To: Wisconsin Department of Natural Resources
Your correspondent is a resident and business owner in Milwaukee Wisconsin. I’ve lived in the state since birth. I am a life-long supporter of parks, woodlands, flora and water. I have camped, walked, biked and swam in Wisconsin.
I weigh into the discussion of the Kohler company’s Draft EIS knowing that I am not an expert each of its technical issues. My business, however, has given me the time and resources to pursue a life-long interest in vegetation and water.
As a citizen of this environmentally conscious state, I rise to the defense of the Black River Woods. I have read the DEIS and here submit my comments.
I am both saddened and outraged by the cavalier attitude that spoils the DEIS. We citizens grant each other, including officials of the Kohler Company that freedom to advocate for what they believe in. But this is a blinkered pursuit of a sport in a space that is hostile to golf. The DEIS and its author assumes it can abandon nature, twist an ecology to suit their purpose, and reverse thousands of years of environmental heritage.
I grew acquainted with prairie and woodland flora over the past two decades with personal study and practice. My entire city yard (almost 4000 square feet) is dedicated to mostly native flowers and grasses – “native” meaning (like myself) Wisconsin-grown, those plants are now recognized as having been “discovered” by immigrants over the last 500 years. This passion brought to my attention the work of Wisconsin’s brilliant horticulturalists who have been my teachers, some of whom have served with the Department [DNR].
I am acquainted with water issues as they pertain to transportation infrastructure – the low quality of water as an effect of pouring concrete on permeable soil, and the creation of wide roads and parking lots and their effects on the beaches of Milwaukee. I have advocated on behalf of children’s health regarding air quality generated by the proliferation of roadway instead of transit.
I read the Kohler DEIS. I was surprised by the statement’s confident attitude toward its plan to make a wholesale restructuring of a natural woodland, of the reparian and shoreline sanctuaries. But then I discovered the gap. They are confident because failure will be someone else’s problem. Some may call it arrogance.
Specifically, I note the cosmetic intentions of your DEIS upon being confronted with this glorious description of Lake Michigan. 1 Upon reading this passage I felt as if I were being introduced to an effort to preserve an ancient heritage.
5.1.3 Surface Waters
This encomium for nature and our precious lake prepares (or tries to prepare) the reader to think kindly about golf. To soften the shock that half the trees are slated for the saw. That vegetation natural to this space is an obstacle to golf. The balance of natural forces controlled by water and wind will now buckle to hubris and whim.
What kind of sport is this style of golf that a carpet of green must be laid down to accommodate the soft feet of its players?
Instead of a due reverence for the thousands of years that created our great lakes, and our magnificent shoreline, the DEIS continues on the same page getting down to business, the point being made; that a property right is absolute over all considerations; never mind the responsibility when the day comes that the golf park can no longer be maintained. 2
Our nation is beginning to experience the crisis of water, long after the world has been alerted. A good DEIS will be based in science if it minimally reverences how the water crisis of our times is addressed, not how it is ignored or aggravated. We are offered a tear-down, an old house that needs to bend to my will because it is *mine* and *I* can do what *I* want here.
Replacing fragile turf - that pristine environment is not clever; in fact it will be long-run expensive. Golf will fade as other sports have. The money will run out; the DEIS must describe the natural consequences of an unmaintained, once “pristine” golf course. 3 If not maintained, the intruder environment will be weathered by the winds, waves and sand, beaten down and become just another sad patch of land over which America made its grand march.
Nature’s Apparent Entropy
There is a reason why a pristine area has few invasive plants, a factoid suggested in the DEIS. It might be described as the apparent natural entropy - the twist and flow of the elements struggling with each other to make an area its own, each succeeding to some degree, each relenting in some degree to the others.
The lack of disturbed soil makes this ecology possible.
But now these elements are confronted with a thoughtless human, single-minded in purpose. Shake it all up; tear the stuff out that makes your sport a physical challenge; cosmeticize the woods. Disturb this soil, OK! Now that you have invited invasives, you will get invasives, you will lose to nature, and nature will lose to you. The invasives will not be the relatively tame invasives that the DEIS throws out to fool the reader. Here 4 the DEIS speaks truth, possibly hoping that DNR horticulturalists will be numb at this point.
This morning as I wrote this comment, I came to my front porch to witness what happens to trees that have served the city, and then fail; the city addresses the problem because we cannot have branches falling on people. Two trucks appeared, and four men. One truck had a cherry picker holding a man with a chainsaw who brought the branches down. In minutes a mature but ailing ash tree was denuded, naked as a corpse. In a city, essential work. In a make-believe environment, an expensive budget item that will one day see the money run out.
I submit that once the tear down is started the maintenance game must be close behind. Disturb the entropy, try to make an easy-walking “wild” woods and you deliver trims on paired trucks. A woodland without the fallen log is no longer a woods that is a refuge for plants and animals; a tree’s final decay is home to insects, bees, reptiles, birds – each feeding on the tree or each other. The charm of the woods will leave twice: first with the antiseptic space portrayed in the DEIS; second with neglect in a future generation which cannot afford the maintenance of that foreign landscape. All the natural support systems will be gone and the space will be ignored like the abandoned mines or post-rust-belt factories scattered around Wisconsin. What will remain is the name of these woods and the documentation by observers.
Other than the chlorofluorocarbons have we ever managed ozone? This problem comes with abuses of fuel, use of unsustainable fuels, and our devotion to building a world that requires everyone to have access to a car. Even before the Black River Woods are touched it is already infected as a “nonattainment” area for ground-level ozone. We will add to that. According to the DEIS these changes are “not expected to significantly contribute to long-term increases in air emissions” – exaggerated un-enumerated claims, no numbers, no statistics, no projected populations of carts, cars, trucks, chainsaws or people. The DEIS suggests we do not have to look closely at these consequences. Let’s call it a day. “There is not expected a concentration of vehicles …” An honest DEIS would have us read numbers so at least we are speaking a common language.
The cost of ozone is borne by nearby residents. The future cost is borne by Wisconsin citizens.
Was no planning given to future costs? Maintenance? Failure of the golf course to earn enough money to maintain itself. Where is that in the DEIS?
Introducing the Japanese Barberry (berberis thunbergii)6 shows how desperate the writer is to slip in the right to spray herbicides. Sure, this plant is a nuisance when allowed to spread. One bible of invasives in Wisconsin tags this plant as “a lesser invader of natural areas.” 7 It could be ignored, except that the DEIS describes it as an “impenetrable thorny tangle.” No golfer would like to walk through this, no hiker, no one. Berberis, however, is not a good example of “invasive” that suggests aggressive means to control. It can be controlled without spraying herbicides.
The point is the game plan, without asking for the option to spray herbicides the DEIS is leaving the door open for the managers to do so. If the DEIS writers will avoid herbicides they should declare that invasives will never be used. But their fantasy environment requires control, or the dream slips away the next morning.
Not all invasives are created equal. Not all are the knotweed for which Monsanto is infamous. Not all are buckthorn, which I have handled and suppressed with basic garden tools. Japanese barberry is a lesser invasive. But the DEIS exaggerates its inconvenience calling it “impenetrable” to the tired feet of a golfer. The DEIS makes space for sprayed herbicides, which dusts everything, desirable and undesirable.
5.1.1 Geology and Soils
This section of the DEIS is a lament how imperfect the Black River Woods for golfing, and the many considerations that must be made to remake a turf that is today the work of thousands of years, a kind of harmony among the elements: vegetation, water, turf - each of which in some way is stated in the DEIS as the foe of golf. On the one hand the soil has the unfortunate proclivity to be unable to support golf-required turf, and so the beautiful dunes and their wild dispositions will need to be tamed by excavation, by laying garden variety topsoil and imported grasses, and lining paths with “a curb and gutter system” 8 to finesse the run-off. Modestly understating problems, the DEIS contributes: “Fair performance and moderate maintenance can be expected.” 9
To highlight the challenge of placing golf on this turf, the DEIS states that the abundance of plant life and the permeability of the soil might not be enough. 10
Pages 17 and 18 of the DEIS are peppered with expressions such as: very limited, somewhat limited. The culprits are the Adrian muck and the Granby soils that “… affect the ease of excavation and grading and the traffic-supporting capacity. Excavation of these soil types, if present, is likely to be needed.” 11 Promethean hubris? Bring it on.
“The [NRCS] ratings are based on the soil properties that affect the capacity of the soil to support a load without movement and on the properties that affect excavation and construction costs.” 12
My reading of the DEIS leaves many questions unanswered. The citizens of Wisconsin deserve an honest appraisal of all the costs of the plan to make a golf course in this space. All the costs including future maintenance, the “intangibles” – what we lose with major surgery on this venerable example of nature now taking care of itself. And, of course, what we will gain. What will it cost to play golf on this property? Will there be a gas station? Perhaps a resident caretaker? Will local police patrol this development? Will the owners have security service? A proper DEIS must lay out the costs because eventually the public will have to cover the bill.
1 “… According to the Great Lakes Information Network (GLIN,) Lake Michigan is the second largest Great Lake by volume with just under 1,180 cubic miles of water, and is the only Great Lake located entirely within the United States. Lake Michigan is approximately 118 miles wide and 307 miles long, has more than 1,600 miles of shoreline, averages 279 feet in depth, and has a maximum depth of 925 feet. The drainage basin is approximately 45,600 square miles with approximately 14,200 square miles located within Wisconsin.
“Lake Michigan is a cold water, oligotrophic lake with summer maximum water temperatures below 72 degrees. Native fish species include lake trout, whitefish, largemouth bass, bullheads, northern pike, lake sturgeon, yellow perch and sculpins. Numerous invasive aquatic species are also present throughout Lake Michigan. There are more than 15 million fish stocked annually in Lake Michigan.
“The eastern edge of the area’s ecological landscape is heavily influenced by the cool waters of Lake Michigan, which has created a cool, moist climate and distinct landforms affected by phenomena such as water level fluctuations, fogs, wave spray, storm wave impacts, ice push, and deposition and erosion of sediments. This physical setting has promoted a unique set of biotic communities, species assemblages, and natural community mosaics of unusual composition, limited geographic distribution, and high ecological value. Species endemic to Great Lakes shoreline habitats occur here. Undeveloped shoreline habitats and the relatively clean, open waters of Lake Michigan in this ecological landscape are highly significant to migratory birds (Steele 2007). Lake Michigan is a Conservation Opportunity Area of global significance (WDNR 2008c). The Wisconsin shore of Lake Michigan within this ecological landscape has shoreline features shaped by wave and river dynamics that made the mouths of rivers along the lake suitable sites for small harbors. These are the present-day locations of the cities of Algoma, Kewaunee, Manitowoc, Two Rivers, Sheboygan and Port Washington. DEIS, p20–21
2 Work in and adjacent to waterways often requires determination of the ordinary high water mark (OHWM). The OHWM, is the point on the bank or shore up to which the presence and action of the water is so continuous as to leave a distinct mark either by erosion, destruction of terrestrial vegetation or other easily recognized characteristic. The OHWM establishes the boundary between public lakebed and private land. When water levels drop below the OHWM, the riparian property owner has exclusive use of the exposed lake or river bed. [emphasis added] DEIS, p21
3 The Kohler Property and the Kohler-Andrae Property contain several upland plant communities. Vegetation would be removed from the footprint of the golf course fairways, greens, and tees and would be replaced with turfgrass. Vegetation would also be removed from the access road and utility right-of-way, building footprints, septic fields, irrigation system, driving range and cart paths. Mature trees and other native vegetation would be retained between the golf holes where possible. It is anticipated that approximately 50 percent of the existing trees would remain following construction. The remaining 50 percent of the existing upland would be preserved and remain located predominantly between golf course features. DEIS, p30
4 This plant community supports mostly native species with few non-native or invasive plants. The plants are highly specialized and conservative. Conservatism is based upon a species fidelity to specific habitat integrity and to varying degrees of disturbance. The most conservative species require a narrow range of ecological conditions, are intolerant of disturbance, and are unlikely to be found outside undegraded remnant natural areas. While conservatism and rarity are not always equated, many conservative species tend to be rare. DEIS, p31
5 According to the U.S. Environmental Protection Agency (EPA), Sheboygan County is identified as a “nonattainment” area for ground-level ozone. This area does not meet the EPA’s 2008 8-hour ozone national air quality standard (75 parts per billion; EPA 2014). The Property and operation of the golf course is not expected to significantly contribute to long-term increases in air emissions. There is not expected to be a concentration of vehicles associated with daily golf course operations and few vehicles are likely to use the Property during winter months when the golf course is closed. DEIS, p20
6 Invasive Plants of the Upper Midwest, Elizabeth J. Czarapata. UW Press. 2005. 5 printings.
7 Ibid., Czarapata.
8 DEIS, p25
9 DEIS, p18
10 To construct the biofiltration areas to hold water long enough and support plant growth, it’s anticipated that less porous soil and topsoil would need to be brought into the site. DEIS, p17
The soils present on site may present challenges for the construction and long term maintenance of the proposed golf course. p18
The “soils are somewhat limited in suitability for lawns, landscaping and golf fairways because the soils have a low exchange capacity, are droughty and can have significant slopes. The dune soil areas are unrated but have these same deficiencies. The Granby soils are very limited due to ponding, saturation, low exchange capacity, and flooding. When water levels drop the Granby soils can also be droughty.” p18
11 DEIS, pp 17–18
12 DEIS, p 19