1.  Delays Unwarranted --- They claim it’s too soon for EPA to write a comprehensive clean-up plan under Superfund, even though planning and over $20 million in studies have already dragged for 13 long years.   The Fox River is one of the most studied in the world. 

2.  Nothing New --- The “demonstration project” will demonstrate nothing new.   It’s just another dredge and landfill proposal.  Dredging is a well-studied activity in rivers around the world.   Several hydraulic dredging techniques have already been proven to minimize downstream flow of contaminants.   They function like vacuum cleaners and, if used thoroughly, can be very effective.   We don’t need to wait for research results from polluters when a plan can be written based on current information.  This may end up being the largest sediment clean-up in the country, but really it’s just a series of smaller projects strung together -- and very manageable. 

3.  Cheap and Dirty? --- The project will cut a hole in a huge continuous bed of contaminated sediments to try to remove the worst PCB hotspot (called 56/57) in the river.   Even before they examined the technical options for this hotspot, they limited themselves to only a  $7 million effort, which may be drastically less than they need to do the project correctly.   They will cut into a layer cake of contaminated sediments, exposing deeper levels of contamination, but after exposing these layers, they may not have enough money to remove all the toxics they should.  In some areas they will be cutting 10 feet down into the sediments, leaving a hole where the sides will slump and refill the hole.  This will allow downstream PCB drift  and expose deeper, hotter PCB layers in the remaining sediments at the edges of the hole. 
   
4.  Deliberate Proof of Failure? --- Industry plans to sample the water and fish afterwards, but how can they demonstrate anything but an increase in PCBs, or at best no improvement, when most of the PCB sediments will still be there, perhaps even more exposed when they’re done?   This is not sound science, nor is it honest. 

5.  Strong Incentives to Fail ---  How can the public be sure they’ll implement the best dredging techniques or conduct fair tests, when the polluters have a strong incentive to show negative results, a failure which could help them argue against dredging and save them from up to $1 billion in future clean-up costs?     

6.  Deliberate Inflated Costs? --- They may also demonstrate inflated costs with such a small limited effort --- another tool for frightening mill workers and swaying public opinion.  They won’t have the economy of scale of a large project which drives down per-unit costs. 

7.  Long Past Due --- They want another delay to conduct and analyze this test.  An obvious question is,  “Why didn’t they fund legitimate, independent studies 13 years ago when official clean-up planning began, so we could be further along now?”   The obvious answer, “Because this demonstration is being used to obstruct progress and develop ammunition for the polluters.” 

8.  Part of a Sweetheart Deal --- This project is part of Gov. Thompson’s secret $10 million settlement contract with the Fox River polluters on January 30, 1997, which created many serious concerns related to Fox River cleanup.  The contract favors the polluters and weakens DNR oversight and enforcement ability. 
    
9.  Polluter Liabilities Capped --- The agreement capped paper industry liabilities at Deposit 56/57 at only  $7 million, before the site cleanup options had been studied.   As a result, DNR staff proposed a project where minimizing cost seems to be the prime goal, rather than public or wildlife health.   If this site had been handled correctly, the DNR would have studied and presented to the public several options for cleanup, and would have chosen the most protective.   At that point, the responsible industries should have paid the full cost for a much larger clean-up --- probably costing much more than $7 million. 

10.   No Detoxification ---This is the most concentrated PCB hotspot in the river, and this project is supposed to be a “demonstration.”   Logically, the DNR should require the polluters to demonstrate several types of PCB detoxification treatment technologies in a full-scale application, but the Governor and Polluter agreement didn’t provide enough money.  This sets a bad precedent for the rest of the river.  If any site deserves detoxification, it is this site. 

11.  Misleading Presentations --- All last summer, the DNR and EPA showed videos of hydraulic dredging at the Manistique Harbor dredging project, with the implication that this technology would be used on the Fox River.   That dredging showed very little sediment stirring.    However, the DNR hired a different contractor to perform dredging at Deposit N using a “swinging ladder” style of hydraulic dredge which is significantly different from the video --- a style which may have resulted in more resuspension of sediments. 

12.  No Public Involvement --- The key decision limiting this project to $7 million was made in January of 1997 at secret meetings arranged by Gov. Thompson (who has received enormous campaign contributions from the paper industry.)   The public was completely excluded from this decision.    

13.  The First Demo was Mishandled --- For $4.5 million, the DNR only removed 38% of what they promised to remove at Deposit N near Kimberly and Little Chute, yet they issued media statements claiming they removed 80%.  We question DNR’s honesty and competence in handling such a serious responsibility without assistance from more experienced federal agencies. 

Please write a letter to the DNR and to your state and federal elected officials to urge them to intervene in this issue. We must speak out, before the project starts this spring.

Mr. George Meyer, Secy.
Wisconsin DNR
P.O. Box 7921
Madison, WI 53707

 

Write to your elected representatives and tell them what you think:
 

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

 

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

 

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

To Contact Wisconsin State Legislators
 

If in Wisconsin call the Wisconsin Legislative Hotline toll free to find out who your Wisconsin Legislators are: 1-800-362-9472 

Wisconsin State Legislators Online & Toll-Free 

Representatives:  Email & Web Page Addresses and Toll-Free Numbers 
Senators:  Email & Web Page Addresses 
Send Email to All Wisconsin State Representatives & Senators

Write Wisconsin State Legislators

State Senator _________________
P.O. Box 7882
Madison, WI  53707

State Rep (Last Name A thru L)
P.O. Box 8952
Madison, WI 53708

State Rep (Last Name Mc thru Z)
P.O. 8953
Madison, WI 53708

 
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