Friday, July 1, 2016

Kohler course plan would severely impact the environment, report shows

This blog has been reporting repeatedly since 2014 on the controversial proposal to convert a heavily-wooded, wetland-and-Native American artifact-rich 247-acre nature preserve adjacent to the popular Kohler-Andrae State Park into a high-end, 18-hole golf course along the Lake Michigan shoreline.

The proposal includes using four acres of state-owned land.

The golf course site is owned by the Kohler Company, a powerful, privately-owned manufacturing company with connections to the pro-corporate, GOP Walker administration.

The Wisconsin Department of Natural Resources has released, amid additional controversy, a preliminary Environmental Impact Statement, (EIS), based heavily on information provide by the company.

The EIS draft was also completed at public expense though no formal proposal for the golf course has been made to the state, and multiple local and federal approvals would also be needed before the course ever break ground.

Here is a link to a Journal Sentinel story about the draft EIS.

And here is a link to the draft EIS.

If environmental protection is goal of the state - - a supposition constantly put in grave doubt by Gov. Walker and his "chamber of commerce" DNR - - any reasonable person reading the document would conclude that the project's environmental harm far outweighs any perceived advantages.

Read the document. Here are some key excerpts from my first reading:

5.1.11 Wildlife

The Project would result in significant changes to the current landscape and the

associated habitats used by wildlife. Some of the changes may have positive impacts to wildlife, while others may have adverse impacts. The Kohler Property is almost 100 percent contiguous forest and at least 50 percent of that would be retained as fragmented forest ensuring some habitat availability during songbird migration. Invasive species management and restoration of native trees and shrubs in invasive removal areas would help control exotic and invasive species in the retained forest. The forest edge along turfgrass and human use areas created from fragmentation of the forest would probably increase the challenge of exotic and invasive species management. The edge would likely provide some habitat for species that inhabit transitions between forest and openings. Habitat value would likely be diminished, however. Tree clearing would occur on the Property for each hole, the access road, the clubhouse/parking lot complex, the practice range, the maintenance facility, the restrooms, and the irrigation pond. Tree clearing may also occur in forested areas between tee and fairways to provide lines of sight. Interior forest bird nesting habitat is likely present within and adjacent to the Project boundary and would likely be eliminated. Wildlife species inhabiting these areas would be permanently impacted by the loss of habitat. However, impact to these species is not expected to create a significant effect on regional populations. 

Following construction of the proposed golf course, forest cover within the Kohler Property would likely provide stopover habitat similar to that in the adjacent residential areas and Kohler-Andrae. However, reduction of the forest to 50 percent cover would likely result in a similar reduction of available stopover habitat on the Kohler Property. The department recognizes a 10-mile zone landward of the shoreline as potential stopover habitat. However, few forests of this size exist within that zone along this stretch of shoreline area.
The proposed amount of clearing would be considered a land use change. Forestry Best Management Practices for water quality should be followed to protect waterways and wetlands, and a county cutting notice would need to be filed with Sheboygan County.

An approximate 5 acre irrigation pond that would be constructed could provide new open water habitat for amphibians, reptiles, water birds, and aquatic organisms. In order to function as a viable wildlife pond, its design would need to include such features as natural substrate, varying depths, natural aquatic structure, submergent and emergent aquatic and shoreline vegetation, and the exclusion of surface water run-off to prevent entrance of nutrients and chemicals from surrounding turf areas. These natural features are usually omitted in irrigation ponds due to problems they cause with irrigation equipment. A pond lacking enough natural features would provide little benefit to wildlife, other than Canada geese (Branta canadensis). The resident “giant” Canada goose (Branta canadensis maxima) usually utilize this perfect mix of open water, surrounded by turfgrass in wide-open spaces that golf course irrigation ponds offer. Their numbers, feeding, and defecation often increase to the point that they become a nuisance to the operation of the course. A natural pond with a wide, natural shoreline buffer would help make the pond less appealing to them. However, a mix of population control methods and hunting are often needed.

The area south of Sheboygan, including the state park lands, has been recognized by others as an important resource for migratory birds. It's been identified as an Important Bird Area, or IBA, a world-wide program in which Wisconsin participates. This area was recognized as an IBA due to the extensive use by birds as on-shore migratory stopover habitat and off-shore wintering waterfowl habitat. This area has also been identified by the Wisconsin Stopover Initiative as a Tier 1 area, the highest level of significance for migratory bird stopover habitat (Grveles et al. 2011). This area was recognized as an IBA due to the extensive use by birds as on-shore migratory stopover habitat and off- shore wintering waterfowl habitat.

The 2013 Christmas Bird Count for Sheboygan noted 50 species, and the Wisconsin Breeding Bird Atlas lists 41 probable and 15 confirmed species for the Sheboygan South survey area. About 41,000 raptors of 26 species have been banded from 1950 through 2013 approximately 8-miles south at Cedar Grove Ornithological Research Station. Additional bird observations on the property are listed in Table 6.

Migratory birds that utilize Lake Michigan waters and the beach area along the Kohler Property would likely be minimally impacted by the Project. These areas will remain undeveloped, but there would be an increase in human disturbance nearby that could negatively impact the birds.

5.1.7 Wetlands

There are approximately 81 wetlands totaling approximately 124.1 acres on the Kohler and Kohler-Andrae Property, ranging from small wetland depressions to an extensive riparian wetland complex associated with the Black River...

The wetland community types present onsite exhibit a plant community with high to exceptional condition with a majority of stressors (invasive species for example) either absent or minimally present. Habitat is provided for a variety of flora and fauna, including threatened, endangered, and special concern species. The combination of contiguous upland and wetland plant communities in a large, unfragmented block of habitat adds to the significance to the Property’s (Kohler and Kohler-Andrae) value for wildlife. The wetlands are hydrologically connected to Lake Michigan. Sand dunes that are eroded by wave action provide a littoral drift source that is critical to lessening erosion in the remainder of lake and also protects the wooded areas landward of the dunes. The wetland communities near the Black River provide value in storing and attenuating peak flows, reducing the potential for downstream flooding. Additionally, the wetlands have a role in shallow groundwater recharge and discharge which in turn, benefits surface waters and adjacent habitats. The wetlands also provide storm water and flood storage benefits.

The wetland impacts described below are based on the selection of Alternative E, Kohler’s preferred alternative. As stated above, compared to the other alternatives presented by Kohler, the Alternative E entrance route and maintenance facility locations would result in the least impact to wetlands (Table 10Figure 17).

5.2.13 Archeological and Historic Resources

Over the course of the last few years, Kohler has proposed a number of developments
for the Kohler Property located immediately north of Kohler-Andrae. Anticipating that development of this area would likely necessitate permitting by both federal and state agencies (Section 106 of the National Historic Preservation Act for the former, and Chapter 44.40 of State statutes for the latter), Kohler proactively undertook cultural resource investigations to identify and evaluate historic properties potentially located on the parcel. Federal agency involvement, consistent with provisions of Section 106, will ensure thoughtful and measured approaches to mitigate potential adverse impacts to identified historic properties, including opportunities for consultation with members of the local community as well as tribal interests.

A review of information complied by the Wisconsin Historical Society indicates that seven (7) prehistoric archaeological sites, including one burial mound group, have been identified as co-incident with the property. The largest of these sites (SB-0173, which extends over most of the property) includes both prehistoric (predominant) and historic (much more limited) habitation components, each of which has been evaluated as potentially eligible for the National Register of Historic Places. Of note, inclusion on the NRHP does not preclude development. Burial mounds and other burial sites are provided with a very substantial measure of protection under provision of WI Statutes. Note further that the location of one reported site (SB-0174, a cache of “net sinkers” first reported in 1902) is unknown. The Department has a tribal consultation policy if proposed actions would envoke the need for such consultation. However, consultations for this project will likely fall under federal jurisdiction.

6.2 Environmental Effects, Their Long-term and Short-term Significance and Cumulative Impacts

The primary impacts associated with the Project involve the removal of vegetation and the grading that would be required to shape the landscape to accommodate the golf course and the installation of a high capacity well. The most obvious secondary impacts would be loss of habitat, potential encroachment of invasive species, and potential impacts to nearby wells. There may be additional short term secondary impacts associated with the construction and physical development of the Project. Impacts resulting from failure or improper installation and maintenance of erosion control devices may result in offsite sediment movement.

Groundwater Resources

The proposed golf course high capacity irrigation well would tap the same Silurian dolomite aquifer that is used by most of the private water supply wells in the area. Based on department projections, operation of the irrigation well may permanently lower groundwater elevations in private wells by 2 to 23 feet in a worst case with an average predicted drawdown of approximately seven feet. There is significant uncertainty associated with this prediction due to the poorly understood flow system within the fractured dolomite aquifer. Affected well owners may need to lower pumps or deepen wells. There would be additional wells for the non-irrigation water needs of the facility, but the proposed location, capacity and number of wells has yet to be determined. It is assumed that the other wells would be in the Silurian dolomite.

Potential Impacts to Ground and Surface Water Resources

The Kohler Property has predominantly sandy soils with high infiltration rates and high hydraulic conductivity. This combined with a shallow depth to the surficial groundwater aquifer increases the potential for pesticides and fertilizer to leach into the shallow aquifer which may additionally reach the Black River, Lake Michigan, and the associated wetlands.

By their very nature, most pesticides create some risk of harm to humans, animals, or the environment because they are designed to kill or otherwise adversely affect living organisms. Studies have shown that several commonly used pesticides have been identified as probable human carcinogens and may be linked to birth defects, endocrine disruption, reproductive effects, neurotoxicity, and kidney/liver damage. 

Chronic, long- term exposure to many pesticides and the associated health risks are not completely understood and it may take years of research before the effects are fully known. Considering their toxicity and ability to leach, monitoring groundwater quality for pesticide contamination and minimizing pesticide use through implementation of an IPM are potential ways to reduce the potential negative effects of pesticide use (New York State, 1991).

At the same time, pesticides can be useful because of their ability to kill potential disease-causing organisms and control insects, weeds, and other pests. Biologically- based pesticides such as pheromones and microbial pesticides are becoming increasingly popular and often are safer than traditional chemical pesticides. Further examination of alternative pesticide management approaches (including alternative products), gaining a better understanding of golfer expectations, educating those that maintain the courses, and incorporating IPM plans may reduce the health and environmental risks associated with pesticide use.

Fertilizer and pesticide requirements may be different during course construction and establishment than for long-term maintenance. Establishment of grasses on fairways, tees, and greens each require specific ratios of nitrogen/phosphorus/potassium for establishment. Once grasses have been established, less fertilizer is needed for maintenance (Walker and Branham, 1992).


The proposed golf course would directly impact 5.01 acres of rare wetland natural community types. Table 10 and Figure 17 summarize the permanently impacted wetland locations and type on Kohler and Kohler-Andrae Properties.

On the Kohler Property three of the six rare wetlands totaling 0.26 acres would be permanently filled, and the remaining three totaling 0.03 acres may experience secondary impacts from tree clearing, modification of hydrology, storm water runoff, and invasive plants.

Approximately 2.65 acres of rare wetlands would be directly impacted by the proposed golf course (Table 10). Four wetlands totaling 0.06 acres wouldn’t be directly impacted but may experience secondary impacts from tree clearing, modification of hydrology, storm water runoff, and invasive plants. Loss or degradation of rare wetlands would reduce habitat for numerous species, including amphibian and reptile breeding habitat, fragment habitat for many species of wildlife, decrease bird habitat through tree removal, and reduce tag alder habitat that supports state special concern blue-winged teal and kingfisher species.

Approximately 0.11 acres of wet meadow wetlands would be directly impacted by the proposed golf course.

Approximately 1.99 acres of rare wetlands would be directly impacted by the proposed golf course. This is approximately 1% of the total riparian wetland complex. Secondary impacts may result from tree clearing, changes in hydrology, and encroachment of invasive species.

Regional wetlands are not anticipated to be affected by the proposed golf course irrigation well drawdown due to the separation between the shallow aquifer and the Silurian dolomite aquifer.

Rare Wetlands

Several globally rare wetlands within the Project Area on Kohler Property are proposed to be directly impacted by filling for the construction of various holes and the associated grading and construction of tee boxes, greens, fairways, and tree clearing. Secondary impacts from things such as changes in hydrology, irrigation, and application of fertilizer may impact rare wetland communities.

Dominant vegetation consists of Canada bluejoint grass (Calamagrostis canadensis), Baltic rush (Juncus balticus), sedges (Carex sp.), northern bugleweed (Lycopus uniflorus), willow species (Salix sp.) and goldenrod (Solidago sp.),. Occasional green ash (Fraxinus pennsylvanica) trees occur within these wetland types. Areas of tag alder (Alnus incana) occur within this wetland type.

 Although invasive species occur in some of the wetlands, they are rarely dominant. Most of the species are conservative. In general, these rare wetlands have exceptional floristic diversity and are relatively free of invasive species.

These wetlands support threatened and endangered species habitat functions and are important breeding grounds for amphibians. Additionally, the wetlands retain intact groundwater processes, including groundwater recharge and discharge, which benefits local surface and groundwater quality within adjacent habitats...page70image14856 page70image15016 page70image15176

Wildlife and Rare Species

The site’s nearly 100% forested canopy would be reduced by nearly half. Habitat value may diminish along forest edges near turf grass and human use areas.

Kohler plans to avoid all impacts to a rare invertebrate. If impacts cannot be avoided, an Incidental Take Permit would be required.

The avoidance of the rare invertebrate and its habitat would also protect other rare invertebrates, which were not surveyed for but are known to occupy similar habitat.

Additional surveys are required to determine if impacts to a rare mammal could be avoided.

Several rare plants were observed on the Kohler Property with the majority of plants occurring in areas outside of proposed development. Although State Endangered, Threatened and Special Concern plants are not protected on private property, Kohler would work with the department to develop mitigation, such as transplanting individual plants to suitable habitat or establishing new populations in suitable areas.

Higher levels of traffic may increase congestion at the Kohler-Andrae entrance and increased demand for overflow parking on nearby roads during Kohler-Andrae’s peak visitor times and golf course special events.

6.3 Significance of Risk

There is information and data that would have been beneficial for the writing of the draft EIS to more accurately and with more certainty review the Project and quantify risk to environmental, historical, archeological, and socioeconomic resources.

For example, there are known burial mounds on the property and there may be other areas of archeological significance. In a letter dated June 21, 2016, the USACE invited tribes to consult on the proposed action. That federal process has not been completed.

Additional information regarding potential traffic impacts (using Saturday and Sunday afternoons as peak traffic times as compared to Friday afternoons, and including a roundabout analysis) would also allow the department to more accurately review and provide suggestions to ensure that users of the Kohler-Andrae and the golf course would be able to enter and exit reasonably.

The additional traffic analysis would also promote further discussion and consideration of items including emergency response. In the event of an operational problem such as a spill, fire, or other hazard, access to the Kohler and/or Kohler-Andrae Properties may be limited especially during an event or a peak time of entry into Kohler-Andrae or the golf course. A delay in access to the site could magnify the effects of the hazards discussed above. As the project design moves forward, these hazards, in conjunction with emergency response and site access should be analyzed and presented in a document similar to an emergency response plan.

The specific locations of other features associated with the Project including but not necessarily limited to cart and drive paths, septic areas, biofiltration, and storm water treatment areas will need to be identified to ensure that all applicable rules and regulations are complied with. The location of these features will likely be identified and reviewed during the permitting process if Kohler decides to proceed with the Project.

The impacts to the groundwater aquifer and the wells that are supplied by the aquifer are not fully understood. The department has completed an analysis with the best information currently available and discusses the results above in Section 5.1.5, Groundwater Resources. There is significant uncertainty in the prediction of drawdown levels in fractured rock aquifers.


Anonymous said...

All this to play a rich man's game.

Anonymous said...

Won't the fertilizer wreck the wetlands? I don't see where that is included here.

Anonymous said...

Pretty soon the whole state will be privately own and dam the wildlife