February 12, 2002

The Commission’s review and comments on the Stage 2 St. Clair River 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?

Completed and ongoing programs are described and evaluated in chapter 4 of the Stage 2 RAP. In addition, the November 1998 revision of the Stage 2 Implementation Annex provides an update of RAP implementation measures. This update includes a summary of information provided by each agency, facility, and municipality. The approach results in a user-ready format that outlines RAP progress to-date.

Have alternative additional measures to restore beneficial uses been evaluated?

Potential additional measures toward the reduction of point source loadings to the St. Clair River were evaluated through a two step process. First, point sources were ranked for prioritization of remediation. Secondly, modeling was utilized to evaluate remedial options.

In order to provide a mechanism to determine the most suitable option for sediment remediation, a decision tree was developed by the St. Clair River Sediment Task Team and Sediment Committee. This mechanism provides a useful means to evaluate the various remedial options under consideration as alternative additional measures to restore beneficial uses.

A listing of candidate sites within the AOC for potential habitat enhancement is provided as a method of directing activity toward the more important areas. Proposed actions at any of these sites can then be readily evaluated in regard to potential benefit toward restoration of impaired uses.

Have additional remedial measures to restore beneficial uses been selected?

The Stage 2 RAP clearly enumerates, in Table 10.1, the significant actions that have been determined as necessary to restore beneficial uses.

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

Table 10.1 lists the agency or facility with primary responsibility as well as the complete dates for specific actions. Table 10.2 also provides an approximation of costs for certain actions to be undertaken by agencies or municipalities. In addition to the information that is provided in the Stage 2 document, Table 2 and Table 3 of the Stage 2 Implementation Annex detail the status of implementation actions and commitments for future implementation of recommended actions, respectively. In order to further enhance implementation efforts, a Four Agency Framework (Four Agency Framework) of Roles and Responsibilities for the Implementation of the Detroit River, St. Clair River and St. Marys River Shared Remedial Action Plans has been developed. The Commission is confident that this Framework will enhance implementation efforts in the St. Clair River AOC.

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

As documented in the Stage 2 RAP, the St. Clair River RAP process followed a locally prescribed ecosystem approach that recognized the St. Clair River AOC as an entity without regard for geo-political borders. During the development of Stage 2 document, the scope of the RAP effort was broadened to encompass the immediate drainage basin of the St. Clair River. This action allowed the RAP participants to more comprehensively address environmental issues in the AOC. The RAP effort has recommended that reductions of concentrations for contaminants within the AOC be a priority for Lake Huron lakewide management efforts. In addition, the RAP effort has clearly recognized the potential for the contribution of contaminants from the atmosphere, contaminated sediment and landfill sites. Accordingly, the RAP participants are judged to be utilizing an ecosystem approach to the restoration and protection of beneficial uses.

Was the public consulted adequately?

The RAP document outlines the public consultation process that was utilized to provide a community-based consensus report. Review opportunities were provided through facilitated workshops, Binational Public Advisory Council meetings, and reviews of draft documents by individuals. The provided documentation confirms that adequate public consultation occurred during the development of the Stage 2 RAP.

Conclusion

The RAP participants have precisely detailed the remedial actions selected for implementation. Additional information such as cost estimates that has been developed and provided should prove useful during the implementation process. In particular, the ranking of sources to allow prioritization of remedial efforts and the decision-making framework for selection of a remedial option for sediment remediation are notable. The previously adopted Four Agency Framework is expected to benefit implementation efforts within the AOC.