May, 2002
Vol. 6, No. 3

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Table of Contents

Fox River To Be Pollution Guinea Pig

Why We Oppose It
Back to Basics
Write Your Elected Representatives Today
Write or E-mail EPA
Please Wash Your Boat!
Toxic Waste Increased 25% In 2000
Update on River and Bay Cleanup
Three Decisions are Pending
Our Concerns
Paper-making Process Reduces Pollution
CWAC Honors Two Leaders
Christine Fossen Rades
David Allen
Kristin Blankenheim: Our New Intern
Concert Thanks!
DNR Proposes to Downgrade River and Stream Protection

For more information about PCBs visit www.FoxRiverWatch.com


Fox River To Be Pollution Guinea Pig

The Bush Administration’s EPA is proposing a new scheme to trade “water quality credits” among pollution sources, with the claim that it will “increase the speed and success of cleaning up polluted rivers, lakes and streams.” 

The Fox/Wolf River Drainage Basin is one of just a few test sites in the country for the proposal.

Under the scheme, individuals and businesses would get “credits” by reducing their pollution to below federal requirements. These credits could then be sold to companies which want to pollute more than they otherwise could. 

For example, a farmer could improve his cropping practices to reduce runoff or plant grassy buffer strips along a streambank, and then sell his pollution reduction credits to Appleton Paper Company, allowing that company to increase pollution discharges.

Under the proposal, industrial and municipal facilities would have to meet minimum technology control requirements before using the credits. 

 The Bush Administration’s EPA claims the program will supposedly create incentives for voluntary reductions of water pollution, but we have serious doubts.

Why We Oppose It 

1. How will the pollution credits be measured? --- It’s very difficult and costly to monitor and quantify the effectiveness of land-based run-off controls over a wide variety of landscapes, and compare them to direct, continuous point-source pipe discharges.  Weather variability is a major confounding factor.  Runoff pollution is often seasonal.

2. Are pollution reductions real, or is this really backsliding? --- 
If industrial or municipal pipe discharges are allowed to increase their discharges and the land runoff reductions are nebulous, couldn’t this rule actually result in INCREASES in pollution?  We worry that all the efforts to improve non-point pollution control will be counteracted by increased industry discharges on the Fox River.  For instance, we worry that the non-point controls proposed in the Fox River compensation plan would simply increase the “assimilative capacity” for industry wasteload allocations on the Fox River, getting us zero net benefit, or worse.

3. Concentrating pollution --- While run-off controls may improve water quality upstream, the pollution credits may be used a long distance away downstream resulting in a localized worsening of pollution.  Pollution concentrations could cause “hotspots” downstream.

4. Apples and Oranges --- Soil erosion pollutants are often not comparable to industry pipe discharges, except for a few common measures such as “total solids,” pH, BOD, etc.   But industry solids may be chemically VERY different from a farmer’s solids, with toxic properties not fully understood or monitored.      Many industries discharge chemicals “under the radar,” where the quantities are low enough to escape regulation or the chemical is uncommon and unknown enough that regulations have yet to be developed.    An example would be municipal wastewater plants and their human drug residue discharges.  Or the newly recognized chemical of concern: PBDE fire retardants that are largely unregulated and yet used in huge quantities. PBDE appears to have persistent toxic properties like PCBs and are rapidly building up in Lake Michigan fish.

5. Rewarding slow actors --- Many farmers and municipalities have already installed run-off controls at their own expense.  Will credits be given only to new controls by those who have dragged their feet and allowed pollution from their properties continuously up to now?  This is rewarding bad behavior.

6. Unequal treatment across the region --- All investors in run-off controls in a watershed should be treated equally and fairly, but only a few may get paid for doing run-off controls.  The program may actually create a disincentive for those who may wait until they can find a paying credit trading partner before installing pollution controls.

7. Undercutting other programs --- Local, state and federal programs already exist to encourage or require farmers and others to install run-off controls.  This trading program will undercut or confuse the situation.

8. Pollution is not a property right --- Pollution should not be the property right of those who can afford to pay to do it.   Our rivers and lakes are PUBLIC property and no one should have the right to degrade their water quality.   Under the Public Trust Doctrine, pollution is supposed to be illegal and public rights in our natural resources are supposed to be protected by our governments.

9. All sources should reduce --- Instead of TRADING pollution to maintain all our waterways at a degraded but  supposedly tolerable pollution level, the EPA should fulfill their promises to reduce ALL pollution sources to restore our nations waterways to “swimmable, fishable, drinkable” waters.

Back to Basics

A more reliable and less complex way to improve the nation’s water quality would be to fully enforce existing Clean Water Act regulations, update clean water criteria, and restrict more types of pollution.

The EPA’s proposal will be open to public comment for 45 days, with the final policy being released later this summer. For more information, visit the EPA’s online website on this topic at: http://www.epa.gov/owow/watershed/trading.htm

Write Your Elected Representatives Today

Please write your federal elected officials and let them know what you think of the EPA’s proposed Water Quality Trading Policy.

Senator Russ Feingold 
U.S. Senate 
Washington, D.C.   20510 

Congressman Thomas Petri
House of Representatives
Washington, D.C.  20515

Senator Herb Kohl 
U.S. Senate 
Washington, D.C.   20510 

President George W. Bush
1600 Pennsylvania Avenue
Washington, DC 20500

Congressman Mark Green 
House of Representatives 
Washington, D.C.  20515 

Write or E-mail EPA

Mail your comments to EPA:  (send original letter and 3 copies)
  W-02-07 Comment Clerk, Water Docket (MC4101), EPA
  1200 Pennsylvania Avenue, NW 
  Washington, DC 20460   Comment deadline: July 1

 E-mail EPA: ow-docket@epamail.epa.gov

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Please Wash Your Boat!

The DNR reports that careless boaters carried two exotic pests into 26 more Wisconsin lakes last year.  Zebra mussels are now found in 32 inland lakes, and Eurasian water milfoil (an aquatic plant) is choking 351 lakes.  These creatures can 
devastate the natural ecology of Wisconsin waterways.

DNR recommends that boaters pump water from bilges, drain water from engines and built-in water storage basins known as live wells, dump water from bait buckets - but not the bait - and clean boat hulls and trailers before leaving launch ramps.  Mussel larvae float in the water, they’re not just attached to the hull; and Eurasian water milfoil can reproduce from a single  segment of stem and leaves. 

It is now illegal to launch a boat or boat trailer in any of the state’s navigable waters if an aquatic plant or a zebra mussel is attached to it.  Violators could pay $50 for a first offense and $100 for a second offense.

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Toxic Waste Increased 25% In 2000

Many people assume we’re making major progress in the fight against pollution. 
Government agencies like to tout their successes (not their failures) and industries chronically downplay their pollution, so the net public news impression is falsely reassuring.

The truth is that toxic waste generated by U.S. industry jumped more than 25 percent in 2000, according to data released by the U.S. EPA as part of the federal Toxics Release Inventory established by Congress in 1986 as the nation’s community right-to-know program.  It shows about 38 billion pounds of toxic waste managed in 2000, with another 7.1 billion pounds released directly to the air, land and water. 

Analysis by the U.S. Public Interest Research Group (PIRG), a non-profit  organization, showed that current Bush Administration proposals to weaken environmental protections would hinder progress toward reducing this toxic pollution and in some cases would worsen the pollution. They argued that billions of pounds of toxic chemicals released show problems with the current laws that make it nearly impossible to remove harmful chemicals from the market.

“The billions of pounds of toxic pollution and toxic waste should show our decision-makers why we need a law that phases out the use of the most toxic chemicals,” said Jeremiah Baumann, environmental health advocate for U.S. PIRG. “But instead, we have the Bush administration letting the very companies that dump these chemicals into our environment rewrite our environmental and public health protections.”

In addition, thousands of facilities were required for the first time in 2000 to report their releases of persistent toxic chemicals like dioxin and mercury, which persist in ecosystems and accumulate in the human body, dramatically increasing the chances of exposure and detrimental health effects. Companies reported releasing 12 million pounds of these persistent chemicals in 2000 and generated nearly 72 million pounds of waste containing these chemicals.

 “For chemicals like dioxin and mercury, this toxic pollution is almost guaranteed exposure,” said Baumann. “These millions of pounds of toxic pollution also demonstrate a major failing in current law.  Chemicals go into use with little testing and regulators have almost no ability to get them off the market.” The Toxic Substances Control Act doesn’t mandate pre-market testing for toxic chemicals and makes it very difficult for EPA to phase out or ban a chemical.

A recently-signed international treaty would create a science-based process for establishing protections from persistent toxic chemicals. However, the Bush administration is proposing to implement the treaty in a way that would address only a handful of the chemicals without establishing a means of addressing the remaining persistent toxics. 

The 2000 data represent the first year that industries have been required to report pollution and wastes containing dioxin. Dioxin is a notorious chemical created in industrial processes that burn or use chlorine or chlorinated materials (such as PVC plastics), and is a highly potent cancer agent also linked to damage to the reproductive, immune, and nervous systems.  The chemical is not only toxic, but persists in the environment and accumulates in the body to such a degree that the World Health Organization estimates a “safe” daily intake of the most toxic form of dioxin to be only 1-4 trillionths of a gram per kilogram of body weight. Polluters reported 495 thousand grams of dioxin released to the environment or generated in toxic waste, with about 100 thousand grams released directly to air, land, and water. The Bush administration has stalled on issuing a long-awaited final assessment of dioxin’s health threats, the release of which would trigger first steps toward developing new protections against dioxin.

Mercury pollution is also particularly striking in the new pollution data: industries released 4.3 million pounds of mercury and mercury compounds to the environment and generated 4.9 million pounds of mercury compounds in toxic waste. By comparison, a teaspoon of mercury deposited every year can contaminate a 20-acre lake to the point that fish are unsafe to eat. A 2001 report by U.S. PIRG and the Environmental Working Group found that fish contamination is already so high that eating fish exposes 1 in 4 pregnant women to levels of mercury that could threaten a developing fetus. The Bush administration’s “Clear Skies Initiative” would allow three times more mercury pollution than full enforcement of the current Clean Air Act.

The new toxic pollution data amplify concerns about toxic waste sites in communities, because many of the chemicals released to the environment in such large quantities are already problems at toxic waste sites. The Bush administration has taken a position against reinstating the “polluter pays” tax, which taxes polluters to fund toxic waste clean-ups. Instead, the administration is asking taxpayers to pay for clean-ups and allowing the number of toxic waste sites cleaned up every year to slow dramatically.

Metal mining and utilities were identified as the nation’s biggest polluters, with 3.4 billion pounds of toxic chemicals released by mines, nearly half of total chemical releases, and 1.2 billion pounds released by the utilities. The Bush administration has proposed weakening Clean Air Act requirements that aging utilities add modern pollution controls when they update their plants, which could result in pollution increases at electric utilities. The administration has also proposed relaxing clean water rules to legalize the dumping of mining waste in rivers and streams. 

“It’s particularly disappointing that the Bush Administration would allow the worst polluters to pollute more,” said Baumann.

The Toxics Release Inventory reflects only a fraction of the toxic hazards in the environment. The program does not include releases from significant pollution sources like oil wells, airports, and waste incinerators, nor does it include significant sources of exposure to chemicals, such as chemicals placed in products. In addition, the TRI represents only a fraction of the chemicals on the market. While there are approximately 80,000 chemicals on the market, according to EPA and American Chemistry Council studies, gaps in toxics laws mean that at least some of the data needed to perform a basic screen for health and environmental effects were not publicly available for more than 90% of the chemicals.

U.S. PIRG called on policymakers to reject proposed Bush administration rollbacks of environmental laws in favor of better protections, including expanding the right-to-know program to include full information on toxic chemical hazards and requiring manufacturers to stop using chemicals that pose a clear hazard.

For more info., contact: U.S. PIRG  218 D St., SE  Washington, D.C. 20003  Phone: 202-546-9707  E-mail: uspirg@pirg.org

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Update on River and Bay Cleanup

The last few months have been quiet on the Fox River PCB cleanup issue, but we’ve heard that activities are fever-pitched in closed-door meetings between the seven paper companies, the EPA, U.S. Fish and Wildlife Service, the Michigan Attorney General’s Office, the Tribes, and DNR (all referred to as “Trustees.”) 

Three Decisions are Pending

1. G-P Settlement ---An announcement is expected soon (June?) on a final settlement with Georgia-Pacific (formerly Fort James) for their portion of the Compensation and Restoration Plan (separate from the sediment cleanup.)  Negotiations are also underway with all the other companies.  It is unknown whether a hearing or comment period will occur.

2. Final Restoration Plan --- Later this summer (August?), a final comprehensive Restoration Plan and Environmental Assessment will be released by the government trustees mentioned above.   This will be the sum of all the companies’ responsibilities (separate from the sediment cleanup.)  A public comment period will be held, and possibly a public hearing.

3. Sediment Cleanup Plan --- Later this summer (July?) or fall, the DNR and EPA will release the final Record of Decision (ROD) on the sediment cleanup plan.  EPA staff couldn’t say whether public meetings would be held or not.

Our Concerns

 While we’re anxious to get these issues resolved in time for cleanup and restoration to start in the spring of 2003, we have a number of worries about the upcoming announcements.   We all need to keep a close watch and  be ready to ask about several issues:
 

1. Settlements in the Dark --- How can citizens evaluate the fairness of a closed-door settlement with Georgia-Pacific, without knowing what the final Restoration Plan says?  We’re opposed to this premature piece-meal approach.  We’ve heard that this settlement could include many of the same elements the public protested strenuously in the DNR’s $7 million deal proposed a year ago (which has lain dormant since.)  The percentage of responsibility allocated to G-P could tell us more about the overall size of the total Restoration Plan, but this information may be missing.

2. Are the Feds Weakening? ---Apparently, the DNR is now on a better working relationship with the other government agencies, even the U.S. Fish & Wildlife Service.  Does this mean that DNR has finally accepted the need to do a good Restoration and Compensation Plan (which they opposed for years), or does it mean that the Bush Administration is seriously weakening the federal plan we all commented on a year ago?   Though many of us thought the federal plan needed to be stronger, it was light-years ahead of DNR’s proposals.  Now, we may have lost the federal leadership we’ve depended on.

3. Changing Rules and Hiding Weaknesses? --- We’re also being told now that the Restoration Plan is being reworked to be based on “habitat restoration goals,” not dollar values.  We been told that settlements may result in companies being given a workplan, with no dollar values attached.   This means citizens may not be able to judge whether the federal restoration plan has been weakened and whether we’re getting fair compensation for damages.  (We were told to expect compensation  of $177 to $333 million total.)  The result could be radically different and much weaker than the federal plan we commented on a year ago.

4. The Cart Before the Horse --Under the Clinton Administration, we were promised many times that the Restoration Plan couldn’t be finalized until after the sediment cleanup plan and Record of Decision were done.  This timing sequence was important because the scale of the restoration is supposed to be based on how long it takes for the sediment cleanup to achieve results.   If it takes longer, then more compensation is due from the polluters and the dollar amount should increase. Now, under the Bush Admin., we’re being told that it’s OK for the Restoration Plan to be released before the ROD, keeping the public in the dark on this issue.

5. Serving the Polluters --- Last year, the Bush Administration and DNR approved a surprise $40 million deal with Appleton Paper Company and NCR Corporation for a partial/interim settlement, with half to be applied to their compensation and restoration responsibilities, and half to start sediment cleanup activities. 
A few weeks ago, the DNR Secretary, Darryl Bazzell, told the Fox Cities Chamber of Commerce (in a meeting where the news media were barred from attending) that a chunk of this money would be used to explore Appleton Paper Company’s proposal to cap PCBs and leave them in the river.  This is not what the public was told the money would be used for. 
This is similar to previous rotten state deals with the paper industry, where industry supposedly “donates” money to “help the public” when the money is really being used to reinforce the industry’s self-interested lobbying arguments.)

6. Stopping the Federal Process --- The U.S. Fish and Wildlife Service (under the Bush Administration) now tells us that they plan no “Report of Assessment,” though this is supposed to be the final stage of the Natural Resources Damage Assessment process.    This final report would have included a “responsiveness summary” (the trustees’ written responses to citizens’ hearing and written testimony).  This report would also have included a “preliminary estimate of damages” with more complete totals than previously reported, and a “demand for sum certain” (a final bill to be presented to the responsible polluters.)  We were told that as long as the governments were satisfied with the negotiated settlements, the Report of Assessment could be skipped, because the polluters don’t want to have to pay for its preparation.    The Service says they will write the report only if a polluter sues to oppose their portion of the Restoration Plan. 
Citizens will be asked to comment on the final proposed Restoration Plan without the benefit of this information, and we may never have a final accounting.

7. Taypayer Costs Should Be Fully Reimbursed --- It’s been expensive for the government to prepare the multi-document scientific damage assessments and economic damage models.  At the end of the 8 year process, we were supposed to learn what the total costs were, but that may not happen now.  We do know that at a similar case in Montrose, California, the U.S. Fish & Wildlife Service assessment research process cost $35 million, which chewed up a huge percentage of the final settlement.  Here on the Fox River and Green Bay, we must insist that these costs are separate, and in addition to, the compensation and restoration settlement from the polluters.  The state’s costs should also be reimbursed completely.  (After all, why should taxpayers be stuck with this?)

8.  Contradicting Legal Determinations? ---  Luckily, the final proposed Restoration and Compensation Determination Plan, which was subjected to numerous public hearings and meetings in the fall of 2000 under the Clinton Administration, has already been completed.  Formal legal determinations of damages were already made then.  If the Bush Administration 
deviates substantially from the dollar values or from the types of restoration projects identified in those documents, we should be able to call attention to these changes.  If accurate dollar values are provided. 

9. Industry Pressure Politics --- We’ve heard may instances of Fox River Group and Appleton Paper Company lawyers and lobbyists meeting with our local, state and federal agency officials and our elected representatives, keeping up constant lobbying pressure for weakening the cleanup and compensation plans. In particular, Appleton Paper Co. has been pushing HARD for their capping proposal, trying to corner the agencies into significantly changing the cleanup plan we all commented on. 

10. Local Professors Not Helping --- Appleton Paper Company was especially devious when they hired key University of Wisconsin professors to push the company’s highly questionable claims.  So our taxpayer supported Universities are being used to subsidize industry arguments.  At the same time, other UW professors tell us they can’t get involved and express their scientific opinions publicly, or it would damage their scientific objectivity and credibility.  (They’ve been making this argument for years.) 
So it’s considered respectable for them to sell their opinions to industry or whoever else can afford to pay them, but it’s not respectable for them to donate their opinions in the public interest.  They need to rethink their arguments and priorities.

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Paper-making Process Reduces Pollution

While we call for the cleanup of contaminated sediments in our rivers and lakes, we also need to stop NEW inputs of pollution.  Several technologies have been proposed for years and shown to work in pilot or full-scale plants, but the paper industry has refused to make the initial capital investment to switch to the new processes, even when they payoff in the long-term economically and environmentally.  The following is a good example:

Scientists with the USDA Forest Products Laboratory in Madison, Wisconsin recently gave a briefing in Washington DC concerning an improved paper bleaching process they’ve developed in a collaborative effort with Emory University, the University of Wisconsin-Madison, and Helsinki University of Technology. 

Their news release states:

“Every year, paper mills release numerous toxins into the world’s rivers and air.  Consequently, the paper mill industry and researchers are keenly interested in finding ways to reduce this ecological hazard.  A promising technology, based on polyoxometalates research, produces paper without chlorine—one of the worst polluting offenders in the bleaching process of paper.  This technology incorporates the use of transition  metal substituted polyoxometalates cluster ions for bleaching pulp.  The goal of the polyoxometalates research is to develop a highly selective, effluent-free, closed mill bleaching process that also produces high quality paper.”

One of the principal researchers has been Dr. Rajai H. Atalla, a Senior Scientist at the USDA Forest Service, Forest Products Laboratory, Madison, Wisconsin.  Before joining the Laboratory full time, Dr. Atalla worked as a Professor of Chemical Engineering at the University of Wisconsin, Madison, and a Professor of Chemistry at the Institute of Paper Science and Technology in Atlanta.  Dr. Atalla has written three papers on the subject of Polyoxometalates. 

For more information, contact Benjamin Needham, (202) 273-4739 or benneedham@fs.fed.us

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CWAC Honors Two Leaders

At our Annual Banquet this year, we honored two individuals who have provided outstanding environmental leadership in our community:

Christine Fossen Rades

We gave our “2002 Environmental Volunteer of the Year” award to Christine Fossen Rades, in recognition of her many years of outstanding efforts to encourage youth activities on environmental and conservation issues.

Christine fostered the development of the East DePere Highschool Ecology Club seven years ago, which now has 120 active student members who plan field trips, conservation efforts, displays, demonstrations, testimony at important hearings, and educational events such as the annual Eco-Jam, a musical, informational and environmental event which draws many organizations and participants from throughout the region.  All of the proceeds from past and current Eco-Jams have gone to non-profit organizations. One year’s proceeds came to help Clean Water Action Council, another purchased 120 acres of climax rainforest in Belize, and this year, they assisted the Multi-Cultural Center of Green Bay with the theme “Embracing a Diverse Planet” (focusing on both biological and cultural diversity.) 

The Ecology Club motto, developed by the kids, is  “to educate mind, body, and spirit, to ensure a healthy environment for ourselves and our planet.”  Key issues have included water quality concerns, Fox River cleanup, wildlife habitat, and cyanide use in mining. 

This past year, the club sponsored an educational forum at school on the Fox River PCB clean up plan, which was open to the public.  In attendance were representatives from the EPA, DNR, U.S. Fish and Wildlife Service, and the Oneida Tribe.  It was very successful and produced local news headlines which read  “Ecology Club Grills DNR on Fox River Clean Up.” 

Other activities:  they practice bio-remediation by raising beetles that eat the noxious and invasive plant, purple loosestrife; they adopt elementary kids and take them to the Izaak Walton League property to study environmental ethics; they canoe and pick-up garbage on the east river and local parks; they go to Belize, in Central America, for 2 weeks and study the rainforest and marine biology complete with scuba diving; they sponsor speakers for the entire school (such as the most recent, from the Wind River Bird Rehabilitation and Release Center); they collect food for the local pantries; and they try to keep their school as ECO-friendly as possible.

Christine also helps students in the Northeast Wisconsin Student Environmental Network, which is a coalition of highschool and college environmental clubs.  Her dedication, enthusiasm, energy, and organizing skills are unusual and greatly appreciated.  Her important work with young people ensures that future generations will continue with a strong environmental ethic.

Last year, we were very pleased when Christine became an active member of the Board of Directors of Clean Water Action Council. 

Background: Christine started teaching highschool science classes at East DePere Highschool 10 years ago, when she was only 21 years old.  She received her Bachelor’s Degree from Lawrence University in Appleton, majoring in marine biology with an emphasis in environmental studies, and a secondary teaching degree.  When it comes to hobbies, Christine says, “I cannot wait for spring to start working on my garden, both veggie, and floral. Likewise, I love to fish, especially for brook trout because they hang out in the most pristine and beautiful places in the state (and my new husband knows how to get there!!)  I love to camp, and be outside, bike, and listen to music, especially blue-grass, folk, and funk!  Oh, yeah, and I like to travel to small, underdeveloped countries, because there’s no high rise hotels, only grass thatched huts separating you from the ocean!!  (You know what I mean?!?)”

David Allen

We gave our “2002 Outstanding Public Servant” award to David Allen, who worked for more than 7 years as Assessment Manager in the Environmental Contaminants Division of the U.S. Fish & Wildlife Service, working on the Fox River Natural Resource Damage Assessment.     David was a special government employee, able to bridge the gaps between government and citizens with good communication and outreach efforts.  For years, he faced enormous resistance and criticism from the Governor’s Office and state DNR staff, because he persisted in pursuing compensation and restoration efforts (as required by law) on behalf of the public’s interest in natural resources of the river and bay. 
And though we didn’t always agree with his agency’s decisions, we trusted David was doing his best within the system.  He helped lead the production of one of the most comprehensive and best written NRDAs in the country, a multi-volume reference resulting from the work of more than 80 world-class experts.  It concluded that the polluters owed the public between $177 and $333 million in compensation and restoration (above and beyond the sediment cleanup plans).  It was a significant achievement and we’re grateful for David’s leadership. 

When it was finished, David left the government to join the private firm, Stratus Consulting, and he continues to work on other NRDA’s around the country in this capacity. 

Background:  David is a wildlife biologist with over 13 years of experience in local, state and federal government in regulatory analysis, NRDAs, avian and mammalian field research, water quality standards development, and environmental assessment and restoration.  Prior to working in Green Bay, David worked as Water Quality Standards Coordinator for U.S. EPA Region V in Chicago.  He holds a Masters Degree in natural resources and a Bachelors in zoology, both from Ohio State University.

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Kristin Blankenheim: Our New Intern

We’re very grateful to have the services this summer of Kristin Blankenheim, who is volunteering her time on a regular schedule in exchange for college credits and real-life experience working for our non-profit public interest group.  Kristin is a Green Bay Preble High School graduate of 1999, and has completed 3 years at UW-Green Bay with a major in Environmental Policy and Planning, and a minor in Geography.  She’s helping us with a variety of office work and issues research, which are both important needs.

Kristin first became involved with CWAC in 1998 when she joined our door-to-door canvassing crew for a few months between school obligations, and has periodically helped as a volunteer at our office.  A few years ago, we invited her to join our Board of Directors, where she still serves.

In addition to being a full-time college student, Kristin works at JoAnn Fabrics and Crafts, a natural outcome of her interests in sewing and macrame.  She also sells handmade clothing at music festivals and concerts, as well as Vagabond Imports in Green Bay.  Other hobbies include: disc golfing, camping, hiking, going to concerts, traveling, reading, and playing with her dog “Phizzgig.”  She’s also studying Tibetan Buddhism.  Other activism interests include: “anything environmental, animal rights, and legalization of hemp.”  As Kristin says, “My parents raised me to respect the Earth and all her creatures; and therefore, protecting the environment has always been part of my life.”

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Concert Thanks!

We want to acknowlege all the great volunteers who helped with our Annual Banquet this year.  We had a wonderful time, and everyone seemed to enjoy the dinner and Berrymans’ Concert.

The staff at the Historic West Theater were very accomodating and helpful with all the food details and set-up.  At our request, they cheerfully researched and made a new vegetarian (vegan) lasagna recipe for us.  The refurbished theater setting was also wonderful.

As usual, Curt Andersen (The Country Woodworker) made the beautiful wooden bases (in the shape of Wisconsin) for our annual award plaques. This year’s wood was a gorgeous streaked spalted maple.

Several people helped with the presentations: Tom Kees, John Shier, Dean Reich, Christine Fossen Rades, Curt Andersen, Bob Schmitz, and Rita LeGros.  Bob also helped with the registration table.

Mike and Becky Katers took care of the organizing and publicity, and several members pitched in for last-minute details.  Somehow it all worked.  Thank you, everyone!

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DNR Proposes to Downgrade River and Stream Protection

The Clean Water Action Council joined with 18 other environmental and conservation groups recently to object to proposed state rules downgrading protections for 94 of Wisconsin’s rivers and streams.  The DNR rule package impacts three administrative rules and lowers water body protections across the state

The groups asked DNR to correct all deficiencies in the rule before seeking approval from the Natural Resources Board and the Legislature.  The DNR has already agreed to drop from this list any stream where the supporting files are missing or no analysis is in the file. 

Even so, the groups found that the rules do not meet the minimum requirements of the Clean Water Act, and are challenging the classification of:

• 22 streams due to lack of proof that the stream could not improve; 
• 11 streams because of no data 
• 13 streams where the downgraded protections threaten to impair downstream trout streams or high quality waters 
• 4 streams where a DNR file memo actually recommends a higher classification 
• 4 permits where DNR simply ignored what the current rule says about water standards. 
 The groups are not objecting to upgrading 4 trout or cold water streams, 19 streams that are upgraded slightly, and the delisting of variances for 107 streams where facilities ceased operations.

Streams and rivers must meet the designated uses established by the Clean Water Act in order to reach the goal of all waters being fishable and swimmable.  Whenever a state wishes to adopt uses that are less stringent, the Clean Water Act requires the state to conduct a use attainability analysis.  The DNR failed to do this analysis, according to the groups’ formal comments.

For more information, contact Melissa Scanlan, Attorney, Midwest Environmental Advocates, Phone: 608-251-5047

Groups co-signing the comment letter include: Midwest Environmental Advocates, Sierra Club - John Muir Chapter and River Touring Section, Clean Water Action Council of Northeastern  Wisconsin, Environmentally Concerned Citizens of the Lakeland Area, Friends of the Jump River, Friends of Milwaukee’s Rivers, Habitat Education Center, Madison Audubon Society, River Alliance of Wisconsin, Wisconsin Association of Lakes, Wisconsin Audubon Council, Wisconsin Environmental Decade Institute, Wisconsin Public Interest Research Group, and Wisconsin Wetlands Association.  Joining the Wisconsin groups are the national offices of American Rivers and Environmental Defense and two regional offices - the Environmental Law and Policy Center of the Midwest and the Sierra Club - Midwest Office.


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