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E-M:/ another threat to essential habitat

Enviro-Mich message from davemec@sojourn.com (Dave Dempsey)

        In an action believed unprecedented in the quarter century of
federal dredge and fill permit review by the U.S. Army Corps of Engineers,
the Secretary of the Army has bowed to several Michigan politicians and
pulled consideration of a proposed Lake St. Clair marina project from its
Detroit district office.

        The move could expose to destruction "unique and irreplaceable
vegetated aquatic habitat" off the City of New Baltimore despite a chorus
of scientific opposition from the Michigan DNR's Fisheries and Wildlife
Divisions, the U.S. Fish and Wildlife Service, and independent consultants.

        It follows a threat by one federal legislator to amend the Clean
Water Act to allow  the New Baltimore marina to proceed.

        Countering the experts is pressure from Michigan Governor John
Engler and U.S. Senator Spencer Abraham. Engler and Abraham have asked
Secretary of the Army Togo West to overturn the Corps' 1996 rejection of
the proposed project.  On May 28, West directed Lieutenant General Joe
N.Ballard, the Chief of Engineers for the Corps, to review the project "at
the Corps of Engineers headquarters level."  In practical terms, the Corps'
Cincinnati office will handle the permit review.

        Among the disturbing implications of the move:

        *  By breaking a tradition of isolating politics from the Corps'
permit process, West's decision risks pressures from members of Congress
and Governors on a host of dredge and fill projects.

        *  By ignoring the clear and convincing conclusions of technical
experts, West may undermine the basis for Corps permit decisions.

        *  A decision to permit the marina will destroy a part of one of
the last, best unspoiled habitats in Lake St. Clair for spawning of
sportfish species such as yellow perch, rainbow smelt, largemouth bass, and
rock bass; and for migrating waterfowl.

        The proposal rejected by the Corps, which was recently resubmitted
without change by the City of New Baltimore, calls for the dredging of
approximately 17,000 cubic yards of bottom material, the installation of
about 420 linear feet of seawall along the existing shoreline and 664
linear feet of offshore breakwater, the replacement of an existing launch
ramp, and the construction of five eight-foot wide main piers of various
lengths with a total of 27 three foot wide finger piers.  The project would
result in a 53-slip, transient mooring facility.

        There is a long litany of expert testimonials to the value of the
habitat that would be destroyed, including:

        *  The DNR Fisheries Division opposed the project on the grounds
that it would "cause immediate and long term destruction of fisheries
habitat through the physical changes in bottom composition and organisms
supported by it."  Numerous studies, it said, provide evidence that the
habitat compromised by the project is important for "spawning, nursery and
feeding habitat for a wide variety of gamefish and forage fish species.
These shallow areas are a natural and integral part of the complex aquatic
ecosystem and should be altered only when specific circumstances fully
justify dredging."  Species identified included smallmouth and large mouth
bass, northern pike, yellow perch, and other panfish.

        Fisheries noted that the annual "Fishfly Festival" in New Baltimore
celebrates the spectacular mayfly hatch supported by mayflies produced in
the very area affected by the project.  The greatest density in the St.
Clair system of burrowing mayflies and greatest diversity of invertebrate
taxa were found by the National Fisheries Center in the area.

        "This taking of nearly 5 acres of public water in one of Michigan's
most valuable resources cannot be allowed," wrote a DNR Fisheries
Biologist.  "If it were tolerated based on 'public benefit,' and the
environmental damage was ignored, what would keep others from doing the
same thing?  The 'nibble effect' has cost most (85%) of Michigan's natural
shoreline in Lake St.Clair to be replaced by steel and concrete. We must
not permit this project to go forward."

        *  The DNR Wildlife Division opposed the project, saying census
data for the area "indicates that the offshore waters of New Baltimore are
one of only 4 or 5 extremely important feeding and resting areas for
thousands of ducks.  Annually, bluebills, redheads, and to a lesser extent,
canvasbacks can be found in large rafts close to the shoreline, seeking
food and protection during strong northerly storms." Wildlife also noted
that the affected bottomlands support valuable submergent aquatic
vegetation beds which provide a valuable food source for diving ducks.

        *  An independent study conducted by Thomas G. Coon in 1994 found
the area to be "a healthy and productive ecosystem dominated by native
vegetation that provides food and habitat values for native fish and
waterfowl species.  Furthermore, it is part of one of the largest beds of
wild celery in Lake St. Clair, and this plant species is especially
important for migratory waterfowl, particularly canvasback and redhead
ducks.  Disturbance caused by dredging and marine construction activities,
along with increased boat traffic in the shallow region is likely to cause
the vegetative community to shift from the current status to a community
dominated by introduced nuisance plant species such as the Eurasian
watermilfoil and curly pondweed. "

        *  An independent study conducted by David J. Jude in 1994
concluded that "building of a marina in the New Baltimore area where we did
our study would result in a degradation of the quality of the area for fish
and benthos...There would probably be increased turbidity and enrichment in
the area, which would decrease the amount of sandy, gravel areas and
plants, decreasing the diversity of the habitats, and therefore its
usefulness as a spawning and nursery area for fish.  These changes would
further cause shifts in fish and benthos populations that would favor those
species that are more adapted for a stressful environment, for example
rough fish species, such as common carp and gizzard shad, and benthic
organisms such as Chironomus spp.  and tubificids."

        *  The U.S. Fish and Wildlife Service said 23 taxa of fish are
known to use the site as a nursery and spawning area, and thousands of
waterfowl which migrate through the lake corridor  use the area for feeding
and protection from strong northerly winds.  Noting an estimated 5,000
boats per year are expected to frequent the marina and 5,000 are expected
to use the upgraded boat ramp, the Service said the composition of the
plant community would convert to one more dominated by non-indigenous
nuisance species.

        "The Service's paramount concern is that this marina would be sited
within one of the few remaining feeding/resting habitats for diving ducks
in Anchor Bay," said the official letter of objection.  "The combination of
protection from north winds and valuable community of submergent plants
makes these habitats highly valuable, unique, and irreplaceable."

        Over 22,000 acres of submergent and emergent wetland habitats have
been lost due to shoreline development in Lake St. Clair between 1873 and
1968, the Service said, adding, "The Service submits the environmentally
preferable alternative in accord with our Mitigation Policy is the 'no
project' alternative, with fulfillment of transient moorage objectives by
other means."

        If you are a defender of essential Great Lakes ecosystem habitat,
your voice needs to be heard.  Here's how you can express your views;

        *  Write Secretary of the Army Togo West voicing strong opposition
to his purely political decision to allow a reapplication for the same
project the Corps previously rejected, and for snatching the decisionmaking
authority away from the District and assigning it to the Chief of
Engineers.  Express concern that this unprecedented action will have severe
impact on the long-term integrity of the Corps' regulatory program.  Write:

        Togo D. West, Secretary of the Army
        Pentagon, Room 3E700
        Arlington, VA  20310-0101

        *  Request to be placed on the public notice mailing list for the
New Baltimore project.  Upon receiving the public notice, make comments
regarding the impacts and need for the project.

        To ask to be placed on the public notice mailing list, write:

        Rodney Woods
        Regulatory Program Manager
        Corps of Engineers
        P.O. Box 1159
        Cincinnati, OH  45201-1159

Dave Dempsey
Michigan Environmental Council
119 Pere Marquette, Suite 2A
Lansing, MI  48912
(517) 487-9539
(517) 487-9541 (fax)

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