We are parents of a family with direct access to Lake Michigan. We are not part of any lakeshore homeowners’ association. We simply love the Great Lakes and am very troubled by the artificially low water levels caused, we fully believe, by decades of ill-advised dredging of the St. Clair River by the U.S. Army Corps of Engineers as part of an irresponsible and ecologically, environmentally and economically ruinous policy of opening up the freshwater Great Lakes to international (i.e., saltwater) vessels. Specifically, we most sincerely, respectfully and strongly recommend the following:

1. Please immediately remove Mr. Eugene Stakhiv from any studies or decision-making in this matter. As a career employee of the U.S. Army Corps of Engineers, Mr. Stakhiv is not independent in appearance, and we believe he is most likely not independent of the Corps’ actions in fact, either. As a career employee of that agency, the decades of bias towards the Corps’ harmful dredging of the St. Clair River are simply too much for Mr. Stakhiv to overcome, even if only subconsciously. For the good of truly independent, unbiased scientific research and the best decision-making for all Great Lakes stakeholders, Mr. Stakhiv should immediately resign or be removed.

2. Please immediately and seriously pursue a man-made structure or structures to restore Great Lakes’ water levels. Those who claim we should not tinker with nature are in a serious contradiction because the U.S. Army Corps already did very serious and damaging tinkering with their insistence on constantly dredging the St. Clair River for at least the last 50 years. We are simply seeking to repair the very serious damage done by the Corps to our wonderful Great Lakes system, especially by the Corps’ destruction of the natural “hard” bottom of the St. Clair River and the resulting persistent erosion for decades which has magnified the low water levels problem.

3. Please immediately state in writing the inescapable conclusion that the greatest weight of all the credible evidence clearly supports – that overall the opening of the Great Lakes to international shipping has been a complete disaster and has been, on balance, an enormous ecological, environmental and economic loss for both the United States and Canada. Billions of dollars of lakeshore property and recreational tourism has been damaged or depressed due to the unacceptably low water levels. Great Lakes fishing has cumulatively sustained billions of dollars of losses due to the introduction of numerous invasive species too numerous and ecologically/environmentally damaging to list and explain here. Finally, due to the relatively small international vessels that can be admitted to the Great Lakes due to the undersized locks, as well as the rise of east coast (e.g., Baltimore, Norfolk, Newark, New York) and west coast (e.g,. Los Angeles, Portland, Seattle) ports as well as air cargo, any economic “advantages” have only amounted to a small fraction of the overly-inflated dollar figures they were projected to be, while the real ecological, environmental and economic losses to the Great Lakes due the to the terrible decision to pursue international shipping into the Great Lakes – and the Corps’ horrible dredging of the St. Clair River – have amounted to many more times that in real, quantifiable harm to Great Lakes stakeholders.

4. Seriously consider and timely pursue practical actions to make feasible the closing of the Great Lakes to international shipping. It is time to cut both Canada’s and the United States’ devastating losses from this seriously failed experiment.

We ask the International Joint Commission, as well as the International Upper Great Lakes Study group, to please take seriously our comments/input and do the right things now to restore Great Lakes water levels and save this wonderful water (and SO MUCH MORE) system from any further ecological, environmental and economic devastation by the U.S. Army Corps of Engineers’ ruinous decisions, policies and actions. Thank you very much.

Sincerely,
Bart & Jodi Williams
West Bend, Wisconsin

Vibrant wetlands sustain so much of the life around us in cottage country. From moles to moose, all rely on finding the right habitat at the watering hole. I have seen our vibrant wetlands recede in the last 13 years and especially rapidly in the last few years; the loss of active beavers and their dams; woodland lakes turn into grasslands. Along with climate change, lake effect precipitation does not help with our loss of water and the wind takes it away. If precipitation is blown in from far away, it runs out of Georgian Bay quickly to the south.
We have a modest family-run cottage resort on a small bay on Georgian Bay that I have been part of since 1960. The water was low in my childhood and very high in my teenage years. I know that this is how it has always been here since recorded history. But the low levels that have developed in the last 13 years show no sign of following the familiar pattern. We had a pool installed 12 years ago and accepted at that time that our business was entering a different phase of life as we knew it. No longer could we rely on the abundant expanse of water as a natural resource for swimming. It used to be exciting to see large fish swim along our granite shoreline; a natural feeding and spawning area with a great variety of aquatic plants and minnows. Two ends of the bay always had the wild rice, lily pads, some pickerel weed and cattails. Boat rides took us through a myriad of small bays with some shallow shoreline areas where the same familiar plants grew. Over the course of a lifetime that is what I remember and have loved about this part of the world.
Today the same aquatic plants are still here, but there is an overwhelming amount of pickerel weed and invasive eurasian milfoil that seem to thrive in the sustained low water level of our bay. Spring run-off of fertilizing phosphorous and nitrogen, along with sunshine and drought conditions in summer, capped by low precipitation and the inability to sustain even the low water level in our bay is creating more of a wetland than a bay each year. To extrapolate this pattern, grassland will grow over wetlands, wetland will take the place of shallow bays – small and large – and only the very deepest areas of Georgian Bay will remain as Georgian Bay.
Our wetlands and shoreline are invaluable resources that need research and constant monitoring . We are adapting to climate change. Our knowledge and actions contribute to a healthy eco-system. We are striving to remain a sustainable shoreline tourism business. Georgian Bay needs water before it is too late. Low water levels are a man-made problem that has a man-made solution. Please restructure the solution to include all forms of life on Georgian Bay.

September 28, 2012

International Joint Commission, Canadian Section,
234 Laurier Avenue West, 22nd Floor
Ottawa, ON K1P 6K6
&
International Joint Commission, US Section,
2000 L Street, NW
Suite #615
Washington, DC 20440

To Whom in May Concern,

Re: International Upper Great Lakes Study, Public Comment

Some of you reading this letter may be aware of the Baird (2005) report on “Regime Changes (Man Made Intervention) and Ongoing Erosion in the St. Clair River and Impacts on Lake Michigan/Huron Levels” that was commissioned by the Georgian Bay Association (GBA). I was the principal author of that report with much support from many of my colleagues here at Baird.

Our report was the first to highlight a serious concern of increased conveyance on the St. Clair River and the related impact of a permanent drop in Lake Huron/Michigan water levels, something that had been going on since approximately 1970 unbeknownst to Environment Canada (EC), the US Army Corps of Engineers (USACE) and the IJC. In the initial meetings we attended with EC and USACE at the outset of the now concluding IJC study, we were told that we could not possibly understand this problem as it was far too complex for a group of engineers and scientists from one company to evaluate. Well it turns out that after many millions of dollars and years of investigation the results of our 3 to 5 months of work on this problem has mostly been confirmed by the 100′s of IJC scientists. Hopefully this in itself provides an added level of credibility for our work on this topic.

We can argue whether the total permanent loss between 1972 and approximately 2000 was 23 cm as we estimated in Baird (2005) or lesser amounts (but still significant) that the IJC has estimated. The IJC indicates that the drop in the Huron/Michigan (H/M) lake level was only partly related to erosion of the St. Clair River bed, whereas we found it to be mostly related to erosion. We also believe that the erosion has continued in the seven years since our original report, more on that below. The IJC on the other hand suggests the erosion is no longer occurring but we have not seen any substantial scientific data to support this, and the analysis presented here suggests otherwise.

A few years ago we wrote a scientific paper on some work that derived from our Baird (2005) investigations for GBA and some other work we were doing at the time. My colleague Dr. Qimiao Lu was the lead author. We submitted the paper to the Journal of Great Lakes Research. I have attached a copy of the paper that we submitted. The editor at JGLR asked us to make modifications and resubmit (see the attached response). Ultimately we elected not to re-submit the paper simply due to the time commitment to conform to the requirements of the journal editors.

What we presented was a method to predict future lake levels based on the historic fluctuations of lake levels. The procedure is complicated but it is well explained in the attached paper. We have attached four figures consisting of a comparison of predicted lake levels using the technique we have developed and the actual measured lake levels for Superior, H/M, Erie and Ontario (see Figures 1 to 4 attached). The measured data is shown in red for our calibration period and blue during our predictive period (i.e. we finalized the development of our predictive technique in 2005 and have not changed it since). It is remarkable how close we were able to predict the measured lake levels on Ontario and Erie between 2005 and the end of August 2012.

Now comes the alarming part. For Superior and Lake H/M our predictions have diverged from the actual lake levels over the seven years since 2005. For H/M this divergence started just before our predictions began (i.e. just before the change from red to blue in the measured data in Figure 3). The H/M levels are at least 50 cm lower than where we predict they should be (keep in mind from the Erie and Ontario results our methods may under or over-estimate actual levels by 20 cm or so in any given month). It is important to note that the difference between predicted and measured levels on H/M has been steadily increasing over this period. As there is no significant difference between predictions and measurements on Erie and Ontario, these differences on H/M and Superior are either related to climate change between the upper and lower lakes of the basin, erosion of the St. Clair River, or both. It should be noted that a reduction of lake level on H/M related to erosion of the St. Clair River could result in a lake level drop on Superior as a result of the controls on Superior releasing more water to H/M.

There is another way to evaluate the change in lake levels that relates to the change in head between Lake Huron and Lake Erie, normalized to eliminate the influence of fluctuations in precipitation and evaporation. This “normalization technique for head drop” was first presented in Baird (2005) and was one of two different approaches we applied that pointed to an approximate 23 cm loss of lake level on Lake H/M between 1972 and 1999. We have applied this technique to update our predictions to the end of 2011 as shown in Figure 5. This figure shows that since 1999 there has been an additional 22 cm of loss in water level for a total of 45 cm since 1972. Differential and recent climate change between the upper and lower lakes of the basin is one possibility for this permanent loss of water from the upper lakes. From our own analysis of the St. Clair River bed changes after 2005 we are of the opinion that changes to the river bed have continued and also are a contributing factor. It is interesting that the total estimated drop of lake level since 1972 of 45 cm is similar to the difference between our predicted and measured lake levels shown in Figure 3 (of approximately 50 cm). This further suggests that the permanent loss in the H/M lake level since 1972 has been occurring at a much greater rate than anything we have seen dating back to the 1800s, and from our analyses this outcome mostly relates to direct and indirect impacts of changes to the St. Clair River.

The two approaches presented above are complex and will be difficult to understand for many readers. The simplest way to present the ongoing issue of low levels on H/M is to review the head difference (or difference in water surface elevation) between Lakes H/M and Erie and compare this to differences between Superior and H/M and Erie and Ontario as shown in Figure 6. It is evident from this figure that there has been little or no change in the difference in lake levels between Superior-H/M and Erie-Ontario over the last 100+ years, and yet there has been a dramatic and continuous, even accelerating trend of drop in H/M compared to Erie levels. From a geologic perspective, there is no reason that the average lake level on H/M should be declining relative to the Lake Erie level (glacial rebound does not figure into this process as the outlet of Lake Huron at the St. Clair River is relatively stable in elevation in geological time). Paleo data and geologic records attest to the fact that the lake levels on H/M have been fluctuating within a stable range with no long-term trend of reduction in levels for thousands of years. It is only since the onset of anthropogenic changes to the St. Clair River in the mid-1800s have we seen a steady, and recently accelerating, decline in H/M levels.

It is interesting that in the multi-year study just being completed by the IJC, we have never been approached to specifically explain the techniques we describe above and presented in Baird (2005), nor have they been directly addressed by IJC in their reports.

In any case, whether we have permanently lost 23, 45 cm or more from the Lake Huron/Michigan level since 1970 the trend is for ongoing loss from all three methods of analysis we have presented here. Also, it is accepted by IJC from their 1987 report “Report on Potential Measures to Alleviate Problems Created by Current High Lake Levels, Task 5, St. Clair/Detroit Rivers” that there was at least 40 cm in permanent water level drop due to the various dredging campaigns on the St. Clair River (dredging to create a 20 ft channel in the late 1800s, sand and gravel mining from 1910 to 1925, dredging to create a 25 ft channel in the early 1930s, the final dredging to create a 27 ft channel in the early 1960s). Therefore, the permanent drop in water level due to human impacts on Lakes Huron/Michigan dating back to the 1850s amounts to something in the range of 63 cm to 85 cm, or more.

I respectfully submit that a “do nothing approach” to the current issue of low water levels on Lakes Huron/Michigan and the causes for those low water levels would be extremely irresponsible. The ecological and financial consequences of past and continued permanent lowering of lake levels on Huron/Michigan (and possible knock on impacts to Superior) are exceedingly large in comparison to costs of compensation or mitigation for the human impacts on the levels.

Yours Sincerely,
Baird & Associates

Robert B. Nairn, Ph.D., P.Eng, Qimiao Lu, Ph.D., P.Eng.
Principal Associate

Att.
• Figures 1 to 6
• “Cyclic Lake Levels on the Great Lakes Past and Future” (JGLR paper submission #4060)
• JGLR 4060 Reviews to Author.pdf (Review and draft paper submission)

I am opposed to the new regulation for Lake Superior because it will have a negative impact on Georgian Bay water levels. We don’t need more human intervention unless it is in the form of re-establishing the “natural” flow of our Great Lake system. In other words, finding the best ways and means to restore the water system back to the way “nature” had originally designed it; back to before humans had reversed the Chicago River, and back to before humans had dredged the St. Clair River.

If, however, there are no ways and means to restore our Great Lakes as they once were, or at least not in the near future, then I am in support of control structure(s) in the St. Clair River to mitigate the damages done by years of government interference. The governments of Canada and the US commissioned the dredging of the St. Clair River without seriously considering if they should. And of course the resulting weirs to control the water loss throughout the whole of the Great Lake system were never actually constructed. The governments should not be absolved from their responsibility because of time, nor the fact the contractor is no longer in business. Since the government changed the “natural” Great Lake system and it must now continue to implement controls for the areas it has negatively impacted. The government cannot simply “stop” or ignore the damage it has caused because a mistake was made; the mistake needs to be corrected before more damage is done! Low water levels are destroying the ecological system! Our water has been taken over by seaweed where previously non-existent, decaying vegetation, and the growth of algae and bacteria. Our resulting larger beach areas have been taken over by invasive grasses and vegetation. Geese are everywhere now, polluting our beaches and water further. Inlets have completely dried up.

We could argue endlessly on how much water was lost due to what cause; however, that should not be the issue. The issue is to save our Great Lakes; how do we get the levels of our waters, particularly Georgian Bay, back to within the historical averages prior to human intervention? And we have to raise the water levels now!! Our water is at the “low water crisis level” identified in the 1993 Levels Reference Study for Lakes Huron and Michigan and, therefore, should trigger remedial action from the Canadian and US governments. The governments should attend to constructing a control system in the St. Clair River that would not only restore the water levels regardless of the various reasons for the losses, but that would also accommodate any historical extremes and/or any future global warming negatively impacting water levels. Also, a temporary restriction should be put in place to immediately start correcting the problem until a permanent solution is implemented.

Another one of my biggest concerns is while the IJC is being public about the low water study, there still seems to be a lot of people unaware of the discussions or, for that matter, the existence of the IJC. I think a mandatory survey, like that of a government census, should be sent to everyone with the results being made public via radio and TV. A brief history of the past and present water situation should be explained, including the details of human intervention. A lot of people are unaware that “people” have interfered with the water levels! A simple vote should be done on control structure(s) (yes, no) based on an acceptable +/- 1ft range around historical average.

And finally, the least of all this, relatively speaking, is the fact that our property values have tremendously plummeted. As mentioned above, the continued low water issue is depleting the water quality of what little water we do have. About a month ago my boyfriend had a hard time getting his little aluminum boat out of the marina because he had to contend with weeds, thick muck and the low water levels. This affects the both of us getting to his island cottage and I know it is detrimental to the marinas and I’m sure it is not good for others trying to enjoy the waters in and around Georgian Bay. I have also just learned, that our particular marina is going to be dredging this Fall which should be unnecessary.

Thank you for your consideration of my points.

Yours sincerely,

Lynn Kennedy

I am opposed to the new regulation for Lake Superior because it could have a negative impact on Georgian Bay water levels. I am in support of control structure(s) in the St Clair River to mitigate damages done by years of government interference with the natural flow of water that affected the levels of the Great Lakes system.

We could argue endlessly on how much water was lost due to what cause; however, that should not be the issue. The issue is how we get the levels on Georgian Bay back to within historical averages prior to human intervention. The water level has been too low for too long and it is now at the low water crisis level identified in the 1993 Levels Reference Study for Lakes Huron and Michigan and therefore, should trigger remedial action from the Canadian and US governments.

One such example of government influence on the natural water flow is when Canada and the USA commissioned the dredging of the St Clair River. This was agreed to with the condition that weirs would be put in place to control water loss. The weirs were never put in place and the governments should not be absolved from their responsible because of time, nor the fact the contractor is no longer in business.

The governments should now place weirs in the St Clair River or use a more modern control structure that can accommodate any historical extremes. A control system in the St Clair River is also prudent if global warming were to further impact waters levels in the future. A temporary restriction should be put in place immediately to start correcting the problem until a permanent solution is in place.

My biggest concern is while the IJC is being public about the low water study, there still seems to be a lot of people unaware of the discussions. I have recently spoken with a marina owner in Honey Harbour who was unaware of his opportunity to provide his comment. I think a mandatory government census should be sent to everyone within the basin with the results being made public. There are a lot of voices not being heard that do have an opinion and a concern. A simple vote should be done on control structure(s) (yes, no) based on an acceptable +/- 1ft range around historical average.

The continued low water level has reduced property values because of reduced access to water access only properties. Last Saturday I had a hard time getting my aluminum boat out of the marina because I had to contend with weeds, thick muck and the low water levels. This affects me getting to my island cottage and I am sure it is not good for the marinas and others trying to enjoy the waters around the Bay.

Thank you for your consideration of my points. Yours sincerely,
Chris Tansley

After reading the views and the comments of Georgian Bay Forever, I am strongly encouraged to support this important organization in their plea to the IJC for the control and restoration of Georgian Bay water levels. At present, the extremely low water level is affecting our tourism industry, the safety of boating, our fish and wildlife habitat, as well as accessibility to many island and “boat-accessible” properties. Please heed the words of Georgian Bay Forever’s executive director, David Sweetnam, that Georgian Bay “needs a bit of manmade help” for our habitat and environment.

It is disappointing that after years and years of study, a report is issued whose conclusion (or rather lack thereof) contains so much hedging that it essentially says it is too complicated to deal with the problems rather than provide a much needed blueprint for action to solve the problems. The report acknowledges in its Key Findings that “…lower (water) levels are likely…” but then stands silent on taking any possible actions to remedy the problems. It seems that the Study writers are unable to see what the IJC constituents (and the commenters on this board) can clearly see – water levels in Lakes Huron and Michigan have simply been very low for much too long and are heading lower.
Water levels do fluctuate. The reasons for this cannot always be explained. But to cover one’s eyes to the clear evidence of the continuing trend of low-water and the historical lows now being reached in Lakes Michigan and Huron is inexcusable.
When reading the section of the report regarding Restoration of Lake Michigan and Huron levels one wonders if the Key Finding is somehow referencing another section of the report which was somehow excluded. This Key Finding is so narrow and biased towards the few(er) items suggesting no action it causes real concern as to the motives behind it. It is the height of folly to suggest that restoration projects, particularly on the St. Clair River, which are put in place to reverse the damages done by “human induced” changes are too costly, politically unfeasible and would cause too much negative impact.
The key point here is to RESTORE what should not have been done in the first place. It seems that there were no concerns about funding when the dredging of the St. Clair River was allowed to take place but now when a “technically feasible” cost-effective solution is proposed, almost any argument against restoration is being offered up no matter how far-fetched or unrealistic. And as for the dredging’s impact on water levels, a precondition for the dredging of the St. Clair river was a commitment by both national governments to build structures that would compensate for the effect of the dredging – 50 years ago! The report states that it will take 20 years for approval and design – is this how long it took for the dredging to be approved? And if so, then let’s get started on this process now. And with water levels at or near historic lows, to give equal weight to the negative impact that would occur “if” water levels become higher in the future is simply unrealistic. If this were actually to become a concern many, many years from now then another study like this one will be in order. Meanwhile, the prima facie evidence of current and future low water levels simply cannot be dismissed with low-likelihood “what if” scenarios about the future.
The IJC’s own earlier Study identified the low water crisis level for Lakes Huron and Michigan which should require remedial action from government. We are NOW at this level but this report refuses to acknowledge that earlier study.
It is difficult for a layman to know what is behind the timidity of the report writers in refusing to support any action on realistic proposals to solve what is now a clearly identifiable problem. But to wait another ten-twenty-thirty years until it is too late to reverse a problem that will by then have become a crisis is another way of saying let’s just cross our fingers and hope for the best. To decide to not make a decision IS a decision. However, it is a fraudulent one which will come back to haunt not only those of us who use and love the lakes but future generations of lake users. We encourage the IJC to live up to its mandate to protect these lakes. Make the right decision to act now so that our children will have the benefits and joys of these lakes just as we did.
Thank you.

It is highly likely that there is a man-made reason (perhaps more than one) for Lakes Michigan/Huron to be at such low levels. While all of the lakes are below their long term averages due to the drought, Michigan/Huron is down over two feet while the rest are only down about a foot. I leave to others to determine the reasons for this, whether it be dredging in the St. Clair river or some diversion such as at Chicago. But the cited cost of remediation (called “too expensive” by some) is miniscule compared to both the economic and ecological impacts. In many areas Lake Michigan frontage has become difficult to sell due to low water, exposed rocks where sand used to be, and accumulation of green algae along the shore. The decline in the value of lake frontage in some areas is well over $1,000,000 per mile. What man has done, man can and should un-do, and please, don’t tell us it will take 20 years to study it and get the necessary approvals. If it were some poor farmer plowing up wetland the EPA would be all over him in short order. Yet here a probable man-made problem with much greater impact seems to be getting an “Oh, well”.

We have had our cottage since 1960 in the Archipelago, Parry Sound, Ontario and have not seen the water levels so low as they are now. There must be a solution to this major problem of low water levels in the Georgian Bay and other Great Lakes!
Please forward our concerns to the proper administrationsl responsible for the very low water levels that are occuring.
Thank you.
David and Jeanne Geddes

I’m the Harbormaster of North Point Marina in Winthrop Harbor, IL, the largest self-contained marina in the Great Lakes. I’m keenly aware of the steady water depletion of Lake Michigan effecting both pleasure boating and Great Lakes commercial shipping. Our marina is forced, like so many others, to constantly dredge and to make other concessions to our ever shrinking lake. I’ve been aware of the St. Clair River dredging issue for many years and have waited for the Army Corps to finish the original project by installing the weirs that were a part of the original project or, failing that, take other measures to stop the increased outflow of fresh lake water to the ocean.
Since the Great Lakes contain over a quarter of the worlds freshwater supply, I would think that we’d want to preserve this vital resource not so much for my industry but for the millions of folks living in the Great Lakes area who are dependent on a safe freshwater supply. Global warming has upped the ante and called our bluff about doing nothing to control the current outflow. Until we can work our way through federal bureaucracy, various commissions, and assorted study groups, why don’t we use the controls that we have (Niagra Falls flow rate) to, at least, slow the waste of our great resource to the ocean?