February 12, 2002

The Commission’s review and comments on the Stage 2 Grand Calumet River and Indiana Harbor RAP reflect an assessment of the document submitted in relation to the five Stage 2 requirements outlined in the introduction , consideration of the implementation of an ecosystem approach to the restoration and protection of beneficial uses, and an assessment of adequacy of public consultation.

Have in-place remedial measures been evaluated?

The Citizens Advisory for the Remediation of the Environment (CARE) Committee and the Indiana Department of Environmental Management (IDEM) have developed a very useful matrix that will be used as a tool in evaluating progress toward restoration of beneficial uses over time. The CARE Committee and IDEM clearly recognize the complexity of environmental issues in the AOC and confirm that the current matrix is a starting point for additional analysis. Accordingly, it is expected that future addendums to the Stage 2 document will provide additional details related to the contribution of in-place and planned remedial measures toward the restoration of beneficial uses in the AOC.

Have alternative additional measures to restore beneficial uses been evaluated?

The Citizens Advisory for the Remediation of the Environment (CARE) Committee and the Indiana Department of Environmental Management (IDEM) have developed a very useful matrix that will be used as a tool in evaluating progress toward restoration of beneficial uses over time. The CARE Committee and IDEM clearly recognize the complexity of environmental issues in the AOC and confirm that the current matrix is a starting point for additional analysis. Accordingly, it is expected that future addendums to the Stage 2 document will provide additional details related to the contribution of in-place and planned remedial measures toward the restoration of beneficial uses in the AOC.

Have additional remedial measures to restore beneficial uses been selected?

The CARE Committee and IDEM produced a Stage 2 addendum that outlines federal, state and local regulatory actions as well as voluntary actions that are advancing the restoration of beneficial uses. Each action is evaluated in regard to every beneficial use impairment so that its relevance to the RAP effort can easily be judged.

Has a schedule for implementation been adopted and have persons and agencies responsible for implementation of remedial measures been identified?

The matrix in the Stage 2 addendum identifies the agency, organization or person considered to be the “owner or principal driver” of each key implementation element. A starting date and completion date are also detailed. It is noted that for some actions these details are still to be determined. The matrix will be an extremely useful method of tracking the long-term implementation effort.

Has an ecosystem approach been taken to the restoration and protection of beneficial uses?

The Stage 2 addendum outlines a detailed examination of stressors and sources that impact each beneficial use in the AOC. For example, in examining contamination that contributes to the degradation of benthos, the following sources were outlined: contaminated sediments, increased sedimentation, industrial and municipal effluent, urban runoff, spills, ground water contamination, atmospheric deposition, dumping from ships, and surface water contamination. In addition to these sources of contamination, the impacts from exotic species, shoreline alterations, altered hydrology, and fragmentation and loss of physical on benthos were considered. This type of comprehensive ecosystem approach has been outlined for the examination of each beneficial use impairment. Such an approach should be of considerable benefit to the RAP effort in future years as restoration of certain beneficial uses is achieved. The utilization of an ecosystem approach will ensure the continuation of preventive activities needed to ensure the protection of restored beneficial uses.

Was the public consulted adequately?

The CARE Committee and IDEM have forged ongoing relationships with environmental and community groups, local governments, and industry to address the long-term remediation and restoration challenges in this AOC. The public consultation process evolved with the recruitment of individuals and institutions in specific RAP projects and workgroups. To facilitate more effective public input in the Stage 2 RAP, individual members of the CARE Committee were designated to serve as “champions” for each technical area. This approach resulted in continuous technical improvement of the RAP document rather than a limited review opportunity.

Conclusion

The Stage 2 RAP for the Grand Calumet River and Indiana Harbor Ship Canal represents an important milestone for one of the more complex restoration efforts in the Great Lakes Basin. The CARE Committee and IDEM adopted an innovative approach to define and attack the environmental challenges in the AOC. In particular, the matrix approach to track advances in the restoration of beneficial uses and the web diagrams to demonstrate how stressors impact beneficial uses are notable products. The Commission looks forward to the opportunity to examine future addendums to the Stage 2 RAP.