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Greetings
Wetland Activist,
The
general permit governing the expansion of existing cranberry operations is
up for renewal and the Army Corps of Engineers is accepting comments
through December 5th.
Wisconsin Wetlands Association has submitted comments on the permit
renewal, but as you know, comments from concerned citizens are very
powerful -- more powerful, perhaps, than comments from statewide
organizations.
Please
take a moment to submit your comments on the propsed permit to the U.S. Army
Corps of Engineers and the Wisconsin Department of Natural Resources
(addresses provided at right). Background information and talking points
are provided below to assist you.
Thank you for your time advocating on behalf of Wisconsin's wetlands!
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Background Information
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Cranberry "bogs" are created by essentially
destroying natural bogs (all the vegetation from the existing bog is
removed, the wetland is re-shaped and graded for a level and even peat
base, and drainage ditches and water control devices are built as
necessary before the cranberries are planted). These newly created
cranberry beds are then flooded with water diverted from streams and
rivers.
In addition to the wetland impacts and water flow issues associated with
the creation of these cranberry bogs, water taken from nearby
rivers and streams and used to flood the beds during the cranberry
harvest is often then returned to the river or stream. Serious water
quality problems downstream from the bogs can occur
when this water is returned because of chemical and thermal pollution.
The
general permit that is up for renewal allows any existing cranberry operation
to impact up to 10 acres of wetland (in addition to any acreage
previously affected) in a five year period for the purpose of increasing
the size of their operation.
The
exemptions called for in this General Permit have not been invoked by any
cranberry operation in the last five year period of the Permit; however,
in the previous five-year cycle, it was invoked 17 times for a total
wetland impact of more than 68 acres. With more than 200 growers in the
state (who would each have permission to impact up to 10 acres of wetland
per five- year cycle), the potential impacts under this permit are
significant.
Because
of the extent of potential impacts, and because of several weak or
unclear provisions of the permit (see "Talking Points" below),
Wisconsin Wetlands Association feels the proposed permit merits
substantial revision prior to its renewal. We urge you to contact both
the US Army Corps of
Engineers and the Wisconsin Department
of Natural Resources with your input on the proposed permit by December
5, 2004.
Review the Corps' Official Public Notice »
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Suggested Talking Points
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Wisconsin Wetlands Association's comments regarding this
permit renewal called for:
· Greater restrictions on
the types of waters which cannot be impacted under this General
Permit. Specific additions include Outstanding and Exceptional Resource
Waters, waters listed on the State's 303(d) list of Impaired Waters,
walleye and wild rice waters.
· Clarification on the notification
requirements. It is unclear from the permit whether DNR has 5 or 60 days
to inform a grower that they are eligible for coverage under this permit.
Previous permits required only 5 days which, we believe, places
unreasonable expectations on DNR staff and inadequate time to properly
review permit terms. We recommend a minimum of 3 weeks.
· A review of
mitigation compliance under this permit. Information on the degree to
which wetland mitigation criteria were met was not readily available.
Wisconsin Wetlands Association submitted a Freedom of Information Act
request to obtain this information and requested the public notice period
be extended pending fulfillment of this request. To our knowledge,
neither the Army Corps of Engineers nor the Wisconsin Department of
Natural Resources has conducted an audit of mitigation compliance under
this permit. We believe such an audit should be conducted to inform and
strengthen the terms of this permit as needed.
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More Information on How To Submit A Comment
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Because the state of Wisconsin
proposes to grant 401 water quality certification to all activities
invoked under this permit, it is important to submit your comments to
both the US Army Corps of Engineers and the Wisconsin Department
of Natural Resources. The contact information for where to submit your
comments is provided on the sidebar at right.
Thank you for your interest in protecting Wisconsin's
wetlands.
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Where to Submit Your Comments
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Submit your
comments to:
U.S. Army Corps of
Engineers
St. Paul District
Attn: Regulatory Division
190 Fifth St. East
St. Paul, MN 55101
Via Email
AND
WI Dept. of Natural Resources
Dale Simon
101 S Webster Street
- FH/3
Madison WI 53703
Via Email
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