§USGS – The United States Geologic Survey (USGS)
1994 study of erosion rates for the north shore bluffs does not support
the Army contention that armoring the bluff in which Landfill 7 sits can
permanently stop erosion.In
fact all the conclusions of this study support the view that this
armoring will fail to stop shore erosion and the contents of Landfill 7
will be washed into
Lake Michigan
if not excavated.The USGS
analyzed the bluffs in 300 sub-divisions between
Evanston
and
Waukegan
over the period from 1887 to 1986 (?).By overlaying land maps from various times the USGS was able to
determine the rate of erosion for the various segments.The conclusion was that while shore protection could create
temporary variances in recession rates between bluff sections, the
protected areas would catch back up to the adjacent recessed areas in
the next time frame and that overall, the bluffs retreated in a parallel
fashion. The implication of
this conclusion is obvious.If
the Army overprotects the bluff containing Landfill 7 relative to the
adjacent areas, this will create a peninsula that will eventually erode
quicker than the adjacent areas to become parallel once again.The Army chose to dismiss the study in response to public
comments, arguing the study does not apply to the situation at Landfill
7.The study included the
caveat that it was to be used for regional planning purposes and not
site specific engineering and the Army used this to justify dismissing
the entire study from the remedy selection process for Landfill 7.This statement does not justify this dismissal because it could
simply mean that the segment data cannot be relied on to forecast the
near term resilience of that segment.In fact, the very next sentence after this caveat is that anyone
planning to build a structure along these bluffs should set the project
back 50 to 75 meters if the useful life of the project is 50 to100
years.The Army chose to
ignore this sentence, and the rest of the study, because the waste
inside Landfill 7 abuts
Lake Michigan
with zero setback. The hazardous waste in the landfill will sit next to
Lake Michigan
for far longer than 50 to 100 years if not excavated and the contents
will remain hazardous for far longer as well.The Army position that capping Landfill 7 in place and armoring
the bluff represents a permanent remedy is indefensible in light of this
study.
§US ACE - The US Army Corps of Engineers gives
guidance to property owners along the Great Lakes for shore protection
through guidance
documents. The newest document published with U-Wisconsin Seagrant
in 2003 marks a fundamental divergence from the previous document
published in the 1970's. Where the ACE previously promoted shore
armoring as a long term effective solution, the new document concludes
that erosion controls are not permanent solutions. Instead,
construction setbacks based on the rate of recession and the expected
useful life of the structure are promoted in the 2003 document. An
additional guidance
document by the ACE in conjunction with the Great Lakes Commission
published in 1999 also concludes that shore protection is no substitute
for construction setback.
§Northwestern
§
Highland Park
Guide
Guidance
Document/
Regulation
Findings
and Recommendations, or Actions Required by Regulation
Recommendations
or Requirements Modified of Waived Based on Shoreline Engineering?
Jibson,
Randall W and Odum, Jackson K. Rates
and Processes of Bluff Recession Along the Lake Michigan Shoreline
in Illinois.U.S.
Geological Survey, Denver, Colorado, 1994
·Shore protective devices had no detectable effect on recession rates
·Temporal and spatial differences existing between adjacent bluff
segments give way over longer periods of time because the bluffs
erode in an overall parallel manner.
·The anticipated life of structures near the bluff should be assessed
for erosion over a 50 to 100 year time frame.
·Any construction along the coast expected to last 100 years should be
set back a minimum 65 to 80 feet
No
U.S.
Army Corps of Engineers, Detroit District and University of
Wisconsin Sea Grant Institute.
Living on the Coast: Protecting Investments in Shore Property
on the Great Lakes. 2003
·“The practice of building close to the edges of erosive coastal
slopes should be discouraged because it minimizes a natural buffer
distance…needed to…accommodate climate changes that are more
extreme than the…historical period of coastal settlement.”
·“setback distances…on properties with existing or planned shore
protection structures should be estimated as if the shore
protection structures were not present. Shore protection can
fail-sometimes quickly and catastrophically.When this happens, the previously protected shoreline tends
to recede rapidly toward the position of neighboring unprotected
shorelines, erasing the benefits gained by the former shore
protection structure”
No
U.S.
Army Corps of Engineers, Detroit District and The Great Lakes
Commission. Living With the Lakes: Understanding and
Adapting to Great Lakes Water Level Changes. 1999
“A
variety of structural options are available to shore property
owners to protect and stabilize bluffs and beaches vulnerable to
the impacts of lake level fluctuations and storm events.The best structural option depends upon the site
characteristics.Professional
design consultation is advisable.None of these options, however, are permanent solutions
against the continued and relentless forces of nature.” Pg. 34
No
The
Heinz Center under FEMA contract. (Mandated
by Section 577 of the National Flood Insurance Reform Act of 1994
(Public
Law 103-325),
Evaluation of Erosion Hazards April 2000
·Relocation away from the shore is the only viable option for
protecting structures already built.
·In discussing if property owners should get a rate reduction for
shoreline protection, “Congress still may want FEMA to ignore
the presence or absence of beach nourishment when setting rates,
or at least offer only modest rate reductions. Nourishment does
not, after all, permanently alter erosion rates.” Pg. 176
No
City
of Highland Park.Living
in a Ravine and Lakefront Community.
“Water
erosion is the most threatening force impacting ravine and
lakefront property. It is a natural force which can be slowed, but
cannot be stopped entirely.”
No
National
Flood Insurance Program Requirements for Insurability of
Coastal Structures
·Community participation in the NFIP requires, “a setback for all new
development from the…lake…, to create a safety buffer….This
buffer will be designated…according to the flood-related erosion
hazard and erosion rate, in conjunction with the anticipated
`useful life’ of structures….”44 C.F.R. 60.5
·Zone of imminent collapse means an area subject to erosion adjacent to
the shoreline of an ocean, bay, or lake and within a distance
equal to 10 feet plus 5 times the average annual long-term erosion
rate for the site…” 44 C.F.R. 59.1
No
City
of Highland Park Zoning Ordinance. Sec. 150 Article XIX
Steep Slope Zone
·“…land should support new structures for a minimum of fifty (50)
years…”Sec. 150.1902(A)(3)
·“The Steep Slope Zone includes…a 40’ setback from the top of a
lake bluff slope.” Special Permit Requirements for Ravine and
Lake Bluff Property and Other Steeply Sloping Lots in Highland
Park
·“…No structures shall be constructed in a Steep Slope Zone.”
Sec. 150.1903(A)
No
City
of Lake Forest Sec. 46-15. Steep Slope Ordinance
“All
building construction shall be on tableland, but in no case shall
a structure or building foundation be located closer than
seventy-five (75) feet to the bluff area.” Sec. 46-15(C)(1)(b)
Building Setbacks From Bluffs
Maybe.
“Variation from any restriction could be recommended if
the…bluff slope does not show any indication of
instability…”Sec. 46-15(D)(d)
Bluff 1/4 mile
south of Landfill 7
Various views of
Landfill 7
Shore make-up
from Chicago to Waukegan
Satellite view of
Landfill 7 with bluff armoring
If you want to know what you can do, stand
up and being counted! Let your legislators know your feelings. You don't
have to be a resident of Highland Park or Lake Forest to be concerned
about this landfill. Lake Michigan is a critical national
fresh water resource.
Send your congressman an e-mail!
Send your senator an e-mail!
Send Governor Blagojevich e-mail!
Send the president an e-mail!
by Steven Pollack
Concerned Citizen
You can become a part of the good fight by helping cover the cost of
advocacy in this matter. While not tax deductible, 100% of your
donation will go towards either litigation expenses or the cost of
publicizing this issue.
