Posted: July 2021

If a marina is going to be developed at the Kalamazoo River Mouth, we all have a responsibility to get it right and fully eliminate all negative impacts. There will be many negative impacts with the proposed marina’s current design, as well as with the construction process; negative impacts that extend far beyond the property of Peg & Jeff Padnos and into adjacent public spaces. Further below we list all the negative impacts that have thus far been revealed.

Over the past four years, the Coastal Alliance has invested about $60,000 in designing several potential Feasible and Prudent Alternatives; alternatives that fully eliminate the negative impacts of the current Padnos design. Here is an image of the most recent conceptual design from FreshWater Engineering and MSA Professional Services.

Click image to enlarge.

The Coastal Alliance strongly believes that a balanced solution, that is both feasible and prudent, can be found that 1) meets the desire of Peg & Jeff Padnos to provide safe mooring for boats, 2) totally eliminates any impacts, now and in the future, to ground water and wetlands.

The Coastal Alliance, working with FreshWater Engineering and marina designers at MSA Professional Services, have created another conceptual marina basin that employs a steel sheet metal seawall to fully stop all wave action. This design eliminates the concerns Peg & Jeff Padnos had with previous alternatives. The new design also fully protects wetlands, ground water, the site of Singapore, water quality, lake sturgeon, prairie warbler and pitcher’s thistle habitat, and eliminates habitat fragmentation. Bruce Lunde, one of the designers at MSA Professional Services, describes the new Feasible and Prudent Alternative as follows:

43 slips from 40’ to 80’ are in the main basin, 12 more are in an upriver dock pod. This main marina is protected by a steel sheet pile double wall that prevents wave damage to the dock system and the boats. The wall system is approximately 12’ wide and is filled with stone. At the downstream end of the basin wall, a submerged culvert penetrates the wall to allow flow through the basin. This basin requires only minimal excavation to trim the shoreline and avoids archaeological sites and environmentally sensitive area.Along the shoreline, a stone revetment protects the upland. This layout also uses a simple gangway for access and provides access during the entire range of lake level elevations.
The dock system can be provided by a wide range of manufacturers. The upstream side of the marina is protected by a sheet pile pier. This extension of the pier will help ensure any large driftwood or other debris is guided around the marina entrance. At the downstream end of the marina, a culvert under the water surface will allow streamflow to pass through the marina. This will take advantage of the natural stream energy to ensure adequate water quality and still provide protection within the marina.

This feasible and prudent alternative design fully eliminates impacts to ground water and wetlands, and meets the private purpose for a marina

The Feasible and Prudent Alternative concept from the Coastal Alliance will:

1. Provide safe mooring for at least 55 vessels, thus meeting the Private Purpose for the proposed marina
2. Fully eliminate the dewatering process during construction, in turn have zero impacts on ground water and thus fully protecting the globally imperiled interdunal wetlands found on the neighboring legally-designated Patty Birkholz Natural Area

The feasible and prudent alternative will also:

• Greatly reduce the excavation process during construction which:
  • Eliminates habitat fragmentation within Michigan’s Critical Dune Boundary caused by the proposed 6-acre 1600’ long land change from Critical Dune to Open Water
  • Eliminates the need for an extensive laydown area for excavation spoils. Eliminating a laydown area will protect trees along the river that are an important feature in the determination that the Kalamazoo River Mouth meets the criteria as a Traditional Cultural Property. This determination, by the Keeper of the National Register of Historic Places, was made after the Public Hearing of 2017.
• Keeps atmospheric impacts – noise, fumes, vibrations, glare caused by vessels – 1600’ further away from the legally designated Patty Birkholz Natural Area, one of only 20 legally designated Natural Areas in the State of Michigan. The parking lot at Saugatuck Dunes State Park was intentionally placed to be as far away as possible from this important Natural Area. Efforts must be made to keep atmospheric impacts away from this Natural Area.
•  Have zero impact to the historic site of Singapore
• Allow for natural river water flow through the conceptual marina basin, in turn fully protecting water quality and thus lake sturgeon (a significant clan animal of the Potawatomi and an important feature in the determination that the Kalamazoo River Mouth meets the criteria as a Traditional Cultural Property.)
• Eliminates the need for a Circulating Piping System and 16 underwater pumps to ensure adequate flow – a requirement for the current NorthShore of Saugatuck proposal before USACE and EGLE. There is concern from Consulting Parties that the Circulation Piping System and 16 underwater pumps could negatively impact and harm lake sturgeon.

The Coastal Alliance has submitted this design to US Army Corps of Engineers in their permit review. The USACE review process is now entering its fifth year. The typical permit review process takes a few months. The complexities of the Kalamazoo River Mouth area are anything but typical.The Coastal Alliance has also submitted this design to Michigan’s Department of Environment, Great Lakes, and Energy.The regulations governing the review process at USACE and EGLE require Feasible and Prudent Alternatives to be developed and considered. If Alternatives are found that eliminate impacts to wetlands and historic sites, then the original permit design must be denied.
Along with submitting a practical alternative, the Coastal Alliance has requested both USACE and EGLE to re-notice the permit and solicit comments on the revised construction process proposed by Peg & Jeff Padnos. Especially given that Peg & Jeff Padnos have made significant, nearly annual, alterations to their original application since the first Public Notice issued on August 11, 2017.

•  January 2018, the Padnos’s NorthShore of Saugatuck (the Applicant) added a 1’ clay layer to the bottom of the proposed boat canal/channel. This was added after comments made during the Public Comment period about wetlands impacts. However, the Applicant’s supporting hydrological modeling did not consider the impact of their estimated 60-day excavation and dewatering. The Applicant’s modeling began once the clay liner was installed.
• November 2018, the Applicant added a 1450’ long Circulating Pipe System requiring an additional excavation of 6,400 CY. This is an effort to protect water quality from stagnation given the dead-end canal design. The Applicant also added 16 underwater pumps following the many questions raised during the Public Hearing on the effectiveness of the Circulating Pipe System.
• March 2020, the Applicant changed their 60-day ‘in the dry’ excavation plan to excavation ‘in the wet’ after modeling prepared by Anthony Kendall, as an expert witness for the Coastal Alliance, was submitted in the appeal before Judge Pulter.
• March 2021, the Applicant has added a 3200’ long ‘recharge trench’ surrounding the proposed boat canal/channel after modeling prepared by Anthony Kendall, an expert witness for the Coastal Alliance, was submitted in the appeal before Judge Pulter.
  Had the Coastal Alliance not provided the detailed hydrogeological modeling of Northshore’s original 60-day dewatering plan, and had Northshore moved forward with that construction plan, the ground water feeding the globally imperiled interdunal wetlands found on the Patty Birkholz Natural Area would have been lowered nearly 14’ (feet). The duration of that impact remains unclear as the applicant did not provide adequate construction details.

The Administrative Code governing the Permit Review Process requires a thorough consideration of “feasible and prudent alternatives” to ensure minimizing to the greatest extent possible impacts to wetlands and ground water discharge(s). The hydrogeological modeling submitted by the Coastal Alliance clearly details how the NorthShore of Saugatuck construction process & dewatering methods for the proposed marina will impact ground water and the wetlands complex on the Patty Birkholz Natural Area.