UPDATE: March 2008
The EIS process has moved forward more slowly than everyone imagined due, in part, to the complexity of the concerns identified during the October 2006 Scoping process, and also due to the need to develop interagency cooperating agreements on how a merged environmental review and wetland permitting process will work.
Because the guidelines for merging the environmental review under the National Environmental Policy Act (NEPA) and Section 404(b) of the Clean Water Act establishes several interagency concurrence points in the review process, WWA and partners advocated for additional public input at these points. Our concern was that public input on a final draft EIS could not be used to inform decision-making if all of the cooperating agencies had essentially concurred on the accuracy and completeness of various sections of the environmental review months earlier.
The Federal Aviation Administration responded by agreeing to include two additional opportunities for public input into the EIS review process. WWA applauds FAA for their commitment to maintaining a thorough and transparent review of the purpose and need, alternatives analysis, and environmental review for this project.
UPDATE: October 11, 2006
WWA staff member Erin O'Brien attended the "scoping meeting" hosted by the Federal Aviation Administration (FAA). A solid turnout of concerned citizens, partner organizations, and local business people were also in attendance. FAA presented a number of informational stations to describe the proposed project and the process of developing an Environmental Impact Statement, and had court reporters on hand to accept oral and written comments. Throughout the evening, conservation and business community leaders engaged in lively discussion regarding alternatives and options for how the project might address both communities' respective needs and concerns.
FAA has launched a website as part of its commitment to an open and public process as the Agency undertakes this EIS. All of the information that was available at last week's "scoping meeting" is now available online at www.westbendeis.com, including the following:
A description of the EIS process
EIS status updates
Proposed expansion project overview
Public meeting notices
EIS related documents
Click here to read WWA’s action alert with more information about the scoping process and how you can get involved. Written comments are due by November 13, 2006, and should be sent to:
Daniel Millenacker
Federal Aviation Administration
Minneapolis Airport District Office
6020 28th Ave. South, Room 102
Minneapolis, MN 55450
SPECIAL EVENT: Protecting West Bend Wetlands - A Field Trip, Fundraiser and Social
In partnership with Friends of Milwaukee's Rivers
Saturday, June 3, 12:30-3:30 pm
Meeting Location: "Fields" parking lot in West Bend, WI (directions below)
Please RSVP by May 30 to WWA (608-250-9971 or programs@wiscwetlands.org)
Spring is here. Please join Wisconsin Wetlands Association and Friends of Milwaukee’s Rivers to see spring in action at the site of the proposed
West Bend Airport Expansion. You’ve heard about the 150+ acres of at-risk wetlands and our perspectives on why this project is not in the best interest of the community or the Milwaukee River. Now you’re invited to see the wetlands first hand and to support our efforts to stop their destruction. Join us afterwards for drinks and snacks at the Riverside Brewery. Donations to support the organizing and advocacy efforts
of Wisconsin Wetlands Association and Friends of
Milwaukee’s Rivers.
Itinerary
12:30 - 1:30: Lowland hardwood swamp walk. Few wetlands
of this type remain in the Milwaukee River Watershed and most of
those left are tucked away on private land. Bring your boots and
plan to be awed by these beautiful wooded wetlands and all of their
hidden treasures.
1:30 - 2:30: The view from across the river. Ozaukee
Washington Land Trust’s Fellenz Woods occupies nearly 1.62 miles
of undeveloped land on the banks of the Milwaukee River. Known
for an impressive diversity of trees and wildlife habitat, this site also
harbors one of only about 12 known heron rookery sites in southeast
Wisconsin.
2:30 - 3:30: Drinks and discussion at the Riverside Brewery,
225 Main St., West Bend. Donations to support the organizing and advocacy efforts
of Wisconsin Wetlands Association and Friends of
Milwaukee’s Rivers.
View and print a PDF version of postcard invitation for the event.
Directions
Meet at 12:15 pm at the "Fields" parking lot on Veterans Ave.
From Hwy 33 turn South on Veterans Ave. Park in the second lot on the
right just after the sharp curve in the road.
UPDATE: May, 2006
The last six months have been very quiet on this project as the Federal Aviation Administration and Wisconsin Department of Transportation work their way through the selection process for a contractor to develop the Environmental Impact Statement. Once that contractor is selected work will begin on "scoping" process to determine what issues and alternatives must be examined as part of that document. Under the National Environmental Policy Act (NEPA), cooperating agency (e.g., Environmental Protection Agency, U.S. Fish & Wildlife Service, Wisconsin Department of Natural Resources) and public input must be considered in the scoping process. Wisconsin Wetlands Association and coalition partners are preparing comments now in anticipation of this opportunity.
UPDATE: June 17, 2005
Great news! The Wisconsin Department of Transportation (WisDOT) has announced they will complete an Environmental Impact Statement (EIS) for the proposed West Bend Airport project. Read the June 17 story in the Milwaukee Journal Sentinel and earlier coverage of this issue.
We are elated by this turn of events and are grateful to the WDNR and the federal regulatory agencies (US EPA, Corps of Engineers and US Fish & Wildlife Service) for working so diligently to ensure project proponents meet all legally required environmental review requirements. We would also like to thank and congratulate Taxpayers Against Airport Growth, Friends of Milwaukee's Rivers, and the Wisconsin Wildlife Federation for their many contributions toward this victory.
As you know, WWA has worked tirelessly on this effort for many months, including coordinating numerous letters, phone calls and meetings with state and federal regulatory agencies, hosting tours of the West Bend wetlands, facilitating coalition activities and conducting hundreds of hours of research to understand complex airport development guidelines and environmental review requirements.
Please consider making a contribution to help us cover our costs for the work we have put into preventing WisDOT from releasing a "Finding of No Significant Impact" for this project. Our battle, though successful, brought unplanned costs to the organization. Your donation will also support us in the critical next stages of this important wetland protection effort. Click here to donate. Our members made today's victory possible -- thank you for your support!
UPDATE: June 3, 2005
West Bend Chamber of Commerce organizes task force to build support for Airport expansion
On April 28th, in direct response to opposition efforts, the West Bend Area Chamber of Commerce sent a letter to their members announcing the formation of Grow West Bend, a task force to "coordinate community and regional support for the airport expansion."
They asked members to contact elected officials to express their support for the proposed expansion. In their letter they acknowledged "strong opposition" to the project, indicating to us that our coalition's efforts are proving effective. In response to the chamber's announcement, the local opposition group Taxpayers Against Airport Growth has launched an information campaign of their own to ensure that business leaders and local residents receive full information about the environmental and economic impacts of the airport project.
EPA considers ALL impacts significant and requests mitigation plan
In a May 5th letter to the Federal Highway Administration (designated as the "lead" agency for the environmental review), the US Environmental Protection Agency (EPA) provided comments on the draft Final Environmental Assessment for the project. Unlike the Wisconsin Department of Transportation (WisDOT), EPA considers the 60 acres of proposed wetland fill and the 88 acres of proposed tree clearing to be significant adverse impacts and suggests a mitigation plan is needed to address all impacts. The EPA went on to say that, in the absence of a "documented and enforceable mitigation plan," they would object to a Finding of No Significant Impact and to the issuance of Clean Water Act Section 404 permits for the project. Note: Even if the mitigation plan is developed and released, WWA will continue to push for the development of a full Environmental Impact Statement for this project.
West Bend Mayor Proposes Mitigation Bank
On May 10th, West Bend Mayor Douglas Bade announced that he will propose that the City of West Bend establish a "wetlands preservation bank" to mitigate the impacts of the airport expansion and future wetland development projects in Washington County. No substantial details were provided and, to our knowledge, the City of West Bend has not consulted with the Department of Natural Resources or the Army Corps of Engineers about their plan. Mayor Bade's proposal to offset wetland losses at the project site through the creation of a wetland mitigation bank does nothing to assuage our concerns; the size of the complex to be destroyed is too great and the wetland types (e.g., ephemeral ponds and lowland hardwood swamps) and wetland functions (e.g., groundwater recharge) that would be affected by the proposed expansion are essentially irreplaceable. This project would never receive a permit under NR 103 if proposed by a private corporation or individual. We believe WisDOT should be accountable for demonstrating the project's benefits to public health and welfare in order to invoke exemptions under the Memorandum of Understanding between WisDOT and Wisconsin Department of Natural Resources.
WWA hosts site visit with regulatory agencies
In response to WWA's requests, on May 16th WWA and coalition partners* hosted representatives from the U.S. Environmental Protection Agency, U.S. Army Corps of Engineers, U.S. Fish & Wildlife Service and Wisconsin Department of Natural Resources for a meeting and tour of the West Bend wetlands. The meeting was designed to orient the regulatory agencies to the quality, type and extent of wetlands slated for direct destruction as well as adjacent wetlands which will be seriously degraded or subsequently filled if the project is allowed to proceed. The group discussed at length the deficiencies of the current alternatives analysis and the concerns about the feasibility of mitigating the impacts of the destruction of irreplaceable wetlands (e.g., lowland hardwood forests and ephemeral ponds).
* Coalition partners include Taxpayers Against Airport Growth (Watershed Watchers), Friends of Milwaukee's Rivers and Wisconsin Wildlife Federation.
To receive future updates, subscribe to WWA’s e-mail Wetland Alert system here
UPDATE: April 22, 2005
In the March 21st edition of Wetland News, WWA's e-newsletter, we reported that WWA had not received a response to our May 7th letter to Governor Doyle. In that letter, we expressed concerns with the adequacy and lack of objectivity of the Wisconsin Department of Transportation’s environmental review of the project. Of particular concern were the questionable purpose and need, a highly deficient alternatives analysis and, most importantly, WisDOT’s apparent plans to issue a Finding of No Significant Impact for the project. Our letter urged Governor Doyle to intervene and insist that WisDOT address these issues by completing a full Environmental Impact Statement.
Though our follow-up calls to the Governor’s office were not returned, we did finally receive a response to our letter on April 1. We were disappointed, however, when the response (PDF) did not come from the Governor's office, but from none other than WisDOT Secretary Frank Busalacchi - when WisDOT was the very entity about which we had expressed concern in our letter to the Governor!
Meanwhile, WisDOT’s support of the project has never been more clear. On April 16th, an interview with Secretary Busalacchi appeared in the West Bend Daily News. Busalacchi came out in strong support of the expansion project and is quoted saying "DOT is doing what it can to move the project quickly through the review and permit process."
The agency has not released a mitigation plan for public or interagency review, but continues to cite mitigation as the reason the conservation community’s concerns are unfounded. In the April 16th article, for example, Director of WisDOT’s Bureau of Aeronautics David Green is quoted saying "the project will end up creating more wetlands than it occupies." Subsequent letters to the Editor of the West Bend Daily News have lauded the project and WisDOT’s commitment to "replace" more wetlands than they destroy. (To date, West Bend Daily News has provided no coverage of the concerns of project opponents.) Recall that in addition to directly filling 61 acres of wetlands, this project proposes to log 88 additional acres of forested wetlands by cutting off the tops of the trees. WisDOT considers the forested wetland impacts to be "indirect" and thus does not intend to mitigate for the severe degradation of wetland function and hydrology.
We share this story as a sobering reminder of the amount of work our community needs to do to educate our government, media and citizenry about the important functions of natural wetlands, and the differences in quality and ecological value between natural and created wetlands. WWA will be issuing a Wetland Alert on this matter next week calling for wetland advocates to contact the WisDOT and others about this project that would set such a dangerous and negative precedent. Stay tuned for more information on how you can help.
Subscribe to WWA’s e-mail Wetland Alert system here
UPDATE: March 9, 2005
In WWA's Winter 2005 newsletter, we reported the latest on the proposed expansion of the West Bend Airport in Washington County. Experts suggest that the proposed expansion would represent the largest single- site concentration of wetland destruction in Wisconsin since the passage of the Clean Water Act in 1972. Proposed impacts include direct fill of 60 acres of high quality wetlands along the upper reaches of the Milwaukee River and serious degradation of at least 88 additional acres of adjacent lowland swamps.
Last month, WWA contacted Wisconsin Department of Transportation (WisDOT) requesting clarification on the status of the environmental review and on key project details including mitigation plans and expected wildlife and groundwater impacts. WWA also called for the development of a comprehensive Environmental Impact Statement (EIS).
On March 2nd, we received a brief response from WisDOT indicating that they will announce later this month whether they will be issuing a Finding of No Significant Impact (FONSI) or proceeding with a full (EIS). Despite the introduction of substantial new information regarding project purpose & need, costs, benefits and mitigation plans, they indicated that no additional public review would be offered.
WWA, and a growing coalition of opposition groups, believes WisDOT's interpretation of the environmental review and public input required by the National Environmental Policy Act (NEPA) is unacceptably narrow. In a March 7th letter to Governor Doyle, the coalition called on the Governor to intervene and insist that WisDOT prepare an EIS for this project. Watch future issues of Wetland News and Wetland Alert for updates and action items on this important issue.
Download a PDF of the March 7th letter to Governor Doyle
Download a PDF of the February 2nd letter to WisDOT
Download a PDF of WisDOT’s response to the February 2 letter
UPDATE: From the Winter 2005 issue of Wisconsin Wetlands, WWA's newsletter
Wisconsin DOT Underestimates Environmental Impacts from the proposed West Bend Airport Expansion. Your input needed soon.
The Wisconsin Department of Transportation (DOT) continues to doggedly search for justification to issue a Finding of No Significant Impact (FONSI) for the proposed West Bend airport expansion. The proposed runway extension at the airport in Washington County (see Summer 2004 issue) would involve filling 66 acres of high quality wetlands and cutting off the tops of trees in an additional 88 acres of lowland swamp. WWA and a coalition of opposition groups, including the locally-based Taxpayers Against Airport Growth and Friends of Milwaukees Rivers, are poised to intervene. The environmental review for the expansion project is grossly inadequate and the stated "purpose and need" does not justify the economic and ecological costs. In a February letter to DOT, WWA outlined these concerns and requested clarification on several procedural issues, including expected regulatory timelines, and how DOT will solicit public input prior to completing the review of the Preliminary Environmental Assessment. (This review will culminate in a decision regarding the need for additional environmental and cost/benefit review.) We expect that we will need to organize opposition to the airport rapidly and loudly in the coming months, and will notify our membership when the time comes. In the meantime, we are actively looking for a volunteer to help with an independent review of the methodologies and interpretations DOT is relying on to justify this project, if you or anyone you know has expertise in FAA regulatory guidance documents and/or airport engineering practices.
Subscribe to WWA’s e-mail Wetland Alert system here
UPDATE: From the Summer 2004 issue of Wisconsin Wetlands, WWA's newsletter
Preliminary Environmental Assessment Completed for West Bend Airport Expansion: Expansion proposal represents the largest single wetland loss in the history of Wisconsin’s wetland regulatory program
The need for an expanded airport in West Bend has still not been clearly justified and yet the destruction to wetlands that would result from the proposed municipal airport expansion would be unprecedented. Despite this, an Environmental Impact Statement may never be prepared for this project, since the Wisconsin Department of Transportation (DOT) appears prepared to issue a FONSI or "Finding of No Significant Impact" for the airport expansion.
The proposed expansion was first introduced in transportation planning documents in 1969 and the justification is based on 30 year old airport use projections, which have not come to fruition. In 2002, the city of West Bend, the DOT, and the Federal Aviation Administration (FAA) introduced a plan to expand the West Bend Municipal airport (which is located in a floodplain) to accommodate jets. The expansion would involve rerouting highway 33 through extensive, high quality wetlands. The Preliminary Environmental Assessment (PEA) has been completed. Projected wetland losses include 60 acres of wetland fill and at least 88 acres of indirect wetland impacts."Indirect" wetland impacts include clearcutting or topping off trees from wooded wetlands.
Both the U.S. Army Corps of Engineers and the Wisconsin DNR noted in their reviews of the PEA that the "Purpose and Need" for the airport had not been adequately presented, especially given the magnitude of projected wetland loss. Deficiencies/Problems with the analysis include: projections for future airport traffic are unsubstantiated; economic development is listed as an important factor, but a supporting economic analysis is lacking; alternative locations for airport expansion are not given adequate review or discussion; and indirect impacts related to fragmentation and degradation of a designated primary environmental corridor are not discussed.
How to remedy this situation? At the very least, a complete Environmental Impact Statement must be prepared before the airport expansion is allowed to proceed. The notion that a "Finding of No Significant Impact" could be issued is appalling. An EIS would require a closer look at purpose and need and a review of alternatives to expansion into wetlands. The Wisconsin Wetlands Association will continue to work with the local group, Taxpayers Against Airport Growth, to fight for adequate environmental review of the airport project and will keep our members updated on the status of our efforts. To receive updates on the West Bend airport and to stay informed on other important wetland issues, sign up for our occasional email alerts.