 2002 letter addressed to James Casey. Office of Water resources, IDNR, from Douglas Chien and Christine Williamson, Illinois Chapter Sierra Club representatives-
 "The construction of a marina will impact the lake bottom, potentially disturbing and redistributing contaminated sediment into the water column and surface area of the lake, as power boats disrupt the entire lake. The wave action created by power boats will also create a significant potential for shoreline erosion."
 
 Quoted from a May 7, 2002 letter addressed to Brent Manning, Director, Office of Water Resources, IDNR, from John H. Nikolai, Principal Consultant, Nikolai &amp; Associates, Ltd.-
 "Marina activity will interfere with regular commercial and industrial waterborne traffic on the Calumet River to the detriment of industry that is the lifeblood of the City of Chicago."
 
 &nbsp;&nbsp;&nbsp;&nbsp;Added expressway traffic in an area already congested by truck traffic would also appear to be a potential consequence of the proposed marina. In summary, a complete Environmental Impact Statement is needed to determine all of the potential impacts of the proposed 1,000 slip marina.
 
 WHY A PUBLIC HEARING?
 &nbsp;&nbsp;&nbsp;&nbsp;A Public Hearing is necessary because of the widespread level of public concern and the presence of Endangered/Threatened Species in the Lake Calumet Area.
 
 WHY AN EXTENSION OF COMMENT PERIOD?
 &nbsp;&nbsp;&nbsp;&nbsp;Although the permit notice was posted May 24, 2002, most concerned citizens did not see it until Friday, May 31, 2002. Based on previous agreements, the environmental community expected direct communication from the USACE on this important topic.
 
 Thank you for the opportunity to comment on this project proposal.
 
 Sincerely,
 Walter J. Marcisz
 Bird Conservation Network of Greater Chicago &nbsp;&nbsp;&nbsp;
 &nbsp;&nbsp;&nbsp;&nbsp;
 
 &nbsp;&nbsp;&nbsp;&nbsp;</HTML>

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