Total Maximum Daily Load and
Watershed Management Plan for
Total Phosphorus and Total Suspended
Solids in the Lower Fox River Basin and
Lower Green Bay
Brown, Calumet, Outagamie, and Winnebago Counties,
Wisconsin
March 2012

Prepared for:
Wisconsin Department
of Natural Resources

Oneida Tribe of
Indians of Wisconsin

Prepared by:

U.S. Environmental
Protection Agency

 TABLE OF CONTENTS
1.0 INTRODUCTION....................................................................................................................................... 1
1.1. Background................................................................................................................................................. 1
1.2. Problem Statement .................................................................................................................................... 1
1.3. Restoration Goals ...................................................................................................................................... 3
2.0 WATERSHED CHARACTERIZATION ............................................................................................... 6
2.1. History of the Basin .................................................................................................................................. 6
2.2. Watershed Characteristics ........................................................................................................................ 7
2.3. Water Quality ........................................................................................................................................... 10
3.0 APPLICABLE WATER QUALITY STANDARDS ........................................................................... 18
3.1. Parameters of Concern and Applicable Water Quality Criteria ....................................................... 18
3.2. Numeric Water Quality Targets ............................................................................................................ 20
4.0 SOURCE ASSESSMENT ......................................................................................................................... 22
4.1. Analysis of Phosphorus and Sediment Loading ................................................................................. 23
4.2. Summary of Baseline Sources of Phosphorus and Sediment Loading............................................ 32
5.0 DETERMINATION OF LOAD CAPACITY ..................................................................................... 36
5.1. Linking Phosphorus and Sediment Loading to the Numeric Water Quality Targets ................... 36
5.2. Critical Conditions ................................................................................................................................... 36
5.3. Loading Capacity ..................................................................................................................................... 37
6.0 POLLUTANT LOAD ALLOCATIONS............................................................................................... 40
6.1. In-Basin Sources ...................................................................................................................................... 40
6.2. Oneida Reservation ................................................................................................................................. 40
6.3. Out-of-Basin Sources .............................................................................................................................. 41
6.4. Margin of Safety ....................................................................................................................................... 41
6.5. Reserve Capacity ...................................................................................................................................... 41
6.6. Seasonal Variation ................................................................................................................................... 42
7.0 IMPLEMENTATION ............................................................................................................................... 88
7.1. Reasonable Assurance for Implementation ......................................................................................... 88
7.2. Watershed Management Plan for Waters within the Oneida Reservation ..................................... 91
7.3. Follow-up Monitoring............................................................................................................................. 92
8.0 PUBLIC PARTICIPATION..................................................................................................................... 93
8.1. Public Notice ............................................................................................................................................ 93
8.2. Stakeholder Engagement, Public Outreach, and Public Participation ............................................ 93
8.3. Technical Team ........................................................................................................................................ 95
8.4. Ad-Hoc Science Team ............................................................................................................................ 96
9.0 REFERENCES ........................................................................................................................................... 97
APPENDIX A. ANALYSIS RESULTS FOR THE NUMERIC WATER QUALITY TARGETS . 101
APPENDIX B. SWAT WATERSHED MODELING ANALYSIS ....................................................... 104
APPENDIX C. TMDL DEVELOPMENT AND LOAD ALLOCATION METHODOLOGY ... 123
APPENDIX D. SUMMARY OF MS4 WASTELOAD ALLOCATIONS ............................................ 133
APPENDIX E. MAPS OF TP AND TSS YIELD FOR THE FOX-WOLF BASINS ....................... 135
APPENDIX F. POTENTIALLY RESTORABLE WETLANDS ANALYSIS.................................... 137
APPENDIX G. STAKEHOLDER ENGAGEMENT AND OUTREACH ACTIVITIES.............. 145
APPENDIX H. RESPONSE TO COMMENTS ....................................................................................... 148
i

 LIST OF FIGURES
Figure 1. Location of the Lower Fox River Basin ................................................................................................. 1
Figure 2. Sediment blooms in Lower Green Bay following 3 inches of rain in April 2011 ............................2
Figure 3. Direct drainage basin for the Lower Fox River Basin and Lower Green Bay ................................. 5
Figure 4. Summary of land use in Lower Fox River Basin ..................................................................................8
Figure 5. Land use/land cover in the Lower Fox River Basin ............................................................................9
Figure 6. Lower Green Bay sampling stations .....................................................................................................12
Figure 7. Lower Fox River Watershed Monitoring Program stations ..............................................................13
Figure 8. Annual summer (May through October) median TP concentrations from 1993-2008 for
Lower Fox River Station 16 .............................................................................................................................14
Figure 9. Annual summer (May through October) median TP concentrations from 1993-2008 for
Lower Green Bay Zone 1 ................................................................................................................................14
Figure 10. Annual summer (May through October) median TP concentrations from 2004-2006 for
Apple Creek (a), Ashwaubenon Creek (b), Baird Creek (c), Duck Creek (d), and East River (e).........15
Figure 11. Annual summer (May through October) median TSS concentrations from 1993-2008 for
Lower Fox River Station 16 .............................................................................................................................16
Figure 12. Annual summer (May through October) median TSS concentrations from 1993-2008 for
Lower Green Bay Zone 1 ................................................................................................................................16
Figure 13. Annual summer (May through October) median TSS concentrations from 2004-2006 for
Apple Creek (a), Ashwaubenon Creek (b), Baird Creek (c), Duck Creek (d), and East River (e) ............17
Figure 14. Location of municipal and industrial WWTFs in the LFR Basin ..................................................28
Figure 15. Location of MS4s in the LFR Basin ...................................................................................................29
Figure 16. Location of CAFOs in the LFR Basin ...............................................................................................30
Figure 17. Drainage basins for the Upper Fox River, Lower Fox River, and Wolf River ............................31
Figure 18. Percent of total land area of the Fox-Wolf Basin .............................................................................31
Figure 19. Sources of baseline TP loading in the LFR Basin ............................................................................32
Figure 20. Sources of baseline TSS loading in the LFR Basin (excluding biotic solids)................................33
Figure 21. Sub-basins in the Lower Fox River Basin ..........................................................................................35

ii

 Figure 22. Predicting the relative biomass of blue-green algae in phytoplankton from total
phosphorus levels in lakes, where %BG = 100/e + 5-2.62 logTP 1 (Trimbee and Prepas, 1987). .. 103
Figure 23. Lower Fox River Basin and Sub-basin boundaries ....................................................................... 107
Figure 24. Flow chart illustrating the steps involved in calculating the TMDLs for TP ............................ 125
Figure 25. Average annual phosphorus loads entering the Lower Fox River Basin at the outlet of
Lake Winnebago. ............................................................................................................................................ 126
Figure 26. Flow chart illustrating the steps involved in calculating the TMDLs for TSS .......................... 129
Figure 27. Average annual TSS loads entering the Lower Fox River Basin at the outlet of Lake
Winnebago....................................................................................................................................................... 130
Figure 28. TSS vs. TP Loads from Lake Winnebago....................................................................................... 130
Figure 29. Summary of TP yields of total loads as routed to Lower Green Bay from the Fox-Wolf
Basin ................................................................................................................................................................. 135
Figure 30. Summary of TSS yields of total loads (including biotic solids) as routed to Lower Green
Bay from the Fox-Wolf Basin ...................................................................................................................... 136
Figure 31. Illustration of GIS overlay analysis .................................................................................................. 137
Figure 32. Distribution of potentially restorable wetlands in the Lower Fox River Basin ........................ 138
Figure 33. Summary of relative predicted TSS yield reduction for each sub-basin in the Lower Fox
River Basin from the PRW Analysis............................................................................................................ 141
Figure 34. Summary of relative predicted particulate phosphorus (sed-P) yield reduction for each
sub-basin in the Lower Fox River Basin from the PRW Analysis.......................................................... 142
Figure 35. Summary of relative predicted TSS yield reduction for each subwatershed the Lower Fox
River Basin from the PRW Analysis............................................................................................................ 143
Figure 36. Summary of relative predicted particulate phosphorus (sed-P) yield reduction for each
subwatershed in the Lower Fox River Basin from the PRW Analysis .................................................. 144

iii

 LIST OF TABLES
Table 1. Impaired segments on Wisconsin’s 2008 303(d) list addressed by the Lower Fox River Basin
and Lower Green Bay TMDL ...........................................................................................................................4
Table 2. Summary of land use in Lower Fox River Basin ....................................................................................8
Table 3. WWTFs in the LFR Basin. ......................................................................................................................27
Table 4. MS4s in the LFR Basin.............................................................................................................................27
Table 5. CAFOs in the LFR Basin.........................................................................................................................27
Table 6. Sources of baseline TP loading in the LFR Basin ................................................................................32
Table 7. Sources of baseline TSS loading in the LFR Basin ..............................................................................33
Table 8. Summary of baseline TP and TSS loads originating from within each sub-basin...........................34
Table 9. Summary of baseline loads, allocated loads, and load reduction goals for TP loads
originating from within each sub-basin..........................................................................................................38
Table 10. Summary of baseline loads, allocated loads, and load reduction goals for TSS loads
originating from within each sub-basin, from biotic solids ........................................................................39
Table 11. TMDL Outreach Team Members ........................................................................................................94
Table 12. TMDL Technical Team Members .......................................................................................................95
Table 13. TMDL Ad-Hoc Science Team Members ............................................................................................96
Table 14. Model results for Secchi depth response to simulated decreases in TP and TSS. ..................... 102
Table 15. Predicted Lower Bay (zones 1 and 2 combined) responses to achieving the LFR main stem
targets of 0.1 mg/L TP and 20 mg/L TSS ................................................................................................. 103
Table 16. Major model input types and sources ............................................................................................... 105
Table 17. Summary of phosphorus and suspended sediment/TSS concentrations measured in urban
streams and storm sewers within Wisconsin and neighboring states ..................................................... 112
Table 18. Calibration and validation summary for Bower Creek monitoring station ................................. 118
Table 19. Simulated and observed monthly flow, TSS, and TP statistics for WY 2004-2005................... 119
Table 20. Simulated and observed monthly flow, TSS, and TP statistics for WY 2004-2008................... 122
Table 21. Annual observed and simulated stream flow, TSS, and TP yields (2004-2008) ......................... 122
Table 22. Data used to calculate the TP adjustment factor ............................................................................ 124
Table 23. Summary of original, lost, remaining, and potentially restorable wetlands (acres) for each
sub-basin in the Lower Fox River Basin..................................................................................................... 139
Table 24. Summary of relative yield reductions for particulate phosphorus (sed-P) and sediment (as
TSS) for each sub-basin in the Lower Fox River Basin ........................................................................... 140
Table 25. Persons, Agencies, and Municipalities that Provided Comments on the Draft TMDL ........... 149

iv

 1.0

INTRODUCTION

1.1.

Background

In April of 1991, the United States Environmental Protection Agency (EPA) Office of Water’s
Assessment and Protection Division published “Guidance for Water Quality-based Decisions: The Total
Maximum Daily Load (TMDL) Process.” In July 1992, EPA published the final “Water Quality Planning
and Management Regulation” (40 CFR Part 130). Together, these documents describe the roles and
responsibilities of EPA and the states in meeting the requirements of Section 303(d) of the Federal Clean
Water Act (CWA) as amended by the Water Quality Act of 1987, Public Law 100-4. Section 303(d) of
the CWA requires each state to identify those waters within its boundaries not meeting EPA-approved
water quality standards for any given pollutant applicable to the water’s designated uses.
Further, Section 303(d) requires EPA and states to develop TMDLs for all pollutants violating or causing
violation of applicable water quality standards for each impaired water body. A TMDL determines the
maximum amount of pollutant that a water body is capable of assimilating while continuing to meet the
existing water quality standards. Such loads are established for all the point and nonpoint sources of
pollution that cause the impairment at levels necessary to meet the applicable standards with
consideration given to seasonal variations and a margin of safety. TMDLs provide the framework that
allows states to establish and implement pollution control and management plans with the ultimate goal
indicated in Section 101(a)(2) of the CWA: “water quality which provides for the protection and
propagation of fish, shellfish, and wildlife, and recreation in and on the water, wherever attainable”
(USEPA, 1991a).
1.2.

Problem Statement

The Lower Fox River (LFR) Basin is located in northeast Wisconsin (Figure 1). The LFR Basin and
Lower Green Bay (also referred to as the Green Bay Area of Concern or AOC) are impaired by excessive
phosphorus and sediment loading, which leads to nuisance algae growth, oxygen depletion, reduced
submerged aquatic vegetation, water clarity problems, and degraded habitat. The TMDL for the LFR
Basin and Lower Green Bay focuses on waters impaired by excessive sediment and/or high phosphorus
concentrations. Phosphorus and sediment cause numerous impairments to waterways, including low
dissolved oxygen concentrations, degraded habitat, and excessive turbidity. These impairments adversely
impact fish and aquatic life, water quality, recreation, and potentially navigation.
Although phosphorus is an essential nutrient for plant growth,
excess phosphorus is a concern for most aquatic ecosystems.
Where human activities do not dominate the landscape,
phosphorus is generally in short supply. The absence of
phosphorus limits the growth of algae and aquatic plants. When a
large amount of phosphorus enters a water body, it essentially
fertilizes the aquatic system, allowing more plants and algae to
grow; this leads to excessive aquatic plant growth, often referred to
as an algae bloom. This condition of nutrient enrichment and high
plant productivity is referred to as eutrophication. Eutrophication
can damage the ecology of the water, degrade its aesthetics and
swimming conditions, and affect the economic well-being of the
surrounding community. Overabundant aquatic plant growth in a
water body can lead to a number of undesirable consequences.
Excessive surface vegetation blocks sunlight from penetrating the

Figure 1. Location of the
Lower Fox River Basin
1

 water, choking out beneficial submerged aquatic vegetation. Large areas of excessive surface vegetation
growth can inhibit or prevent access to a waterway, which restricts use of the water for fishing, boating,
and swimming. A bloom of aquatic plants may include toxic blue-green algae or cyanobacteria, which are
harmful to fish and pose health risks to humans. Algal blooms, and particularly surface scums that form,
are unsightly and can have unpleasant odors. This makes recreational use of the water body unpleasant
and poses a problem for people who live close to the affected water body. When the large masses of
both submerged and surface aquatic plants die, the decomposition of the organic matter depletes the
supply of dissolved oxygen in the water, suffocating fish and other aquatic life; depending on the severity
of the low dissolved oxygen event, large fish kills can occur. Nearly all of these effects have economic
impacts on the local community, as well as the state.
The Lower Fox River, its tributaries, and Lower Green Bay are also impacted by excess sediment loading
(Figure 2). Excess sediments in the river and bay scatter and absorb sunlight, reducing the amount of
light that reaches submerged aquatic vegetation, which restricts its ability to grow via photosynthesis.
Bottom-rooted aquatic plants produce life-giving oxygen, provide food and habitat for fish and other
aquatic life, stabilize bottom sediments, protect shorelines from erosion, and utilize nutrients that would
otherwise be available for nuisance algae growth. As photosynthetic rates decrease, less oxygen is
released into the water by the plants. If light is completely blocked from bottom dwelling plants, the
plants stop producing oxygen and die. While decomposing the plants, bacteria use up even more oxygen
from the water. Historically, fish kills have been reported in Green Bay and the Lower Fox River in
association with low oxygen events (WDNR, 1988; WDNR, 1993a). Submerged aquatic vegetation also
serves as vital habitat and is a food source for fish, waterfowl, frogs, turtles, insects, and other aquatic
life. Reduced water clarity also interferes with
the ability of fish and waterfowl to see and
catch food. Suspended sediments can also clog
fish and invertebrate gills and cause respiratory
stress. When sediments settle to the bottom of
the river and bay, they can smother the eggs of
fish and aquatic insects, as well as suffocate
newly hatched insect larvae. Settling sediments
can also fill in spaces between rocks, reducing
the amount of sheltered habitat available to
aquatic organisms. The aforementioned ability
of sediment particles to absorb heat from
sunlight can also cause an increase in surface
water temperature. This can cause dissolved
oxygen levels to drop even lower (warmer Figure 2. Sediment blooms in Lower Green Bay
following 3 inches of rain in April 2011
waters hold less dissolved oxygen that colder
(Photo credit: Steve Seilo)
waters), and further harm aquatic life.
Over the last 15 years, the Wisconsin Department of Natural Resources (WDNR) has placed numerous
waters in the LFR Basin, including Lower Green Bay, on the state’s 303(d) Impaired Waters List, and has
ranked the waters as high priority for the development of TMDLs to address the impairments caused by
excess phosphorus and sediment loading. The complete list of impaired waters and impairments being
addressed by the TMDL are listed in Table 1 and shown in Figure 3. Note that the term “designated
use” in Table 1 refers to those waters that are codified in Wisconsin Administrative Code NR 104.
Trout Creek and portions of Duck and Dutchman Creeks are not included on Wisconsin’s 303(d)
Impaired Waters List because they are within the Oneida Tribe of Wisconsin’s Reservation, and,
therefore, the State of Wisconsin does not have authority to develop TMDLs for these waters. In
2

 addition, the Oneida Tribe of Wisconsin does not currently have Water Quality Standards Program
authorization from EPA. TMDLs can only be developed for waters that are not meeting EPA-approved
water quality standards. However, Trout Creek and portions of Duck and Dutchman Creeks exhibit
similar low dissolved oxygen and degraded habitat impairments due to excess phosphorus and sediment
loading. Although the TMDLs established for the LFR Basin and Lower Green Bay are not applicable to
the water bodies located within the boundary of the Oneida Reservation, in order to meet the TMDLs
for the LFR Basin and Lower Green Bay, voluntary reductions are needed from sources located within
the Oneida Tribe of Wisconsin’s Reservation. Therefore, load reduction goals for pollutants in the
waters that flow through the Oneida Tribe of Wisconsin’s Reservation have been identified in this report
in the form of a Watershed Management Plan.
As shown in Table 1, there are 27 segments listed as impaired on the state’s 303(d) Impaired Waters List
due to excess phosphorus and/or sediment loading, resulting in a need for 45 individual TMDLs. The
TMDLs for the LFR Basin and Lower Green Bay were developed using a watershed framework to
address each of the 45 TMDLs needed. Under a watershed framework, TMDLs and the associated tasks1
are simultaneously completed for multiple impaired water bodies in a watershed. This report identifies
the TMDLs, load allocations, and recommended management actions that will help restore water quality
in the Lower Fox River, the tributaries in the basin, and Lower Green Bay.
1.3.

Restoration Goals

The following list summarizes the primary restoration goals for the LFR Basin (including tributary
streams) and Lower Green Bay that will be addressed through implementation of this TMDL.

1
2

•

Reduce excess algal growth . Aesthetic reasons aside, reducing blue-green algae will reduce the

•

Increase water clarity in Lower Green Bay. Achieving an average Secchi 2 depth measurement

risks associated with algal toxins to recreational users of the river and bay. In addition, a decrease
in algal cover will also increase light penetration into deeper waters of the bay.

of at least 1.14 meters will allow photosynthesis to occur at deeper levels in the bay, as well as
improve conditions for recreational activities such as swimming.

•

Increase growth of beneficial submerged aquatic vegetation in Lower Green Bay . This
will help reduce the re-suspension of sediment particles from the bottom of the bay up into the
water column, which will increase water clarity.

•

Increase dissolved oxygen levels. This will better support aquatic life in the tributary streams

•

Restore degraded habitat. This will better support aquatic life.

and main stem of the Lower Fox River.

Characterizing the impaired water body and its watershed, identifying sources, setting targets, calculating the loading
capacity, identifying source allocations, preparing TMDL reports, and coordinating with stakeholders.
A Secchi disk is a black-and-white disk that is lowered into the water until it is no longer visible. The point where it
disappears from sight is the Secchi depth. Higher Secchi depths indicate clearer water and lower Secchi depths indicate
more turbid water.

3

 Table 1. Impaired segments on Wisconsin’s 2008 303(d) list addressed by the Lower Fox River Basin and Lower Green Bay TMDL
Water body Name
Green Bay
Fox River
Fox River
Fox River
East River
East River
Baird Creek
Baird Creek
Bower Creek
Bower Creek
Dutchman Creek
Ashwaubenon Creek
Apple Creek
Apple Creek
Plum Creek
Plum Creek
Plum Creek
Kankapot Creek
Kankapot Creek
Garners Creek
Mud Creek
Mud Creek
Neenah Slough
Neenah Slough
Neenah Slough
Duck Creek
Duck Creek
DH = Degraded habitat
DO = Dissolved oxygen

County
Brown
Brown
Brown, Outagamie
Outagamie, Winnebago
Brown
Brown, Calumet
Brown
Brown
Brown
Brown
Brown
Brown
Brown, Outagamie
Brown
Brown
Brown, Calumet
Calumet
Outagamie
Calumet, Outagamie
Outagamie
Outagamie, Winnebago
Outagamie
Winnebago
Winnebago
Winnebago
Brown
Outagamie
TSS = Total suspended solids
TP = Total phosphorus

WATERS ID
357876
10678
357301
357364
10679
10680
10681
10682
10683
10684
10832
10834
10839
313933
10841
357670
357719
10844
357763
10845
10846
10847
10848
357915
357955
10850
10851

Start Mile
End Mile
2
21 mi
0
7.39
7.39
32.18
32.18
40.09
0
14.15
14.15
42.25
0
3.5
3.5
13.1
0
3
3
13
0
4.04
0
15
3.99
23.88
0
3.99
0
13.86
13.87
16.42
16.42
19.5
0
2.66
2.66
9.57
0
5
0
3.71
3.71
6.87
0
2.77
2.77
3.54
3.55
6.12
0
4.96
25.69
39.46

Impairments
DH, Low DO
DH, Low DO
Low DO
Low DO
DH, Low DO
DH, Low DO
DH, Low DO
DH, Low DO
DH
DH
Low DO
DH, Low DO
DH, Low DO
DH, Low DO
DH
DH
DH
DH
DH
DH
DH
DH
Low DO
Low DO
Low DO
DH, Low DO
DH, Low DO

Pollutants
TSS, TP
TSS, TP
TP
TP
TSS, TP
TSS, TP
TSS, TP
TSS, TP
TSS, TP
TSS, TP
TP
TSS, TP
TSS, TP
TSS, TP
TSS, TP
TSS
TSS
TSS, TP
TSS, TP
TSS, TP
TSS, TP
TSS
TP
TP
TP
TSS, TP
TSS, TP

Designated Use
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL
Default - FAL

Default FAL = No use classification survey completed for Fish and Aquatic Life Use

4

  

SHAWANO CO.
OUTAGAMI C0.

 

   
 
 

CALUMET C0.

- Winnebago

 

Waters Impaired by
Phosphorus or Sediment

River or Stream

   

 

County Boundary
Lake or Bay

- Oneida Reservation
fl City

Lower Fox River Basin

WINNEBAGO COL
CALUMET CO.

 

 

 

 

 

 

 

 

 

  
     
 
  
   

   

Au -
Bay

 

Lower Green
"(Am

 

MAN ITOWOC CO.

 

 

 

Figure 3. Direct drainage basin for the Lower Fox River Basin and Lower Green Bay

 

2.0

WATERSHED CHARACTERIZATION

2.1.

History of the Basin

Green Bay is the largest freshwater estuary in the world. The bay itself is an inflow to Lake Michigan.
The Lower Fox River and Green Bay are important environmental and economic resources for the state,
as well as the local community. The wetlands along Green Bay’s west shore, as well as the wetlands lining
the banks of the Lower Fox River, provide critical fish spawning habitat for perch, northern walleye, and
the elusive spotted musky. The natural resources of the Lower Fox River and Green Bay support
popular recreational activities such as boating and fishing. People have long used the river and bay for
transportation, commerce, energy, food, and recreation. Historically, Native Americans occupied the
banks of the Fox River for centuries and used the water as a source of food and water, as well as for
recreation, transportation, and crop irrigation. Beginning in the 1600s, European pioneers used the river
for fur trading and as an exploration route. Settlements were established in the early 1800s, including
Fort Howard, which is now the City of Green Bay.
Paper mills began to flourish in the mid 1800s, after the flour mill industry peaked (WDNR, 1991). The
early 1900s saw a booming timber industry followed by rapid urbanization (WDNR, 1988). As logging,
agriculture, and industry spread into Wisconsin, the Lower Fox River developed into an urbanized,
industrialized area. The forests were harvested and land was cleared for agriculture, causing severe soil
erosion, increased sediment and nutrient loadings, and higher water temperatures in the river and the
bay. Over the past century hundreds of acres of wetlands that provided important habitat for fish and
wildlife were filled and/or destroyed along the river and in the bay (WDNR, 1988).
Numerous occurrences of low dissolved oxygen and fish kills were reported from the 1920s through the
1970s. During this time, the river and bay also saw an increasing predominance of only those organisms
able to tolerate highly polluted conditions. From the 1930s to 1970s, dissolved oxygen conditions grew
worse due to increased industrial discharges and population growth. Between 1972 and 1985, the area
saw dramatic improvements in dissolved oxygen levels and the fishery due to passage of the CWA. As a
result of the CWA’s stricter pollution control requirements, industries and municipalities invested more
than $300 million to reduce pollutant discharges to the river (WDNR, 1988). As a result, dissolved
oxygen levels improved in the river and, to a lesser extent, in the bay. This helped to revive the diversity
of aquatic life in the river and the bay. This improvement encouraged WDNR to establish a walleye fish
stocking program below the De Pere Dam from 1977 through 1984 (WDNR, 1988). This helped revive
the diversity of aquatic life in the river and bay. More than 35 species of native fish have been
documented in the Lower Fox River since 1980. The program was also successful in attracting many
people to fish in the area. Walleye were stocked from 1977 to 1984 and today provide a nationallyfamous fishery (Kapuscinski, 2010). A WDNR Lake Michigan Creel Survey estimated that 47,000
walleyes were harvested from the Lower Fox River and the Brown County waters of Green Bay in
2009. Muskellunge restoration began in 1989 to return this extirpated native species to Green
Bay. Stocking has re-established a population, and in 2008, natural reproduction was documented for the
first time (Rowe and Lange, 2009). In addition to restoring a native species, this program has created a
very popular fishery, and in 2009, more than 31,000 hours of fishing were targeted at muskellunge on
Green Bay. Restoring water quality in the entire LFR Basin through this TMDL will help to protect this
important fishery and continue to improve upstream habitat for fish and aquatic life.
Industries, municipalities, small businesses, farms, and thousands of residents occupy the LFR Basin
today. A significant amount of phosphorous is still discharged to the Lower Fox River from municipal
and industrial dischargers, as well as from runoff from croplands, barnyards, construction sites, parking
6

 lots, residential yards, streets, and other sources. Many of these sources also contribute significant
amounts of sediment to the river and bay as well.
2.2.

Watershed Characteristics

The 641 mi2 (1,661 km2) LFR Basin is located in northeast Wisconsin and encompasses the following
counties: Brown, Calumet, Outagamie, and Winnebago, and most of the Oneida Tribe of Wisconsin’s
Reservation (Figure 3). The Lower Fox River originates at the outlet of Lake Winnebago and flows
northeast for 39 miles where it empties into Lower Green Bay. Although the Lower Fox River is
impounded by 12 dams and is navigable through 17 locks, the river has the appearance and
characteristics of a large flowing stream rather than a series of impoundments (WDNR, 1988).
Green Bay is an elongated arm of Lake Michigan partially separated from the lake by the Door County
peninsula. The bay runs northeast from the Fox River’s mouth, is 119 miles long, and has a maximum
width of 23 miles. Green Bay is relatively shallow, ranging from an average of 10 to 15 feet at the
southwestern end to 120 feet at its deepest point (WDNR, 1988). Lower Green Bay includes a little over
21 mi2 of southern Green Bay out to Point au Sable and Long Tail Point (Figure 3).
The LFR Basin, often referred to as the Fox River Valley, is the second largest urbanized area in the
State of Wisconsin (WDNR, 2001a). According to the 2000 U.S. Census, about 404,000 people reside in
the LFR Basin (USCB, 2000). Most of the LFR Basin’s urban areas are near the main stem of the Lower
Fox River, and localized urban and industrial runoff has contributed to water quality problems.
Existing land use and land cover in the LFR Basin was determined in a geographic information system
(GIS) using digital aerial photography and spatial datasets (see Appendix B for more detail). Table 2 and
Figure 4 summarize land use data for the LFR Basin, and Figure 5 shows the final basin land use layer
used for the TMDL analysis. Approximately 50% of the basin consists of agricultural land (including
barnyards), 35% consists of urban land (including regulated and non-regulated areas, as well as land
under construction), and just under 15% consists of natural areas, including forests and wetlands, which
are considered background sources of phosphorus and sediment in the basin.
Those interested in additional details on other characteristics about the basin are encouraged to review
the State of the Green Bay Report (Qualls et al. 2010), Lower Fox River Basin Integrated Management Plan
(WDNR, 1991) and Lower Green Bay Remedial Action Plan (WNDR, 1988), which provide additional details
on other characteristics of the basin, including geography, geology, soils, meteorology, groundwater,
ecological resources, and cultural resources.

7

 Table 2. Summary of land use in Lower Fox River Basin
Land Use Category
Agriculture (includes barnyards)
Urban (non-regulated)
Urban (regulated MS4)
Construction Sites
Natural Areas (forests & wetlands)
TOTAL

Acres
202,580
34,955
104,598
2,275
59,249
403,657

% of Drainage Basin
50.2%
8.7%
25.9%
0.6%
14.7%
100%

Construction Sites
0.6%
Urban
(regulated MS4)
25.9%
Urban
(non-regulated)
8.7%

Natural areas
14.7%

Agriculture
(includes barnyards)
50.2%

Figure 4. Summary of land use in Lower Fox River Basin

8

  

 

 
 
 
 
 
 
    
     

Green Bay

 

Oneida Reservation

"Lowe-r Green Bay -- .-

t? (ADC) Loerw 
. a


.

  

It Lake Winnebago
I:l Urban (non-regulated)

- Urban (regulated MS4)

- Agriculture

- Natural Background
0 2.5 5
_:IMi es - Water

 

 

 

 

 

 

Figure 5. Land use land cover in the Lower Fox River Basin

 

2.3.

Water Quality

The following sections provide a summary of baseline water quality conditions (based on phosphorus
and sediment concentrations) in the LFR Basin, including the outlet of the main stem of the Lower Fox
River to Lower Green Bay. All of the impaired tributary streams in the LFR Basin have been assessed at
one or more sites over the last two decades, with the majority of the data collected during or after the
2000 field season. The majority of warmwater Index of Biotic Integrity (IBI 3) scores for the tributary
streams range from very poor to poor. Macroinvertebrate sampling results (Hilsenhoff Biotic Index
value, or HBI) range from very poor to good depending on the sampling locale. Habitat surveys
conducted on several streams characterize habitat as very poor to fair (WDNR, 1993b; WDNR, 1997).
2.3.1.

Total Phosphorus

A 30-year record of total phosphorus (TP) concentrations is available for Green Bay from the Green Bay
Metropolitan Sewerage District 4 (GBMSD) ambient water quality monitoring program, as well as
research efforts at University of Wisconsin Green Bay (UWGB) (Qualls et al., 2010). GBMSD is a
Wisconsin state-certified lab that maintains up-to-date quality assurance and quality control procedures
for the collection and analysis of water samples. UWGB’s methods for collecting data are overseen and
set forth by the United States Geological Survey (USGS). USGS’ monitoring procedures and data quality
statements are available online. 5
Figure 6 and Figure 7 show the monitoring stations for which the 30-year record of data exists. Figure 8
provides a summary of annual summer (May through October) median TP concentrations from 1993 to
2008 (post zebra mussel invasion 6) for the outlet of the Lower Fox River to Lower Green Bay (River
Station 16 in Figure 6). Between 1993 and 2008, summer median concentrations ranged from 0.12 to
0.28 mg/L. Figure 9 provides a summary of annual summer (May through October) median TP
concentrations from 1993 to 2008 (post zebra mussel invasion) for Lower Green Bay (Zone 1 in Figure
6). Between 1993 and 2008, summer median TP concentrations ranged from 0.09 to 0.22 mg/L.
A 3-year record of TP concentrations is also available from the Lower Fox River Watershed Monitoring
Program 7 (LFRWMP) for Apple Creek, Ashwaubenon Creek, Baird Creek, Duck Creek, and East River.
Figure 10 provides a summary of annual summer (May through October) median TP concentrations
from 2004 to 2006 for these tributary streams. Between 2004 and 2006, summer median concentrations
ranged from 0.2 to 0.31 mg/L in Apple Creek; 0.275 to 0.4 mg/L in Ashwaubenon Creek; 0.12 to 0.19
mg/L in Baird Creek; 0.16 to 0.195 mg/L in Duck Creek; and 0.18 to 0.355 mg/L in East River (P.
Baumgart, personal communication, May 8, 2009).

An IBI is a scientific tool used to identify and classify water pollution problems. An IBI associates anthropogenic
influences on a water body with biological activity in the water body, and is formulated using data developed from
biosurveys.
4 Web site for the GBMSD Ambient Water Quality Monitoring Program:
http://gbmsd.org/gbsewer/water+quality+research/ambient+water+quality+monitoring+program/default.asp
5 http://wdr.water.usgs.gov/current/documentation.html
6 Zebra mussels are a notorious exotic species that entered Green Bay around 1991. Zebra mussels are filter feeders that
may improve water clarity, affecting the entire lake ecosystem. Although zebra mussels are present in Green Bay, they
are not as abundant in zone 1 (the area including the AOC), and there is no significant difference in Secchi depth
(water clarity) before or after the zebra mussel invasion of the Great Lakes (Qualls et al., 2010).
7 Web site for the LFRWMP Monitoring Program: http://www.uwgb.edu/watershed/data/index.htm
3

10

 2.3.2. Total Suspended Solids
The amount of sediment in a water body is usually measured as turbidity, total suspended solids (TSS),
and water clarity. For the Lower Fox River TMDL, sediment concentration is estimated and measured as
TSS. TSS can include a wide variety of material, such as soil, biological solids, decaying organic matter,
and particles discharged in wastewater. Figure 11 provides a summary of annual summer (May through
October) median TSS concentrations from 1993 to 2008 (post zebra mussel invasion) for the outlet of
the Lower Fox River to Lower Green Bay (River Station 16 in Figure 6). Between 1993 and 2008,
summer median TSS concentrations ranged from 26 to 62 mg/L. Figure 12 provides a summary of
annual summer (May through October) median TSS concentrations from 1993 to 2008 (post zebra
mussel invasion) for Lower Green Bay (Zone 1 in Figure 6). Between 1993 and 2008, summer median
TSS concentrations ranged from 20.0 to 38.8 mg/L.
A 3-year record of TSS concentrations is also available from the Lower Fox River Watershed Monitoring
Program for Apple Creek, Ashwaubenon Creek, Baird Creek, Duck Creek, and East River. Figure 13
provides a summary of annual summer (May through October) median TSS concentrations from 2004 to
2006 for these tributary streams. Between 2004 and 2006, summer median concentrations ranged from
13 to 22 mg/L in Apple Creek; 22 to 34 mg/L in Ashwaubenon Creek; 5.4 to 20 mg/L in Baird Creek;
4.8 to 7.6 mg/L in Duck Creek; and 40 to 74.5 mg/L in East River (unpublished data provided by P.
Baumgart, personal communication, May 8, 2009).
The majority of sediment annually deposited in the tributaries on the east side of the Lower Fox River is
from agricultural upland erosion, gully erosion, and stream bank erosion. Soils in this part of the basin
are relatively fine in texture with slow permeability. In addition, the landscape consists of moderate to
steep slopes and is subject to increased urbanization and significant agricultural land use. All of these
conditions play a part in the increased erosion potential and delivery of sediment to the streams,
especially for areas in close proximity to the streams.
On the west side of the Lower Fox River, soils tend toward clay loam glacial till or sandy soils, which
range from poorly-drained to well-drained. Upland erosion in this area of the basin contributes to high
sediment loading to the tributary streams. Improperly managed livestock operations that allow cattle
access to streams are a key cause for eroding stream banks, loss of bank cover and vegetation, and
degradation to the stream-bed and habitat. Eroding stream banks contribute to flashy stream conditions,
which results in smaller tributaries experiencing little to no flow in summers, limiting fish and aquatic life
uses. In addition, organic pollutants from livestock waste can cause in-stream temperatures to rise and
dissolved oxygen levels to fall.
Increased urbanization in the basin also impacts stream hydrology, as runoff volume increases in
magnitude and peak stream flows intensify. Flashy stream flows can heighten the impact of stream bank
erosion, changing the overall morphology of streams. The natural system is destroyed in many cases,
increasing the transport rate of pollutants downstream to the Lower Fox River and Lower Green Bay. In
addition, increased areas of impervious surface (e.g., parking lots, roads, rooftops, etc.) result in
decreased groundwater recharge; this can reduce base flow to regional streams that are vital to sustaining
fish and aquatic life during periods of low rainfall.

11

  

 

  


55
I
57
Zone 3
Green Bay ADC
Long Tail Point
Fox River
Tl}: "Em?g
Fox River fir-"57 .
sf East River
1* z?
1' sf
4.7 ?3:910

.J 55;: ..
-
5 3-1: 
Wisconsin 3
U)
:2 
. .
Michigan
ifS?q' Grant Kilometers

 

 

 
 
  
 

 

 

 

 

 

   

  

    
   

  

 

 

 

 

 

Figure 6. Lower Green Bay sampling stations
(Qualls et al., 2010)

12

 

Figure 7. Lower Fox River Watershed Monitoring Program stations
(P. Baumgart, personal communication, May 8, 2009)
13

 0.3

N = 11

Summer Median
Water Quality Target

0.25

N=8

N = 11

N = 13 N = 14

N = 13

0.2

N = 12

N = 11

N = 11

N = 12
N = 11

N = 12 N = 14

TP
0.15
(mg/L)

N = 11
N = 15

N = 14

0.1
0.05
0
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Figure 8. Annual summer (May through October) median TP concentrations from 1993-2008 for
Lower Fox River Station 16
(see Figure 6 for station location; Qualls et al., 2010)

0.3
Summer Median

0.25
N = 54

0.2
N = 43

TP
0.15
(mg/L)
0.1

N = 59

N = 48
N = 55

N = 45

N = 59

N = 66
N = 60

N = 49
N = 57

N = 44 N = 68

N = 51
N = 41

N = 41

0.05
0
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Figure 9. Annual summer (May through October) median TP concentrations from 1993-2008 for
Lower Green Bay Zone 1 8
(see Figure 6 for station location; Qualls et al., 2010)
8

A numeric water quality target is not shown on the chart, as Lower Green Bay only has a narrative target.

14

 0.4

0.4
N=6

0.3
TP
0.2
(mg/L)

0.3
N=6

N=6

0.1

2005

2006

N=8

TP
0.2
(mg/L)

0
2004

2005

2006

2004

(a) Apple Creek

(b) Ashwaubenon Creek

0.4

0.4

0.3

0.3
N=6
N=6

N=6

0.1

TP
0.2
(mg/L)

N=6

N=6
N=6

0.1

0

0
2004

2005

2006

(c) Baird Creek
0.4

N = 13

0.1

0

TP
0.2
(mg/L)

N = 12

2004

2005

2006

(d) Duck Creek

N=4
N=6

0.3
TP
0.2
(mg/L)

N=5

0.1

0
2004

2005

2006

(e) East River
Figure 10. Annual summer (May through October) median TP concentrations from 2004-2006
for Apple Creek (a), Ashwaubenon Creek (b), Baird Creek (c), Duck Creek (d), and East River (e)
(see Figure 7 for station locations; unpublished data provided by P. Baumgart, personal
communication, May 8, 2009)
15

 70

Summer Median
Water Quality Target (including MOS)

60

N = 11

50

N = 11

N = 14
N=8

TSS
(mg/L)

N = 12

N = 12

40

N = 13

30

N = 11

N = 13
N = 12 N = 14

N = 11
N = 11

N = 11

N = 14

N = 15

20
10
0
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Figure 11. Annual summer (May through October) median TSS concentrations from 1993-2008
for Lower Fox River Station 16
(see Figure 6 for station location; Qualls et al., 2010)

70
Summer Median

60
50

TSS
(mg/L)

N = 54

40

N = 59
N = 45

30

N = 44
N = 60 N = 65 N = 49 N = 57

20

N = 48

N = 59

N = 43

N = 68

N = 51 N = 41 N = 41

N = 64

10
0
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Figure 12. Annual summer (May through October) median TSS concentrations from 1993-2008
for Lower Green Bay Zone 1 9
(see Figure 6 for station location; Qualls et al., 2010)
9

A numeric target is not shown on the chart, as Lower Green Bay only has a narrative target.

16

 TSS
(mg/L)

75

75

60

60

45

TSS
(mg/L)

30

45
N=8

30

N = 12

N=6

15

N=6

N=6

2004

2005

15

0

0
2006

2004

(a) Apple Creek

TSS
(mg/L)

N = 13

2005

2006

(b) Ashwaubenon Creek

75

75

60

60

45

TSS
(mg/L)

30

45
30

N=8

15

15

N = 12

N = 13

2005

2006

0

(c) Baird Creek

N = 13

2004

2005

2006

(d) Duck Creek

N=4

60

TSS
(mg/L)

N = 12

0
2004

75

N=8

N=6

45

N=5

30
15
0
2004

2005

2006

(e) East River
Figure 13. Annual summer (May through October) median TSS concentrations from 2004-2006 for
Apple Creek (a), Ashwaubenon Creek (b), Baird Creek (c), Duck Creek (d), and East River (e)
(see Figure 7 for station locations; unpublished data provided by P. Baumgart, personal
communication, May 8, 2009)
17

 3.0

APPLICABLE WATER QUALITY STANDARDS

3.1.

Parameters of Concern and Applicable Water Quality Criteria

There are currently 27 impaired water body segments in the LFR Basin, including Lower Green Bay
(Table 1). Section 303(d) of the CWA requires that a TMDL be developed for each pollutant for each
listed water body. The watershed TMDL for the LFR Basin and Lower Green Bay includes the
development of 45 individual TMDLs for phosphorus and sediment. As described in Section 1.2, excess
phosphorus and sediment can cause numerous impairments to waterways including low dissolved
oxygen concentrations, degraded habitat, degraded biological community, and excessive turbidity. These
impairments impact fish and aquatic life, water quality, recreation, and potentially navigation.
Due to excessive phosphorus and sediment loading, the segments listed in Table 1 are not currently
meeting the applicable narrative water quality criterion as defined in Wisconsin Administrative Code NR
102.04(1), and must meet the following water quality standards regardless of their designated uses, as
follows:
“NR 102.04(1). GENERAL. To preserve and enhance the quality of waters, standards are
established to govern water management decisions. Practices attributable to municipal, industrial,
commercial, domestic, agricultural, land development or other activities shall be controlled so
that all waters including the mixing zone and the effluent channel meet the following conditions
at all times and under all flow conditions: (a) Substances that will cause objectionable deposits on
the shore or in the bed of a body of water, shall not be present in such amounts as to interfere
with public rights in waters of the state, (b) Floating or submerged debris, oil, scum or other
material shall not be present in such amounts as to interfere with public rights in waters of the
states, (c) Materials producing color, odor, taste or unsightliness shall not be present in such
amounts as to interfere with public rights in waters of the state.”
Excessive sediments are considered objectionable deposits.
In addition, the applicable numeric water quality standard for phosphorus as described in Wisconsin
Administrative Code NR 102.06(1) and 102.06(3) must be met in the LFR Basin:
“(1). GENERAL. This section identifies the water quality criteria for total phosphorus that shall
be met in surface waters.
(3) STREAMS AND RIVERS. To protect the fish and aquatic life uses established in s. NR
102.04(3) on rivers and streams that generally exhibit unidirectional flow, total phosphorus
criteria are established as follows:
(a) A total phosphorus criterion of 100 ug/L is established for the following rivers…
14. Fox River from outlet of Lake Puckaway near Princeton to Green Bay,
excluding Lake Butte des Mortes and Lake Winnebago.
(b) Except as provided in subs (6) and (7) all other surface waters generally exhibiting
unidirectional flow that are not listed in par. (a) are considered streams and shall meet a
total phosphorus criterion of 75 ug/L.”

18

 Therefore, the numeric water quality criterion that applies to the main stem of the LFR from Lake
Winnebago to Green Bay is a summer median concentration of 0.10 mg/L (100 µg/L); and the numeric
water quality criterion that applies to all tributary streams in the LFR Basin is a summer median
concentration of 0.075 mg/L (75 µg/L). In addition, the narrative standard also is applicable in this
TMDL. Excessive phosphorus loading causes algal blooms in the LFR Basin, which may be
characterized as floating scum, producing a green color, strong odor, and unsightliness. Sometimes these
algal blooms contain toxins that limit recreational uses of the water bodies. Because of the low dissolved
oxygen and degraded habitat caused by TP and TSS, the codified designated uses as warm water sport
and forage fish communities and limited forage fish communities are not supported (parts b, c, and d
below). Algal blooms associated with excess phosphorus loading are also considered “objectionable
deposits,” and are characterized as “floating debris, scum and material,” which produce “color, odor,
taste, or unsightliness” that interferes with both the fish and aquatic life and recreational uses of the
water body.
The designated uses of the segments listed in Table 1 10 are described in Wisconsin Administrative Code
NR 102.04(3) introduction and (b), (c), and (d), as follows:
“(3) FISH AND OTHER AQUATIC LIFE USES. The department shall classify all surface
waters into one of the fish and other aquatic life subcategories described in this subsection. Only
those use subcategories identified in pars. (a) to (c) shall be considered suitable for the protection
and propagation of a balanced fish and other aquatic life community as provided in federal water
pollution control act amendments of 1972, PL 92-500; 33 USC 1251 et.seq.
(a) Cold water communities. This subcategory includes surface waters capable of
supporting a community of cold water fish and other aquatic life, or serving as a spawning
area for cold water fish species. This subcategory includes, but is not restricted to, surface
waters identified as trout waters by the department of natural resources (Wisconsin Trout
Streams, publication 6-3600(80)).
(b) Warm water sport fish communities. This subcategory includes surface waters capable
of supporting a community of warm water sport fish or serving as a spawning area for
warm water sport fish.
(c) Warm water forage fish communities. This subcategory includes surface waters capable
of supporting an abundant diverse community of forage fish and other aquatic life.
(d) Limited forage fish communities. (Intermediate surface waters). This subcategory
includes surface waters of limited capacity and naturally poor water quality or habitat.
These surface waters are capable of supporting only a limited community of forage fish
and other aquatic life.”
Lastly, the following narrative criteria are applicable for the Lower Green Bay segment:
“NR 102.06(5). GREAT LAKES. To protect fish and aquatic life uses established in s. NR
102.04(3) and recreational uses established in NR 102.04(5) on the Great Lakes, total
phosphorus criteria are established as follows:
Note that the term “designated use” in Table 1 refers to those waters that are codified in NR 104, and “current use”
refers to the existing use or existing condition of the water body.

10

19

 (c) For the portion of Green Bay from the mouth of the Fox River to a line from Long
Tail Point to Point au Sable, the water clarity and other phosphorus-related conditions
that are suitable for support of a diverse biological community, including a robust and
sustainable area of submersed aquatic vegetation in shallow water areas.”
3.2.

Numeric Water Quality Targets

The TMDL target is a numeric endpoint specified to represent the level of acceptable water quality that
is to be achieved by implementing the TMDL. For phosphorus, these targets are equal to the numeric
water quality standard in Wisconsin Administrative Code NR 102.06. Numeric standards do not exist for
total suspended solids in Wisconsin, but numeric water quality targets for this TMDL may be determined
under Wisconsin Administrative Code NR 102.04(1) to control activities that may result in harm to
humans and fish and other aquatic life.
Using its authority under Wisconsin Administrative Code NR 102.04(1), WDNR has established sitespecific numeric water quality targets for the tributary streams and main stem of the Lower Fox River for
this TMDL. The targets were developed with the input of an Ad-Hoc Science Team 11 and using the best
available monitoring and scientific data. The targets are linked to biological indicators and other
conditions that are protective of the designated uses and applicable water quality standards for the
impaired segments in the LFR Basin. In addition, the targets reflect what is needed to meet narrative
water quality goals for Lower Green Bay
Numeric targets for TP and TSS were set for the tributary streams and main stem of the Lower Fox
River by evaluating predicted improvements in water quality and littoral zone habitats in Zones 1 and 2
in Green Bay (see Figure 6) from simulated reductions in LFR levels of TP and TSS. Using data collected
by GBMSD from 1993-2005 (for the period June through September), a multiple regression model was
established, relating Epar in Zones 1 and 2 to corresponding levels of TP and TSS in the LFR. Epar
scores are inversely proportional indicators of the ability of light to penetrate the water column. Low
Epar scores suggest clearer water with deep light penetration, while high scores suggest turbid water with
minimal light penetration. An additional, simple regression model was calculated to relate Epar to Secchi
depth measurements. Appendix A provides a summary table of the results of the model calculations for
Epar for the various TP and TSS reduction scenarios, and the relationship of those values to Secchi
depth.
The targets for TP (consistent with existing numeric water quality criteria in Wisconsin Administrative
Code NR 102.06) are a summer median concentration of 0.10 mg/L (100 µg/L) for the main stem of the
river (from the outlet of Lake Winnebago to the mouth of Green Bay) and a summer median
concentration of 0.075 mg/L (75 µg/L) for all of the tributary streams in the basin. The initial target for
TSS for the outlet of the Lower Fox River is a summer median concentration of 20 mg/L. When an
implicit margin of safety (MOS) of 10% is taken into account, the target for TSS for the outlet of the
Lower Fox River is a summer median concentration not to exceed 18 mg/L. These targets are expected
to result in a mean Epar of 1.5 m in zones 1 and 2, which translates to an estimated Secchi depth of 1.14
m. Achieving this Secchi depth is expected to result in a 63% increase in water clarity from the 19932005 (median) baseline Secchi depth of 0.70 m.

11

An Ad-hoc Science Team for this TMDL was formed in June 2007. The purpose of this team was to contribute local data
and scientific expertise to set numeric targets for the TMDL in the LFR Basin because numeric water quality standards
for TP were not yet promulgated in Wisconsin when this TMDL was initiated. The Ad-Hoc Science Team includes staff
from WDNR, UWGB, UW-Milwaukee Water Institute, GBMSD, UW-Sea Grant, Oneida Reservation, and EPA.

20

 The projected levels of TP and TSS for Zones 1 and 2 can be used to predict two additional responses to
the TMDL target for the LFR. The response of Secchi transparency has been estimated to reach 1.14 m
for Zones 1 and 2 based on the LFR TMDL data (see Appendix A). Using the GBMSD data on Secchi
depth, TP, and TSS in Zones 1 and 2, a multiple regression model was created. This model yields a
Secchi depth transparency of 1.17 m for a TP (0.06 mg/l) and TSS (15 mg/l) that agree closely with the
1.14 m value produced by the LFR- based model.
A specific numeric water quality target for TSS was not established for tributary streams or the main
stem of the Lower Fox River, as it is believed that the estimated percent reductions in TSS loads from
the tributaries and main stem needed to meet the target for the outlet of the Lower Fox River will
achieve the water quality goals and meet the narrative water quality criteria, and improve stream habitat
conditions for the tributary streams and main stem. Further, TP and TSS concentrations are reasonably
well-correlated and proportionally responsive to the same watershed build-up and wash-off processes.
Therefore, attainment of the TP water quality standards for the main stem of the river and for all of the
tributary streams in the LFR Basin is believed to result in sufficient reductions in TSS to achieve the water
quality goals and meet the narrative water quality criteria.
Water quality improvements and attainment with the TMDL target for TP will be evaluated based on the
comparison of annual summer median water column TP concentrations during critical conditions (i.e.,
May through October) to the targets. Water quality improvements and attainment with the TMDL target
for TSS will be evaluated based on the comparison of the target to annual summer median water column
TSS concentrations taken at the outlet of the Lower Fox River during critical conditions (i.e., May
through October). In order to delist the water bodies, both the water quality standards and the fish and
aquatic life and recreational use designations need to be met.
As the numeric targets for this TMDL are met, improved water clarity in Lower Green Bay is expected,
as well as other conditions suitable to support a diverse biological community, including a robust and
sustainable area of submersed aquatic vegetation (e.g., Vallisneria americana) in shallow water areas.
Meeting the numeric targets for this TMDL will achieve the aquatic life uses in the water bodies in the
basin.
Sedimentation is the suspected cause of habitat degradation in the tributary streams of the LFR Basin.
Achieving the TSS load reductions identified in this TMDL (based on the numeric target) will result in
reduced sedimentation and embeddedness of the substrate, which will help foster native aquatic life and
result in an increase in biotic integrity scores for fish and macroinvertebrate communities. In addition,
achieving the phosphorus load reductions identified in this TMDL will significantly reduce the frequency
and extent of algae blooms in the LFR main stem and in Lower Green Bay; as a result, this will achieve
the narrative criteria of no nuisance deposits or algal blooms.
Additional benefits from achieving the numeric TMDL targets (attributable to increased water clarity and
reduced phosphorus and sediment loading) include:
•

Increased area (~35-45%) of littoral zone habitat for invertebrates, fish, and waterfowl resulting
from increased water clarity (Sager, 1993).

•

Reduced density and frequency of nuisance algal blooms resulting in lowered health risks to
humans and animals – especially pets (reduced TP).

•

Increased dissolved oxygen concentrations that will support a more diverse and robust
community of fish and other aquatic life (increased water clarity and reduced TP).
21

 4.0

•

Reduced resuspension of sediment due to the stabilizing effect of increased submerged aquatic
vegetation (increased water clarity).

•

Increased numbers and safety of swimmers, boaters, wind-surfers, and other water craft users
(increased water clarity).
SOURCE ASSESSMENT

There are two general types of water pollution: point source and nonpoint source. Point source pollution
come from identifiable, localized sources that discharge directly into a water body, usually through a pipe
or outfall. Industries and wastewater treatment facilities are two common point sources. Stormwater
runoff from certain urban areas is also considered a point source (see Section 4.1.3 for more about this).
Nonpoint source pollution does not come from a single source like point source pollution; it comes
from land use activities such as agriculture and other diffuse sources. Most nonpoint source pollution
occurs as a result of runoff. When rain or melted snow moves over and through the ground, the water
carries any pollutants it comes into contact with to nearby water bodies. Sources of phosphorus and
sediment loading in the LFR Basin include: discharges from regulated wastewater treatment facilities and
runoff from agricultural land, urban land (both regulated and non-regulated areas), and natural areas (i.e.,
forests and wetlands).
In particular, nonpoint sources of pollution from agricultural and urban runoff contribute an excess of
sediment and phosphorus loading to smaller streams, such as the tributaries in the LFR Basin. As
discussed earlier, this excessive loading leads to degraded stream habitat, unbalanced fish populations,
and eutrophic conditions. Sediment deposition leads to loss of spawning habitat for fish, burial of fish
eggs and embryos, reduction of forage fish populations, reduced macroinvertebrate populations, and
altered channel morphology. Suspended solids in the water column and excessive algal growth also
reduce water clarity, decrease light availability for beneficial aquatic plants, increase water temperatures,
and can cause fish kills due to clogging of gills.
Specific overland sources of TP and TSS loading in the LFR Basin include: runoff from agricultural
fields, urban areas (regulated and non-regulated areas as previously discussed), construction sites, and
natural areas (i.e., forests and wetlands, which are considered background sources); and discharges from
wastewater treatment facilities.
Runoff from agricultural land is one of the largest contributors of TP and TSS in the basin. TP and TSS
loading from agricultural land in the basin originate primarily from soil erosion and the application
fertilizers and manure (i.e., animal waste applied to agricultural fields as fertilizer) to cropland. Pasture
land and animal feeding operations in the basin are also sources of agricultural TP and TSS loading.
Runoff from animal feedlots can transport animal waste high in phosphorus to surface waters.
Permitting livestock direct access to streams not only allows direct input of phosphorus, but also erodes
the stream bank, causing excess sediments to enter the water body, and contributes to habitat and
channel degradation. Even if livestock are not allowed direct access to a water body, allowing livestock to
graze to the edge of a water body eliminates essential riparian vegetation (through consumption and/or
trampling), which results in destabilized stream banks and increased transport of eroded material to the
water body.
TP and TSS loading from urban areas originates primarily from human activities, such as applying
fertilizer to lawns. The development of stormwater sewer systems has increased the speed and efficiency
of transporting urban runoff to local water bodies. This runoff carries materials like grass clippings,
fertilizers, leaves, car wash wastewater, soil, and animal waste; all of which contain phosphorus.
22

 Construction activities and new development can have a large TP and TSS loading impact on nearby
water bodies, especially if the activity is near the shorelines of water bodies.
Internal production represents the growth of biotic solids (e.g., plankton) in the water column of the
Lower Fox River main stem in response to temperature, light, and nutrients. Internal biotic solids are an
important component of the overall solids balance of the Lower Fox River and are accounted for in the
TMDL analysis for TSS. Internal biotic solids are estimated to contribute an additional 34,833,037 lbs/yr
(1989-95 average based on data summarized by WDNR) to TSS loads in the Lower Fox River between
the Lake Winnebago outlet and LFR outlet (WDNR 2001b, LTI, 1999).
Atmospheric deposition, residential on-site septic systems, wildlife, waterfowl, and domestic pets may
also be potential sources of TP and/or TSS loading in the basin, and have been incorporated into the
land use loadings as identified in the TMDL analysis (and therefore accounted for).
Section 4.1 briefly summarizes the methods used to calculate loads from each of these sources in the
LFR Basin; additional details are provided in Appendix B. Section 4.2 provides a quantitative summary
of the phosphorus and sediment loads originating from each source within the LFR Basin.
4.1.

Analysis of Phosphorus and Sediment Loading

4.1.1.

Nonpoint Source Runoff

The Soil & Water Assessment Tool (SWAT) was used to calculate nonpoint sources of phosphorus and
sediment loading under baseline conditions in the LFR Basin. Nonpoint sources of phosphorus and
sediment loading simulated by SWAT include runoff from agricultural and urban land, as well as from
natural areas (i.e., forests and wetlands, herein referred to as natural background). Nonpoint source loads
were calculated by SWAT using a 23-year (1977-2000) long-term hydrologic simulation period, as well as
land use data that reflect the 2004-2005 timeframe (see Appendix B). Use of a 23-year averaging period
for hydrologic simulations minimizes the potential influence of climate dependant factors and provides a
more representative estimate of average conditions. Output from the model was on a daily time step, but
was summarized on an average annual basis for the TMDL analysis.
SWAT is a distributed parameter, daily time-step model that was developed by the U.S. Department of
Agriculture - Agricultural Research Service (USDA-ARS) to assess nonpoint source pollution from
watersheds and large complex river basins (Neitsch et al., 2002). SWAT simulates hydrologic and related
processes to predict the impact of land use management on water, sediment, nutrient, and pesticide
export. With SWAT, a large heterogeneous river basin can be divided into hundreds of subwatersheds;
thereby, permitting more detailed representations of the specific soil, topography, hydrology, climate and
management features of a particular area. Crop and management components within the model permit
representation of the cropping, tillage, and nutrient management practices typically used in Wisconsin.
Major processes simulated within the SWAT model include: surface and groundwater hydrology,
weather, soil water percolation, crop growth, evapotranspiration, agricultural management, urban and
rural management, sedimentation, nutrient cycling and fate, pesticide fate, and water and constituent
routing. The QUAL2E sub-model within SWAT was used to simulate nutrient transport within each of
the tributary reaches, but not the LFR main stem. A detailed description of the SWAT model can be
found on the SWAT model’s Web site. 12

12

http://www.brc.tamus.edu/swat/

23

 The SWAT model was previously calibrated and validated for use in estimating TP and TSS loading in
the LFR Basin (Baumgart, 2005; Cadmus, 2007). The previously calibrated and validated SWAT model
was refined for this TMDL analysis in order to make use of new data sets of continuous flow and daily
loads of TP and TSS from the five LFRWMP monitoring stations (Figure 7). The new model calibration
and validation strengthened the ability of SWAT to simulate flow, TP, and TSS with a reasonable level of
accuracy. Appendix B provides a detailed summary of the calibration and validation of SWAT, including
the results of the model calibration and validation.
4.1.2.

Regulated Wastewater Treatment Facilities

Phosphorus and sediment loads for regulated municipal and industrial wastewater treatment facilities
(WWTFs) were calculated using an average of actual loads reported to WDNR in Discharge Monitoring
Reports (DMRs) between 2003 and 2009 (averaging period for each facility calculated using one or more
years of data in this timeframe). At the time of the TMDL analysis, there were 20 industrial and 14
municipal permitted WWTFs operating in the LFR Basin (Table 3 and Figure 14). GW Partners LLC
(permit no. 0001121) is not listed in this table, as it is no longer operating. However, the estimated
baseline load from GW Partners LLC (6,362 lbs/year for TP and 52,979 lbs/year for TSS) is being set
aside to support potential new or expanded permits on the main stem of the Lower Fox River (see
Section 6.5.1 for additional discussion about this). Through the use of coordinates, GIS software, and
aerial photos, it was determined to which subwatershed each of the municipal and industrial WWTFs
discharges. Each facility’s load was added to the SWAT simulated load for the corresponding
subwatershed.
4.1.3.

Regulated Stormwater Runoff

Stormwater runoff from municipal areas contains a mixture of pollutants from parking lots, streets,
rooftops, lawns, and other areas. Although these areas are efficient at diverting water to avoid flooding in
developed areas, they also transport polluted runoff (including sediments and phosphorus) into nearby
lakes, rivers, and streams without the benefit of wastewater treatment or filtration by soil or vegetation.
Even though stormwater is precipitation driven and better fits the model of nonpoint pollution,
stormwater runoff from regulated municipalities is considered a point source and, therefore, accounted
for in the wasteload allocation of a TMDL.
To meet the requirements of the federal CWA, WDNR developed the Wisconsin Pollutant Discharge
Elimination System (WPDES) Storm Water Discharge Permit Program, which is administered under
Wisconsin Administrative Code NR 216. The WPDES Storm Water Program regulates discharge of
storm water in Wisconsin from municipalities, industrial facilities, and construction sites. The goal of
WDNR’s municipal storm water management program is to decrease the pollutants carried to waters of
the state through these Municipal Separate Storm Sewer Systems (MS4s). Communities that meet the
requirements stipulated under EPA’s Phase 1 or Phase 2 stormwater regulations are required to obtain a
permit to discharge stormwater. Under Phase 1, communities with a population greater than 100,000
were required to obtain a permit. Under Phase 2, communities that meet the definition of an urbanized
area (a total population of 10,000 or more as determined by U.S. Census data) were required to obtain a
permit. In limited cases, Wisconsin regulations allow for smaller communities to be issued a permit if
they are part of an urbanized area.
Currently there are five different WPDES industrial storm water general permits. WDNR coverage for
general industrial storm water discharges is based on the type of industrial activity and how likely a
facility is to contaminate storm water. The requirements of each general permit differ in chemical
monitoring requirements, inspection frequency, plan development requirements and the annual permit
24

 fee. A list of general permits can be found on WDNR’s storm water website. 13 The industrial storm
water general permits in the LFR Basin include: Storm Water Auto Parts Recycling; Tier 1 and Tier 2
Industrial Storm Water; Storm Water Scrap Recycling; and Nonmetallic Mining Operations. There are
approximately 256 industrial storm water general permits within the MS4 boundaries, and approximately
142 industrial storm water general permits outside of the MS4 boundaries in the LFR Basin.
The SWAT model was used to calculate phosphorus and sediment loading from urban sources regulated
by WPDES stormwater permits. These regulated sources include stormwater runoff from MS4s,
industrial facilities, and construction sites. Details about the use of the SWAT model to simulate loading
from regulated urban areas, including a summary of the studies upon which the sediment and
phosphorus yield estimates are based, are provided in Appendix B.
There are 29 regulated MS4s in the LFR Basin (Table 4 and Figure 15). Loads were simulated for MS4
and industrial urban areas using the build-up and wash-off routine in SWAT, along with a sediment yield
of 275 lbs/acre and phosphorus yield of 0.7 lbs/acre. Using an area-weighted approach, loads were
apportioned to each MS4 using the MS4 boundaries developed for this TMDL analysis (see Appendix
B). Loads from facilities covered under a general permit and located within an MS4 are included in the
simulation of loads from the MS4s. Similarly, stormwater runoff from the Wisconsin Department of
Transportation system is also accounted for in simulated loads for the MS4s. Loads from facilities
covered under a general permit outside of the MS4 boundaries were estimated to be 10% of the
pollutant runoff from SWAT simulated loads from non-regulated urban land (WDNR, personal
communication, November 9, 2009).
The area of land under construction (also called urbanizing land) represents a transitional change from
rural to urban land use. The rate and amount of urbanization is variable making it difficult to simulate in
a model. For the TMDL, loads from construction sites were simulated by adding a separately calculated
urban load to the SWAT-simulated loads. Loads were computed for each subwatershed by assuming that
the annualized change in urban area from 2001 to 2004 remained constant. The area of land under
construction was estimated as the change in urban areas between a land use layer representative of 2001
developed by Baumgart (2005) in a previous modeling effort, and the 2004-2005 land use layer
developed for this analysis. To derive the load associated with urbanizing areas (i.e., construction sites),
the annual average increase in urban area within each subwatershed was multiplied by a sediment yield of
4,047 lbs/acre (5.0 t/ha) and a phosphorus yield of 4.5 lbs/acre (as routed to the watershed outlets).
These yields are based on two separate Wisconsin studies conducted by Owens et al. (2000) and Madison
et al. (1979), as well as SWAT simulations under fallow conditions. Appendix B provides detail about
these studies.
4.1.4.

Regulated Concentrated Animal Feeding Operations

Every farm, regardless of size, is responsible for proper manure management to protect water quality
from discharges. Over the past ten years, Wisconsin has become home to an increasing number of
Concentrated Animal Feeding Operations (CAFOs), those operations with 1,000 or more animal units.
Due to the increased number and concentration of animals, it is particularly important for these facilities
to properly manage manure in order to protect water quality in Wisconsin.
A specific regulatory program for the handling, storage, and utilization of manure was developed by
WDNR in 1984 in Wisconsin Administrative Code Chapter NR 243. The rule creates criteria and
standards to be used in issuing permits to CAFOs as well as establishing procedures for investigating
13

WDNR’s storm water web site: http://dnr.wi.gov/runoff/stormwater.htm

25

 water quality problems caused by smaller animal feeding operations. Because of the potential water
quality impacts from CAFOs, animal feeding operations with 1,000 animal units or more are required to
have a WPDES CAFO permit. These permits are designed to ensure that operations choosing to expand
to 1,000 animal units or more use proper planning, construction, and manure management to protect
water quality from adverse impacts.
There are 15 regulated CAFOs in the LFR Basin, including United Meadows Dairy in Brown County,
which has a medium 14 size CAFO permit, but does not have more than 1,000 animal units (Table 5 and
Figure 16). WPDES permits for CAFOs require that the facilities be designed, constructed and operated
to have no discharge of pollutants to navigable waters, unless caused by a catastrophic storm (24-hour
duration exceeding the 25-year recurrence interval). CAFOs must comply with their no-discharge permit
requirements; therefore, loading from CAFOs is assumed to be zero (0) from the production area. Land
application of manure from CAFOs, however, is not included in the assumption of zero discharge.
Loading of phosphorus and sediments from land spreading is accounted for in the nonpoint source
loads.

14

WDNR’s definition for a medium sized CAFO is described in NR 243.03 (39): “Medium CAFO” means an animal
feeding operation with 300 to 999 animal units that has a category I discharge to navigable waters under s. NR 243.24,
or that is designated by the department as a CAFO under s. NR 243.26 (2).

26

 Table 3. WWTFs in the LFR Basin.
Industrial Facilities
Appleton Coated LLC
Arla Foods Production LLC –
Holland
Belgioso Cheese - Sherwood
Cellu Tissue – Neenah
Fox Energy LLC
Galloway Company
Georgia Pacific Consumer
Products LP
Georgia Pacific Consumer
Products LP
Green Bay Packaging - Green
Bay
Neenah Paper, Inc.
Menasha Electric & Water Utility
NewPage Wisconsin Systems –
Kimberly
Pechiney Plastic Packaging Menasha 001
Procter & Gamble
Provimi Foods – Seymour
SCA Tissue North America 001 &
002
Schroeder's Greenhouse
Thilmany LLC – DePere
Thilmany LLC – Kaukauna
Wisconsin Public Service Corp.,
Pulliam
Municipal Facilities
Appleton
GBMSD - De Pere
Forest Junction
Freedom San. Dist. #1
Grand Chute - Menasha West
Green Bay MSD
Heart of the Valley
Neenah – Menasha
Oneida WWTF *
Sherwood
Town of Holland SD #1 001 &
003
Wrightstown
Wrightstown SD#1
Wrightstown SD#2
* Regulated via EPA NPDES permit

Table 4. MS4s in the LFR Basin.

Permit
0000990

Map
1

0027197

2

0027201
0000680
0061891
0027553

3
4
5
6

0001261

7

0001848

8

0000973

9

0037842
0027707

10
11

0000698

12

0026999

13

0001031
0044628

14
15

0037389

16

0046248
0001473
0000825

17
18
19

0000965

20

Permit
0023221
0023787
0032123
0020842
0024686
0020991
0031232
0026085
WI0071323
0031127

Map
21
22
23
24
25
26
27
28
29
30

0028207

31

0022497
0022438
0022357

32
33
34

MS4s
Brown County
Calumet County
City of Appleton
City of De Pere
City of Green Bay
City of Kaukauna
City of Menasha
City of Neenah
Outagamie County
Town of Buchanan
Town of Grand Chute
Town of Greenville
Town of Harrison
Town of Lawrence
Town of Ledgeview
Town of Menasha
Town of Neenah
Town of Scott
University of Wisconsin Green Bay
Village of Allouez
Village of Ashwaubenon
Village of Bellevue
Village of Combined Locks
Village of Hobart
Village of Howard
Village of Kimberly
Village of Little Chute
Village of Suamico
Winnebago County

FIN
33656
33653
31098
31088
33657
31102
31110
31112
33644
31099
31102
31103
31104
31092
31093
31111
31113
31095
37165
31085
31086
31087
31100
Oneida
31091
31107
31108
31096
33642

Table 5. CAFOs in the LFR Basin.
CAFOs
Country Aire Farms
Brickstead Dairy
Meadowlark Dairy L.L.C.
Neighborhood Dairy, L.L.C.
New Horizons Dairy LLC
Ranovael Dairy
Rueden Beef LLC
Schuh View Dairy L.L.C.
Stencil Farms
Thompsons Gold Dust Dairy
Tidy View Farm, Inc.
Tinedale Farms L.L.C.
United Meadows Dairy
Verhasselt Farm
Weise Brothers Farms

Permit
0059200
0064378
0061905
0062618
0063428
0062821
0063312
0059129
0056731
0058386
0056839
0058947
0064106
0049034
0059056

27

 Figure 14. Location of municipal and industrial WWTFs in the LFR Basin
(see Table 3 for facilities names corresponding to numbers on map)
28

  

   
 
  

Green Bay

    
   
   
 
   
   

Oneida Reservation 


{Lower Green Bay

Duck Creek

'ower Creek

7 Town of Buchanacn

Town 
Creek

Lake Winnebago

 

?:Miles 

 

 

 

 

 

Figure 15. Location of MS4s in the LFR Basin

 

29

 

 

Green Bay

?1
(0062824) ..

    
 

-??Stencii Farms
(0056731)

     
 
 
 
 
 
 
 

Schuh Vi?ew DEiny?1?00591291F

  

. Verhasselt
I Farm (0049034)
TidyNi?WsFarm (0056839 )?Fjw New Horizons Dairy(0063428}

Unite? Meadows - Meadbwlark\Dairy(0061905)
Dairy/(0064106) 

 

(0059200)
Rueden Beef (0063312)

  
  

 

CAFO

Waters impaired by
Phosphorus or Sediment

  
     

. St
Lake-Winnebago Iver or ream
Lake or Bay

- Oneida Reservation
i City

 

0 3 6 
Miles Lower Fox River Basin



 

 

 

 

 

 

 

Figure 16. Location of CAFOs in the LFR Basin

30

 

4.1.5.

Out-of-Basin Sources

The drainage basin for Lower Green Bay actually includes more than just the LFR Basin. As shown in
Figure 17, three major river basins (the Upper Fox River, the Lower Fox River, and the Wolf River),
referred to collectively as the Fox-Wolf Basin, represent the drainage basin for Lower Green Bay. Figure
18 shows the percent of total land area in the Fox-Wolf Basin for each of the Upper Fox River, the
Lower Fox River, and the Wolf River Basins. This includes Lake Winnebago, which is an inlet to the
LFR Basin. The focus of this TMDL is the LFR Basin and Lower Green Bay; however, contributions
from Lake Winnebago and the Upper Fox and Wolf Basins must also be reduced if the goals established
by this TMDL are to be met. This will be addressed in a forthcoming TMDL report slated to be final in
the next few years, as federal and state resources allow.
Baseline loads entering the LFR Basin at the outlet of Lake Winnebago were derived from a regression
equation developed by Dale Robertson of the USGS (unpublished data produced for the Lower Fox
River TMDL project by Dale Robertson of the USGS in 2008; methods provided in Robertson and
Saad, 1996, and Robertson, 1996). Robertson’s constituent transport regression model was applied to
estimate TP and TSS loads entering the Lower Fox River from the outlet of Lake Winnebago from 1989
to 2006, and an average was used to represent baseline conditions. Appendix C provides a summary of
these data.

Wolf
River
57%

Upper
Fox
33%

Lower
Fox
10%

Figure 17. Drainage basins for the Upper Fox
River, Lower Fox River, and Wolf River

Figure 18. Percent of total land area of
the Fox-Wolf Basin

31

 4.2.

Summary of Baseline Sources of Phosphorus and Sediment Loading

Baseline TP and TSS loading conditions in the LFR Basin were estimated using the methods
summarized in Section 4.1. This section provides a data summary of baseline loads and sources of
baseline loads for the basin.
Mean annual TP loading in the LFR Basin is an estimated 549,703 lbs/yr (Table 6 and Figure 19). Lake
Winnebago is estimated to contribute an additional 716,954 lbs/yr at its outlet, resulting in a combined
total mean annual TP loading of 1,266,657 lbs/yr.
Table 6. Sources of baseline TP loading in the LFR Basin
Source
Natural Background
Agriculture
Urban (non-regulated)
Urban (regulated MS4)
Construction Sites
General Permits
Industrial WWTFs
Municipal WWTFs
TOTAL (in-basin)

Total Phosphorus (lbs/yr)
5,609
251,382
15,960
65,829
7,296
2,041
114,426
87,160
549,703

Lake Winnebago
TOTAL (in-basin + Lake Winnebago)

716,954
1,266,657

Urban (nonregulated)
Natural Background
2.9%
1.0%
Agriculture
45.7%

Urban (regulated
MS4)
12.0%
Construction Sites
1.3%

Municipal
WWTFs
15.9%

Industrial
WWTFs
20.8%

General Permits
0.4%

Figure 19. Sources of baseline TP loading in the LFR Basin
32

 Mean annual TSS loading in the LFR Basin is an estimated 176,434,787 lbs/yr (Table 7 and Figure 20).
Lake Winnebago is estimated to contribute an additional 127,397,076 lbs/yr at its outlet, resulting in a
combined total mean annual TSS loading of 303,831,863 lbs/yr.
Table 7. Sources of baseline TSS loading in the LFR Basin
Source
Natural Background
Agriculture
Urban (non-regulated)
Urban (regulated MS4)
Construction Sites
General Permits
Industrial WWTFs
Municipal WWTFs
Biotic Solids
TOTAL (in-basin)

Total Suspended Solids (lbs/yr)
1,264,433
93,101,945
4,491,399
31,505,733
7,015,420
616,532
2,435,778
1,170,510
34,833,037
176,434,787

Total Suspended Solids (mt/yr)
574
42,230
2,037
14,291
3,182
280
1,105
531
15,800
80,030

Lake Winnebago
TOTAL (in-basin + Lake Winnebago)

127,397,076
303,831,863

57,786
137,816

Natural Background
0.9%
Urban (nonregulated)
3.2%

Urban (regulated
MS4)
22.2%

Construction Sites
5.0%
General Permits
0.4%
Industrial WWTFs
1.7%
Municipal WWTFs
0.8%

Agriculture
65.7%

Figure 20. Sources of baseline TSS loading in the LFR Basin (excluding biotic solids)

33

 In order to support planning for implementation of the TMDL within the LFR Basin, the results of the
analysis are summarized by the 15 major sub-basins that make up the LFR Basin (Figure 21). Table 8
provides a summary of mean annual baseline TP and TSS loads originating from within each of the 15
sub-basins.
Table 8. Summary of baseline TP and TSS loads originating from within each sub-basin
Sub-Basin

Total Phosphorus
(lbs/yr)

East River
Baird Creek
Bower Creek
Apple Creek
Ashwaubenon Creek
Dutchman Creek
Plum Creek
Kankapot Creek
Garners Creek
Mud Creek
Duck Creek
Trout Creek
Neenah Slough
Lower Fox River (main stem)
Lower Green Bay
TOTAL (in-basin)*

48,748
12,748
27,777
35,088
15,681
15,280
31,569
20,050
6,575
6,594
63,172
4,518
11,912
237,339
12,652
549,703

Total Suspended Solids
lbs/yr
mt/yr
19,796,496
8,980
3,791,217
1,720
10,318,235
4,680
12,736,271
5,777
4,871,171
2,210
5,033,703
2,283
12,038,905
5,461
7,253,520
3,290
2,863,318
1,299
2,924,841
1,327
25,394,165
11,519
1,451,838
659
4,846,168
2,198
23,980,196
10,877
4,301,706
1,951
141,601,750
64,231

* Not including loads from biotic solids

34

  

 

   
 
   
    

Oneida Reservation

 

  

Waters Impaired by
Phosphorus or Sediment

Sub-basins

 

 

 

 

 

Figure 21. Sub-basins in the Lower Fox River Basin

35

5.0

DETERMINATION OF LOAD CAPACITY

5.1.

Linking Phosphorus and Sediment Loading to the Numeric Water Quality Targets

The targets for TP are a summer (May through October 15) median concentration of 0.10 mg/L (100
µg/L) for the main stem of the Lower Fox River and a summer (May through October) median
concentration of 0.075 mg/L (75 µg/L) for tributary streams in the basin, including Duck Creek, which
discharges directly to Lower Green Bay. The target for TSS for the outlet of the LFR Basin to Lower
Green Bay is a summer (May through October) median concentration of 18 mg/L. TSS targets for the
tributary streams and main stem of the river are calculated as the percent load reductions needed to meet
the target for the outlet of the LFR Basin to Lower Green Bay. The SWAT model is only capable of
simulating phosphorus and sediment concentrations and loads rather than response variables in the
water body (such as biological conditions). However, this TMDL is based on in-stream phosphorus and
sediment targets that are linked to biological indicators and other conditions that are protective of the
designated uses and applicable water quality standards for the impaired segments in the LFR Basin.
Water quality monitoring data will need to be collected to determine whether numeric water quality
targets and load allocations are being met for this TMDL. This evaluation of compliance with water
quality standards will be made based on minimum data requirements and thresholds as outlined in
Wisconsin’s Consolidated Assessment and Listing Methodology (WisCALM) document.
5.2.

Critical Conditions

TMDLs must take into account critical environmental conditions to ensure that water quality is
protected during times when it is most vulnerable. Critical conditions for phosphorous impairments are
generally during summer months when temperature, flow, and sunlight conditions are conducive to
excessive plant growth. However, loadings throughout the entire year contribute to high phosphorus
concentrations during this critical period. Critical loadings for TSS impairments occur during wet
weather events, which result in upland and stream bank erosion. Wet weather events can occur at various
times during the year, but are especially prevalent in spring and summer.
A TMDL is typically expressed as a load over time; however, it is the in-stream phosphorus and
sediment concentrations under critical conditions that must be reduced to remove the impairments in
the LFR Basin and Lower Green Bay. Therefore, water quality improvements will be evaluated through
comparison of water column concentrations during the critical period (i.e., summer). The SWAT model
uses daily time steps for weather data and water balance calculations. Annual calculations are made for
phosphorus and sediment loads based on the daily water balance accumulated to annual values.
Therefore, all possible flow conditions are taken into account for loading calculations. Because there is
generally a significant lag time between the introduction of phosphorus and sediment to a water body
and the resulting impact on beneficial uses, establishing this TMDL using average annual conditions is
protective of the impaired segments in the LFR Basin. Further, the TMDLs are presented as both a daily
load and an average annual load. An annual loading target is more appropriate than a daily loading target
for guiding implementation efforts, as annual loads are more easily aligned with the design of best
management practices (BMPs) used to implement nonpoint source and stormwater controls for nutrient
and sediment impairments. The daily TMDLs and allocations were calculated by dividing the annual load
by the number of days in the year.

15

During the algae growing season.

36

 5.3.

Loading Capacity

The objective of a TMDL is to allocate loads among pollutant sources so that appropriate control
measures can be implemented and water quality standards achieved. Wasteload allocations (WLAs)
are assigned to point source discharges regulated by WPDES permits and unregulated nonpoint source
loads are assigned load allocations (LAs). A TMDL is expressed as the sum of all individual WLAs for
point source loads, LAs for nonpoint source loads, and an appropriate margin of safety (MOS), which
takes into account uncertainty (Equation 1).
Equation 1. Calculation of the TMDL

TMDL = ∑ WLA + ∑ LA + MOS
As previously mentioned, this TMDL was developed using a watershed framework. Under a watershed
framework, TMDLs and the associated tasks 16 are simultaneously completed for multiple impaired water
bodies in a watershed. Appendix C summarizes the methodology used to calculate the TMDLs and load
reductions needed to attain the numeric targets.
A portion of the LFR Basin is located within the Oneida Tribe of Wisconsin’s Reservation. This TMDL
is not applicable to the water bodies located within the boundary of the Oneida Reservation. However,
to meet the TMDLs for the LFR Basin and Lower Green Bay, voluntary reductions are needed from
sources located within the Oneida Reservation. Therefore, load reduction goals for pollutant loads
originating from within the Oneida Reservation have been identified in this report.
5.3.1.

Total Phosphorus

The maximum average annual phosphorus load that will achieve the 0.075 mg/L target for the tributary
streams in the basin and the 0.1 mg/L target for the LFR main stem and outlet to the bay is an average
annual TP load of 224,301 lbs/yr from in-basin loads. The daily equivalent TMDL of this load is 614
lbs/day. Achieving the average annual TMDL will require a 59.2% total reduction from in-basin loads.
Table 9 provides a summary of baseline loads, allocated loads, and load reduction goals for TP loads
originating from within each sub-basin. Voluntary reduction goals for phosphorus loads originating from
within the Oneida Reservation have also been identified in Table 9.
As previously discussed, phosphorus loads from Lake Winnebago (and the Upper Fox and Wolf Basins)
must also be reduced if the goals established by this TMDL are to be met. As discussed in Appendix C, a
40% reduction goal (286,782 lbs/yr) has been established for phosphorus loads entering the basin at the
outlet of Lake Winnebago. This reduction goal for loads entering the LFR Basin from the outlet of Lake
Winnebago represents reasonable expectations for load reductions that may be achievable in the Upper
Fox and Wolf Basins given that Lake Winnebago is a eutrophic/hypereutrophic lake. Reducing the
amount of phosphorus released from the lake by greater than 40% may not be feasible given that part of
the phosphorus input to Lake Winnebago may come from internal sources (D. Robertson, personal
communication, June 2010). Further studies by USGS and WDNR are being conducted to determine
what measures would be needed to reduce phosphorus loading from Lake Winnebago by 40%. The
reduction goal for Lake Winnebago may need to be adjusted following the TMDL analysis for the Upper
Fox and Wolf Basins.
16

Characterizing the impaired water body and its watershed, identifying sources, setting targets, calculating the loading
capacity, identifying source allocations, preparing TMDL reports, and coordinating with stakeholders.

37

 Table 9. Summary of baseline loads, allocated loads, and load reduction goals for TP loads
originating from within each sub-basin
Allocated TP (lbs/yr)

TP
Reduction
(lbs/yr)
34,156

Baseline TP
(lbs/yr)

State

Oneida

Total

East River

48,748

14,592

0

14,592

Baird Creek

12,748

4,801

0

4,801

7,947

62.3%

Bower Creek

27,777

7,964

0

7,964

19,813

71.3%

Apple Creek

35,088

12,557

0

12,557

22,531

64.2%

Ashwaubenon Creek

15,681

4,636

1,151

5,787

9,894

63.1%

Dutchman Creek

15,280

2,626

3,638

6,263

9,017

59.0%

Plum Creek

31,569

7,193

0

7,193

24,376

77.2%

Kankapot Creek

20,050

5,548

0

5,548

14,502

72.3%

Garners Creek

6,575

2,949

0

2,949

3,626

55.1%

Mud Creek

6,594

4,254

0

4,254

2,340

35.5%

Duck Creek

63,172

14,113

9,139

23,252

39,920

63.2%

Trout Creek

4,518

0

2,495

2,495

2,023

44.8%

Neenah Slough

11,912

5,758

0

5,758

6,154

51.7%

Lower Fox River (main stem)

237,339

114,263

0

114,263

123,076

51.9%

Sub-Basin

Lower Green Bay
TOTAL (in-basin)

%
Reduction*
70.1%

12,652

6,625

0

6,625

6,027

47.6%

549,703

207,878

16,423

224,301

325,402

59.2%

*Provided for informational purposes only and calculated as follows: Baseline TP / TP Reduction

38

 5.3.2. Total Suspended Solids
The maximum average annual sediment load that will achieve compliance with the 18 mg/L target for
the outlet to Lower Green Bay is an average annual TSS load of 79,512,059 lbs/yr from in-basin loads.
The daily equivalent TMDL of this load is 217,692 lbs/day. Achieving the average annual TMDL will
require a 54.9% total reduction in loads from in-basin loads. Table 10 provides a summary of baseline
loads, allocated loads, and load reductions goals for TSS loads originating from within each sub-basin, as
well as from biotic solids from the Lower Fox River main stem. Voluntary reduction goals for TSS loads
originating from within the Oneida Reservation have also been identified in Table 10.
TSS loads from Lake Winnebago (and the Upper Fox and Wolf Basins) must also be reduced if the goals
established by this TMDL are to be met. As discussed in Appendix C, an estimated 48.3% reduction goal
(61,472,726 lbs/yr) is expected for TSS loads entering the basin at the outlet of Lake Winnebago. This
reduction goal for loads entering the LFR Basin from the outlet of Lake Winnebago represents
reasonable expectations for load reductions that may be achievable in the Upper Fox and Wolf Basins.
This reduction goal may need to be adjusted following the TMDL analysis for the Upper Fox and Wolf
Basins.
Table 10. Summary of baseline loads, allocated loads, and load reduction goals for TSS loads
originating from within each sub-basin, from biotic solids
Baseline TSS
(lbs/yr)

State

Oneida

Total

East River

19,796,496

7,231,130

0

7,231,130

TSS
Reduction
(lbs/yr)
12,565,366

Baird Creek

3,791,217

2,374,777

0

2,374,777

1,416,440

37.4%

Bower Creek

10,318,235

3,939,913

0

3,939,913

6,378,322

61.8%

Apple Creek

12,736,271

6,211,712

0

6,211,712

6,524,559

51.2%

Ashwaubenon Creek

4,871,171

2,198,993

664,069

2,863,062

2,008,109

41.2%

Dutchman Creek

5,033,703

1,075,794

2,022,278

3,098,072

1,935,631

38.5%

Plum Creek

12,038,905

3,558,318

0

3,558,318

8,480,587

70.4%

Kankapot Creek

7,253,520

2,744,726

0

2,744,726

4,508,794

62.2%

Garners Creek

2,863,318

1,459,045

0

1,459,045

1,404,273

49.0%

Mud Creek

2,924,841

2,104,168

0

2,104,168

820,673

28.1%

Duck Creek

25,394,165

7,095,397

4,321,078

11,416,475

13,977,690

55.0%

Trout Creek

1,451,838

0

1,234,199

1,234,199

217,639

15.0%

Neenah Slough
Lower Fox River
(main stem)
Lower Green Bay

4,846,168

2,848,353

0

2,848,353

1,997,815

41.2%

23,980,196

11,115,433

0

11,115,433

12,864,763

53.6%

4,301,706

2,265,758

0

2,265,758

2,035,948

47.3%

Biotic Solids

34,833,037

15,046,918

0

15,046,918

19,786,119

56.8%

176,434,787

71,270,435

8,241,624

79,512,059

96,922,728

54.9%

Sub-Basin

TOTAL (in-basin)

Allocated TSS (lbs/yr)

%
Reduction*
63.5%

*Provided for informational purposes only and calculated as follows: Baseline TSS / TSS Reduction

39

 6.0

POLLUTANT LOAD ALLOCATIONS

6.1.

In-Basin Sources

Each sub-basin’s TMDL, load allocations, wasteload allocations, and needed reductions for both TP and
TSS are summarized in tables on pages 43–87. Individual sub-basin maps are provided with the
allocation tables. Appendix C provides a summary of the methodology used to calculate the TMDLs and
the load and wasteload allocations.
6.1.1.

Load Allocation

The load allocations for nonpoint sources of TP and TSS are summarized on pages 43–87. Appendix C
provides a summary of the methodology used to calculate the load allocations.
6.1.2.

Wasteload Allocation

The wasteload allocations for point sources of TP and TSS are summarized on pages 43–87. Appendix C
provides a summary of the methodology used to calculate the wasteload allocations.
Water quality-based effluent limits (WQBELs) that implement WLAs in approved TMDLs must be
“consistent with the assumptions and requirements of any available WLA for the discharge” (Title 40 of
the Code of Federal Regulations [CFR] 122.44(d)(1)(vii)(B)). Note that these provisions do not require that
effluent limits in WPDES permits be expressed in a form that is identical to the form in which the WLA
for the discharge is expressed in a TMDL. Permit limits need only be “consistent with the assumptions
and requirements” of a TMDL’s WLA (USEPA, 2007). Accordingly, WDNR may use the guidance in
EPA’s Technical Support Document for Water Quality-based Toxics Control (1991b) to derive WQBELs from the
WLA established by this TMDL. The approach in this guidance takes into consideration inherent
variability of wastewater treatment effectiveness and effluent monitoring. For example, applying EPA’s
guidance to a hypothetical point source with a WLA of 365 pounds per year and 1 pound per day, an
effluent monitoring frequency of weekly, and an effluent coefficient of variation of 0.6 would produce a
daily maximum effluent limit of 2.7 lbs/day and a monthly average effluent limit of 1.4 lbs/day. To meet
the daily maximum and monthly average effluent limits consistently, the discharger’s effluent would have
to average 1 pound per day over the entire year, which totals 365 pounds per year. Conversely, to
consistently meet a daily maximum effluent limit of 1 pound per day, the effluent would have to average
0.37 pounds per day over the entire year, which equals a total of only 135 pounds per year.
In addition to showing each MS4’s WLA on pages 43–87, Appendix D includes additional tables that
summarize each MS4’s WLA by subwatershed and in total (for both TP and TSS). Each MS4 has been
assigned a WLA as specified in Appendix C. In some cases, the WLA for TSS assigned to MS4s in
certain sub-basins (e.g., Mud Creek) results in a lower percent reduction (from baseline conditions) than
that required by Wisconsin Administrative Code NR 151. The developed urban area of each unique MS4
is still required to meet, at a minimum, the Wisconsin Administrative Code NR 151 mandated 40% TSS
reduction specified in MS4 permits.
6.2.

Oneida Reservation

Trout Creek and portions of Duck and Dutchman Creeks are located within the boundary of the Oneida
Reservation. The TMDLs established for the LFR Basin and Lower Green Bay are not applicable to the
water bodies located within the boundary of the Oneida Reservation. However, to meet the TMDLs for
the LFR Basin and Lower Green Bay, voluntary reductions are needed from sources within the Oneida
40

 Reservation. Therefore, load reduction goals for pollutant loads originating from within the Oneida
Reservation are also identified on pages 43–87.
6.3.

Out-of-Basin Sources

Even though the LFR Basin accounts for only 10% of the land area of the Fox-Wolf Basin (see Figure
17 and Figure 18), it contributes about 43% of the TP load and 56% of the TSS load delivered to Lower
Green Bay (at the outlet of the Lower Fox River main stem). Also, as illustrated in the maps in Figure 29
and Figure 30 in Appendix E, the sources of TP and TSS loads originating from within the Upper Fox
River and Wolf River are more diffuse than those originating from within the LFR Basin. Therefore, TP
and TSS loads from Lake Winnebago (and the Upper Fox and Wolf Basins) must be reduced if the goals
established by this TMDL are to be met. A 40% reduction goal (286,782 lbs/yr) has been established for
TP loads entering the basin at the outlet of Lake Winnebago; and a 48.3% reduction goal (61,472,726
lbs/yr) is expected for TSS loads entering the basin at the outlet of Lake Winnebago. These reduction
goals for loads entering the LFR Basin from the outlet of Lake Winnebago represent reasonable
expectations for load reductions that may be achievable in the Upper Fox and Wolf Basins. These
reduction goals may need to be adjusted if the TMDL analysis for the Upper Fox and Wolf Basins
reveals that these reduction goals are not feasible. The TMDL for the Upper Fox and Wolf Basins is
slated to be final in the next few years, as federal and state resources allow.
6.4.

Margin of Safety

The margin of safety (MOS) can be implicit (incorporated into the TMDL analysis through conservative
assumptions) or explicit (expressed in the TMDL as a portion of the loadings) or a combination of both.
A margin of safety has been incorporated implicitly into the TMDLs for phosphorus and TSS as follows:
•

Although the calibration and validation of SWAT indicate that it can be applied to reliably simulate
phosphorus and TSS loads in the LFR Basin, the model shows a slight tendency to over predict
flows and loads at some of the calibration sites when comparing model output to observed data (see
Appendix B for more discussion). This occasional over-prediction of loads provides for an implicit
MOS in the TMDL analysis.

•

An additional 10% MOS is implicitly incorporated in the TMDL analysis for TSS to account for
uncertainty in meeting the load reduction goal for biotic solids. This was done through use of an 18
mg/L summer (May through October) median TMDL target for the outlet to the bay (see Appendix
C for more information).

The MOS can be reviewed in the future as new data become available.
6.5.

Reserve Capacity

Reserve capacity is an optional means of reserving a portion of the loading capacity to allow for future
growth. Reserve capacity is typically considered in an area where new or expanded WPDES permits are
likely. The following summarizes how reserve capacity is included in the TMDL.
6.5.1.

Wastewater Treatment Facilities

Although GW Partners LLC (permit no. 0001121) still has an active permit, the facility is no longer
operating. Therefore, the estimated baseline load from GW Partners LLC (6,362 lbs/year for TP and
52,979 lbs/year for TSS,) is being set aside to support potential new or expanded WPDES permits on

41

 the main stem of the Lower Fox River. This WWTF Reserve Capacity load is shown in the Lower Fox
River main stem subwatershed allocation tables (in the following pages).
6.5.2. Regulated MS4 Communities
Two main factors limit the need for a reserve capacity being set aside for MS4 communities:
1. Expansion of municipalities generally involves the conversion of agricultural land into urban
land. The growth of MS4 communities generally involves conversion of agricultural land into urban
land uses. Under this model, TP and TSS loads may remain the same or decrease as soils are either
placed under perennial vegetation (lawns) or impervious surfaces. Therefore urban growth possibly
will entail a transfer of the load allocation for phosphorus and sediment from agriculture land be
assigned to the waste load allocation for the MS4. If this transfer requires more load allocation than
available, than the urban area must either find additional reductions within its service area or
pollutant trade to offset the difference in loads. This process differs from wastewater treatment
plants that may increase discharge with no change in land area served.
2. MS4s need to comply with the requirements contained in Wisconsin Administrative Code
NR 151 and NR 216, which limit pollutant loads from urban areas . Under WDNR’s storm
water regulations and performance standards, new urban development is required to reduce TSS
loads and meet infiltration requirements; also, urban re-development is required to reduce TSS loads.
These performance standards were promulgated to meet water quality standards. If more stringent
standards are needed, targeted performance standards may be promulgated through Wisconsin
Administrative Code NR 151.004 such that urban development will meet allocations stipulated in the
TMDL
6.6.

Seasonal Variation

TMDLs must take into account seasonal variation in environmental conditions. As previously discussed,
critical conditions for phosphorus impairments generally occur during summer months when
temperature, flow, and sunlight conditions are conducive to excessive plant growth. However, loadings
throughout the entire year contribute to high phosphorus concentrations during this critical period.
Critical loadings for TSS impairments occur during wet weather events, which result in upland and
stream bank erosion. Wet weather events are especially prevalent in spring and summer.
Seasonal variations in the phosphorus and TSS loads are captured in the model used for the TMDL
analysis. First, SWAT uses daily time steps for weather data and water balance calculations. Loads were
calculated by SWAT using a 23-year (1977-2000) long-term hydrologic simulation period, which
minimizes the potential influence of climate dependant factors and provides a more representative
estimate of average conditions. Second, output from SWAT is on a daily time step, but is summarized on
an average annual basis for the TMDL analysis. Therefore, all possible flow conditions are taken into
account for load calculations.

42

 EAST RIVER SUB-BASIN

 



 




 

   
 

East River
Su b-Ba sin
LFR Basin

 

 

 

0 Municipal WFS

Waters Impaired by
Phosphorus or Sediment

I:i Urban (non-regulated)
- Urban (regulated M84)

- Agriculture

- Natural Background

- Water

 

 

 

0 2 4

 

 

 

Miles

 

43

 

EAST RIVER
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
48,748
TMDL
14,592
Reduction
34,156
% Reduction Needed
70.1%

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
26,520
54.3%
4,423
9.1%
9,091
18.6%
256
0.5%
8,571
17.5%
48,861
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
38,020
6,123
31,897
83.9%
Urban (non-regulated)
2,195
2,195
Natural Background
853
853
LOAD ALLOCATION 41,068
9,171
31,897
77.7%
Urban (MS4)
5,797
4,058
1,739
30.0%
Construction
836
836
General Permits
322
322
WWTF-Industrial
WWTF-Municipal
725
205
520
71.7%
WASTELOAD ALLOCATION
7,680
5,421
2,259
29.4%
TOTAL (WLA + LA) 48,748
14,592
34,156
70.1%

Allocated
(lbs/day)
16.76
6.01
2.34
25.11
11.11
2.29
0.88
0.56
14.84
39.95

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
1,101
771
330
30.0%
1,076
753
323
30.0%
737
516
221
30.0%
2,122
1,485
637
30.0%
761
533
228
30.0%

Allocated
(lbs/day)
2.11
2.06
1.41
4.07
1.46

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
690
170
520
75.4%
35
35
-

Allocated
(lbs/day)
0.47
0.10

Daily TMDL (lbs/day)

39.95

Sources

Urban (MS4)
Allouez
Bellevue
DePere
Green Bay
Ledgeview

WWTF-Municipal
Wrightstown SD#1
Wrightstown SD#2

44

 EAST RIVER
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
19,796,496
TMDL
7,231,130
Reduction
12,565,366
% Reduction Needed
63.5%
Daily TMDL (lbs/day)

Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Allouez
Bellevue
DePere
Green Bay
Ledgeview

WWTF-Municipal
Wrightstown SD#1
Wrightstown SD#2

TOTAL

Acres % of Total
26,520
54.3%
4,423
9.1%
9,091
18.6%
256
0.5%
8,571
17.5%
48,861
100.0%

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
15,364,278
4,511,822
10,852,456
70.6%
581,660
581,660
279,417
279,417
16,225,355
5,372,899
10,852,456
66.9%
2,622,118
1,573,271
1,048,847
40.0%
830,079
166,016
664,063
80.0%
118,364
118,364
580
580
3,571,141
1,858,231
1,712,910
48.0%
19,796,496
7,231,130
12,565,366
63.5%

Allocated
(lbs/day)
12,353
1,592
765
14,710
4,307
455
324
2
5,088
19,798

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
444,964
266,978
177,986
40%
511,765
307,059
204,706
40%
273,714
164,228
109,486
40%
1,119,137
671,482
447,655
40%
272,538
163,523
109,015
40%

Allocated
(lbs/day)
731
841
450
1,838
448

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
472
472
108
108
-

Allocated
(lbs/day)
1
-

19,798

Sources

Urban (MS4)

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

% Reduction
from Baseline
-

45

 BAIRD CREEK SUB-BASIN

 



  
 

  
 
 

 

Waters Impaired by
Phosphorus or Sediment

Urban (non-regulated)
- Urban (regulated M84)

- Agriculture

- Natural Background

- Water

 

A 
#773?
g?gl. 3:33.55:

LFR Basin aMiles

 

 

 

 

 

 

 

 

 

BAIRD CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
12,748
TMDL
4,801
Reduction
7,947
% Reduction Needed
62.3%

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
8,633
52.7%
1,437
8.8%
3,004
18.3%
149
0.9%
3,149
19.2%
16,372
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
9,018
1,772
7,246
80.4%
Urban (non-regulated)
588
588
Natural Background
263
263
LOAD ALLOCATION
9,869
2,623
7,246
73.4%
Urban (MS4)
2,338
1,637
701
30.0%
Construction
476
476
General Permits
65
65
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
2,879
2,178
701
24.3%
TOTAL (WLA + LA) 12,748
4,801
7,947
62.3%

Allocated
(lbs/day)
4.85
1.61
0.72
7.18
4.48
1.30
0.18
5.96
13.14

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
4
2.8
1.2
30.0%
2,334
1,634.2
699.8
30.0%

Allocated
(lbs/day)
0.01
4.47

Daily TMDL (lbs/day)

13.14

Sources

Urban (MS4)
Bellevue
Green Bay

47

 BAIRD CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
3,791,217
TMDL
2,374,777
Reduction
1,416,440
37.4%
% Reduction Needed
Daily TMDL (lbs/day)

6,503

Sources
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Bellevue
Green Bay

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

TOTAL

Acres % of Total
8,633
52.7%
1,437
8.8%
3,004
18.3%
149
0.9%
3,149
19.2%
16,372
100.0%

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
2,146,760
1,495,195
651,565
30.4%
108,357
108,357
40,639
40,639
2,295,756
1,644,191
651,565
28.4%
1,054,983
632,990
421,993
40.0%
428,603
85,721
342,882
80.0%
11,875
11,875
1,495,461
730,586
764,875
51.1%
3,791,217
2,374,777
1,416,440
37.4%

Allocated
(lbs/day)
4,094
297
111
4,502
1,733
235
33
2,001
6,503

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
2,631
1,579
1,052
40.0%
1,052,352
631,411
420,941
40.0%

Allocated
(lbs/day)
4
1,729

48

 BOWER CREEK SUB-BASIN

 



 

 

  
  

Bower Creek
Sub- Basin

LFR Basin

 

 

 

 

 

 

Waters Impaired by
Phosphorus or Sediment

Urban (non?regulated)
- Urban (regulated M84)

- Agriculture

- Natural Background

- Water

 

 

 

49

 

BOWER CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
27,777
TMDL
7,964
Reduction
19,813
% Reduction Needed
71.3%

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
17,142
63.6%
2,983
11.1%
3,203
11.9%
142
0.5%
3,468
12.9%
26,938
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
22,946
3,860
19,086
83.2%
Urban (non-regulated)
1,435
1,435
Natural Background
283
283
LOAD ALLOCATION 24,664
5,578
19,086
77.4%
Urban (MS4)
2,422
1,695
727
30.0%
Construction
445
445
General Permits
246
246
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
3,113
2,386
727
23.4%
TOTAL (WLA + LA) 27,777
7,964
19,813
71.3%

Allocated
(lbs/day)
10.57
3.93
0.77
15.27
4.64
1.22
0.67
6.53
21.80

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
1,545
1,081.2
463.8
30.0%
29
20.3
8.7
30.0%
848
593.5
254.5
30.0%

Allocated
(lbs/day)
2.96
0.06
1.62

Daily TMDL (lbs/day)

21.80

Sources

Urban (MS4)
Bellevue
Green Bay
Ledgeview

50

 BOWER CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
10,318,235
TMDL
3,939,913
Reduction
6,378,322
61.8%
% Reduction Needed
Daily TMDL (lbs/day)

10,787

Sources
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Bellevue
Green Bay
Ledgeview

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

TOTAL

Acres % of Total
17,142
63.6%
2,983
11.1%
3,203
11.9%
142
0.5%
3,468
12.9%
26,938
100.0%

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
8,490,347
2,776,357
5,713,990
67.3%
387,277
387,277
118,283
118,283
8,995,907
3,281,917
5,713,990
63.5%
828,393
497,036
331,357
40.0%
416,219
83,244
332,975
80.0%
77,716
77,716
1,322,328
657,996
664,332
50.2%
10,318,235
3,939,913
6,378,322
61.8%

Allocated
(lbs/day)
7,601
1,060
324
8,985
1,361
228
213
1,802
10,787

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
536,593
321,956
214,637
40.0%
9,715
5,829
3,886
40.0%
282,085
169,251
112,834
40.0%

Allocated
(lbs/day)
881
16
463

51

 APPLE CREEK SUB-BASIN

 



 

 

LFR Basin

    

 

 

 

2.5

5

 

1Miles

 

 

 

Waters Impaired by
PhOSphorus or Sediment

Urban (non-regulated)
- Urban (regulated M84)

- Agriculture

- Natural Background

- Water

 

 

 

 

52

APPLE CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
35,088
TMDL
12,557
Reduction
22,531
% Reduction Needed
64.2%

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
20,613
60.2%
5,378
15.7%
5,653
16.5%
245
0.7%
2,343
6.8%
34,232
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
27,297
5,828
21,469
78.6%
Urban (non-regulated)
2,837
2,837
Natural Background
255
255
LOAD ALLOCATION 30,389
8,920
21,469
70.6%
Urban (MS4)
3,541
2,479
1,062
30.0%
Construction
890
890
General Permits
268
268
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
4,699
3,637
1,062
22.6%
TOTAL (WLA + LA) 35,088
12,557
22,531
64.2%

Allocated
(lbs/day)
15.96
7.77
0.70
24.43
6.79
2.44
0.73
9.96
34.39

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
1,617
1,132
485
30.0%
571
399.7
171.3
30.0%
563
394.1
168.9
30.0%
58
40.6
17.4
30.0%
732
512.5
219.5
30.0%

Allocated
(lbs/day)
3.10
1.09
1.08
0.11
1.40

Daily TMDL (lbs/day)

34.39

Sources

Urban (MS4)
Appleton
GrandChute
Kaukauna
Lawrence
LittleChute

53

 APPLE CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
12,736,271
TMDL
6,211,712
Reduction
6,524,559
51.2%
% Reduction Needed
Daily TMDL (lbs/day)

17,007

Sources
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Appleton
GrandChute
Kaukauna
Lawrence
LittleChute

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

TOTAL

Acres % of Total
20,613
60.2%
5,378
15.7%
5,653
16.5%
245
0.7%
2,343
6.8%
34,232
100.0%

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
9,450,834
4,149,661
5,301,173
56.1%
886,462
886,462
68,486
68,486
10,405,782
5,104,609
5,301,173
50.9%
1,411,610
846,966
564,644
40.0%
823,428
164,686
658,742
80.0%
95,451
95,451
2,330,489
1,107,103
1,223,386
52.5%
12,736,271
6,211,712
6,524,559
51.2%

Allocated
(lbs/day)
11,361
2,427
188
13,976
2,319
451
261
3,031
17,007

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
635,802
381,481
254,321
40.0%
200,022
120,013
80,009
40.0%
237,775
142,665
95,110
40.0%
21,308
12,785
8,523
40.0%
316,703
190,022
126,681
40.0%

Allocated
(lbs/day)
1,044
329
391
35
520

54

 ASHWAUBENON CREEK SUB-BASIN

 



 

   

 

 

Ashwaubenon

   
   

LFR Basin

 

 

 

 

 

 

Waters Impaired by
Phosphorus or Sediment

Oneida Reservation
:1 Urban (non~regulaled)
- Urban (regulated M54)

- Agriculture

- Natural Background

- Water

 

 

 

 

55

ASHWAUBENON CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
15,681
TMDL
5,787
Reduction
9,894
% Reduction Needed
63.1%
Daily TMDL (lbs/day)

15.83

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres
State
Oneida
8,220 3,244
454
112
4,352
354
106
31
1,276
379
14,408 4,120

Total
11,464
566
4,706
137
1,655
18,528

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
8,797
2,288
6,509
74.0%
Urban (non-regulated)
154
154
Natural Background
113
136
(23)
LOAD ALLOCATION
9,064
2,578
6,486
71.6%
Urban (MS4)
2,549
1,784
765
30.0%
Construction
268
268
General Permits
6
6
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
2,823
2,058
765
27.1%
TOTAL (WLA + LA) 11,887
4,636
7,251
61.0%

Allocated
(lbs/day)
6.26
0.42
0.37
7.05
4.88
0.73
0.02
5.63
12.68

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
554
387.7
166.3
30.0%
927
648.8
278.2
30.0%
1,068
747.5
320.5
30.0%

Allocated
(lbs/day)
1.06
1.78
2.05

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
3,472
903
2,569
74.0%
Urban (non-regulated)
38
38
Natural Background
34
11
23
67.6%
NONPOINT SOURCES
3,544
952
2,592
73.1%
Urban (MS4)
170
119
51
30.0%
Construction
78
78
General Permits
2
2
WWTF-Industrial
WWTF-Municipal
POINT SOURCES
250
199
51
20.4%
TOTAL (NPS + PS)
3,794
1,151
2,643
69.7%

Allocated
(lbs/day)
2.47
0.10
0.03
2.60
0.33
0.21
0.01
0.55
3.15

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
170
119.0
51.0
30.0%
-

Allocated
(lbs/day)
0.33
-

Sources from State Land

Urban (MS4)
Ashwaubenon
DePere
Hobart
Lawrence

Sources from Oneida Reservation

Urban (MS4)
Ashwaubenon
DePere
Hobart
Lawrence

% of
Total
61.9%
3.1%
25.4%
0.7%
8.9%
100.0%

56

 ASHWAUBENON CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
4,871,171
TMDL
2,863,062
Reduction
2,008,109
41.2%
% Reduction Needed
Daily TMDL (lbs/day)

7,840

Sources from State Land
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Ashwaubenon
DePere
Hobart
Lawrence

Sources from Oneida Reservation
Agriculture
Urban (non-regulated)
Natural Background
NONPOINT SOURCES
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
POINT SOURCES
TOTAL (NPS + PS)

Urban (MS4)
Ashwaubenon
DePere
Hobart
Lawrence

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

TOTAL

Acres
State
Oneida
8,220 3,244
454
112
4,352
354
106
31
1,276
379
14,408 4,120

Total
11,464
566
4,706
137
1,655
18,528

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
2,555,692
1,539,868
1,015,824
39.7%
55,179
55,179
24,136
24,136
2,635,007
1,619,183
1,015,824
38.6%
894,105
536,463
357,642
40.0%
211,272
42,255
169,017
80.0%
1,092
1,092
1,106,469
579,810
526,659
47.6%
3,741,476
2,198,993
1,542,483
41.2%

Allocated
(lbs/day)
4,216
151
66
4,433
1,469
116
3
1,588
6,021

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
249,169
149,501
99,668
40.0%
329,712
197,827
131,885
40.0%
315,224
189,134
126,090
40.0%

Allocated
(lbs/day)
409
542
518

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
1,008,597
607,705
400,892
39.7%
13,613
13,613
7,169
7,169
1,029,379
628,487
400,892
38.9%
38,259
22,955
15,304
40.0%
61,787
12,357
49,430
80.0%
270
270
100,316
35,582
64,734
64.5%
1,129,695
664,069
465,626
41.2%

Allocated
(lbs/day)
1,664
37
20
1,721
63
34
1
98
1,819

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
38,259
22,955
15,304
40.0%
-

Allocated
(lbs/day)
63
-

% of
Total
61.9%
3.1%
25.4%
0.7%
8.9%
100.0%

57

 DUTCHMAN CREEK SUB-BASIN

 



5 .

e10"
. 

.1.-

h;

      

4

   

Miles

 

I .


 

r.


Dutchman Waters Impaired by
Creek Phosphorus or Sediment
Sub?Basin Oneida Reservation

Urban (non-regulated)
- Urban (regulated M34)

- Agriculture

- Natural Background

- Water

 

 

 

 

 

LFR Basin

 

 

 

 

DUTCHMAN CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
15,280
TMDL
6,263
Reduction
9,017
% Reduction Needed
59.0%
Daily TMDL (lbs/day)

17.16

Sources from State Land
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Ashwaubenon
Green Bay
Hobart
Lawrence

Sources from Oneida Reservation
Agriculture
Urban (non-regulated)
Natural Background
NONPOINT SOURCES
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
POINT SOURCES
TOTAL (PS + NPS)

Urban (MS4)
Ashwaubenon
Green Bay
Hobart
Lawrence

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

State
1,809
398
3,714
74
1,459
7,454

Acres
Oneida
7,888
634
2,800
31
379
11,732

Total
9,697
1,032
6,514
105
1,838
19,186

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline
Allocated Reduction from Baseline
1,890
446
1,444
76.4%
156
156
122
122
2,168
724
1,444
66.6%
2,404
1,683
721
30.0%
204
204
15
15
2,623
1,902
721.00
27.5%
4,791
2,626
2,165
45.2%

Allocated
(lbs/day)
1.22
0.43
0.33
1.98
4.61
0.56
0.04
5.21
7.19

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline
Allocated Reduction from Baseline
2,113
1,478.9
634.1
30.0%
98
68.6
29.4
30.0%
193
135.1
57.9
30.0%

Allocated
(lbs/day)
4.05
0.19
0.37

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline
Allocated Reduction from Baseline
8,240
1,946
6,294
76.4%
248
248
32
32
8,520
2,226
6,294
73.9%
1,858
1,301
557
30.0%
86
86
25
25
1,969
1,412
557
28.3%
10,489
3,638
6,851
65.3%

Allocated
(lbs/day)
5.33
0.68
0.09
6.10
3.56
0.24
0.07
3.87
9.97

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline
Allocated Reduction from Baseline
500
350.0
150.0
30.0%
298.2
127.8
30.0%
426
932
652.3
279.7
30.0%
-

Allocated
(lbs/day)
0.96
0.82
1.79
-

% of
Total
50.5%
5.4%
34.0%
0.5%
9.6%
100.0%

59

 DUTCHMAN CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
5,033,703
TMDL
3,098,072
Reduction
1,935,631
38.5%
% Reduction Needed
Daily TMDL (lbs/day)

8,483

Sources from State Land
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Ashwaubenon
Green Bay
Hobart
Lawrence

Sources from Oneida Reservation
Agriculture
Urban (non-regulated)
Natural Background
NONPOINT SOURCES
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
POINT SOURCES
TOTAL (PS + NPS)

Urban (MS4)
Ashwaubenon
Green Bay
Hobart
Lawrence

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

TOTAL

Acres
State
Oneida
1,809 7,888
398
634
3,714 2,800
74
31
1,459
379

Total
9,697
1,032
6,514
105
1,838
19,186

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
535,463
343,756
191,707
35.8%
34,083
34,083
19,266
19,266
588,812
397,105
191,707
32.6%
1,070,534
642,321
428,213
40.0%
161,830
32,366
129,464
80.0%
4,002
4,002
1,236,366
678,689
557,677
45.1%
1,825,178
1,075,794
749,384
41.1%

Allocated
(lbs/day)
941
93
53
1,087
1,759
89
11
1,859
2,946

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
961,049
576,630
384,419
40.0%
37,282
22,369
14,913
40.0%
72,203
43,322
28,881
40.0%

Allocated
(lbs/day)
1,579
61
119

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
2,334,844
1,498,918
835,926
35.8%
54,292
54,292
5,005
5,005
2,394,141
1,558,215
835,926
34.9%
740,214
444,128
296,086
40.0%
67,794
13,559
54,235
80.0%
6,376
6,376
814,384
464,063
350,321
43.0%
3,208,525
2,022,278
1,186,247
37.0%

Allocated
(lbs/day)
4,104
149
14
4,267
1,216
37
17
1,270
5,537

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
227,524
136,514
91,010
40.0%
162,975
97,785
65,190
40.0%
349,715
209,829
139,886
40.0%
-

Allocated
(lbs/day)
374
268
574
-

% of
Total
50.5%
5.4%
34.0%
0.5%
9.6%
100.0%

60

 PLUM CREEK SUB-BASIN

 



 

   
 

Plum Creek
Sub? Basin

LFR Basin

 

 

Municipal Will-?5
I Industrial WINTFS

Waters impaired by
Phosphorus or Sediment

Urban (non-regulated)
- Urban (regulated M84)
- Agriculture

- Natural Background

- Water

 

 

 

 

   
  
  
 

Town of Holland SD #1
001 8: 003

Forest Junction

Arla Foods Production
Holland

 

 

61

PLUM CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
31,569
TMDL
7,193
Reduction
24,376
77.2%
% Reduction Needed

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
17,382
76.2%
2,465
10.8%
79
0.3%
45
0.2%
2,833
12.4%
22,804
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
27,660
3,861
23,799
86.0%
Urban (non-regulated)
1,316
1,316
Natural Background
359
359
LOAD ALLOCATION 29,335
5,536
23,799
81.1%
Urban (MS4)
76
53
23
30.0%
Construction
164
164
General Permits
168
168
WWTF-Industrial
546
341
205
37.5%
WWTF-Municipal
1,280
931
349
27.3%
WASTELOAD ALLOCATION
2,234
1,657
577
25.8%
TOTAL (WLA + LA) 31,569
7,193
24,376
77.2%

Allocated
(lbs/day)
10.57
3.60
0.98
15.15
0.15
0.45
0.46
0.93
2.55
4.54
19.69

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
30
21
9
30.0%
46
32
14
30.0%

Allocated
(lbs/day)
0.06
0.09

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
546
341
205
37.5%

Allocated
(lbs/day)
0.93

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
471
122
349
74.1%
809
809
-

Allocated
(lbs/day)
0.33
2.21

Daily TMDL (lbs/day)

19.69

Sources

Urban (MS4)
Buchanan
Kaukauna

WWTF-Industrial
Arla Foods Production LLC - Holland

WWTF-Municipal
Forest Junction
Town of Holland SD #1

62

 PLUM CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
12,038,905
TMDL
3,558,318
Reduction
8,480,587
70.4%
% Reduction Needed
Daily TMDL (lbs/day)

Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Buchanan
Kaukauna

WWTF-Industrial
Arla Foods Production LLC - Holland

Forest Junction
Town of Holland SD #1

TOTAL

Acres % of Total
17,382
76.2%
2,465
10.8%
79
0.3%
45
0.2%
2,833
12.4%
22,804
100.0%

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
11,171,743
2,835,478
8,336,265
74.6%
447,810
447,810
148,577
148,577
11,768,130
3,431,865
8,336,265
70.8%
24,329
14,597
9,732
40.0%
168,238
33,648
134,590
80.0%
47,269
47,269
682
682
30,257
30,257
270,775
126,453
144,322
53.3%
12,038,905
3,558,318
8,480,587
70.4%

Allocated
(lbs/day)
7,763
1,226
407
9,396
40
92
129
2
83
346
9,742

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
9,209.00
5,525
3,684
40.0%
15,120.00
9,072
6,048
40.0%

Allocated
(lbs/day)
15
25

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
682
682
-

% Reduction
from Baseline
-

Allocated
(lbs/day)
2

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
2,471
2,471
27,786
27,786
-

% Reduction
from Baseline
-

Allocated
(lbs/day)
7
76

9,742

Sources

WWTF-Municipal

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

63

 KANKAPOT CREEK SUB-BASIN

 



 

  
   

Kanka pot
Creek
Sub-Basin

 

LFR Basin

 

 

 

  

Miles

 

 

 

0 Municipal 
0 Industrial WFS

Waters Impaired by
Phosphorus or Sediment

Urban (non-regulated}
- Urban (regulated M54)

- Agriculture

- Natural Background

- iir'ii'ater

   

 

 

 

 

64

KANKAPOT CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
20,050
TMDL
5,548
Reduction
14,502
72.3%
% Reduction Needed

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
11,367
69.3%
1,120
6.8%
1,711
10.4%
31
0.2%
2,172
13.2%
16,401
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
17,195
3,135
14,060
81.8%
Urban (non-regulated)
493
493
Natural Background
269
269
LOAD ALLOCATION 17,957
3,897
14,060
78.3%
Urban (MS4)
1,473
1,031
442
30.0%
Construction
99
99
General Permits
83
83
WWTF-Industrial
143
143
WWTF-Municipal
295
295
WASTELOAD ALLOCATION
2,093
1,651
442
21.1%
TOTAL (WLA + LA) 20,050
5,548
14,502
72.3%

Allocated
(lbs/day)
8.58
1.35
0.74
10.67
2.82
0.27
0.23
0.39
0.81
4.52
15.19

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
156
109.2
46.8
30.0%
5
3.5
1.5
30.0%
1,312
918.3
393.7
30.0%

Allocated
(lbs/day)
0.30
0.01
2.51

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
143
143
-

Allocated
(lbs/day)
0.39

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
295
295
-

Allocated
(lbs/day)
0.81

Daily TMDL (lbs/day)

15.19

Sources

Urban (MS4)
Buchanan
CombLocks
Kaukauna

WWTF-Industrial
Belgioso Cheese - Sherwood

WWTF-Municipal
Sherwood

65

 KANKAPOT CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
7,253,520
TMDL
2,744,726
Reduction
4,508,794
62.2%
% Reduction Needed
Daily TMDL (lbs/day)

Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Buchanan
CombLocks
Kaukauna

WWTF-Industrial
Belgioso Cheese - Sherwood

WWTF-Municipal
Sherwood

TOTAL

Acres % of Total
11,367
69.3%
1,120
6.8%
1,711
10.4%
31
0.2%
2,172
13.2%
16,401
100.0%

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
6,144,676
2,002,512
4,142,164
67.4%
192,526
192,526
62,915
62,915
6,400,117
2,257,953
4,142,164
64.7%
736,480
441,888
294,592
40.0%
90,047
18,009
72,038
80.0%
22,731
22,731
2,432
2,432
1,713
1,713
853,403
486,773
366,630
43.0%
7,253,520
2,744,726
4,508,794
62.2%

Allocated
(lbs/day)
5,483
527
172
6,182
1,210
49
62
7
5
1,333
7,515

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
68,126
40,876
27,250
40.0%
2,354
1,412
942
40.0%
666,000
399,600
266,400
40.0%

Allocated
(lbs/day)
112
4
1,094

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
2,432
2,432
-

% Reduction
from Baseline
-

Allocated
(lbs/day)
7

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
1,713
1,713
-

% Reduction
from Baseline
-

Allocated
(lbs/day)
5

7,515

Sources

Urban (MS4)

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

66

 GARNERS CREEK SUB-BASIN

 



 

 

Creek

LFR Basin

 

 

 

       

Miles

 

 

1meters Impaired by
Phosphorus or Sediment

Urban (non-regulated)
- Urban (regulated M84)

- Agriculture

- Natural Background

- Water

 

 

 

 

67

GARNERS CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
6,575
TMDL
2,949
Reduction
3,626
55.1%
% Reduction Needed
Daily TMDL (lbs/day)

8.07

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

Acres % of Total
2,256
32.1%
201
2.9%
3,814
54.2%
208
3.0%
558
7.9%
TOTAL 7,037
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
2,908
1,072
1,836
63.1%
Urban (non-regulated)
46
46
Natural Background
67
67
LOAD ALLOCATION
3,021
1,185
1,836
60.8%
Urban (MS4)
2,835
1,045
1,790
63.1%
Construction
697
697
General Permits
22
22
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
3,554
1,764
1,790
50.4%
TOTAL (WLA + LA)
6,575
2,949
3,626
55.1%

Allocated
(lbs/day)
2.93
0.13
0.18
3.24
2.86
1.91
0.06
4.83
8.07

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
313
115.4
197.6
63.1%
1,096
404.0
692.0
63.1%
372
137.1
234.9
63.1%
872
321.4
550.6
63.1%
126
46.4
79.6
63.1%
56
20.6
35.4
63.1%

Allocated
(lbs/day)
0.32
1.11
0.38
0.88
0.13
0.06

Sources

Urban (MS4)
Appleton
Buchanan
CombLocks
Harrison
Kaukauna
Kimberly

68

 GARNERS CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
2,863,318
TMDL
1,459,045
Reduction
1,404,273
49.0%
% Reduction Needed
Daily TMDL (lbs/day)

3,994

Sources
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Appleton
Buchanan
CombLocks
Harrison
Kaukauna
Kimberly

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

Acres % of Total
2,256
32.1%
201
2.9%
3,814
54.2%
208
3.0%
558
7.9%
TOTAL 7,037
100.0%

Total Suspended Solids Load (lbs/yr) % Reduction
Baseline
Allocated
Reduction from Baseline
990,663
669,193
321,470
32.4%
26,395
26,395
17,920
17,920
1,034,978
713,508
321,470
31.1%
1,249,940
626,306
623,634
49.9%
573,961
114,792
459,169
80.0%
4,439
4,439
1,828,340
745,537
1,082,803
59.2%
2,863,318
1,459,045
1,404,273
49.0%

Allocated
(lbs/day)
1,832
72
49
1,953
1,715
314
12
2,041
3,994

Total Suspended Solids Load (lbs/yr) % Reduction
Baseline
Allocated
Reduction from Baseline
147,082
73,698
73,384
49.9%
484,488
242,762
241,726
49.9%
167,155
83,756
83,399
49.9%
371,650
186,222
185,428
49.9%
54,218
27,167
27,051
49.9%
25,347
12,701
12,646
49.9%

Allocated
(lbs/day)
202
665
229
510
74
35

69

 MUD CREEK SUB-BASIN

 



 

 

Waters impaired by
Phosphorus or Sediment

Urban (non-regulated)
- Urban (regulated M84)

- Agriculture

- Natural Background

- Water

 

 

 

 

   

Miles

 

 

     

Mud Creek
Sub-Basin

LFR Basin

 

 

 

 

70

MUD CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
6,594
TMDL
4,254
Reduction
2,340
% Reduction Needed
35.5%
Daily TMDL (lbs/day)

11.64

Land Use
Acres % of Total
Agriculture
1,474
15.4%
Urban (non-regulated)
335
3.5%
Urban (MS4)
7,165
74.8%
Construction
79
0.8%
Natural Background
532
5.6%
TOTAL 9,585
100.0%

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline Allocated Reduction from Baseline
Agriculture
1,884
1,150
734
39.0%
Urban (non-regulated)
245
245
Natural Background
49
49
LOAD ALLOCATION
2,178
1,444
734
33.7%
Urban (MS4)
4,119
2,513
1,606
39.0%
Construction
290
290
General Permits
7
7
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
4,416
2,810
1,606
36.4%
TOTAL (WLA + LA)
6,594
4,254
2,340
35.5%

Allocated
(lbs/day)
3.15
0.67
0.13
3.95
6.88
0.79
0.02
7.69
11.64

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline Allocated Reduction from Baseline
725
442.32
282.68
39.0%
3,053
1,862.63
1,190.37
39.0%
288
175.71
112.29
39.0%
53
32.34
20.66
39.0%

Allocated
(lbs/day)
1.21
5.10
0.48
0.09

Sources

Urban (MS4)
Appleton
GrandChute
Greenville
T_Menasha

71

 MUD CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
2,924,841
TMDL
2,104,168
Reduction
820,673
28.1%
% Reduction Needed
Daily TMDL (lbs/day)

5,761

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

Acres % of Total
1,474
15.4%
335
3.5%
7,165
74.8%
79
0.8%
532
5.6%
TOTAL 9,585
100.0%

Total Suspended Solids Load (lbs/yr) % Reduction
Baseline
Allocated Reduction from Baseline
Agriculture
679,097
619,002
60,095
8.8%
Urban (non-regulated)
35,252
35,252
Natural Background
7,405
7,405
LOAD ALLOCATION
721,754
661,659
60,095
8.3%
Urban (MS4)
1,942,546
1,389,118
553,428
28.5%
Construction
258,937
51,787
207,150
80.0%
General Permits
1,604
1,604
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION 2,203,087
1,442,509
760,578
34.5%
TOTAL (WLA + LA) 2,924,841
2,104,168
820,673
28.1%

Allocated
(lbs/day)
1,695
97
20
1,812
3,803
142
4
3,949
5,761

Total Suspended Solids Load (lbs/yr) % Reduction
Baseline
Allocated Reduction from Baseline
374,837
268,047
106,790
28.5%
1,414,456
1,011,480
402,976
28.5%
127,695
91,315
36,380
28.5%
25,558
18,277
7,281
28.5%

Allocated
(lbs/day)
734
2,769
250
50

Sources

Urban (MS4)
Appleton
GrandChute
Greenville
T_Menasha

72

 DUCK CREEK SUB-BASIN

 



 

Preuimi Feeds - Se

iw' in;

 

W-r: we; a;
'l 4' 

vrnour

Oneida WWTF

:1 
-.-- 4? 
?36

   
 
 
 

 

 

Sub-Basin

 

  

LFR Basin

   

 

 

 

 

2.5 5
Miles

 

 

0 Industrial WFS
Municipal WWI Fs

Waters Impaired by
Phosphorus or Sediment

Oneida Reservation
Urban (non-regulated)
- Urban (regulated M54)

- Agriculture

- Natural Background

- Water

 

 

 

 

73

DUCK CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
63,172
TMDL
23,252
Reduction
39,920
63.2%
% Reduction Needed
Daily TMDL (lbs/day)

63.66

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

State
30,098
5,407
7,512
214
8,972
52,203

Acres
Oneida
18760
3585
4570
131
8020
35,066

Total
48,858
8,992
12,082
345
16,992
87,269

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
30,382
7,028
23,354
76.9%
Urban (non-regulated)
2,070
2,070
Natural Background
790
790
LOAD ALLOCATION 33,242
9,888
23,354
70.3%
Urban (MS4)
4,076
2,853
1,223
30.0%
Construction
532
532
General Permits
224
224
WWTF-Industrial
74
74
WWTF-Municipal
542
542
WASTELOAD ALLOCATION
5,448
4,225
1,223
22.4%
TOTAL (WLA + LA) 38,690
14,113
24,577
63.5%

Allocated
(lbs/day)
19.24
5.67
2.16
27.07
7.81
1.46
0.61
0.20
1.48
11.56
38.63

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
2
1.40
0.60
30.0%
302
211.39
90.61
30.0%
474
331.79
142.21
30.0%
2,790
1,952.92
837.08
30.0%
508
355.58
152.42
30.0%

Allocated
(lbs/day)
0.58
0.91
5.35
0.97

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
74
74
-

Allocated
(lbs/day)
0.20

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
542
542
-

Allocated
(lbs/day)
1.48

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
18,937
4,380
14,557
76.9%
Urban (non-regulated)
1,372
1,372
Natural Background
707
707
NONPOINT SOURCES 21,016
6,459
14,557
69.3%
Urban (MS4)
2,620
1,834
786
30.0%
Construction
326
326
General Permits
137
137
WWTF-Industrial
WWTF-Municipal
383
383
POINT SOURCES
3,466
2,680
786
22.7%
TOTAL (PS + NPS) 24,482
9,139
15,343
62.7%

Allocated
(lbs/day)
11.99
3.76
1.94
17.69
5.02
0.89
0.38
1.05
7.34
25.03

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
1,290
903.0
387.0
30.0%
1,316
921.2
394.8
30.0%
14
9.8
4.2
30.0%
-

Allocated
(lbs/day)
2.47
2.52
0.03
-

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
383
383
-

Allocated
(lbs/day)
1.05

Sources from State Land

Urban (MS4)
Appleton
Ashwaubenon
Green Bay
Hobart
Howard
Suamico

WWTP-Industrial
Provimi Foods - Seymour

WWTF-Municipal
Freedom San. Dist. #1

Sources from Oneida Reservation

Urban (MS4)
Appleton
Ashwaubenon
Green Bay
Hobart
Howard
Suamico
WWTF-Municipal
Oneida (regulated via EPA NPDES)

% of
Total
56.0%
10.3%
13.8%
0.4%
19.5%
100.0%

74

 DUCK CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
25,394,165
TMDL
11,416,475
Reduction
13,977,690
55.0%
% Reduction Needed
Daily TMDL (lbs/day)

31,257

Sources from State Land
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Appleton
Ashwaubenon
Green Bay
Hobart
Howard
Suamico

WWTP-Industrial
Provimi Foods - Seymour

WWTF-Municipal
Freedom San. Dist. #1

Sources from Oneida Reservation
Agriculture
Urban (non-regulated)
Natural Background
NONPOINT SOURCES
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
POINT SOURCES
TOTAL (PS + NPS)

Urban (MS4)
Appleton
Ashwaubenon
Green Bay
Hobart
Howard
Suamico
WWTF-Municipal
Oneida (regulated via EPA NPDES)

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

TOTAL

State
30,098
5,407
7,512
214
8,972
52,203

Acres
Oneida
18760
3585
4570
131
8020
35,066

Total
48,858
8,992
12,082
345
16,992
87,269

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
12,724,387
5,273,111
7,451,276
58.6%
478,796
478,796
114,410
114,410
13,317,593
5,866,317
7,451,276
56.0%
1,655,931
993,559
662,372
40.0%
671,326
134,265
537,061
80.0%
97,759
97,759
544
544
2,953
2,953
2,428,513
1,229,080
1,199,433
49.4%
15,746,106
7,095,397
8,650,709
54.9%

Allocated
(lbs/day)
14,437
1,311
313
16,061.00
2,720
368
268
1
8
3,365
19,426

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
456
274
182
40.0%
123,637
74,182
49,455
40.0%
189,004
113,402
75,602
40.0%
1,164,267
698,560
465,707
40.0%
178,567
107,140
71,427
40.0%

Allocated
(lbs/day)
1
203
310
1,913
293

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
544
544
-

% Reduction
from Baseline
-

Allocated
(lbs/day)
1

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
2,953
2,953
-

% Reduction
from Baseline
-

Allocated
(lbs/day)
8

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
7,931,075
3,286,715
4,644,360
58.6%
317,456
317,456
102,270
102,270
8,350,801
3,706,441
4,644,360
55.6%
884,650
530,790
353,860
40.0%
410,952
82,191
328,761
80.0%
1,656
1,656
1,297,258
614,637
682,621
52.6%
9,648,059
4,321,078
5,326,981
55.2%

Allocated
(lbs/day)
8,999
869
280
10,148
1,453
225
5
1,683
11,831

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
514,879
308,928
205,952
40.0%
363,933
218,360
145,573
40.0%
5,838
3,503
2,335
40.0%
-

Allocated
(lbs/day)
846
598
10
-

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
1,656
1,656
-

Allocated
(lbs/day)
5

% Reduction
from Baseline
-

% of
Total
56.0%
10.3%
13.8%
0.4%
19.5%
100.0%

75

 TROUT CREEK SUB-BASIN

 

 

 

12:33? ,9 .
WW
I 

LFR Basin

 

    

 

 

 

{Ah--4 

'35

 

Miles

 

 

Waters Impaired by
Phosphorus or Sediment

Oneida Reservation
Urban (nun-regulated)
- Urban [regulated M54)

- Agriculture

- Natural Background

- Water

 

 

 

 

76

TROUT CREEK
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
4,518
Loading Goal
2,495
Reduction
2,023
44.8%
% Reduction Needed

Land Use
Acres % of Total
Agriculture
4,580
47.6%
Urban (non-regulated)
584
6.1%
Urban (MS4)
1,941
20.2%
Construction
8
0.1%
Natural Background
2,517
26.1%
TOTAL 9,630
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
3,272
1,477
1,795
54.9%
Urban (non-regulated)
253
253
Natural Background
211
211
NONPOINT SOURCES
3,736
1,941
1,795
48.0%
Urban (MS4)
759
531
228
30.0%
Construction
6
6
General Permits
17
17
WWTF-Industrial
WWTF-Municipal
POINT SOURCES
782
554
228
29.2%
TOTAL (PS + NPS)
4,518
2,495
2,023
44.8%
Sources from Oneida Reservation

Urban (MS4)
Hobart
Howard

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
748
523.3
224.7
30.0%
11
7.7
3.3
30.0%

77

 TROUT CREEK
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
1,451,838
Loading Goal
1,234,199
Reduction
217,639
15.0%
% Reduction Needed

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background
TOTAL

Acres
% of Total
4,580
47.6%
584
6.1%
1,941
20.2%
8
0.1%
2,517
26.1%
9,630
100.0%

Total Suspended Solids Load (lbs/yr) % Reduction
Baseline
Allocated Reduction from Baseline
Agriculture
1,221,136
1,070,556
150,580
12.3%
Urban (non-regulated)
40,313
40,313
Natural Background
27,743
27,743
NONPOINT SOURCES 1,289,192
1,138,612
150,580
11.7%
Urban (MS4)
148,430
89,058
59,372
40.0%
Construction
9,609
1,922
7,687
80.0%
General Permits
4,607
4,607
WWTF-Industrial
WWTF-Municipal
POINT SOURCES
162,646
95,587
67,059
41.2%
TOTAL (PS + NPS) 1,451,838
1,234,199
217,639
15.0%
Sources from Oneida Reservation

Urban (MS4)
Hobart
Howard

Total Suspended Solids Load (lbs/yr) % Reduction
Baseline
Allocated Reduction from Baseline
145,976
87,586
58,390
40.0%
2,454
1,472
982
40.0%

78

 NEENAH SLOUGH SUB-BASIN

 



 

 

I Industrial 

waters Impaired by
Phosphorus or Sediment

Urban {non~regulated)
- Urban {regulated M84)

- Agriculture

- Natural Background

- Water

 

 

 

   

 

 

Neenah Slough

  
   

LFR Basin

 

 

 

 

79

NEENAH SLOUGH
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
11,912
TMDL
5,758
Reduction
6,154
51.7%
% Reduction Needed

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
6,302
43.6%
1,447
10.0%
5,007
34.6%
89
0.6%
1,616
11.2%
14,461
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
8,015
2,665
5,350
66.7%
Urban (non-regulated)
572
572
Natural Background
173
173
LOAD ALLOCATION
8,760
3,410
5,350
61.1%
Urban (MS4)
2,681
1,877
804
30.0%
Construction
287
287
General Permits
128
128
WWTF-Industrial
56
56
WWTF-Municipal
WASTELOAD ALLOCATION
3,152
2,348
804
25.5%
TOTAL (WLA + LA) 11,912
5,758
6,154
51.7%

Allocated
(lbs/day)
7.30
1.57
0.47
9.34
5.14
0.79
0.35
0.15
6.43
15.77

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
2,121
1,485
636
30.0%
560
392
168
30.0%

Allocated
(lbs/day)
4.07
1.07

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
56
56
-

Allocated
(lbs/day)
0.15

Daily TMDL (lbs/day)

15.77

Sources

Urban (MS4)
Neenah
T_Neenah

WWTF-Industrial
Galloway Company

80

 NEENAH SLOUGH
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
4,846,168
TMDL
2,848,353
Reduction
1,997,815
41.2%
% Reduction Needed
Daily TMDL (lbs/day)

Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Neenah
T_Neenah
WWTF-Industrial
Galloway Company

TOTAL

Acres % of Total
6,302
43.6%
1,447
10.0%
5,007
34.6%
89
0.6%
1,616
11.2%
14,461
100.0%

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
2,719,043
1,544,583
1,174,460
43.2%
247,820
247,820
23,302
23,302
2,990,165
1,815,705
1,174,460
39.3%
1,575,942
945,565
630,377
40.0%
241,223
48,245
192,978
80.0%
38,217
38,217
621
621
1,856,003
1,032,648
823,355
44.4%
4,846,168
2,848,353
1,997,815
41.2%

Allocated
(lbs/day)
4,229
678
64
4,971
2,589
132
105
2
2,828
7,799

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
1,303,458
782,075
521,383
40.0%
272,484
163,490
108,994
40.0%

Allocated
(lbs/day)
2,141
448

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
621
621
-

Allocated
(lbs/day)
2

7,799

Sources

Urban (MS4)

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

% Reduction
from Baseline
-

81

 LOWER FOX RIVER MAIN STEM SUB-BASIN

 

 

Wisconsin Public Service Corp., Pulliam

Green Bay MSD

 

Georgia Pacific Consumer Products LP
Green Bay Packaging
Georgia Pacific Consumer Products LP

- De Pere

SCA Tissue North
America 001 8L 00

Grand Chute -

Thilmany LLC DePere


Heart of the Valley

Menasha Wes.
Cellu Tissue - NewPage Wisconsin
Neenah uvstems Kimberly

1 ppleton

   
  
  
 
 
 

Fox Energy LLC

Thilmany 
Kaukauna

 

ppleton Coated LLC

Neenah Menasha

Menasha Electric 31 Water Utility
Pechinev Plastic Packaging - Menasha 001

I 4 a
a" i 

_:1Miles
Neenah Paper, Inc. Lake 

  

Lower Green Bay
- ?31. (ADC)





 

  
  
  
   
  
  
     
    
  
 

. 
n?


Procter 3L Gamble
chroeder's Greenhouse

LFR Mainstem
Sub?Basin

 
  
  



LFR Basin

 

 

 

9 Municipal WFS
I Industrial WFS

Mters Impaired by
Phosphorus or Sediment

I: Urban (?OH?regulated)
E: Urban (regulated M34)
- Agriculture

- Natural Background

 

- Water

 

 

 

82

LOWER FOX RIVER MAINSTEM
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
237,339
TMDL
114,263
Reduction
123,076
51.9%
% Reduction Needed

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
9,157
17.0%
3,183
5.9%
36,779
68.4%
297
0.6%
4,328
8.1%
53,744
100.0%

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline Allocated Reduction from Baseline
Agriculture
12,779
3,291
9,488
74.2%
Urban (non-regulated)
1,618
1,618
Natural Background
454
454
LOAD ALLOCATION
14,851
5,363
9,488
63.9%
Urban (MS4)
23,557
16,490
7,067
30.0%
Construction
1,114
1,114
General Permits
275
275
WWTF-Industrial
107,245
41,713
65,532
61.1%
WWTF-Municipal
83,935
42,946
40,989
48.8%
WWTF Reserve Capacity
6,362
6,362
WASTELOAD ALLOCATION 222,488
108,900
113,588
51.1%
TOTAL (WLA + LA) 237,339
114,263
123,076
51.9%

Allocated
(lbs/day)
9.01
4.43
1.24
14.68
45.15
3.05
0.75
114.20
117.58
17.42
298.15
312.83

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline Allocated Reduction from Baseline
579
405.3
173.7
30.0%
5,239
3,667.3
1,571.7
30.0%
437
305.9
131.1
30.0%
49
34.3
14.7
30.0%
217
151.9
65.1
30.0%
2,079
1,455.3
623.7
30.0%
1,085
759.5
325.5
30.0%
4,637
3,245.9
1,391.1
30.0%
738
516.6
221.4
30.0%
10
7.0
3.0
30.0%
3
2.1
0.9
30.0%
739
517.3
221.7
30.0%
830
581.0
249.0
30.0%
543
380.1
162.9
30.0%
151
105.7
45.3
30.0%
974
681.8
292.2
30.0%
1,638
1,146.6
491.4
30.0%
252
176.4
75.6
30.0%
3,163
2,214.1
948.9
30.0%
194
135.8
58.2
30.0%

Allocated
(lbs/day)
1.11
10.04
0.84
0.09
0.42
3.98
2.08
8.89
1.41
0.02
0.01
1.42
1.59
1.04
0.29
1.87
3.14
0.48
6.06
0.37

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline Allocated Reduction from Baseline
9,645
4,174
5,471
56.7%
749
749
570
570
-

Allocated
(lbs/day)
11.43
2.05
1.56

Daily TMDL (lbs/day)

312.83

Sources

Urban (MS4)
Allouez
Appleton
Ashwaubenon
Buchanan
CombLocks
DePere
GrandChute
Green Bay
Greenville
Harrison
Howard
Kaukauna
Kimberly
Lawrence
Ledgeview
LittleChute
Menasha
Neenah
T_Menasha
T_Neenah

WWTF-Industrial
Appleton Coated LLC
Cellu Tissue - Neenah
Fox Energy LLC
Georgia Pacific Consumer Products LP
{ex FJGBE}
Georgia Pacific Consumer Products LP
{ex FJGBW}
Green Bay Packaging - Green Bay
Neenah Paper, Inc.
Menasha Electric & Water Utility
NewPage Wisconsin Systems Kimberly
Pechiney Plastic Packaging - Menasha
001
Procter & Gamble
SCA Tissue North America
Schroeder's Greenhouse
Thilmany LLC - DePere
Thilmany LLC - Kaukauna
Wisconsin Public Service Corp., Pulliam

WWTF-Municipal
Appleton
GBMSD - De Pere
Grand Chute - Menasha West
Green Bay MSD
Heart of the Valley
Neenah - Menasha
Wrightstown

3,826

3,826

21,200

6,558

629
2,499
72

-

-

10.48

14,642

69.1%

17.95

629
927
72

1,572
-

62.9%
-

1.72
2.54
0.20

20,268

5,648

14,620

72.1%

15.46

1,166

1,166

-

3.19

238
6,971
36
313
37,855

238
3,623
36
313
11,976

48.0%
68.4%

0.65
9.92
0.10
0.86
32.79

1,208

1,208

-

3.31

Total Phosphorus Load (lbs/yr)
% Reduction
Baseline Allocated Reduction from Baseline
13,414
7,556
5,858
43.7%
5,565
4,943
622
11.2%
7,730
3,110
4,620
59.8%
26,059
17,349
8,710
33.4%
11,509
3,467
8,042
69.9%
19,412
6,275
13,137
67.7%
246
246
-

Allocated
(lbs/day)
20.69
13.53
8.51
47.50
9.49
17.18
0.67

3,348
25,879
-

83

 LOWER FOX RIVER MAINSTEM
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
23,980,196
TMDL
11,115,433
Reduction
12,864,763
53.6%
% Reduction Needed

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

Acres
9,157
3,183
36,779
297
4,328
53,744

% of Total
17.0%
5.9%
68.4%
0.6%
8.1%
100.0%

30,432

TOTAL

Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WWTF Reserve Capacity
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction
from Baseline
4,942,324
1,881,910
3,060,414
61.9%
475,960
475,960
128,777
128,777
5,547,061
2,486,647
3,060,414
55.2%
13,693,558
4,765,188
8,928,370
65.2%
1,094,974
218,995
875,979
80.0%
79,753
79,753
2,378,520
2,378,520
1,133,351
1,133,351
52,979
52,979
18,433,135
8,628,786
9,804,349
53.2%
23,980,196
11,115,433
12,864,763
53.6%

Allocated
(lbs/day)
5,152
1,303
353
6,808
13,046
600
218
6,512
3,103
145
23,624
30,432

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction
from Baseline
285,657
99,405
186,252
65.2%
3,030,547
1,054,593
1,975,954
65.2%
299,242
104,132
195,110
65.2%
28,603
9,953
18,650
65.2%
123,837
43,094
80,743
65.2%
1,102,905
383,797
719,108
65.2%
524,839
182,637
342,202
65.2%
3,084,098
1,073,228
2,010,870
65.2%
373,661
130,029
243,632
65.2%
7,086
2,466
4,620
65.2%
2,220
773
1,447
65.2%
410,816
142,959
267,857
65.2%
535,583
186,376
349,207
65.2%
198,889
69,211
129,678
65.2%
66,978
23,308
43,670
65.2%
539,026
187,574
351,452
65.2%
1,060,370
368,996
691,374
65.2%
159,612
55,543
104,069
65.2%
1,743,480
606,709
1,136,771
65.2%
116,109
40,404
75,705
65.2%

Allocated
(lbs/day)
272
2,887
285
27
118
1,051
500
2,938
356
7
2
391
510
189
64
514
1,010
152
1,661
111

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
249,129
249,129
53,937
53,937
5,042
5,042

Allocated
(lbs/day)
682
148
14

Daily TMDL (lbs/day)

Sources

Urban (MS4)
Allouez
Appleton
Ashwaubenon
Buchanan
CombLocks
DePere
GrandChute
Green Bay
Greenville
Harrison
Howard
Kaukauna
Kimberly
Lawrence
Ledgeview
LittleChute
Menasha
Neenah
T_Menasha
T_Neenah

WWTF-Industrial
Appleton Coated LLC
Cellu Tissue - Neenah
Fox Energy LLC
Georgia Pacific Consumer Products LP
{ex FJGBE}
Georgia Pacific Consumer Products LP
{ex FJGBW}
Green Bay Packaging - Green Bay
Neenah Paper, Inc.
Menasha Electric & Water Utility
NewPage Wisconsin Systems Kimberly
Pechiney Plastic Packaging - Menasha
001
Procter & Gamble
SCA Tissue North America
Schroeder's Greenhouse
Thilmany LLC - DePere
Thilmany LLC - Kaukauna
Wisconsin Public Service Corp., Pulliam

WWTF-Municipal
Appleton
GBMSD - De Pere
Grand Chute - Menasha West
Green Bay MSD
Heart of the Valley
Neenah - Menasha
Wrightstown

105,698

105,698

% Reduction
from Baseline
-

-

289

175,717

175,717

-

-

481

108,259
81,301
239

108,259
81,301
239

-

-

296
223
1

111,969

111,969

-

-

307

3,373

3,373

-

-

9

155,432
136,023
341
29,003
1,122,241

155,432
136,023
341
29,003
1,122,241

-

-

426
372
1
79
3,073

40,816

40,816

-

-

112

-

% Reduction
from Baseline
-

Allocated
(lbs/day)
465
138
619
972
402
494
14

Total Suspended Solids Load (lbs/yr)
Baseline
Allocated
Reduction
169,857
169,857
50,297
50,297
225,925
225,925
354,861
354,861
147,003
147,003
180,258
180,258
5,150
5,150

84

 LOWER GREEN BAY SUB-BASIN

 

 

      

  
  
    

Lower Green
,Bay Sub-Basin


LFR Basin

 

 

Waters Impaired by
Phosphorus or Sediment

Urban (non-regulated)
Urban (regulated M34)

- Agriculture

- Natural Background

- Water

 

 

 

Lower Green Bay (ADC)



 

Miles

 

 

85

LOWER GREEN BAY
TOTAL PHOSPHORUS
Sub-basin Loading Summary (lbs/yr)
Baseline
12,652
TMDL
6,625
Reduction
6,027
47.6%
% Reduction Needed

Land Use
Agriculture
Urban (non-regulated)
Urban (MS4)
Construction
Natural Background
TOTAL

Acres % of Total
7,135
38.3%
809
4.3%
3,849
20.7%
139
0.7%
6,677
35.9%
18,609
100.0%

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
Agriculture
8,670
3,409
5,261
60.7%
Urban (non-regulated)
324
324
Natural Background
575
575
LOAD ALLOCATION
9,569
4,308
5,261
55.0%
Urban (MS4)
2,554
1,788
766
30.0%
Construction
498
498
General Permits
31
31
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
3,083
2,317
766
24.8%
TOTAL (WLA + LA) 12,652
6,625
6,027
47.6%

Allocated
(lbs/day)
9.33
0.89
1.57
11.79
4.90
1.36
0.08
6.34
18.13

Total Phosphorus Load (lbs/yr) % Reduction
Baseline Allocated Reduction from Baseline
898
628.7
269.3
30.0%
41
28.7
12.3
30.0%
422
295.4
126.6
30.0%
915
640.6
274.4
30.0%
278
194.6
83.4
30.0%

Allocated
(lbs/day)
1.72
0.08
0.81
1.75
0.53

Daily TMDL (lbs/day)

18.13

Sources

Urban (MS4)
Green Bay
Howard
Scott
Suamico
UWGB

86

 LOWER GREEN BAY
TOTAL SUSPENDED SOLIDS
Sub-basin Loading Summary (lbs/yr)
Baseline
4,301,706
TMDL
2,265,758
Reduction
2,035,948
47.3%
% Reduction Needed
Daily TMDL (lbs/day)

6,203

Sources
Agriculture
Urban (non-regulated)
Natural Background
LOAD ALLOCATION
Urban (MS4)
Construction
General Permits
WWTF-Industrial
WWTF-Municipal
WASTELOAD ALLOCATION
TOTAL (WLA + LA)

Urban (MS4)
Green Bay
Howard
Scott
Suamico
UWGB

Land Use
Agriculture
Urban
Urban-MS4
Construction
Natural Background

TOTAL

Acres % of Total
7,135
38.3%
809
4.3%
3,849
20.7%
139
0.7%
6,677
35.9%
18,609
100.0%

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
2,690,986
1,424,635
1,266,351
47.1%
108,148
108,148
68,713
68,713
2,867,847
1,601,496
1,266,351
44.2%
933,711
560,227
373,484
40.0%
495,141
99,028
396,113
80.0%
5,007
5,007
1,433,859
664,262
769,597
53.7%
4,301,706
2,265,758
2,035,948
47.3%

Allocated
(lbs/day)
3,900
296
188
4,384
1,534
271
14
1,819
6,203

Total Suspended Solids Load (lbs/yr)
% Reduction
Baseline
Allocated
Reduction from Baseline
330,584
198,351
132,233
40.0%
16,804
10,082
6,722
40.0%
142,874
85,724
57,150
40.0%
318,128
190,877
127,251
40.0%
125,321
75,193
50,128
40.0%

Allocated
(lbs/day)
543
28
235
523
206

87

 7.0

IMPLEMENTATION

7.1.

Reasonable Assurance for Implementation

Required by the Clean Water Act, reasonable assurances provide a level of confidence that the wasteload
allocations and load allocations in TMDLs will be implemented. This TMDL will be implemented
through enforcement of existing regulations, financial incentives, and various local, state, tribal, and
federal water pollution control programs. The following are some of the activities, programs,
requirements, and institutional arrangements that will provide reasonable assurance that this TMDL will
be implemented and that the water quality goals will be achieved. Following approval by WDNR and
EPA, the TMDL will be amended to the Areawide Water Quality Management Plan for the LFR Basin
pursuant to chapter Wisconsin Administrative Code NR 121.
7.1.1.

Point Sources

Sources of point source discharge in the LFR Basin include municipal and industrial wastewater
treatment facilities, stormwater, and CAFOs. WDNR regulates point sources discharging wastewater to
surface water or groundwater through the WPDES Permit Program. WPDES permits are divided into
two categories - specific and general permits. Specific permits are issued to more complex facilities and
activities such as municipal and industrial wastewater discharges. General permits are issued to classes of
industries or activities that are similar in nature, such as nonmetallic mining, non-contact cooling water,
and stormwater discharges.
Individual WPDES permits issued to municipal and industrial wastewater discharges to surface water will
include limits that are consistent with the approved TMDL wasteload allocations, and may include
options such as adaptive management as outlined in Wisconsin Administrative Code NR 217.06, while
providing the necessary reasonable assurance that the WLAs in the TMDL will be achieved. Once a
TMDL has been state and federally-approved, the permit for a point source that has been allocated a
WLA by the TMDL may not be reissued without a limit that is consistent with the WLA. WDNR may
modify an existing permit to include WLA-derived limits or wait until the permit is reissued to include
WLA-derived limits. Facilities operating under general permits will be screened to determine whether
additional requirements may be needed to ensure that the permitted activity is consistent with TMDL
goals; this may include issuing individual permits or other measures.
7.1.2.

Nonpoint Sources

To ensure the reduction goals of this TMDL are attained, management measures must be implemented
and maintained to control phosphorus and sediment loadings from nonpoint sources of pollution.
Wisconsin’s Nonpoint Source Pollution Abatement Program (NPS Program), described in the state’s
Section 319 Program Management Plan outlines a variety of financial, technical, and educational
programs, which support implementation of management measures to address nonpoint source
pollution.
WDNR is a leader in the development of regulatory authority to prevent and control nonpoint source
pollution. Wisconsin Administrative Code NR 151 establishes polluted runoff performance standards
and prohibitions for agricultural and non-agricultural facilities and practices. These standards are
intended to be minimum standards of performance necessary to achieve water quality standards.
Implementing the performance standards and prohibitions on a statewide basis is a high priority for the
NPS Program.

88

 In particular, the implementation and enforcement of agricultural performance standards and manure
management prohibitions, listed below, will be critical to achieving the necessary nonpoint source load
reductions throughout the basin:
•

Sheet, rill and wind erosion: All cropped fields shall meet the tolerable (T) soil erosion rate
established for that soil.

•

Manure storage facilities: All new, substantially altered, or abandoned manure storage facilities
shall be constructed, maintained or abandoned in accordance with accepted standards. Failing
and leaking existing facilities posing an imminent threat to public health or fish and aquatic life
or violating groundwater standards shall be upgraded or replaced.

•

Clean water diversions: Runoff from agricultural buildings and fields shall be diverted away from
contacting feedlots, manure storage areas, and barnyards located within water quality
management areas (300 feet from a stream or 1,000 feet from a lake or areas susceptible to
groundwater contamination).

•

Nutrient management: Agricultural operations applying nutrients to agricultural fields shall do so
according to a nutrient management plan.

•

Manure management prohibitions:
o No overflow of manure storage facilities;
o No unconfined manure piles in a water quality management area;
o No direct runoff from feedlots or stored manure into state waters; and
o No unlimited livestock access to waters of the state in locations where high
concentrations of animals prevent the maintenance of adequate or self-sustaining sod
cover.

In addition to the performance standards and prohibitions, the NPS Program supports NPS pollution
abatement by administering and providing cost-sharing grants to fund BMPs through various WDNR
grant programs, including the Targeted Runoff Management (TRM) Grant Program; the Notice of
Discharge (NOD) Grant Program; the Urban Nonpoint Source & Storm Water Management Grant
Program; and the River Planning & Protection Grant Program.
It is important to partner with the Department of Agriculture, Trade, and Consumer Protection
(DATCP), which oversees and supports county conservation programs that implement the state
performance standards and prohibitions and conservation practices. DATCP’s Soil and Water Resource
Management Program requires counties to develop Land and Water Resource Management (LWRM)
Plans to identify conservation needs. Counties must receive DATCP’s approval of their plans to receive
state cost-sharing grants for BMP installation. DATCP is also responsible for providing local assistance
grant (LAG) funding for county conservation staff implementing NPS control programs included in the
LWRM plans. County LWRM plans advance land and water conservation and prevent NPS pollution by:
•

Inventorying water quality and soil erosion conditions in the county.

•

Identifying relevant state and local regulations, and any inconsistencies between them.

•

Setting water quality goals in consultation with WDNR.

•

Identifying key water quality and soil erosion problems, and practices to address those problems.

89

 •

Identifying priority farm areas using a range of criteria (e.g., impaired waters, manure
management, high nutrient applications).

•

Identifying strategies to promote voluntary compliance with statewide performance standards
and prohibitions, including information, cost-sharing, and technical assistance.

•

Identifying enforcement procedures, including notice and appeal procedures.

•

Including a multi-year work plan to achieve soil and water conservation objectives.

WDNR, DATCP, and the county (Brown, Calumet, Outagamie, and Winnebago) Land Conservation
Departments (LCD) will work with landowners to implement agricultural and non-agricultural
performance standards and manure management prohibitions to address sediment and nutrient loadings
in the LFR Basin. Many landowners voluntarily install BMPs to help improve water quality and comply
with the performance standards. Cost sharing may be available for many of these BMPs. In most cases,
farmers will not be required to comply with the agricultural performance standards and prohibitions
unless they are offered at least 70% cost sharing funds. If cost-share money is offered, those in violation
of the standards are obligated to comply with the rule.
The four counties and other local units of government in the basin may apply for TRM grants through
WDNR. TRM grants are competitive financial awards to support small-scale, short-term projects (24
months) completed locally to reduce runoff pollution. Both urban and agricultural projects can be
funded through TRM grants, which require a local contribution to the project. Projects that correct
violations of the performance standards and prohibitions and reduce runoff pollution to impaired waters
are a high priority for this grant program.
Numerous federal programs are also being implemented in the basin and are expected to be an
important source of funds for future projects designed to control phosphorus and sediment loadings in
the LFR Basin. A few of the federal programs include:
•

Environmental Quality Incentive Program (EQIP). EQIP is a federal cost-share program
administered by the Natural Resources Conservation Service (NRCS) that provides farmers with
technical and financial assistance. Farmers receive flat rate payments for installing and
implementing runoff management practices. Projects include terraces, waterways, diversions, and
contour strips to manage agricultural waste, promote stream buffers, and control erosion on
agricultural lands.

•

Conservation Reserve Program (CRP). CRP is a voluntary program available to agricultural
producers to help them safeguard environmentally sensitive land. Producers enrolled in CRP
plant long-term, resource conserving covers to improve the quality of water, control soil erosion,
and enhance wildlife habitat. In return, the Farm Service Agency (FSA) provides participants
with rental payments and cost-share assistance.

•

Conservation Reserve Enhancement Program (CREP). CREP provides annual rental payments
up to 15 years for taking cropland adjacent to surface water and sinkholes out of production. A
strip of land adjacent to the stream must be planted and maintained in vegetative cover
consisting of certain mixtures of tree, shrub, forbs, and/or grass species. Cost sharing incentives
and technical assistance are provided for planting and maintenance of the vegetative strips.
Landowners also receive an upfront, lump sum payment for enrolling in the program, with the
amount of payment dependent on whether they enroll in the program for 15 years or
permanently.

90

 7.1.3.

Implementation Plan Development

The next step following approval of the TMDL is to develop an implementation plan (or multiple
implementation plans – one for each sub-basin) that specifically describes how the TMDL goals will be
achieved. The implementation planning process may develop strategies to most effectively utilize existing
federal, state, and county-based programs to achieve wasteload and load allocations outlined in the
TMDL. Details of the implementation plan may include project goals, actions, costs, timelines, reporting
requirements, and evaluation criteria.
Over the last three decades, there has been a tremendous amount of collaboration and partnering
throughout the LFR Basin to try to restore beneficial uses and reduce loadings of nutrients and sediment
to Green Bay. Since the 1980s, WDNR has worked with local stakeholders to implement the Remedial
Action Plan for the Lower Fox River/Green Bay Area of Concern, as well as the
Duck/Apple/Ashwaubenon Creeks and East River Priority Watershed Projects, bringing together
people, policies, priorities, and resources through a watershed approach. Development of a TMDL
implementation plan will require a continued collaborative effort that utilizes the funding and technical
expertise of various agencies and private organizations.
An additional resource recently developed to support implementation planning efforts is an analysis of
potentially restorable wetlands (PRWs) in the LFR Basin, which quantifies the estimated phosphorus and
sediment that could potentially be reduced if all original wetlands in the basin are restored (Appendix F).
7.2.

Watershed Management Plan for Waters within the Oneida Reservation

7.2.1.

Point Sources within Oneida Reservation

For approximately ten years, the Oneida Reservation has required onsite treatment of stormwater for all
new buildings. This includes a treatment train system at the Health Center, an innovative no discharge
swale system at the Elder Complex, as well as wetland treatment designed to recharge the Oneida Creek
watershed at the WWTF, which itself is a state of the art treatment system. Currently, any land disturbing
activity of one acre or more on the Oneida Reservation is required to be covered under the EPA issued
Construction Site General Permit. Coverage under this permit is to ensure that proper erosion control
practices be implemented to prevent sediment and possibly other pollutants from leaving construction
sites and negatively impacting surface or groundwater systems. Oneida Reservation staff work with
EPA’s Region 5 stormwater coordinator to ensure compliance and proper use of erosion control BMPs
within the Reservation. With regards to industrial stormwater, the EPA Multi-Sector General Permit
(MSGP) was issued in 2008, but has not been implemented as of yet. However, with the MS4 permit, the
Oneida Reservation and three other entities covering the same urbanized area will all be implementing
post-construction maintenance and monitoring of stormwater systems.
7.2.2. Nonpoint Sources within Oneida Reservation
The tribe has a nonpoint source program which works with the tribal farm and non-tribal farmers and
focuses on agricultural BMPs. They have installed hundreds of acres of grassed waterways, buffers, and
Water and Sediment Control Basins (WASCOBS) in the last 15 years. All agricultural leases made by the
tribe include mandatory compliance with a nutrient management plan, as well as minimum buffers for
any waterways or wetlands. The tribe also has partnered with other agencies such as Glacierland R, C,
and D, Brown and Outagamie Counties, and WDNR to implement watershed-scale nonpoint source
management.

91

 7.3.

Follow-up Monitoring

A post-TMDL monitoring effort will determine the effectiveness of the implementation activities
associated with the TMDL. WDNR will monitor the tributaries of the LFR Basin based on the rate of
management practices installed through the implementation of the TMDL, including sites where TRM
grants are aimed at mitigating TSS and TP loading. Monitoring will occur as staff and fiscal resources
allow until it is deemed that stream quality has responded to the point where it is meeting its codified
designated uses and applicable water quality standards. In addition, the streams of the LFR Basin may
be monitored on a 5-year rotational basis as part of WDNR’s statewide water quality monitoring
strategy to assess current conditions and trends in overall stream quality. That monitoring consists of
collecting data to support a myriad of metrics contained in WDNR’s baseline protocol for wadeable
streams, such as the IBI, the HBI, a habitat assessment tool, and several water quality parameters
determined on a site by site basis.
WDNR will work in partnership with local interest groups including the LFRWMP and GBMSD, to
support monitoring efforts which often provide a wealth of data to supplement WDNR data. All other
quality-assured available data in the basin will be considered when looking at the effectiveness of the
implementation activities associated with the TMDL. In addition, WDNR will consider providing
support for a more detailed monitoring strategy that may eventually be a component of a TMDL
implementation plan developed for the LFR Basin and Lower Green Bay.
Additionally, the Oneida Reservation plans to continue to implement its own Water Quality Monitoring
Program, which includes the collection of water samples for analysis of TP and TSS, as well as biological
data (i.e., fish and aquatic invertebrate samples). The primary objective of the Oneida Reservation’s
Water Quality Monitoring Program is to gather data to evaluate baseline water quality for the water
bodies of the Reservation, as well as trends in water quality (e.g., increases or decreases in parameters
over time). Baseline physical, chemical, and biological information will be collected regularly at
designated stations throughout the Reservation. This level of monitoring helps to determine water
quality and biological status and trends in each subwatershed using ecologically-based indicators and
identifies potential problem areas. Current baseline sites are located within the Reservation boundary;
however, select sites outside of the Reservation boundary may also be monitored. These will be chosen
based on proximity to the Reservation, as well as land use and/or wastewater discharge practices that
may affect waters of the Reservation. Various approaches will be employed for sample collection (e.g.
fixed station/site, surveys, and periodic sampling). When baseline monitoring data indicate a potential
problem within a subwatershed, targeted site-specific monitoring is conducted. In addition, targeted sitespecific monitoring is conducted for episodic events, such as reported fish kills, and monitoring
(including collection of biological data) to measure water quality improvements associated with
management actions.

92

 8.0

PUBLIC PARTICIPATION

8.1.

Public Notice

This draft TMDL was released and public notice was issued on June 24, 2010. A public hearing was held
on July 12, 2010, in Grand Chute, WI. A 30-day public review period was established for soliciting
written comments from stakeholders prior to the finalization and submission of the TMDL for EPA
approval. Responses to comments received during the public review period are provided in Appendix H.
8.2.

Stakeholder Engagement, Public Outreach, and Public Participation

WDNR supported the formation of three advisory teams to assist with the development of the TMDL:
The Outreach Team, the Ad Hoc Science Team, and the Technical Team. While WDNR convened and led
the latter two groups, the Outreach Team was convened and led by a partner agency, the UW Sea Grant
Institute.
Outreach Team
In the fall of 2006, Victoria Harris, Water Quality Specialist with UW Sea Grant Institute, convened an
Outreach Team to support WDNR in its efforts to inform stakeholders about the TMDL and engage
them in TMDL development while also looking ahead to TMDL implementation. The Outreach Team
members are listed in Table 11. The Team met 23 times between September 2006 and May 2010. In
2006, the team established the following theme and vision to guide outreach and education activities:
Restoring Our Water Heritage:

Together we can create a better future for the Lower Fox River and Green Bay
Our Vision: The Lower Fox River and Green Bay will be:
•

Clean, healthy water bodies that are a destination for residents and visitors because of their
abundant fish and wildlife resources and diverse recreational opportunities.

•

Water bodies whose protection is widely acknowledged as critical to the economic health of the
region.

•

Recognized by area residents as valued resources that are important to their quality of life.

•

Examples of a balanced, fair approach to solving water quality challenges.

•

Identified by communities as an important stewardship responsibility and protected for future
generations.

93

 Table 11. TMDL Outreach Team Members
Name

Organization

Victoria Harris (Chair)

UW-Sea Grant Institute

Theresa Qualls

UW-Sea Grant Institute

Pat Robinson

UW-Extension

Kendra Axness

UW-Extension

Ken Genskow

UW-Extension

Denise Scheberle

UW-Green Bay

Trisha Cooper

UW-Green Bay

Jill Fermanich

UW-Green Bay

Bud Harris

UW-Green Bay

Paul Abrahams

Baird Creek Preservation Foundation

Michael Finney

Oneida Tribe of Indians

Bill Hafs

Brown Co. Land and Water Conservation Dept

Rama Zenz

Brown Co. Land and Water Conservation Dept

Lisa Evenson

Green Bay Metropolitan Sewerage District

Rob McLennan

WDNR

Nicole Clayton

WDNR

Erin Hanson

WDNR

Alie Muneer

USEPA

Dean Maraldo

USEPA

John Perrecone

USEPA-GLNPO

Angela Pierce

Bay Lake RPC

The Outreach Team recognized the need to better understand the perspectives, needs, and concerns of
audiences that would be affected by the TMDL. With support from EPA and UW-Green Bay faculty,
facilitated stakeholder meetings were held in late 2007 and early 2008 to better understand the concerns
of agricultural and municipal stormwater stakeholders. Supplementing this information were two
stakeholder surveys, conducted as part of an EPA Region 5 initiative to develop “social indicators” for
nonpoint source pollution management. The first survey was mailed to dairy farmers in the Lower Fox
Basin, and the second survey was mailed to urban residents within the East River Sub-basin. The surveys
provided information about current awareness of water quality issues and attitudes toward water
resources, status of best management practice implementation, and willingness to try new practices.
While the stakeholder meetings and surveys were underway, the Outreach Team developed and
implemented communication strategies to inform watershed residents about the TMDL. Team members
developed a variety of written materials, including fact sheets, newsletters, and web pages. In fall 2008, a
two-page fact sheet and cover letter were mailed to approximately 1,600 farmers within the basin using
county Farm Preservation and other mailing lists. The fact sheet was also mailed to local officials and
environmental groups along with a cover letter inviting these recipients to contact either a WDNR staff
person or Outreach Team member with any questions.

94

 In late 2008, several Outreach Team members met with the Green Bay Press-Gazette editorial board.
The meeting resulted in publication of an article titled, “Groups push to reduce pollution entering Fox
River.” The article appeared approximately two weeks before a January 23, 2009 public informational
meeting that was attended by 63 individuals. Additional informational meetings were held for
stakeholders throughout the TMDL development process. Outreach Team members also gave
presentations to various groups and provided posters and exhibits for local events. Details regarding the
Outreach Team’s efforts during TMDL development are presented in Appendix G.
8.3.

Technical Team

WDNR convened the Technical Team in October 2008 to ensure that stakeholder interests were
represented throughout the TMDL development process. The role of the Technical Team was to ensure
that watershed models for various restoration scenarios were grounded in feasible, socially acceptable
best management practices. The team was also charged with exploring and assessing costs and barriers to
implementation for a variety of best management practices (and/or potential modifications to
wastewater treatment facilities). WDNR also asked the team to be creative in exploring allocation and
restoration scenarios and implementation approaches. The Technical Team members are listed in Table
12. The team met five times between October 2008 and May 2010 (dates listed in Appendix G).
Table 12. TMDL Technical Team Members
Name

Title

Organization

Jim Bachhuber

National Stormwater Practice Leader

Earth Tech AECOM

Nick Vande Hey

Senior Project Engineer

McMahon and Associates

Ed Wilusz

Wisconsin Paper Council

Bill Hafs

VP, Government Relations
Optimizer Effluent Treatment/#10
Boiler
County Conservationist

Greg Baneck

County Conservationist

Eugene McLeod

County Conservationist

Brown Co. Land & Water Conservation Dept
Outagamie Co. Land & Water Conservation
Dept.
Calumet Co. Land & Water Conservation Dept.

John Kennedy

Environmental Programs Manager

Green Bay Metropolitan Sewerage District

Matt Heckenlaible

City of Green Bay

Dennis Frame

Assistant City Engineer
Conservation Professional
Development & Training Coordinator
Director

Bud Harris

Professor Emeritus

UW-Green Bay

Kevin Fermanich

Associate Professor

UW-Green Bay

Paul Baumgart

Watershed Analyst

UW-Green Bay

Kelly Mattfield

Senior Water Resources Engineer

Earth Tech AECOM (alternate)

Steve Jossart

Kevin Erb

Georgia Pacific

UW-Extension
UW-Discovery Farms

95

 8.4.

Ad-Hoc Science Team

The role of the Ad-Hoc Science Team was to contribute local data and scientific expertise in setting the
numeric targets and restoration goals for the TMDL. The Ad Hoc Science Team members are listed in
Table 13.
Table 13. TMDL Ad-Hoc Science Team Members
Name

Title

Organization

Bud Harris

Professor Emeritus

UW-Green Bay

Kevin Fermanich

Associate Professor

UW-Green Bay

Paul Baumgart

Watershed Analyst

UW-Green Bay

Paul Sager

Professor Emeritus

UW-Green Bay

John Kennedy

Environmental Programs Manager

Green Bay Metropolitan Sewerage District

Val Klump

Director, School of Freshwater Science

UW-Milwaukee

Tim Ehlinger

Associate Professor

UW-Milwaukee

Victoria Harris

Water Quality Specialist

UW-Sea Grant Institute

Theresa Qualls

Research Analyst

UW-Sea Grant Institute

Nicole Clayton

State TMDL Coordinator

WDNR

Rob McLennan

Regional Impaired Waters Coordinator

WDNR

96

 9.0

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in cooperation with the U.S. Environmental Protection Agency.
Rowe, D.R. and Lange, R. M. 2009. Status of Reintroduction of Great Lakes muskellunge in Wisconsin
Waters of Green Bay, Lake Michigan. in Lake Michigan Management Report Series, Wisconsin
Department of Natural Resources. Madison, WI. pp. 37-43.
Sager, Eric. 1993. Use of GIS to predict colonization patterns of submergent vegetation in Lower Green
Bay with Changes in Light Conditions. Unpublished Independent Study, Trent University.
Steuer J., W. Selbig, and N. Hornewer. 1996. Contamination concentration in stormwater from eight
Lake Superior cities, 1993-94. U.S. Geological Survey. Open-File Report 96-122. Madison,
Wisconsin. Prepared in Cooperation with the Wisconsin Dept. of Natural Resources.
Steuer, J., W. Selbig, N. Hornewer, and J. Prey. 1997. Sources of contamination in an urban basin in
Marquette, Michigan and an analysis of concentration, loads, and data quality. U.S. Geological
Survey. Water Resources Investigations Report 97-4242. Middleton, Wisconsin. Prepared in
Cooperation with the Wisconsin Dept. of Natural Resources and U.S. EPA.
Trimbee A.M. and Prepas, E.E. 1987. Evaluation of total phosphorus as a predictor of the relative
biomass of blue-green algae with emphasis on Alberta lakes. Can. J. Fish Aquatic Sci. 44:1387-1342.
United States Census Bureau (USCB). 2000. U.S. Census 2000. Available at http://www.census.gov/.
United States Environmental Protection Agency (USEPA). 2007. Options for Expressing Daily Loads in
TMDLs (Draft). June 22, 2007.
United States Environmental Protection Agency (USEPA). 1991a. Guidance for Water Quality-based
Decisions: The TMDL Process. U.S. Environmental Protection Agency, Office of Water,
Washington, DC. http://www.epa.gov/owow/tmdl/decisions/dec1c.html.
United States Environmental Protection Agency (USEPA). 1991b. Technical Support Document for
Water Quality-based Toxics Control. U.S. Environmental Protection Agency, Office of Water,
Washington, DC.
Voss, K. (2007). Mead Lake Watershed Wetland Assessment Project. Madison, WI: Wisconsin Department of
Natural Resources.
Waschbusch, R.J. 1995. Stormwater-runoff data, Madison, 1993-94. U.S. Geological Survey. Open-File
95-733. Madison, Wisconsin. Prepared in Cooperation with the City of Madison, Wisconsin.
Waschbusch, R.J., W.R. Selbig, and R.T. Bannerman. 1999. Sources of phosphorus in Stormwater and
Street Dirt from two urban residential basins in Madison, Wisconsin, 1994-95. U.S. Geological
Survey Water-Resources Investigations Report 99-4021. Prepared in Cooperation with the City of
Madison, Wisconsin and the Wisconsin Department of Natural Resources. 47 p.

99

 Waschbusch, R.J. 1999. Evaluation of the Effectiveness of an Urban Stormwater Treatment Unit in
Madison, Wisconsin, 1996-97. U.S. Geological Survey. Water-Resources Investigation Report 994195. Madison, Wisconsin. Prepared in Cooperation with the City of Madison, Wisconsin and the
Wisconsin Department of Natural Resources.
Wisconsin Department of Natural Resources (WDNR). 2001a. Lower Fox River Basin Integrated
Management Plan. Publication WT-666-2001.
Wisconsin Department of Natural Resources (WDNR). 2001b. Model Evaluation Workgroup Technical
Memorandum 3a. Evaluation of Flows, Loads, Initial Conditions, and Boundary Conditions. Edited
by Mark Velleux of the Wisc. Dept. of Natural Resources, with collaboration from Limno-Tech Inc.
on behalf of the Fox River Group.
Wisconsin Department of Natural Resources (WDNR). 1997. The Nonpoint Source Control Plan for
the Duck, Apple and Ashwaubenon Creeks Priority Watershed Project.
Wisconsin Department of Natural Resources (WDNR). 1993a. Lower Green Bay Remedial Action Plan.
1993 Update.
Wisconsin Department of Natural Resources (WDNR). 1993b. The Nonpoint Source Control Plan for
the East River Priority Watershed Project.
Wisconsin Department of Natural Resources (WDNR). 1991. Lower Fox River Basin Integrated
Management Plan.
Wisconsin Department of Natural Resources (WDNR). 1988. Lower Green Bay Remedial Action Plan.

100

 APPENDIX A. ANALYSIS RESULTS FOR THE NUMERIC WATER QUALITY TARGETS
As discussed in the main body of the report, numeric targets for TP and TSS were needed for this
TMDL, in lieu of no statewide numeric water quality criterion for these two parameters. Local
monitoring data were used to determine the water quality targets for the TMDL. Predicted
improvements in water quality and littoral zone habitat in Zones 1 and 2 were evaluated by simulating
reductions in LFR Basin levels of TP and TSS. Using a data set produced by GBMSD sampling from
June through September for the period, 1993-2005, a multiple regression model was determined relating
Epar in Zones 1 and 2 to corresponding levels of TP and TSS in the LFR.
Understanding Light Extinction (Epar) and Secchi Depth Relationships
Light extinction or attenuation is the reduction of light with depth of the water by light scattering and
absorption. Light scattering is a deflection of light predominantly by particles suspended in water and to
a lesser extent by water. Absorption of light occurs by the water itself and by dissolved and suspended
particles in it. Visible light is composed of many wavelengths and they are not all equally scattered or
absorbed in lake water. Most light sensors used in lake studies operate in the photosynthetically available
radiation (PAR) portion of the visible spectrum (400-700 nm), which ranges from blues to red-violets.
Even in this range there are differences in specific wavelengths. For example, the blues (shorter
wavelengths) penetrate deeper than the reds (longer wavelengths). The sensors used today integrate the
different wavelengths and then measure PAR in mEinsteins/m2/minute. Light measurements are taken
at 1-meter intervals from the surface to a depth where light intensity is greatly reduced. Epar is calculated
as the slope of a linear regression (a statistical analysis) of the natural log of light intensity versus depth,
and is a measure of light attenuation through the water column. Low values of Epar indicate low light
attenuation with depth and high values indicate high light attenuation and subsequently a shallow zone
of light sufficient for photosynthesis by algae and plants. Lower Green Bay has high Epar values and the
Upper Bay has low values and thus, a deeper photic zone, which refers to the photosynthetically active
zone of the water column for algae and aquatic plants (zone where rate of photosynthesis is higher than
respiration rate). When the factors influencing Epar in the AOC are better understood, goals can be set
to reach lower values, in turn improving and restoring biotic diversity and production in the shallow
zone of Lower Green Bay, the ultimate goal.
Epar scores are inversely proportional indicators of the ability of light to penetrate water. Low Epar
scores suggest clearer water with deep light penetration while high scores suggest turbid water with
minimal light penetration. Baseline data in LFR were then altered in six reduction scenarios and inserted
into the regression model.
An additional, simple regression model was calculated to relate Epar to the more public-friendly, Secchi
depth expression. Table 14 presents the models and the results of the calculations showing the increase
in Secchi depth in response to the simulated decreases in TP levels and TSS levels in the LFR.

101

 Table 14. Model results for Secchi depth response to simulated decreases in TP and TSS.
A) Baseline conditions summary (Summer median values, 1993-2005)
Variable

Median

N

Std Dev

Std Error

Minimum

Maximum

Epar Zones 1 & 2

1.89

1116

1.36

0.04

0.42

11.06

Secchi Zones 1 & 2 (m)

0.7

1235

0.69

0.02

0.1

5

TSS River (mg/l)

36.25

468

17.6

0.81

15.5

175.5

TP River (mg/l)

0.1805

468

0.09

0

0.06

0.74

B) TP and TSS levels determined by percent reduction from baseline means

Variable
TP river (mg/l)

Baseline
Median
(93-05)

25%
Reduction

40%
Reduction

45%
Reduction

50%
Reduction

60%
Reduction

75%
Reduction

0.181

0.135

0.108

0.099

0.09

0.072

0.045

18.125

14.5

9.063

50%

60%

75%

1.44

1.3

1.11

50%

60%

75%

1.16

1.21

1.27

TSS river (mg/l)

36.25
27.188
21.75
19.983
C) Epar values calculated for reduction scenarios for TP and TSS
2

Epar = 0.78 + 2.80TP + 0.02TSS (r =0.35)
Variable
Epar

Baseline

25%

40%

45%

2.1

1.77

1.57

1.5

TP 40%
TSS 60%
1.41

D) Secchi depth predictions based on relationships to light extinction coefficients
2

Secchi = 1.65 – 0.34 Epar (r =0.58)
Variable
Secchi (meters)

Baseline

25%

40%

45%

0.94

1.05

1.12

1.14

TP 40%
TSS 60%
1.17

Evaluating TP concentrations and Blue-green Algae Relationships
In addition to the relationship between TSS, TP loading and corresponding light extinction coefficients
and Secchi depth, a relationship between the relative biomass of blue-green algae (%BG) in
phytoplankton of lakes in relation to TP concentrations was also explored (Figure 22). Nuisance bluegreen algae blooms are common in Lower Green Bay, presenting both an aesthetic problem as well as a
health risk problem for pets and recreational users. Currently blue-green algae make up over 70% of the
phytoplankton in Lower Green Bay. The vertical lines in Figure 22 identify baseline TP in the LFR (180
µg/l), the TMDL target for the LFR (100 µg/l) and a predicted numeric level (60 µg/l-for Zones 1 and
2) when the TMDL target is achieved (Table 15). The reduction in percent blue-green algae
corresponding to the TP change is apparent and is likely one of the major benefits of the TMDL
initiative.

102

 Figure 22. Predicting the relative biomass of blue-green algae in phytoplankton from total
phosphorus levels in lakes, where %BG = 100/e + 5-2.62 logTP 1 (Trimbee and Prepas, 1987).
80
70
61

% Blue-green

60

68

65

71

74

56

50

50
42

40
31

30
20

17

10
0
0

20

40

60

80

100

120

140

160

180

200

220

240

TP (ug/l)

Note:
a) The 180 µg/l line is the median TP level for the LFR in the period 1993-2005
b) The 100 µg/l line is the TMDL numerical target for the LFR
c) The 60 µg/l line is the mean TP level for Zones 1 and 2, predicted from the LFR target by the regression: TP =
0.02 + 0.60 (LFR TP) r2 = 0.469 (see text above)

Table 15. Predicted Lower Bay (zones 1 and 2 combined) responses to achieving the LFR main
stem targets of 0.1 mg/L TP and 20 mg/L TSS
2

TP = 60 µg/l (mean) by the regression: TP = 0.02 + 0.60LFR TP (r =0.469)
2

TSS = 15 mg/l(mean) by the regression: TSS = 6.7 + 0.41LFR TSS (r = 0.350)
2

Secchi Depth = 1.7 m (mean) by the regression: Secchi = 1.62 – 0.85TP – 0.027 TSS (r = 0.439)
% blue-green algae in the phytoplankton in relation to TP levels (Figure 2)
TP

%BG

0.180 mg/l(LFR baseline)

71

0.100 mg/l(LFR TMDL Target)

56

0.060 mg/l(Zones 1 and 2)

42

103

 APPENDIX B. SWAT WATERSHED MODELING ANALYSIS

Prepared by Paul Baumgart, University of Wisconsin – Green Bay, 10/19/09
The following provides a description of the SWAT model, describes the methods used to supply new
inputs to the model, discusses model refinement and assessment, and contains summaries of some of the
major outputs from the model.
Model Overview
SWAT is a distributed parameter, daily time step model that was developed by the USDA-ARS to
primarily assess nonpoint source pollution from watersheds and large complex river basins (Neitsch et al.
2002). SWAT simulates hydrologic and related processes to predict the impact of land use management
on water, sediment, nutrient and pesticide export. With SWAT, a large heterogeneous river basin can be
divided into hundreds of subwatersheds; thereby, permitting more realistic representations of the specific
soil, topography, hydrology, climate and management features of a particular area. Crop and
management components within the model permit representation of the actual cropping, tillage and
nutrient management practices typically used in Wisconsin. Modeled output data from SWAT can be
easily input to a spreadsheet or database program, thereby enabling efficient modeling of large complex
watersheds with multiple management scenarios. Major processes simulated within the SWAT model
include: surface and groundwater hydrology, climate, soil water percolation, crop growth,
evapotranspiration, agricultural management, urban and rural management, sedimentation, nutrient
cycling and fate, pesticide fate, and water and constituent routing. SWAT also utilizes the QUAL2E submodel to simulate nutrient transport. A detailed description of SWAT can be found on the SWAT web
site (http://www.brc.tamus.edu/swat/).
The SWAT model framework that Baumgart (2005) applied to the LFR sub-basin for the allocation of
total phosphorus (TP) and total suspended solids (TSS) loads was refined as part of a recent
demonstration project (Cadmus, 2007) to estimate the load reduction associated with changes in
agricultural management. For the LFR and Green Bay TMDL, this model was refined, extended,
recalibrated, and validated. The LFR sub-basin model was expanded to include watersheds that drain
directly to Lower Green Bay. The urban stormwater component of the model was refined to allow for
the evaluation of TP and TSS loading from MS4 urban areas covered under WPDES stormwater
permits. The model was refined to make use of new data sets of continuous flow and daily loads of TP
and TSS from five Lower Fox River Watershed Monitoring Program (LFRWMP) monitoring stations.
This extensive data set of continuous flow and daily loads of TP and TSS from these monitoring stations
made it possible to further test the ability of the model to simulate flow, TP and TSS with a reasonable
level of accuracy. After calibration and validation, the model was applied for a 1977 to 2000 period to
simulate flow and loads from major nonpoint source categories under 2004 conditions. Loads from each
source category were generated at the subwatershed outlet, watershed outlet, and to Green Bay.
Model Inputs and Methods
Model input data were acquired from a variety of qualified sources including, federal, state, and tribal
agencies, as well as universities. Model inputs and sources are summarized in Table 16. The Geographical
Information System (GIS) software product ArcGIS, created by the Environmental Systems Research
Institute, Inc. (ESRI), was utilized to generate model inputs, conduct analyses and produce maps. Many
of these inputs had already been assembled by Baumgart (2005; Cadmus, 2007), but were modified with
more recent data.

104

 Table 16. Major model input types and sources
GIS/Data Type

Meteorological:
Daily rainfall,
temperature and
monthly statistics

Stream Flow &
Water Quality (TSS
and TP loads)

Source Agency
NOAA Daily Climatic Data
from NWS and co-op
stations
USGS: 4 tipping
bucket/loggers at USGS
and LFRWMP gages, plus
Bower Creek station
LFRWMP: 12 tipping
bucket gauges with loggers
USGS

LFRWMP

Hydrography based
on GIS data
merged from many
sources

WI Department of Natural
Resources - surface waters
WI Department of Natural
Resources - watershed
boundaries
Bay-Lake Regional
Planning Commission watershed boundaries
USGS - Wisconsin,
watershed boundaries
USEPA - watershed
boundaries
LFRWMP - Final watershed
boundaries

Hydrography 303(d) Impaired
surface waters

WI Department of Natural
Resources

Soil Types
(SSURGO)

USDA-NRCS

Elevation (DEM)

WI Dept. of Natural
Resources
WI Department of Water
Resources

Land use, Land
cover and orthophotos

Brown County Planning
Dept.
East Central Wisconsin
Regional Planning
Commission
US Dept. of Agriculture
(USDA) - FSA

Source Location/Metadata Link
Data available on request. Data obtained from UW-Extension
Geological and Natural History Survey State Climatology Office in
Madison, Wisconsin
http://waterdata.usgs.gov/wi/nwis/sw
Bower-04085119; Baird-040851325; Ashwaubenon-04085068;
Apple-04085046; Duck-04072150
Rainfall data on request.
http://www.uwgb.edu/watershed/data/climate.htm
http://waterdata.usgs.gov/wi/nwis/sw Bower-04085119; Baird040851325; East-040851378; Fox-040851385; Ashwaubenon04085068; Apple-04085046; Duck-04072150
Baird Creek 2008 discharge and load data on request http://www.uwgb.edu/watershed/data/index.htm; TP and TSS
concentrations from USGS Baird station 040851325
Utilized earlier version (available on request): most recent version
at: ftp://gomapout.dnr.state.wi.us/geodata/hydro_24k/
Utilized earlier version (available on request): most recent version
at ftp://gomapout.dnr.state.wi.us/geodata/watersheds/
Lower portion of East River only. Available on request from source.
GIS web site: http://www.baylakerpc.org/
Upper portion of East River only. Data available on request from
source.
12-digit HUC obtained from EPA, available on request. Utilized for
comparison purposes.
Available on request. Compiled and modified from above layers
http://www.uwgb.edu/watershed/data/index.htm
Available on request from source. Contact:
Matt.Rehwald@dnr.state.wi.us
Wisconsin: Brown, Calumet, Outagamie, Winnebago Counties
http://soildatamart.nrcs.usda.gov
http://soildatamart.nrcs.usda.gov/SSURGOMetadata.aspx
ftp://gomapout.dnr.state.wi.us/geodata/elevation/
Metadata for most WDNR layers available at
ftp://gomapout.dnr.state.wi.us/geodata/metadata/ and/or
included at data site in ZIP file
WISCLAND land cover, primarily for wetlands:
ftp://gomapout.dnr.state.wi.us/landcover/
ftp://gomapout.dnr.state.wi.us/metadata/
2001 to 2004 land use. 2004 ortho-photo. Available on request to
data source. GIS web site:
http://www.co.brown.wi.us/Land_Information_Office/IMS.htm
2002 to 2003 land use. Available on request to data source. GIS
web site:
http://www.eastcentralrpc.org/
NASS 2007 cropland:
www.nass.usda.gov/research/Cropland/SARS1a.htm

105

 GIS/Data Type

Source Agency
USDA-FSA, from Wisconsin
View

Elevation and
contours

Brown County Planning
Dept.

Elevation and
contours

Outagamie County
Planning Dept

WDNR-Enhanced
USGS 1:24K DRG
topographic maps

WI Dept. of Natural
Resources

Crop residue levels

WDATCP, USDA-NRCS and
county land conservation
departments

Political/municipal
boundaries

MS4 Boundaries
Vegetated Buffer
Strips
Wetlands
Point Source Loads

Brown, Calumet,
Outagamie and
Winnebago county
Planning Departments
WI Dept. of Natural
Resources
Brown County Land
Conservation Department
WI Dept. of Natural
Resources
WI Dept. of Natural
Resources

Source Location/Metadata Link
NAIP 2004, 2005 and 2008 color ortho-photos
http://www.wisconsinview.org/documents/2005_NAIP_FAQs.pdf
data: http://www.wisconsinview.org/
Data utilized only as needed in this phase.
http://www.co.brown.wi.us/planning_and_land_services/land_in
formation_office/IMS.htm
Data utilized only as needed in this phase.
http://www.co.outagamie.wi.us/applications/arcims/public/html
/
http://dnrmaps.wisconsin.gov/webview/themes/drg.html
http://dnr.wi.gov/maps/gis/documents/digital_raster_graphics_2
4k.pdf
Data available on request. WI Dept. of Ag, Trade and Consumer
Protection (WDATCP), NRCS county offices and Brown, Calumet,
Outagamie, Winnebago Land and Water Conservation
Departments
Minor civil divisions (MCD) from counties. GIS layer available on
request from source. County boundary from
ftp://gomapout.dnr.state.wi.us/geodata/county_bnds/
WDNR provided data, mostly from consulting firms contracted by
MS4’s, including EarthTech, Inc. and McMahon and Associates.
GIS layer available on request from source.
GIS layer available on request from source.
WDNR WISCLAND land cover layer:
ftp://gomapout.dnr.state.wi.us/geodata/watersheds/
Loads and GIS layer available on request from source.

Watershed Delineations and Sub-basin Configuration
The LFR subwatershed delineation that was created by Baumgart (2005) and altered slightly to coincide
with the location of the LFRWMP monitoring stations (Cadmus, 2007) was extended to include
watersheds that contributed to Lower Green Bay. ArcGIS was used to create the revised subwatershed
delineations. Subwatershed boundaries for the latest revision were based on merging data from the
sources listed in Table 16. USGS digital raster graphic 1:24,000 topographic images and two-foot
contours provided by Outagamie and Brown County Planning Departments were occasionally utilized
where there were areas in question. As illustrated in Figure 23, the Lower Fox River sub-basin was
divided into nine major hydrologic units (watersheds) for the calibration: (1) LF01 - East River; (2) LF02
- Dutchman, Ashwaubenon, and Apple Creeks; (3) LF03 - Plum, Kankapot and Garners Creeks; (4)
LF04 - Appleton Watershed, which includes Mud Creek; (5) LF05 - Duck Creek; (6) LF06 - Little Lake
Buttes des Morts Watershed, which includes the Neenah Slough Creek; (7) LFM - Lower Fox River
Main Channel; (8) LFS7 - East Shore Watershed near; and (9) LFS8 - West Shore Watershed. These
watersheds were further delineated into a total of 69 subwatersheds according to surface hydrology, land
use and the placement of monitoring stations.

106

 Figure 23. Lower Fox River Basin and Sub-basin boundaries
(USGS monitoring stations used for calibrating and validating the SWAT model are also shown)

107

 Land Use GIS Baseline Layer
To create a year 2004 land use gridded raster and the associated model inputs, a GIS land use shapefile
developed by the Brown County Planning Department 17 (BCPD) was merged with an East Central
Wisconsin Regional Planning Commission (ECWRPC) land use shapefile, 18 and clipped to the LFR subbasin boundary. The resulting shapefile was converted to a 5 m gridded raster, which was supplemented
with additional wetland data from the WDNR 1993 WISCLAND land cover image. High-resolution
color aerial photographs (2004 and 2005) were obtained from the U.S. Department of Agriculture
(USDA) Wisconsin Farm Service Agency (WI-FSA) National Agriculture Imagery Program (NAIP) and
used to manually update and refine land use categories for portions of the drainage basin to better reflect
baseline land use conditions in the drainage basin. This was accomplished by adding urban areas where
agriculture or other land use had been indicated.
Urban areas were identified as either regulated Municipal Separate Storm Sewer Systems (MS4s) or nonregulated urban areas. These areas were distinguished using a combination of the MS4 boundary areas
provided by stormwater planning consultants, and the minor civil division (MCD) boundaries obtained
from Brown, Calumet, Outagamie and Winnebago Counties.
Agricultural land cover is the most prevalent land cover in the sub-basin. Wetlands, grasslands and
forested areas are relatively small components of the sub-basin compared to urban and agricultural areas.
With the exception of LF01-5 and LF05-15, which have a high proportion of wetlands, most of the subwatersheds are predominantly agricultural or urban.
Seven major land use categories were modeled with methods that are described in greater detail later in
this section: agriculture, urban, golf course, forest, grassland, wetland and quarries. These land uses were
further divided into 23 major groups of hydrologic response units (HRU's) which were directly modeled
in the following fashion:
Agriculture – Dairy 6 year rotation (corn, soybean, corn, alfalfa, alfalfa, alfalfa)
1
Conventional tillage practice (CT)
2
Mulch-till (MT30)
3
Ridge-till or no-till (NT)
Agriculture - Cash Crop 2 year rotation (corn, soybean)
4
Conventional tillage practice (CT)
5
Mulch-till (MT30)
6
Ridge-till or no-till (NT)
7
Grassland
8
Forest
9
Wetland
10
Quarries
Urban (8 urban sub-classes plus rural residential large lot):
11-13
MS4 areas: high density (HD), medium density (MD), low density (LD)
14-16
Non-MS4 areas within MS4 municipal MCD boundaries: HD, MD, LD
17
18

The BCPD land use data approximately represent 2004 conditions.
The ECWRPC land use data represent 2002 to 2003 conditions, depending on which county it was obtained from.

108

 17-18
19
20
21
22
23

Other urban outside of the MS4 areas and MCD boundaries: HD, MD
Rural Residential (simulated as large lot low density urban)
Farm building lot
Barnyard
Golf course
Rural Roads
Surface waters not included in simulation

HRUs represent areas within a subwatershed that are similar in a hydrology or management, but are not
necessarily contiguous. For this TMDL, HRUs are the total area in the subwatershed with a particular
land use and/or management. A GIS operation involving the land use image and sub-watershed
boundary shapefile was used to derive the proportional area of the major HRUs within each of the 69
modeled subwatersheds.
The proportion of crops within each sub-watershed, and the typical crop rotations used to represent the
LFR sub-basin were determined using the USDA NASS 2007 cropland image. Row crops, other than
corn, were modeled as soybean to simplify the possible combinations of rotations that would otherwise
need to be modeled. No single specific farming practice could be used to model the entire watershed;
therefore, various proportions of the six possible agricultural practices that are listed above (six major
HRUs) were used to simulate what occurred in each sub-watershed. Corn-silage and corn-grain were
assumed to constitute tow thirds and one third, respectively, of the corn grown in a typical dairy rotation.
In order to simulate all phases of a crop rotation in a single model run, the dairy (corn-silage, corn-grain,
alfalfa, soybean) and cash crop (corn, soybean) rotations were modeled by adding HRUs to represent
each phase of a crop rotation. Alternatively, separate model runs would be required to simulate each
phase of a crop rotation. Since there were six years in a dairy rotation, two years in a cash crop rotation,
and 69 sub-watersheds, the total number of modeled HRUs was 2,829 [69 subwatersheds * (6 years * 3
tillage practices + 2 years * 3 tillage practices + 17 other land uses)]. Many of these HRUs were later
grouped for load allocation purposes.

Tillage Practices and Crop Residue
The conservation tillage levels utilized by Baumgart (2005) were updated to coincide with more recent
LFRWMP water monitoring record from 2004 to 2008. Conservation Technology Information Center
(CTIC) Conservation Tillage Reports (Transect Surveys) from the four counties were analyzed to
determine the primary tillage practice inputs to SWAT. These Transect Survey reports were based on
statistical sampling procedures of farm fields to estimate residue levels present shortly after spring
planting, as well as other information. Data were supplied by the Wisconsin Department of Agriculture,
Trade and Consumer Protection and analyzed with the Transect 2.16 software program produced by
Purdue Research Foundation, Purdue University.
The most recent sub-basin wide crop residue and tillage practice reports were from 2002, and they
indicated that there was a sharp decrease in the amount of residue left on the field since data had been
collected in 1999 and 2000, especially for watersheds that had higher residue cover in the previous years.
There was much variation in residue cover between watersheds, and some uncertainty in the applicability
of the residue data because water monitoring data was from late 2003 to 2008 instead of 2002. Because
of this uncertainty, the watershed-specific crop residue levels from 1999, 2000 and 2002 were averaged
and applied uniformly as conservation tillage inputs to all of the watersheds in the LFR sub-basin. The
average tillage inputs that were assumed for the baseline conditions were: 83.1% conventional tillage,

109

 15.2% mulch-till, and 1.7% no-till, zone-till or high residue for the dairy crop rotation; and 75.9%
conventional tillage, 20.2% mulch-till, and 3.9% no-till for the cash crop rotation. The NRCS field office
conducted a joint NRCS and LFRWMP-funded survey over Brown County in the spring of 2008. The
results were essentially the same as those assumed for Baseline Conditions, except for the Duck Creek
watershed. Therefore the 2008 data were utilized for the Duck Creek watershed and the following tillage
inputs were assumed for baseline conditions: 69.4% conventional tillage, 27.4% mulch-till, and 3.2% notill, zone-till or high residue for the dairy crop rotation; and 56.3% conventional tillage, 36.5% mulch-till,
and 7.2% no-till for the cash crop rotation.

Non-agricultural Rural Land Areas
HRUs designated as grassland, forest, wetlands and golf courses were assigned values from SWAT's
default crop data sets for pasture, forest, wetland and lawn data sets, respectively. Those areas that were
classified as barren were primarily quarries, and simulated accordingly. Rural roads were simulated as a
combination of impervious road surface and grass ditch.

Urban MS4 Areas
Initially, the area of the LFR sub-basin that was considered to be regulated as municipal stormwater areas
was delineated by combining GIS datasets that were provided by the consultants who developed
stormwater management plans for many of the regulated communities. These GIS datasets, along with
many of the associated stormwater permit plans was provided by the WDNR. Stormwater plans were
not sufficiently developed for several communities, so the boundaries of these MS4 areas were estimated
by Baumgart and added to the other areas through “heads-up-digitizing.” Much editing was required to
repair and label many open polygons, and to improve consistency between all of the labeled land use
categories and the MS4 areas. The result was a shapefile that delineated the MS4 areas in the LFR subbasin.
However, there was still significant inconsistency between the municipalities with regards to what areas
were or were not classified as MS4s in the original GIS layers provided by the consultants. In addition,
not all communities were able to supply MS4 boundaries, because their stormwater plans were not
complete. Also, many areas were not classified as MS4s, in part because GIS data was not obtained from
all MS4s, so there were concerns about how these areas would be affected under a TMDL. Therefore, it
was decided by the WDNR that the MS4-classified area should include all urban areas within MS4designated communities. To accommodate this change, minor civil division (MCD) boundaries obtained
from Brown, Calumet, Outagamie and Winnebago counties were merged into a single GIS MCD
shapefile that contained municipal boundaries. A field was added to separate MS4 and non-MS4
municipalities. Furthermore, six MS4 municipalities had relatively large areas that were mostly rural, so
the rural portions of the following municipalities were not included in the MS4 boundary: Village of
Bellevue, Village of Ledgeview, Village of Hobart, Town of Scott, Town of Buchanan and Town of
Harrison. The original MS4 boundary shapefile was kept intact and intersected with the MCD shapefile.
This process resulted in three major urban categories that were modeled in SWAT: 1) directly delineated
MS4 areas (as provided by stormwater planning consultants or added where none were available); 2)
indirectly delineated MS4 areas that were within MS4-designated municipal boundaries but not originally
labeled as such; and 3) all other non-MS4 urban areas. For purposes related to TMDL allocations, loads
and flow from the two MS4 categories were later combined into a single MS4 category.
Finally, the urban shapefile was overlaid with the USDA-NASS 2007 classified land cover raster image to
create separate urban sub-classes for high and medium/low density urban areas that were directly
simulated as HRUs in SWAT. Another shapefile was created to discriminate between rural areas and
110

 urban metropolitan areas so that relatively large low density rural residential lots could be distinguished
from smaller low density lots within this quasi-metropolitan boundary. This boundary was primarily
based on the U.S. Census Bureau 2000 urban boundary shapefile. These two shapefiles were combined
with the three-category MS4 shapefile to create a final urban shapefile that contained a total of nine
combinations of urban land use classes (including a low density rural residential class), which were
modeled as the nine previously listed urban HRUs.

Urban Areas
The buildup and washoff option was selected as the method to simulate urban loads from impervious
surfaces in SWAT. The buildup and washoff method incorporated in SWAT is similar to that used in the
Storm Water Management Model (SWMM, Huber and Dickinson, 1988). Measured loads from different
urban sources were not available within the project area, so all metropolitan urban areas were lumped
into two primary classes: medium density residential areas and high intensity commercial/industrial areas.
Some high density residential or mixed residential areas were included in the latter class. The fraction of
impervious area was assumed to be: (1) 0.335 for medium residential, compared to the SWAT default of
0.38; and (2) 0.70 for commercial/industrial areas, which was based on averaging the SWAT defaults of
0.60 for high density urban, 0.67 for commercial, and 0.84 for industrial areas. For the pervious portion
of the urban HRU, phosphorus and sediment loadings were simulated by assuming that these areas were
in lawn grass, and a SWAT management routine was developed to simulate the runoff and loadings from
these areas. Areas that were classified as urban lots that were located outside of metropolitan areas were
assumed to be low density residential lots with a relatively low proportion of impervious area (0.09)
because these lots can vary in size from a minimum of 0.75 acre to over 8 acres. The default SWAT
value for the fraction of impervious area for low density residential is 0.12.
The urban component of the SWAT model was initially calibrated for TSS and TP by adjusting the
urban management file and associated files to obtain a representative TSS concentration of about 90
mg/L and a TP concentration of 0.18 mg/L during a 1977-2000 climatic period (representative
concentration = total simulated long-term load/total long-term water volume). These calibration
concentrations and corresponding yields were based on a review of the following urban runoff data
which is summarized in Table 17: (1) four urban Milwaukee, Wisconsin streams with a median and mean
of 107 mg/L and 152 mg/L TSS, respectively, and median and mean of 0.18 mg/L and 0.21 mg/L TP,
respectively (Bannerman et al., 1996); (2) eight Wisconsin and two Upper Michigan storm sewer sites
with a median and mean of 120 mg/L and 237 mg/L TSS, respectively ,and median and mean of 0.29
mg/L and 0.45 mg/L TP, respectively (Bannerman et al. 1996); (3) eight Lake Superior Basin cities
storm sewer sites with a median and mean of 284 mg/L and 433 mg/L TSS, respectively, and median
and mean of 0.44 mg/L and 0.47 mg/L TP, respectively (Steuer et al., 1996); (4) Marquette, Michigan
storm sewer site with a geometric means of 159 mg/L TSS and 0.29 mg/L TP (Steuer et al., 1997); (5)
seven stormwater sites in Madison, Wisconsin with a median and mean of 93 mg/L and 106 mg/L TSS,
respectively, and a median and mean of 0.32 and 0.38 mg/L TP, respectively (Waschbusch, 1995); (6)
stormwater from 25 runoff events within residential basins in Madison, Wisconsin had a median and
mean of 136 mg/L and 171 mg/L TSS, respectively, and a median and mean of 0.45 and 0.59 mg/L TP,
respectively (Waschbusch et al., 1999); (7) stormwater from 15 runoff events that entered a treatment
chamber installed below the pavement surface at a municipal maintenance garage and parking facility in
Milwaukee, Wisconsin contained median event mean concentrations of 232 mg/L TSS, and 0.26 mg/L
TP (Corsi et al., 1999); (8) 43 samples of stormwater that entered an urban stormwater treatment unit
which collected runoff from a 4.3 acre municipal maintenance yard in Madison, Wisconsin contained
median and mean concentrations of 251 mg/L and 345 mg/L TSS, respectively (Waschbusch et al.,
1999); and (9) during 64 runoff events, stormwater entering a wet detention pond in Madison, Wisconsin
from a 0.96 km2 residential area had median and average event mean concentrations of 144 mg/L and
111

 239 mg/L TSS, respectively, and median and average event mean concentrations of 0.45 mg/L and 0.57
mg/L TP, respectively (House et al., 1993).
Suspended solids in storm sewers are expected to have a higher proportion of large particles than in
urban streams because as larger particles are more likely to settle out in streams, or before reaching the
stream, than in storm sewers. Larger particles are not associated with reduced water clarity in Green Bay,
nor are they expected to be a major component of runoff from rural areas. Therefore, greater emphasis
was given to water quality data collected from streams than data from storm sewers when selecting the
calibration concentrations. In addition, urban areas contribute more than just overland runoff to the
stream, so urban runoff concentrations should be diluted by recharge or lateral flow that also comes
from urban areas.
Table 17. Summary of phosphorus and suspended sediment/TSS concentrations measured in
urban streams and storm sewers within Wisconsin and neighboring states
Sediment/TSS (mg/L)
Reference

storm sewer

Total Phosphorus (mg/L)

urban stream

storm sewer

urban stream

median

mean

median

mean

median

mean

median

mean

Bannerman, et al. 1996

120

237

107

152

0.29

0.45

0.18

0.21

Steuer et al. 1996

284

433

0.44

0.47

Waschbusch, R.J. 1995

93

106

0.32

0.38

Waschbusch, R.J. 1999

251

345

House et al. 1993

144

239

0.45

0.57

Steuer et al. 1999

159

0.29

Corsi et al. 1999

232

0.26

Waschbusch et al. 1999

136

171

Median

152

238

107

Mean

177

255

107

0.45

0.59

152

0.32

0.47

0.18

0.21

152

0.36

0.49

0.18

0.21

The primary change that was made to calibrate the urban component of the SWAT model was to
decrease the urban wash-off coefficient from 0.18 to 0.055 for residential areas and 0.039 for high
density areas. This change was made to reduce the overall sediment concentration and loads (and
associated phosphorus), and to have sediment yields from the two urban classes reflect the same relative
proportions as in SLAMM modeling for the City of Green Bay (EarthTech, 2007).
After calibration, the 1977-2000 average annual SWAT-simulated TSS yield was 275 lbs/acre, based on
24 typical urban sub-watersheds. This area-weighted average TSS yield is similar to the observed median
unit-area annualized yield of 372 lbs/acre TSS from 15 urban watersheds in Southeastern, Wisconsin till
plains ecoregion (Corsi et al., 1997; ranging from 49 to 1,279 lbs/acre). The 1992-2008 mean annual
suspended sediment yield was 275 lbs/acre at the USGS urban monitoring station located at Spring
Harbor near Madison, Wisconsin (USGS #05427965), while the mean yield between 1999 and 2008
was243 lbs/acre. SWAT simulated TSS yields were also similar to the range of baseline and existing
urban yields that were generated with the SLAMM model by Earth Tech (2007, 2008a, 2008b) for the
stormwater management plans of the City of Green Bay (235 and 210 lbs/acre), Appleton (251 and 194
lbs/acre), and DePere (251 and 170 lbs/acre). The mean annual baseline urban yield from 14 LFR subbasin municipal stormwater plans was 243 lbs/acre (reports produced by Earth Tech, McMahon
Associates, Omni Associates and others). These values include contributions from open spaces. Without

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 including open spaces, the SLAMM modeled TSS yield was 227 lbs/acre for Green Bay under existing
conditions; whereas, the average sediment yield was 210 lbs/acre with open space areas. The former
value is more comparable to the SWAT simulated yields because many of the open spaces are modeled
as such in the SWAT framework.
After the initial calibration, the 1977-2000 average annual SWAT-simulated phosphorus yield was 0.52
lbs/acre, based on 24 typical urban sub-watersheds. However, the model was adjusted to increase the
phosphorus yield to coincide more closely to the simulated yields from local stormwater plans. After
final calibration, the 1977-2000 average annual SWAT-simulated urban phosphorus yield was 0.70
lbs/acre, based on the urban portions of nine sub-watersheds located in the East River watershed. The
SWAT simulated phosphorus yields were similar to the baseline and existing condition urban yields that
were generated with the SLAMM model by Earth Tech (2007, 2008a, 2008b) for the stormwater
management plans of the City of Green Bay (0.77 and 0.70 lbs/acre), Appleton (0.85 and 0.70 lbs/acre),
and DePere (0.84 and 0.71 lbs/acre). The mean simulated phosphorus yield under baseline condition
from 14 LFR sub-basin municipal stormwater plans was 0.72 lbs/acre (reports produced by Earth Tech,
McMahon Associates, Omni Associates and others). However, the SWAT-simulated phosphorus yield is
somewhat higher than the observed median unit-area load of 0.50 lbs/acre phosphorus from four urban
watersheds in Southeastern, Wisconsin till plains ecoregion (Corsi et al., 1997; ranged from 0.21 to 1.89
lbs/acre kg/ha).

Construction Sites - Urbanizing Areas
Urbanization is a transitional change from rural to urban land use. Urbanization and associated land use
changes for the simulation period are by nature continuous. Therefore, the problem of constructing a
model framework for simulating the spatial and time dependant nature of this change throughout the
simulation period did not render a simple or obvious solution. Perhaps understandably, the current
version of SWAT does not directly model continuous changes in land use over time in a single model
simulation; that is, the area of each HRU remains unchanged over time.
Therefore, the rural to urban transition was simulated by adding a separate HRU within the model to
represent construction sites, but the area of the HRU was kept constant and represented the average area
transitioning to urban over a limited period of time. Loads were simulated with SWAT by assuming that
the annualized change in urban area from 2001 to 2004 remained constant for each sub-watershed. The
land use GIS raster image that was developed by Baumgart (2005) in a previous modeling exercise served
as the 2001 land use, which was then compared to the baseline 2004 land use image that was created for
this project to estimate the change in urban area. The average annual increase in urban area within each
sub-watershed then served as the area of the construction site HRU. The total urban area within each
sub-watershed was reduced to offset the area from HRU construction sites that was added to the model.
The simulated load and yields for the construction site HRU were based on several factors, including
data from two separate Wisconsin construction site studies that are described below. In a study
conducted from spring 1977 to summer 1978, Madison et al. (1979) found that the mean and median
TSS concentrations from rapidly urbanizing watersheds in Germantown, Wisconsin were approximately
6,900 and 5,100 mg/L, respectively during monitored runoff events. The mean and median TP
concentrations were about 4.5 and 2.9 mg/L, respectively. The mean sediment yield was roughly 13,193
lbs/acre and the mean phosphorus yield was approximately 9.55 lbs/acre over the two partial year
sampling periods. The yields would be lower if calculated on an annualized basis. While some erosion
controls were implemented in the non-control watershed, they were judged to be ineffective due to
drought conditions. Owens et al. (2000) studied soil erosion from two small construction sites in Dane
County, Wisconsin. Both sites were less than five acres. During the active construction phase the flow113

 weighted average concentration of suspended sediment from a commercial site was 12,700 mg/L (n=8),
and 2,600 mg/L (n=3) from a residential site. However, they noted that few of the storms produced
runoff at the residential site because most of the construction took place in winter; whereas, construction
at the commercial site primarily took place during the summer months. Furthermore, they suggested that
there was evidence which indicated that the suspended sediment concentrations could have been as high
at the residential site as they were at the commercial site if construction had instead taken place during
the summer months. An annualized sediment yield of 6,750 lbs/acre was estimated for the summer
construction season at the commercial construction site, whereas 1,650 lbs/acre was estimated for the
winter construction season at the residential construction site (Owens et al., 2000; loads estimated for
un-sampled events).
Erosion controls are currently required at most constructions sites in the LFR sub-basin; whereas,
controls were minimal or ineffective at the construction sites in the Dane County and Germantown
studies. In addition, both total precipitation and rainfall intensity are lower in Northeastern Wisconsin.
Therefore, baseline yields from construction sites in the LFR sub-basin would be expected to be lower
than the aforementioned study sites where minimal controls were implemented. An HRU was created to
roughly simulate fallow or limited vegetation conditions similar to what might occur at a construction
site under “existing” 2004 condition. Based on the Wisconsin construction site runoff data and
associated caveats about current erosion controls, the SWAT model construction site HRU was
calibrated to produce average annual sediment yields of 4,047 lbs/acre (5.0 t/ha) and phosphorus yields
of 4.5 lbs/acre from construction sites within the East River watershed over a 1977 to 2000 period (as
routed to the sub-watershed outlet). These sediment and phosphorus yields were on average, 7.5 times
and 3.1 times higher, respectively, than yields generated during the same 1977 to 2000 simulation period
for comparable agricultural areas under a typical dairy rotation with conventional high intensity tillage.
Compared to standard urban development that occurs within the metropolitan areas, areas transitioning
from agricultural land use to low density, large, rural residential lots should produce lower TP and TSS
yields, because only a relatively small portion of the large lot is usually developed. To accommodate this
difference, TSS yields and associated TP yields were reduced by decreasing the yields in proportion to
the amount of very low density land use within each sub-watershed, and assuming that the yield from
these areas was one third that of more dense developing areas.
Climatological Inputs
Daily precipitation and temperature data from the following weather stations served as input to the
climate sub-model in SWAT: NOAA National Weather Service (NWS) Station at the Green Bay airport
(long-term); three USGS stations located in the Upper Bower Creek watershed (1990-97); and official
NWS cooperative stations in Appleton and Brillion (long-term). These data were combined to create a
1976 to 2000 climate data set that was used for all Baseline and optimal scenario simulations. Climatic
data were assigned to each sub-watershed according to the nearest weather station.
In addition, up to four rain gauge-logger units were operated by the USGS (4 in 2003-06; 2 in 20072008), and 12 tipping bucket rain gauges and loggers were installed throughout the basin by the UWGreen Bay through the LFRWMP (2004-2008). Daily precipitation data from four independent stations
that were part of a weather network whose real-time data was posted on the internet were also added to
the climate database (http:/www.wbaytv.com). This dataset was checked for accuracy by comparison
with nearby stations, and questionable data were removed from the database. Data from these stations
were used to supplement the other data and provide more accurate precipitation data to the model for
the 2004-2008 calibration and validation periods. During the calibration and validation periods,
precipitation inputs to the model were generated for each sub-watershed based on an inverse-distance
114

 weighted formula and the distance between the centroid of each sub-watershed and the surrounding
precipitation stations.
Routing TSS and Phosphorus to Green Bay
Subwatershed loads were routed from sub-watershed outlets to the watershed outlet within the SWAT
model. However, in SWAT the loads and flow from all sources (i.e., simulated HRUs) are combined at
the sub-watershed outlet and subsequent downstream points of interest. For the TMDL, the sources
responsible for the loads need to be identified. Therefore, loads and flow from sources were tracked by
routing these sources outside of the SWAT model and assuming that losses via settling were the same
for all source loads as they were routed downstream. Phosphorus was routed as combined dissolved and
organic/sediment phosphorus (TP) by using the net phosphorus that entered and exited a SWAT
routing reach to derive the TP routing ratio. TSS and TP loads were then routed from the watershed
outlets to Green Bay, along the main stem of the Fox River channel. Sediment routing/trapping
coefficients for the main stem of the Fox River were based on a relationship between trapping efficiency
and the reservoir capacity/average annual inflow ratio that was developed by Brune (1953) and by Dendy
(1974). It was assumed that all of the dissolved P from the watersheds reached the outlet to Green Bay
(no settling), while sediment-attached phosphorus had the same trapping efficiency as sediment; this was
done by apportioning the now combined TP loads back into a dissolved phosphorus and sedimentattached phosphorus based on the respective proportions from SWAT output files that were generated
for the major watershed outlets. In this way, both the sub-watershed routed loads and the loads from the
SWAT watershed outlet files were consistent.
Stream Bank Erosion
The stream bank erosion sub-model within SWAT was not updated as planned for in the QAPP,
because most of the data from an ongoing sediment source tracing investigation of LFR tributaries was
not available in time to calibrate the SWAT model. Therefore, as in previous LFR modeling projects
(Baumgart, 2005; Cadmus, 2007), the stream bank erosion component of the modeling framework was
“turned off” which effectively lumped these contributions with upland sources because 1) county land
conservation departments assessed the stream bank contributions of TSS and TP during watershed
planning and estimated that they were not a major source compared to upland sources; and 2) actual
watershed-wide precise measurements of stream bank contributions were not available to calibrate the
model.
Model Calibration and Assessment

Stream Flow and Water Quality Data
Calibration and initial validation of the SWAT model was conducted with continuous stream discharge
and daily TP and TSS loads from the USGS-WDNR monitoring station located on Bower Creek at CTH
MM (1990-1997; 36 km2). In addition, five continuous discharge monitoring stations within the LFR
sub-basin were upgraded or installed through the LFRWMP and were operated cooperatively with the
USGS, the Oneida Tribe, and the GBMSD. Three to five years of stream flow and water quality data
from October 2003 through September 30, 2008 were available from the following stations:
1) Duck Creek at CTH FF (276 km2; 2004 to 2008), upgraded with sampler (co-sponsored by
Oneida Tribe).
2) Baird Creek at Superior Road (54 km2; 2004 to 2008).

115

 3) Apple Creek at CTH U / Campground (117 km2; 2004 to 2006).
4) Ashwaubenon Creek at Creamery Road (48 km2; 2004 to 2006).
5) East River at Monroe Street (374 km2; 2004 to 2007), (co-sponsored by the GBMSD).
The USGS computed daily TP and TSS loads for each stream based on continuous discharge and
discrete low-flow and automated event sampling. The UW-Green Bay applied regression analysis to
estimate dissolved phosphorus loads. Data from the five LFRWMP USGS monitoring stations were
utilized for model assessment as published by the USGS with two types of exceptions. First, the USGS
did not officially track stream flow or calculate daily loads at the Baird Creek station after USGS water
year 2007. However, the USGS continued the operation of all monitoring equipment at the Baird Creek
station through 2008 and provided the unofficial discharge data to the LFRWMP; in return, the
LFRWMP agreed to assist in the collection and processing of water samples from the USGS station at
Bower Creek. The Baird Creek discharge measurements during 2008 remain unofficial because the
USGS did not continue field measurements to verify that the stage-discharge relationship did not change,
nor did the USGS maintain the monitoring equipment and verify that it was functioning correctly. The
LFRWMP continued the same monitoring protocol that was utilized from 2004 to 2007 to collect and
analyze samples. The LFRWMP then adjusted the 2008 raw stream flow data where necessary (e.g., iceaffected periods to ensure water balance was reasonable, or small log jam), and applied the USGS
software program GCLAS to calculate daily loads of TSS and phosphorus using the unofficial discharge
measurements from Baird. GCLAS was also used by the USGS to calculate the official loads from this
site, as well as the other LFRWMP stations. The TSS and phosphorus concentrations from 2008 and
2009 are available for download from the USGS web site.
Second, as stated in the QAPP, there were times when the stage-discharge relationship in a stream was
affected by ice conditions, thereby affecting stream flow and associated loads. During these times, the
USGS estimated the flow. However, there were times when it appeared that the estimated stream flow
was too high relative to the overall water balance and expected water inputs. That is, the water balance
during and preceding the ice-affected flow events did not seem correct in the sense that the flow volume
came close to, or even exceeded total precipitation during or preceding the event. Stream flow and
associated loads estimated by the USGS during ice-affected periods were therefore adjusted
approximately one year prior to model assessment by Paul Baumgart, UW-Green Bay watershed analyst
with the LFRWMP. The TP and TSS loads were adjusted in proportion to the change in flow. Iceaffected estimated flow and loads were adjusted well before any modeling efforts were made; thereby
limiting bias when the adjusted values were utilized for model assessment. Although the adjustments
often favored an improved correspondence between simulated and observed flows, there were also times
when they decreased the fit. The adjusted and un-adjusted daily flow and load data set from the
LFRWMP are included with the electronic data submitted with this project.

Calibration
Model calibration involved adjusting model inputs within acceptable and published ranges to obtain the
best fit between observed and simulated values. The Nash-Sutcliffe coefficient of efficiency (NSE; Nash
and Sutcliffe, 1970), regression analysis, and visual inspection served as the criteria to compare observed
and simulated flow and loads on an event, monthly, and annual basis. The Upper Bower Creek
watershed (LF01-15, 36 km2) was utilized as the primary calibration site for stream flow, TSS loads, and
phosphorus loads. Recalibration of the previous SWAT model (Baumgart, 2005; Cadmus, 2007) was
performed because the input structure of the model was altered to accommodate an increased number of
HRUs, including an HRU for construction sites. These changes did not affect crop yields and crop
biomass production, so no changes were made to related input parameters.
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 The Bower Creek monitoring site (USGS Station #04085119) is located in the East River Watershed
(jointly funded by the USGS and WDNR), and has a continuous record of flow data and daily loads,
which are vital to the model calibration. The Upper Bower Creek watershed has silty clay to clay loam
soils with slow infiltration rates (NRCS hydrologic group C soils), shallow overland slopes, and land use
comprised of 83% agriculture (mostly dairy) and 9% forest and wetland in 2004. These characteristics are
typical of most areas within the LFR sub-basin.
The 1991 to 1994 (Oct. 1990 to March 31, 1995) Bower Creek monitoring data (daily flow and loads)
were used for calibrating the model (50 to 52 events), while the monitoring data from 1996 to 1997 (17
events), along with data from other sites, were used in the model assessment phase. For model
calibration and assessment purposes, the SWAT model was applied to the Bower Creek LF01-15 subwatershed for a 1989 to 1997 climatic period. Only a single slight adjustment was made to calibrate the
LFR sub-basin model that was previously used by Baumgart (2005; Cadmus, 2007): the
evapotranspiration coefficient was increased by 0.5% (0.806 versus 0.810) to decrease the volume of
runoff. Calibration results are summarized in Table 18. After calibration, the total simulated stream flow
during the 1990 to 1994 calibration period was 909 mm compared to 902 mm for the observed stream
flow. Annual simulated and observed stream flows were: 1991 (201 vs. 180 mm), 1992 (210 vs. 230 mm),
1993 (344 vs. 370 mm), and 1994 (132 vs. 102 mm), respectively. The maximum relative difference was
30% in 1994, when the lowest flow occurred; thereby, suggesting that the model may have greater
difficulty simulating water yields during dry periods.
The NSE for 52 total event stream flow volumes was 0.79 and the coefficient of determination (rsquared) was 0.80. A NSE of one indicates a perfect fit. The NSE and r-squared were both 0.86 for
monthly flows during the calibration period. The NSE and r-squared were 0.89 and 0.91, respectively for
monthly TSS loads. The NSE and r-squared were 0.77 and 0.79, respectively for monthly TP loads. Two
very large events that were utilized for flow evaluation were not used for evaluating TSS and TP event
loads because no samples were collected during these events so the loads were only estimated by the
USGS. The NSE for 50 total events was 0.90 for TSS and 0.80 for TP. NSE and r-squared statistics were
above the minimum criteria of 0.6 that was stated in the QAPP. Relative differences were below the
maximum level of 30% that was stated in the QAPP. Therefore, the statistical measures indicate that
there was an acceptable level of correspondence between simulated and observed events, and that model
assessment could proceed.

117

 Table 18. Calibration and validation summary for Bower Creek monitoring station
Observed

SWAT

R

2

NSE

2

Relative
difference

R or NSE
basis

Calibration Period (1991 to 1994)
Flow (mm)

902

909

0.86

0.86

0.8%

monthly

TSS (tons)

6,610

6,890

0.91

0.89

4.2%

Monthly

Phosphorus (kg)

22,380

21,250

0.79

0.77

-5.1%

Monthly

Flow (mm)

673

583

0.80

0.79

-13.4%

52 events

TSS (tons)

6,120

5,720

0.93

0.90

-6.6%

50 events

Phosphorus (kg)

18,460

15,879

0.82

0.80

-14.0%

50 events

Validation Period (April 1, 1996 to June 30, 1997)
Flow (mm)

330

322

0.77

0.77

-2.4%

monthly

TSS (tons)

2,290

2,810

0.86

0.85

22.2%

monthly

Phosphorus (kg)

7,470

8,500

0.90

0.90

13.8%

monthly

Flow (mm)

178

164

0.80

0.79

-7.7%

17 events

TSS (tons)

1,920

2,010

0.83

0.81

4.9%

17 events

Phosphorus (kg)

5,420

5,320

0.85

0.84

-1.9%

17 events

Validation/Assessment
Model validation involved testing the ability of the calibrated model to predict flow and loads at times or
locations other than those in the calibration phase, without adjusting model parameters. Model
assessment and potential refinement were particularly important because the previous LFR modeling
effort relied heavily on daily loads from the Bower Creek USGS station (Baumgart, 2005). With data
made available through the LFRWMP, it was possible to thoroughly assess the ability of the model to
provide reasonably accurate predictions in five LFR watersheds. Model assessment involved comparing
the simulated output to continuous flow and daily loads of TSS and TP from the 1996 to 1997 Bower
Creek data set, as well as the 2004 to 2008 data sets from the five USGS stations operated and funded
cooperatively through the LFRWMP, the Oneida Nation, and the GBMSD. The SWAT model was
applied to the LFRWMP watersheds for a 2002 to 2008 climatic period during the model assessment
phase. R-squared and NSE values of 0.6 or greater, and percent bias of 30% or less served as goals for
successful validation of the model for stream flow, TSS loads, and TP loads on an annual and monthly
basis. As stated in the QAPP, any excursions from this target should be limited in scope, and a rationale
provided to explain why the model would still be deemed valid.
As shown in Table 18, the relative differences between observed and simulated Bower Creek values were
-2.4% for stream flow, 22% for TSS and 14% for phosphorus over the entire 1996 to 1997 validation
period. The monthly NSE’s were 0.77 for flow, 0.85 for TSS and 0.90 for phosphorus. Similar results
were obtained for the 17 events that were selected for analysis, although relative differences between
observed and simulated TSS and TP loads were smaller. NSE and r-squared statistics were above the
minimum criterion of 0.6 that was stated in the QAPP. Relative differences were below the maximum

118

 level of 30% that was stated in the QAPP. These statistics indicate that there was an acceptable level of
correspondence between simulated and observed events for the Bower Creek station.
As previously stated, the model was also applied to the five LFRWMP watersheds for the model
assessment phase. Only data from USGS water years 2004 and 2005 were utilized in the initial
assessment phase for these watersheds. This approach was used because Baumgart (Cadmus, 2007)
found in a previous assessment that SWAT inputs for two of the watersheds needed to be adjusted to
provide a more acceptable fit between observed and simulated loads. In general, the un-adjusted LFR
sub-basin model was able to estimate flow, TSS loads and TP loads at the LFRWMP monitored sites
with a reasonable degree of accuracy on a monthly and annual basis during the 2004 and 2005 USGS
water year monitoring period. As summarized in Table 19, R-squared and NSE monthly flow statistics
ranged from 0.84 to 0.94. R-squared and NSE statistics ranged from 0.67 to 0.88 for monthly TSS loads,
and from 0.66 to 0.84 for monthly TP loads. All of these statistics are better than the minimum criterion
of 0.60, which is stated in the QAPP.
Relative differences between observed and simulated flows over the 2004 to 2005 period ranged from 11.1% at Duck Creek to +22.2% at Ashwaubenon Creek. Relative differences for the total TSS load over
the 2004 to 2005 period ranged from -26.8% at Apple Creek to +21.7% at East River. Relative
differences for the TP load over the 2004 to 2005 period ranged from –12.9% at Ashwaubenon Creek to
+13.2% at Duck Creek. Therefore, the relative differences between observed and simulated loads during
the 2004 to 2005 initial assessment period were better than the 30% maximum criterion stated in the
QAPP. In general, the un-adjusted LFR sub-basin model was able to estimate flow, TSS loads and TP
loads at the LFRWMP monitored sites with a reasonable degree of accuracy on a monthly and total basis
during the 2004 and 2005 USGS water year monitoring period. The model was therefore judged to be
valid, and could be applied to reliably predict flow and loads of TSS and phosphorus from the LFR
watersheds without further adjustments.
Table 19. Simulated and observed monthly flow, TSS, and TP statistics for WY 2004-2005
Simulated results based on un-adjusted LFR calibration parameters. Relative differences are for
the entire period
Stream

Flow
R

2

TSS

NSE

% diff

R

2

Phosphorus

NSE

% diff

R

2

NSE

% diff

Apple

0.86

0.86

6.6%

0.88

0.74

-26.8%

0.82

0.82

-5.6%

Ashwaubenon

0.89

0.84

22.2%

0.69

0.67

-12.8%

0.82

0.81

-12.9%

Baird

0.87

0.86

12.3%

0.73

0.69

-12.4%

0.74

0.68

-7.4%

Duck

0.89

0.87

-11.1%

0.76

0.75

1.7%

0.67

0.66

13.2%

East River

0.94

0.94

-5.0%

0.72

0.70

21.7%

0.84

0.83

2.6%

119

 Model Adjustments
Adjustments were made to the model because of the tendency for the model to overstate TSS loads
from the East River, and to a lesser degree, TP loads from Duck Creek, particularly during the previous
model assessment conducted by Baumgart (Cadmus, 2007). In the 2007 project, the monthly NSE was
0.59 for TSS in the East River watershed for the un-adjusted model, which was just short of the
minimum QAPP criterion of 0.60. Importantly, the total simulated TSS loads at the East River site
exceeded the observed loads by 45.6%. 19 This discrepancy compares to the 21.7% excess in simulated
TSS loads for the current project. The improvement is likely due to: 1) areas identified as barren land
use, now being simulated as quarries in the TMDL rather than barren lots; and 2) the addition of other
urban land use HRUs instead of just one, so low density rural residential lots now have lower TSS loads
than when there was just a single urban HRU.
To reduce TSS and improve model performance the stream power concentration parameter (SPCON)
was decreased from 0.0008 (800 mg/L) to 0.0005 (500 mg/L) for the East River watershed, which was
also done by Baumgart in the 2007 LFR model. Prior to calibration and the initial assessment phase,
SPCON had been set at 0.0003 in the Duck Creek watershed and 0.0008 for all other major watershed
modeling units. This change reduced the TSS load, but did not affect phosphorus, because the latter is
only affected by the QUAL2E water quality sub-model and not the sediment transport sub-model.
Lowering the SPCON effectively decreases the amount of sediment that can be re-entrained for a given
flow and transported downstream.
Although the simulated phosphorus loads for the Duck Creek monitoring station were acceptable with
the un-adjusted model (+25.5% in 2007, and +13.2% in current project), a slight modification was made
to improve the fit of the model. As previously done by Baumgart in the 2007 LFR model, the
phosphorus sorption coefficient (PSP) was changed from 0.39 to 0.44, and the phosphorus soil
partitioning coefficient (PHOSKD) was changed from 185 to 235 for the Duck Creek watershed dataset.
This change effectively decreased the simulated TP load from all of the sub-watersheds in the Duck
Creek watershed, while maintaining a similar proportion of dissolved phosphorus. The soils within the
Duck Creek watershed generally have lower clay content than those in the rest of the LFR sub-basin, and
are more likely to be classified as hydrologic group B soils compared to group C soils that overly most of
the rest of the LFR sub-basin. Therefore, it is not unreasonable to assume that some changes might be
needed to account for this difference. These values were not changed for the other watersheds.
No effort was made to alter the Apple Creek inputs, because much of the difference between the
observed and simulated TSS load was due to a single event in late November of 2004. Removing the
daily TSS loads from this event changed the relative difference from -27% to -11%. This event was
unusual in a number of ways. The scale of this event may have been influenced by sediment that likely
accumulated just upstream of the monitoring site during very large events that occurred in late summer
of 2004 (prior to the monitored period). During the 2004 to 2006 monitored record, this stretch of
The precise reason for the discrepancy between observed and simulated 2004 to 2005 TSS loads at the East River site
was not entirely clear in the 2007 modeling project. However, it may be due to the difficulty in simulating the load at
the mouth of the East River, which is essentially part of the lowest portion of the Fox River, which is greatly affected
by water levels and currents from Lower Green Bay, including the seiche induced flow reversals. Major flow reversals
are common at the river outlet. The model may not be adequately simulating the effects of riparian wetlands, the
Niagara escarpment, or other aspects of this watershed on TSS, particularly during a relatively dry year such as 2005.
There may also be difficulties in obtaining representative samples at this station with just the single sampler inlet. There
have only been a limited number of simultaneous pump samples and Equal-Width-Increment (EWI) samples collected
at this monitoring station during major runoff events, which may not be enough to ensure that the pump samples are
truly representative, or can be accurately adjusted with a correction factor.

19

120

 stream area was observed by the LFRWMP to be prone to ice and log jams, and associated large
sediment deposits. Eventually, the next large runoff event would flush much of the debris and sediment
out where it was picked up by the sampling equipment.

Model Validation Results After Adjustments to East River and Duck Creek Parameters
In general, the LFR sub-basin model was able to estimate flow, TSS loads and TP loads at the LFRWMP
monitored sites with a reasonable degree of accuracy on a monthly and total basis during the 2004 to
2008 monitoring record. The QAPP noted that it may not be possible to obtain percent bias values less
than 40% or r-squared and NSE statistics much greater than 0.45 at one or two streams for some
parameters, but the model may still be deemed valid as long as such excursions from our targets are
limited in scope. The aforementioned slight excursion occurred only for TSS at Duck Creek. This
excursion from the QAPP goal of 30% or less was slight, and possible explanations for lower than
expected observed TSS and TP concentrations in 2008 at Duck Creek are discussed further in Cibulka
(2009). The model is therefore judged to be valid, and can be applied to reliably predict flow and loads of
TSS and phosphorus from the LFR watersheds without further adjustments.
The relative differences between simulated and observed event loads improved with the revised model.
For the 2004 to 2005 model assessment period, the total relative difference between observed and
simulated TSS loads improved from +21.7% to -4.0% at the East River site, while the monthly NSE
statistic increased slightly from 0.70 to 0.71. The total relative difference between observed and
simulated TSS loads improved from +13.2% to -4.0% at the Duck Creek site, while the monthly NSE
statistic remained unchanged.
Final model assessment results for the entire 2004 to 2008 monitoring period are summarized in Table
20 and Table 21. R-squared and NSE monthly flow statistics ranged from 0.80 to 0.91. R-squared and
NSE statistics ranged from 0.65 to 0.81 for monthly TSS loads, and from 0.68 to 0.82 for monthly TP
loads. All of these statistics are better than the minimum criterion of 0.60, as stated in the QAPP.
Relative differences between observed and simulated flows over the 2004 to 2008 period ranged from 7.9% at Duck Creek to +26.7% at Ashwaubenon Creek. Relative differences for the TSS load over the
2004 to 2008 period ranged from -16.2% at Apple Creek to +30.3% at Duck Creek. Relative differences
for the TP load over the 2004 to 2008 period ranged from –5.6% at Ashwaubenon Creek to +17.4% at
Duck Creek. With the exception of the Duck Creek TSS loads, the relative differences between observed
and simulated loads during the 2004 to 2008 final assessment period were better than the 30% maximum
criterion stated in the QAPP.
The difference between the observed and simulated TSS loads from Duck Creek was 1.0% over the 2004
to 2005 period, 13.4% over the 2004 to 2006 period, 17.3% over the 2004 to 2007 period, and 30.3%
over the 2004 to 2008 period. Therefore, the model seems to be overstating TSS loads from Duck Creek
primarily during the more recent years, particularly in 2008. Perhaps not coincidently, Cibulka (2009)
found that a regression model that was used to predict TP loads as a function of flow, seasonality and
time, had distinctly different coefficients and probabilities when data from 2008 were added. The 2008
spring snowmelt was rather unusual from two perspectives: 1) It was the third highest snow fall on
record with associated high snow pack; and 2) Essentially no rain fall occurred during the main snow
melt runoff event in the spring. Therefore, there was a large amount of runoff generated from the snow
melt, but relatively low sediment because there was no rain drop impact energy adding to upland
sediment erosion, or accelerating the runoff to create large rills or gullies. Another possible explanation
for the model overstating TSS loads is that BMPs that have been implemented in recent years may be
reducing the TSS load, and the model is not fully accounting for this effect. However, the regression
model developed by Cibulka (2009) shows such a large drop off in both TP and TSS in 2008 that it
121

 seems unlikely that BMPs could have such a sudden impact on the water quality of a stream with a
relatively large catchment area of 276 km2. The discrepancy between the observed and simulated TSS
loads deserves further attention.
The adjusted validated model was then applied to simulate flow, TSS and TP from the entire LFR subbasin under baseline conditions and alternative scenarios.
Table 20. Simulated and observed monthly flow, TSS, and TP statistics for WY 2004-2008
Simulated results based on adjusted LFR calibration parameters for Duck Creek and East
River*. Relative differences are for the entire period
Stream
Apple
Ashwaubenon
Baird
*
Duck
*
East River

Flow
NSE
0.83
0.83
0.80
0.87
0.91

2

R
0.85
0.89
0.81
0.89
0.91

2

% diff
14.1%
26.7%
19.0%
-7.9%
-6.5%

R
0.81
0.66
0.66
0.73
0.66

TSS
NSE
0.72
0.66
0.66
0.72
0.65

% diff
-16.2%
2.1%
9.0%
30.3%
4.8%

2

R
0.78
0.82
0.71
0.69
0.79

Phosphorus
NSE
0.78
0.82
0.69
0.68
0.78

% diff
4.2%
-5.6%
8.5%
17.4%
13.5%

Table 21. Annual observed and simulated stream flow, TSS, and TP yields (2004-2008)
Stream

2004
Obs.

2005

SWAT

Obs.

2006

SWAT

Obs.

2007

SWAT

2008

Obs.

SWAT

Obs.

SWAT

Flow (mm)
Apple

322

349

144

148

121

173

Ashwaubenon

276

349

114

127

102

147

Baird

364

399

114

137

173

220

119

149

259

317

Duck

344

333

140

97

116

119

75

68

241

226

East River

339

335

173

151

209

200

156

133

Total Suspended Solids (metric tons/ha)
Apple

0.93

0.59

0.12

0.18

0.16

0.25

Ashwaubenon

0.70

0.59

0.20

0.20

0.07

0.20

Baird

0.73

0.59

0.10

0.13

0.18

0.27

0.12

0.18

0.23

0.31

Duck

0.36

0.36

0.11

0.11

0.03

0.09

0.04

0.06

0.11

0.21

East River

0.49

0.40

0.06

0.14

0.13

0.20

0.14

0.13

Total Phosphorus (kg/ha)
Apple

1.89

1.74

0.59

0.60

0.51

0.77

Ashwaubenon

2.02

1.79

0.82

0.68

0.53

0.71

Baird

2.34

2.03

0.53

0.63

0.73

1.01

0.51

0.72

1.16

1.32

Duck

1.29

1.32

0.57

0.47

0.35

0.46

0.19

0.30

0.54

0.90

East River

1.63

1.58

0.46

0.67

0.68

0.89

0.53

0.62

122

 APPENDIX C. TMDL DEVELOPMENT AND LOAD ALLOCATION METHODOLOGY
Calculating TMDLs for Total Phosphorus
Sixty-nine subwatersheds were delineated for the purpose of tracking and routing loads in the LFR
Basin. Using an Excel-based TMDL tracking tool, each of the 69 subwatersheds was identified as either a
tributary or a main stem segment; a few segments discharge directly to the bay and were identified as
such. Loads entering the basin from Lake Winnebago were also tracked as an input to the LFR Basin.
The goal of the TMDL analysis for TP is to reduce total average annual TP loads, such that both of the
following are achieved:
•

Summer median TP concentration of 0.075 mg/L (75 µg/L) for tributary streams in the basin.

•

Summer median TP concentration of 0.10 mg/L (100 µg/L) for the main stem of the river.

Figure 24 provides a flow chart that illustrates the steps involved in calculating the TMDLs for TP. As a
first step, the baseline TP concentration for each subwatershed was calculated using each subwatershed’s
estimated loading and flow. Next, the estimated baseline TP concentration was compared against the
appropriate numeric target (i.e., 0.075 mg/L for tributary segments and 0.10 mg/L for the main stem
segments). The numeric targets are defined as summer (May through October) medians. However,
estimated baseline TP concentrations for each subwatershed are defined as average annual volume
weighted concentration (VWC), which is calculated as follows:
𝑎𝑣𝑒𝑟𝑎𝑔𝑒 𝑎𝑛𝑛𝑢𝑎𝑙 𝑉𝑊𝐶 =

𝑎𝑣𝑒𝑟𝑎𝑔𝑒 𝑎𝑛𝑛𝑢𝑎𝑙 𝑙𝑜𝑎𝑑
𝑎𝑣𝑒𝑟𝑎𝑔𝑒 𝑎𝑛𝑛𝑢𝑎𝑙 𝑣𝑜𝑙𝑢𝑚𝑒 𝑜𝑓 𝑤𝑎𝑡𝑒𝑟

Due to the difference in timeframes of the estimated baseline concentrations (i.e., annual VWC) and the
target concentration (i.e., summer median), the annual VWC was converted into a summer median
concentration, which could then be directly compared to the summer median targets. This conversion
was accomplished by multiplying each subwatershed’s estimated baseline annual VWC by an adjustment
factor of 0.56. This adjustment factor was calculated using observed data from the LFRWMP sampling
stations for Apple Creek, Ashwaubenon Creek, Baird Creek, Duck River, and East River (see Section
2.3). The adjustment factor was calculated as follows (see Table 22 for the data and calculation results):
1. Adjustment factors were calculated for each of the five monitoring stations by dividing the
estimated baseline annual VWC by the observed summer median concentrations for each station
(this was done for both monthly and weekly calculations 20). For example:
Apple Creek’s monthly adjustment factor: 0.22 / 0.37 = 1.73
Apple Creek’s weekly adjustment factor: 0.24 / 0.37 = 1.57
2. An average was calculated for all of the monthly and weekly values:
(1.73+1.29+2.88+2.18+1.33+1.57+0.99+1.92+2.18+1.66) / 10 = 1.78
20

Ideally, there should be little difference between the observed medians, regardless of whether the observed datasets
were sub-sampled on a monthly or weekly basis. The LFRWMP was focused primarily on calculating loads as
accurately as possible. Therefore, storm events were favored when sampling. It is difficult to remove all sampling bias
by simply sub-sampling the dataset on a monthly, biweekly, weekly, or other basis. Since there is no way to determine
which sub-sampling period is best to use, averaging the weekly and monthly summer medians is a compromise.

123

 3. The final adjustment factor was then calculated by taking the inverse of this average value:
1 / 1.78 = 0.56
Table 22. Data used to calculate the TP adjustment factor
Observed Summer Median (mg/L)
Monthly

Weekly

Baseline Annual
VWC (mg/L)

Apple

0.22

0.24

Ashwaubenon

0.33

Baird

Adjustment Factors
Monthly

Weekly

0.37

1.73

1.57

0.43

0.43

1.29

0.99

0.14

0.20

0.39

2.88

1.95

Duck

0.16

0.16

0.35

2.18

2.18

East River

0.30

0.24

0.40

1.33

1.66

Adjustment factor for tributary and main stem subwatersheds:

0.56

Each subwatershed’s estimated baseline annual VWC was converted to a summer median concentration
by multiplying the estimated baseline annual VWC by the 0.56 adjustment factor. This estimated baseline
summer median concentration was then compared against the appropriate numeric target (i.e., 0.075
mg/L for tributary segments and 0.10 mg/L for the main stem segments). If a subwatershed’s baseline
summer median concentration exceeded the target, that subwatershed’s average annual load was reduced
by the amount necessary to meet the target concentration. Once this was completed for all of the
subwatersheds, the allocated loads were then aggregated for each of the sub-basins. As an extra check,
the annual VWC associated with the total allocated load for each sub-basin was converted to a summer
median concentration and compared against the appropriate target to confirm that the target was being
met at the sub-basin scale, as well as the subwatershed scale.
Final allocated loads for each of the tributaries were routed to the outlet of the sub-basin. An additional
loss of load at the confluence of the sub-basins with the main stem occurs during this step. In other
words, the TMDLs for the tributaries result in a summer median TP concentration of 0.072 mg/L at the
point of confluence with the main stem (note that the main stem’s target is 0.1 mg/L).
Estimated baseline average annual loads (for the years 1989-2006) entering the LFR Basin at the outlet of
Lake Winnebago were derived from a regression equation developed by Dale Robertson of the U.S.
Geological Survey (unpublished data produced for the Lower Fox River TMDL project by Dale
Robertson of the USGS in 2008; methods provided in Robertson and Saad, 1996 and Robertson, 1996).
Figure 25 provides a summary of these average annual loads; the average of all years was used in the
TMDL analysis. It should also be noted that the summer median TP concentration of inflow from Lake
Winnebago is 0.093 mg/L. The estimated baseline average annual load from Lake Winnebago was also
routed to the main stem and Lower Green Bay.

124

  

Estimated baseline
loads and flow from
SWAT and 

 

 

 

Reduce subwatershed?s annual load
by the amount needed to meet the
applicable targets



 

 

 

 

 

Calculate baseline annual VWC for
each of the 69 subwatersheds using
estimated baseline loads and flows

 

 

 



 

 

Convert each subwatershed?s
baseline annual VWC to summer
median concentration using
adjustment factor

 

 

    
   

  

  

Does baseline
summer median concentration
eet applicable targets?

 

 

 

 

  

 
   

.
sti'mated Reduce Lake
baseline loads .
Winnebago
from Lake loadin
Winnebago 

 

 

Route all tributary su bwatersheds?

allocated loads to sub-basin outlet

confluence with main stem or
Lower Green Bay}

 

 

No load reduction needed -
subwatershed's allocation set equal
to baseline load

 

 

 

 

 

 



 

 

 

 

 

Route all loads to the outlet to
Lower Green Bay

 

 



 

Calculate annual VWC of this
combined load to the outlet
of Lower Green Bay

 

 



 

 

Convert annual VWC of combined
load to summer median
concentration using adjustment
factor

 

 

       
   
 

  

Does summer median
concentration of the combined
load meet target?

N0

lr

 

Increase reduction goal

 

for loads originating from
Lake Winnebago

 

 

 

 
  
   

  

TM DL allocation
process complete

Figure 24. Flow chart illustrating the steps involved in calculating the for TP

125

 

1,600,000
1,400,000
1,200,000

Average

1,000,000
TP
(lbs/yr)

800,000
600,000
400,000
200,000
0

Figure 25. Average annual phosphorus loads entering the Lower Fox River Basin at the outlet of
Lake Winnebago.
(unpublished data produced for the Lower Fox River TMDL project by Dale Robertson of the
USGS in 2008; methods provided in Robertson and Saad, 1996 and Robertson, 1996)
The estimated baseline average annual load from Lake Winnebago and each tributary sub-basins’
allocated load were added to the allocated loads for the main stem subwatersheds, and routed through
the main stem and to the bay. The concentration of this “combined” load in the main stem and as routed
to the bay was evaluated for compliance against the target for the main stem and outlet to the bay (0.1
mg/L). However, due to the difference in timeframes of this concentration (i.e., annual VWC) and the
target concentration (i.e., summer median), the annual VWC for the “combined” load in the main stem
and as routed to the bay was converted into a summer median concentration, which could then be
directly compared to the summer median target. This conversion was accomplished by multiplying the
estimated annual VWC for the main stem and as routed to the bay by an adjustment factor of 1.48. This
adjustment factor was calculated by dividing the estimated baseline annual VWC for the outlet of the
Lower Fox River (0.122 mg/L) with the observed summer median baseline concentration at GBMSD
Fox River monitoring stations 7, 13 and 16 (0.1805 mg/L), and taking the inverse.
Upon evaluating the combined load against the target for the main stem and outlet to the bay, it was
determined that the load allocations for the tributaries and main stem alone were not sufficient to meet
the 0.1 mg/L target for the main stem and outlet to the bay. The additional needed reductions were
taken from loads originating from Lake Winnebago. A 40% reduction goal has been established for
phosphorus loads originating from Lake Winnebago. This reduction goal for loads entering the LFR
Basin from the outlet of Lake Winnebago represents reasonable expectations for load reductions that
may be achievable in the Upper Fox and Wolf Basins. This reduction goal may need to be adjusted if the
TMDL analysis for the Upper Fox and Wolf Basins reveals that it is not feasible.

126

 Load Allocation Process for Total Phosphorus
1. Loads from natural/background sources cannot be controlled, therefore, the LA for these sources is
set equal to its baseline load for each sub-basin.
2. The LA for non‐regulated urban areas is set equal to its baseline loads for each sub-basin.
3. The WLA for general permit holders is set equal to baseline loads. General permit holders are
considered in compliance with the WLA if they are in compliance with their permit requirements.
4. The WLA for construction sites is set equal to baseline loads. Construction sites are considered in
compliance with the WLA if they are in compliance with their stormwater permit requirements.
5. Loads from municipal and industrial wastewater treatment facilities discharging to tributary streams:
•

If a facility’s baseline average annual effluent concentration is less than 1.0 mg/L, the facility’s
WLA is set equal to its average annual baseline load.

•

If a facility’s baseline average annual effluent concentration is greater than 1.0 mg/L, and
o The facility’s baseline average annual load accounts for less than 1% of the total baseline
load for the sub-basin, the facility’s WLA is set equal to its average annual baseline load.
o The facility’s baseline average annual load accounts for greater than 1% of the total baseline
load for the sub-basin, the facility’s WLA is set to meet a 1 mg/L average annual effluent
concentration.

6. Loads from municipal and industrial wastewater treatment facilities discharging to the main stem:
•

If a facility’s baseline average annual effluent concentration is less than 0.2 mg/L, the facility’s
WLA is set equal to its average annual baseline load.

•

If a facility’s baseline average annual effluent concentration is greater than 0.2 mg/L, and
o The facility’s baseline average annual load accounts for less than 1% of the total baseline
load for the sub-basin, the facility’s WLA is set equal to its average annual baseline load.
o The facility’s baseline average annual load accounts for greater than 1% of the total baseline
load for the sub-basin, the facility’s WLA is set to meet a 0.2 mg/L average annual effluent
concentration.

7. Loads from regulated urban MS4s:

21

•

If the load from regulated urban MS4s accounts for less than 30% of the total baseline load for
the sub-basin, the WLA for MS4s is set equal to 70% of their baseline load. This results in a
reduction goal of 30% from the MS4s’ baseline load. 21

•

If the load from regulated urban MS4s accounts for greater than 30% of the total baseline load
for the sub-basin, the WLA for MS4s is set equal to the load that results in a percent reduction
equal to the MS4s’ percent contribution to the controllable baseline load for the sub-basin.

30% is the average approximate reduction in TP that is expected if MS4s achieve a 40% TSS reduction.

127

 •

Agricultural areas are assigned a LA equal to the load that results in achievement of the
remaining reductions needed to meet the TMDL after loads have been allocated to all other
sources.

Calculating TMDLs for Total Suspended Solids
Sixty-nine subwatersheds were delineated for the purpose of tracking and routing loads in the LFR
Basin. Using an Excel-based TMDL tracking tool, each of the 69 subwatersheds was identified as either a
tributary or a main stem segment; a few segments discharge directly to the bay and were identified as
such. Loads entering the basin from Lake Winnebago were also tracked as an input to the LFR Basin.
Internal production represents the growth of biotic solids (e.g., plankton) in the water column of the
LFR main stem in response to temperature, light, and nutrients. Internal biotic solids are an important
component of the overall solids balance of the Lower Fox River. Therefore, internal biotic solids were
also calculated using data from past studies (WDNR, 2001b; LTI, 1999) and tracked as a component of
the loads generated within the LFR main stem segment.
The goal of the TMDL analysis for TSS is to reduce total average annual TSS loads by the amount
necessary to meet a summer median TSS concentration of 20 mg/L at the outlet to Lower Green Bay,
plus a margin of safety of 10%. The 10% margin of safety (to account for uncertainty in meeting the load
reduction goal for biotic solids) is implicitly incorporated in the analysis through use of an 18 mg/L
summer median TMDL target for the outlet to the bay, which is calculated as follows:
20 𝑚𝑔⁄𝐿 × 10% = 2 𝑚𝑔/𝐿

20 𝑚𝑔⁄𝐿 − 2 𝑚𝑔⁄𝐿 = 18 𝑚𝑔/𝐿

Figure 26 provides a flow chart that illustrates the steps involved in calculating the TMDLs for TSS.
Similar to TP (see above), estimated baseline TSS concentrations are average annual VWCs. Due to the
difference in timeframes of the estimated baseline concentrations (i.e., annual VWC) and the target
concentration (i.e., summer median), the annual VWC was converted into a summer median
concentration, which could then be directly compared to the summer median target. This conversion
was accomplished by multiplying the estimated baseline annual VWC for the outlet to the bay by an
adjustment factor of 1.38. This adjustment factor was calculated by dividing the simulated baseline
annual VWC for the outlet of the Lower Fox River (26.24 mg/L) with the observed summer median
baseline concentration at GBMSD Fox River monitoring stations 7, 13 and 16 (36.25 mg/L), and taking
the inverse.
Estimated baseline average annual loads (for the years 1989-2006) entering the LFR Basin at the outlet of
Lake Winnebago were derived from a regression equation developed by Dale Robertson of the U.S.
Geological Survey (unpublished data produced for the Lower Fox River TMDL project by Dale
Robertson of the USGS in 2008; methods provided in Robertson and Saad, 1996 and Robertson, 1996).
Figure 27 provides a summary of these average annual loads; the average of all years was used in the
TMDL analysis. The reduction goal for TSS loads leaving Lake Winnebago was set at 48.3%.22 This is
the estimated TSS load reduction expected at the outlet of Lake Winnebago if the TP load reduction goal
for the outlet of Lake Winnebago is met. This TSS load reduction goal is calculated based on the linear
relationship between annual TP and annual TSS loads from Winnebago, as shown in Figure 28. This
reduction goal for loads entering the LFR Basin from the outlet of Lake Winnebago represents
This does not represent the load reduction goal for the Upper Fox-Wolf River Basin. The load reduction goal needed
from the upper basin (and into Lake Winnebago) will be determined as part of a separate TMDL analysis.
22

128

 reasonable expectations for load reductions that may be achievable in the Upper Fox and Wolf Basins.
This reduction goal may need to be adjusted if the TMDL analysis for the Upper Fox and Wolf Basins
reveals that it is not feasible.

Figure 26. Flow chart illustrating the steps involved in calculating the TMDLs for TSS

129

 350,000,000
300,000,000
250,000,000
Average
TSS
(lbs/yr)

200,000,000
150,000,000
100,000,000
50,000,000
0
1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Figure 27. Average annual TSS loads entering the Lower Fox River Basin at the outlet of Lake
Winnebago.
(unpublished data produced for the Lower Fox River TMDL project by Dale Robertson of the
USGS in 2008; methods provided in Robertson and Saad, 1996and Robertson, 1996)

350,000,000
300,000,000

y = 212.17x - 3E+07
R² = 0.862

250,000,000
TSS
(lbs/yr)

200,000,000
150,000,000
100,000,000
50,000,000
0
0

250,000

500,000

750,000

1,000,000

1,250,000

1,500,000

TP (lbs/yr)

Figure 28. TSS vs. TP Loads from Lake Winnebago
130

 The 56.8% reduction goal for biotic solids represents the estimated load reduction expected as a result of
meeting the 0.1 mg/L TP target at the outlet to Green Bay, and was calculated using data summarized in
Reynolds (1986) and Nalewajko (1966).
After accounting for the load reduction goal for Lake Winnebago and the estimated biotic solids load
reduction expected as a result of meeting the 0.1 mg/L TP target at the outlet to Lower Green Bay, the
TMDL for in-basin loads was calculated based on the additional reduction needed to meet the target at
the outlet to the bay (i.e., 18 mg/L). This was accomplished by reducing sub-basin loads until the target
was met at the outlet to the bay. Two methods were examined for setting the load reduction goals for
the sub-basins: 1) Equal percent load reduction; and 2) Equal VWC (the final method used for
determining the allocations for TSS).
The equal percent load reduction method assigns all of the sub-basins with the same percent reduction
from their baseline load. The percent reduction is set based on the load reduction needed to meet the
target at the outlet to the bay. Each sub-basin’s percentage of the total reduced load is equal to its
percent contribution to the total baseline load. As a result, sub-basins discharging greater loads to the bay
will require greater reductions. This approach was not used for the final analysis because it penalizes subbasins that discharge lower TSS concentrations (e.g., Duck Creek).
The equal VWC method was the final method selected for the TMDL analysis. The equal VWC method
assigns each of the sub-basins a load reduction goal based on what is needed to meet an equal VWC at
the outlet of each sub-basin. An annual VWC of 65.9 mg/L was used in the analysis; this represents the
annual VWC for the outlet of each subwatershed that will result in attainment of the target for the outlet
to the bay (i.e., 18 mg/L). The equal VWC method results in a different load reduction goal for each
sub-basin; therefore, it does not penalize those sub-basins that are already discharging lower TSS
concentrations (e.g., Duck Creek).

131

 Load Allocation Process for Total Suspended Solids
1. Loads from natural/background sources cannot be controlled, therefore, the LA for these sources is
set equal to its baseline load for each sub-basin.
2. The LA for non‐regulated urban areas is set equal to its baseline load for each sub-basin.
3. The WLA for general permit holders is set equal to baseline loads. General permit holders are
considered in compliance with the WLA if they are in compliance with permit requirements.
4. Loads from construction sites are assigned a WLA set equal to 20% of their baseline load. This
results in a reduction goal of 80% from their baseline loads, which is consistent with stormwater
permit requirements.
5. Municipal and industrial wastewater treatment facilities are assigned WLAs set equal to their average
annual baseline load.
6. Loads from regulated urban MS4s:
•

If the load from regulated urban MS4s accounts for less than 40% of the total baseline load for
the sub-basin, the WLA for MS4s is set equal to 60% of their baseline load. This results in a
reduction goal of 40% from the MS4s’ baseline load. 23

•

If the load from regulated urban MS4s accounts for greater than 40% of the total baseline load
for the sub-basin, the WLA for MS4s is set equal to the load that results in a percent reduction
equal to the MS4s’ percent contribution to the controllable baseline load for the tributary basin.

7. Agricultural areas are assigned a LA equal to the load that results in achievement of the remaining
reductions needed to meet the TMDL after loads have been allocated to all other sources.

23

40% is the TSS reduction required by NR 151 stormwater regulations.

132

 APPENDIX D. SUMMARY OF MS4 WASTELOAD ALLOCATIONS
Total Phosphorus
MS4
Allouez
Appleton
State
Oneida Reservation
Ashwaubenon
State
Oneida Reservation
Bellevue
Buchanan
CombLocks
DePere
State
Oneida Reservation
GrandChute
Green Bay
State
Oneida Reservation
Greenville
Harrison
Hobart
State
Oneida Reservation
Howard
State
Oneida Reservation
Kaukauna
Kimberly
Lawrence
State
Oneida Reservation
Ledgeview
LittleChute
Menasha
Neenah
Scott
Suamico
State
Oneida Reservation
T_Menasha
T_Neenah
UWGB
TOTAL

East
771

Baird

Bower

Apple

Ashwaubenon

Dutchman

Plum

Kankapot

1,132
1,132
0

115
115
0
388
388
0

753

3

Garners

442
442
0

1,829
1,479
350

Duck

Trout

Neenah

1
1
0
211
211
0

516
516
0

109
4

404
137

34
152
1,455
1,455
0
760
3,246
3,246
0
517
7

649
649
0
400
1,634
1,634
0

1,863

20
20
0

367
69
298

1,235
332
903
176
321

119
0
119

652
0
652

394
41
41
0
533

LFR (main stem)
405
3,667
3,667
0
306
306
0

921
0
921
1,963
1,953
10
32

748
748
0

918

523
0
523
8
8
0

46
21

135
135
0

594
513
1,485

2
2
0
517
581
380
380
0
106
682
1,147
176

32

1,637

1,695

2,479

1,903

2,983

53

1,031

1,045

2,513

4,687

629
629
0

29
29
0

295
641
641
0

356
356
0

4,058

LGB

1,081
21

1,485
1,485
0

Mud

531

392

2,214
136

1,877

16,490

195
1,788

TOTAL
1,176
5,358
5,358
0
2,734
2,384
350
1,837
569
293
2,620
2,620
0
3,022
8,616
7,414
1,201
692
328
2,216
0
2,216
2,001
1,991
10
1,908
602
1,303
1,303
0
1,232
1,194
1,147
1,661
295
996
996
0
2,246
528
195
44,770

133

 Total Suspended Solids
MS4
Allouez
Appleton
State
Oneida Reservation
Ashwaubenon
State
Oneida Reservation
Bellevue
Buchanan
CombLocks
DePere
State
Oneida Reservation
GrandChute
Green Bay
State
Oneida Reservation
Greenville
Harrison
Hobart
State
Oneida Reservation
Howard
State
Oneida Reservation
Kaukauna
Kimberly
Lawrence
State
Oneida Reservation
Ledgeview
LittleChute
Menasha
Neenah
Scott
Suamico
State
Oneida Reservation
T_Menasha
T_Neenah
UWGB
TOTAL

East
266,978

Baird

Bower

Apple

Ashwaubenon Dutchman

Plum

Kankapot Garners

381,481
381,481
0

73,698
73,698
0
149,501
149,501
0

307,059

1,579

268,047
268,047
0

713,144
576,630
136,514

Duck

Trout

Neenah

274
274
0
74,182
74,182
0

164,228
164,228
0

40,876 242,762
1,412 83,756

9,953
43,094
383,797
383,797
0
182,637
1,073,228
1,073,228
0
130,029
2,466

197,827
197,827
0
120,013
631,411
631,411
0

1,011,480

5,829
5,829
0

120,154
22,369
97,785

422,330
113,402
308,928
91,315
186,222

22,955
0
22,955

209,829
0
209,829

142,665
12,785
12,785
0
163,523

LFR (main stem)
99,405
1,054,593
1,054,593
0
104,132
104,132
0

218,360
0
218,360
702,063
698,560
3,503
9,072

189,134
189,134
0

399,600

87,586
0
87,586
1,472
1,472
0

27,167
12,701

43,322
43,322
0

169,251
190,022
782,075

773
773
0
142,959
186,376
69,211
69,211
0
23,308
187,574
368,996
55,543

18,277

632,990

497,036

846,966

559,418

1,086,449

14,597

441,888 626,306

1,389,118

1,524,349

198,351
198,351
0

10,082
10,082
0

85,724
190,877
190,877
0

107,140
107,140
0

1,573,271

LGB

321,956
5,525

671,482
671,482
0

Mud

163,490

606,709
40,404

89,058 945,565

4,765,187

75,193
560,227

TOTAL
366,383
1,778,092
1,778,092
0
1,040,960
904,446
136,514
630,594
299,116
128,262
745,853
745,853
0
1,314,130
3,122,785
2,716,073
406,713
221,344
188,688
538,730
0
538,730
714,390
710,887
3,503
721,463
199,077
314,452
314,452
0
356,082
377,596
368,996
837,618
85,724
298,017
298,017
0
624,986
203,894
75,193
15,552,425

134

 APPENDIX E. MAPS OF TP AND TSS YIELD FOR THE FOX-WOLF BASINS

Figure 29. Summary of TP yields of total loads as routed to Lower Green Bay from the Fox-Wolf
Basin
135

 Figure 30. Summary of TSS yields of total loads (including biotic solids) as routed to Lower
Green Bay from the Fox-Wolf Basin

136

 APPENDIX F. POTENTIALLY RESTORABLE WETLANDS ANALYSIS
Wetlands provide a number of ecosystem services including water quality improvement, wildlife habitat,
and flood control. As water flows over and through the landscape, it carries soluble and particulate
materials with it. When this water enters a wetland, the reduction in velocity allows sediment and other
pollutants to “settle out.” Wetland vegetation can also remove a significant amount of pollutants from
the water column, especially nutrients such as phosphorus. As a result of their water quality
improvement functions, wetlands are now seen as an important component of healthy watersheds. They
were not always viewed in this way, however. Between 1780 and 1980, an estimated 53% of the wetlands
in the conterminous United States were lost (Mitsch & Gosselink, 2007). Much of this loss was the result
of extensive agricultural development. Agricultural development is frequently associated with nonpoint
source (NPS) pollution, specifically nitrogen, phosphorus, and sediment. Thus restoration of previously
lost wetlands can be an attractive option for improving water quality in many NPS-impaired watersheds.
The Wetlands Reserve Program (WRP) and Conservation Reserve Program (CRP) are two federal
initiatives that provide landowner incentives for wetland restoration on agricultural lands.
The Lower Fox River (LFR) Basin typifies the kind of wetland loss that has occurred throughout the
nation. The original extent of wetlands in the LFR Basin was an estimated 50,900 acres (13% of the
Basin). Due to extensive agricultural and urban development, an estimated 42% (21,244 acres) of these
wetlands have been lost (Table 23). With 549,695 lbs/yr of phosphorus and 141,589,688 lbs/yr of
sediment being discharged from the Basin, restoration of these wetlands is an attractive option for
improving water quality, while also restoring the landscape to a condition more reminiscent of its natural
state. To facilitate watershed-scale planning of wetland restoration for the purposes of implementing the
LFR TMDL, a potentially restorable wetlands (PRW) analysis was conducted for the LFR Basin. The
methodology developed and applied by the Wisconsin Department of Natural Resources (WDNR) in
the Milwaukee, Mead Lake, and Rock River Basins served as the foundation for this analysis (Kline,
Bernthal, & Burzynski, 2006; Voss, 2007; Hatch & Bernthal, 2008).
A PRW can be defined as a lost wetland (based on the presence of hydric soils where wetlands no longer
exist) that has a current land use compatible with restoration (i.e.,
non-urban land uses). This definition is predicated on the
assumption that hydric soils indicate a site that is or was once under
Hydric Soils
saturated conditions (a wetland or water body) and that wetland
restoration is not feasible in urban areas. The analysis is conducted
WWI
using standard GIS techniques to overlay available spatial data layers
including land use, the Wisconsin Wetlands Inventory (WWI), and
Land Use
hydric soils (Figure 31). The land use layer was the same as that used
in the development of the TMDL. Any wetland restorations that
have already been documented through the WRP or the Wisconsin
PRWs
Wetlands Restoration Tracking Database (WRTD) were removed
from the PRW analysis. Additionally, lost wetland sites under 0.5
acres were considered economically infeasible for restoration and Figure 31. Illustration of GIS
overlay analysis
thus not considered PRWs.
The analysis identified 14,365 acres of PRWs in the LFR Basin (68% of the lost wetlands). Figure 32
displays all of the PRWs in the LFR Basin. While individual PRW sites cannot be easily discerned in a
map of this scale, the figure gives an overall impression of the distribution of PRWs throughout the
Basin. Table 23 details the acreage of original, lost, remaining, and potentially restorable wetlands for
each sub-basin.
137

  

 

 

    
  
 
 
   

Lower
Green Bay

 
  
   
 

 

 
 
 

       
 
     
 

Baird Creek
Duck Creek 0

$0
\k 
?deg ?a ower Creek
Q5
c39
v.5? 
East River
Apple Creek
Plum Creek
Garners
Lower Creek
Fox River Kankapot
Creek

Neenah

Slough

Legend
Sub-Basin Boundaries
Miles Potentially Restorable
0 4 8 12 16 Wetlands

 

 

Figure 32. Distribution of potentially restorable wetlands in the Lower Fox River Basin

138

Table 23. Summary of original, lost, remaining, and potentially restorable wetlands (acres) for
each sub-basin in the Lower Fox River Basin
Sub-Basins

Original

Lost

Remaining

PRWs

East River

4,479

2,052

2,427

1,558

Baird Creek

3,584

1,831

1,753

1,498

Bower Creek

2,221

1,541

680

1,193

Apple Creek

2,270

1,458

811

1,002

Ashwaubenon Creek

1,075

625

450

439

Dutchman Creek

2,168

949

1,219

561

667

389

277

352

Plum Creek
Kankapot Creek

1,993

704

1,289

619

Garners Creek

254

91

163

34

Mud Creek

753

394

359

103

Duck Creek

16,403

5,166

11,238

3,715

Trout Creek

2,753

838

1,915

662

Neenah Slough

1,734

998

735

696

Lower Fox (main stem)

3,974

2,163

1,811

494

Lower Green Bay

6,572

2,045

4,527

1,438

50,900

21,244

29,654

14,364

13% of Basin

42% of Original

58% of Original

68% of Lost

Total
Percent

An assessment of the relative water quality benefits that could be expected through restoration of PRWs
in the LFR Basin was performed to help target wetland restoration efforts in those subwatersheds where
they would have the greatest effect on phosphorus and sediment reductions. This assessment utilized
regression equations from the P8 model, which were developed for use in the Milwaukee River Basin
(Kline, Bernthal, & Burzynski, 2006). These equations estimate sediment and particulate phosphorus
reductions in wetlands via settling based on the ratio of subwatershed area to PRW area and the average
curve number for the subwatershed. In the P8 model, the ratio of subwatershed area to PRW area is
used along with an assumed mean wetland depth of 1.5 meters and daily water balance calculations to
estimate the hydraulic residence time for different Natural Resource Conservation Service (NRCS) curve
numbers. The hydraulic residence time is strongly associated with the amount of pollutant removal in
wetlands. The longer the residence time of the water in a wetland, the more sediment and particulate
phosphorus that will be expected to settle out. Due to the complexity of simulating nutrient uptake of
wetland vegetation and the fact that different PRWs likely have different types of wetland vegetation
present, reductions in soluble phosphorus were not simulated (about 39% of the phosphorus yield in the
LFR Basin is in soluble form). Thus the P8 model was used to estimate only the removal of sediment
and particulate phosphorus. The ratio of subwatershed to PRW area was the independent variable in the
regression equations that were developed for each curve number. These regression equations were
applied to the PRWs and subwatersheds in the LFR Basin. In addition to the reduction in pollutant loads
through wetland retention, restoration of a PRW in agricultural areas will also remove a source of
pollutants. Therefore, a direct conversion reduction of sediment and particulate phosphorus was also
calculated for agricultural PRWs. Sub-basins with relatively large reductions from direct conversion and
high particulate phosphorus to sediment ratios will result in somewhat larger reductions of particulate
phosphorus than sediment (on a percentage basis). The relative yield reductions expected from full
139

 restoration of all PRWs are documented for each sub-basin in Table 24. These results are graphically
depicted for each sub-basin (Figure 33 and Figure 34) and each subwatershed (Figure 35 and Figure 36).
Table 24. Summary of relative yield reductions for particulate phosphorus (sed-P) and sediment
(as TSS) for each sub-basin in the Lower Fox River Basin

East River

0.66

Relative
Sed-P Yield
Reduction
(lbs/ac/yr)
0.28

Baird Creek

0.45

0.28

62%

231.6

131.7

57%

Bower Creek

0.68

0.34

51%

383.0

194.0

51%

Apple Creek

0.63

0.23

37%

372.1

133.4

36%

Ashwaubenon Creek

0.49

0.17

35%

262.9

87.7

33%

Dutchman Creek

0.45

0.18

41%

262.4

107.8

41%

Plum Creek

0.90

0.24

27%

526.6

138.0

26%

Kankapot Creek

0.79

0.38

49%

442.0

212.8

48%

Garners Creek

0.58

0.05

9%

406.9

37.7

9%

Mud Creek

0.38

0.08

20%

305.1

62.2

20%

Duck Creek

0.43

0.21

49%

290.9

141.7

49%

Trout Creek

0.23

0.15

64%

150.8

97.0

64%

Neenah Slough

0.47

0.24

51%

335.1

147.7

44%

Lower Fox (main stem)

0.43

0.08

18%

379.9

64.4

17%

Lower Green Bay

0.41

0.24

59%

231.2

127.8

55%

Sub-Basins

Baseline
Sed-P Yield
(lbs/ac/yr)

Sed-P
Reduction
(%)

Baseline
TSS Yield
(lbs/ac/yr)

42%

405.1

Relative
TSS Yield
Reduction
(lbs/ac/yr)
168.1

TSS
Reduction
(%)
42%

Due to inherent uncertainties and assumptions in the modeling approach, the yield reduction estimates
in Table 24 should only be considered relative to one another for the purpose of prioritizing wetland
restoration in certain sub-basins. For example, the Kankapot Creek sub-basin has the highest predicted
yield reductions for both particulate phosphorus and sediment. This means that restoration of wetlands
in the Kankapot Creek sub-basin will likely have the greatest effect on reducing both particulate
phosphorus and sediment loads. However, restoration of any particular individual PRW within this subbasin will not necessarily reduce particulate phosphorus or sediment by the exact amounts listed in the
table. These values represent expected average results only.
According to the analysis, assuming 100% restoration of all PRWs in the LFR Basin, an
estimated 87,015 lbs/yr of particulate phosphorus and 52,634,010 lbs/yr of sediment could be
reduced through wetland retention. This analysis, however, does not estimate reductions in soluble
phosphorus, which makes up 39% of the total phosphorus yield in the LFR Basin. Therefore, reductions
in total phosphorus would actually be higher than that predicted for particulate phosphorus. Again, these
estimates should only be considered in relative terms for planning purposes. The actual load reductions
that would occur through wetland restoration depend on a variety of physical, chemical, biological, and
cultural factors that would be unique to each PRW restoration site.

140

 Figure 33. Summary of relative predicted TSS yield reduction for each sub-basin in the Lower
Fox River Basin from the PRW analysis
141

 Figure 34. Summary of relative predicted particulate phosphorus (sed-P) yield reduction for
each sub-basin in the Lower Fox River Basin from the PRW Analysis
142

 Figure 35. Summary of relative predicted TSS yield reduction for each subwatershed the Lower
Fox River Basin from the PRW analysis
143

 Figure 36. Summary of relative predicted particulate phosphorus (sed-P) yield reduction for
each subwatershed in the Lower Fox River Basin from the PRW analysis
144

 APPENDIX G. STAKEHOLDER ENGAGEMENT AND OUTREACH ACTIVITIES
Meetings
Outreach Team (23 meetings over 45 months, September 2006 through May 2010)
• 4-7-09
• 1-23-08
• 9-15-06
• 10-8-09
• 2-14-08
• 11-8-06
• 11-4-09
• 3-31-08
• 12-19-06
•
12-8-09
•
8-6-08
• 5-7-07
• 12-18-09
• 10-30-08
• 6-28-07
• 3-16-10
• 12-5-08
• 10-19-07
• 5-5-10
• 1-15-09
• 12-1-07
• 2-16-09
• 12-19-07
Communications Strategy Subcommittee of the Outreach Team (4 meetings, September 2008 through
January 2009)
• 9-22-08
• 10-14-08
• 11-4-08
• 1-8-09
Technical Team (7 meetings, October 2008 through May 2010)
• 10-02-08
• 10-24-08
• 11-12-08
• 01-14-09
• 06-03-09
• 12-02-09
• 05-05-10
Ad Hoc Science Team (10 meetings, March 2007 through January 2009)
• 03-19-07
• 06-19-07
• 07-27-07
• 09-10-07
• 03-17-08
• 03-31-08
• 05-21-08
• 08-21-08
• 12-04-08
• 01-29-09
TMDL Development “Kick-off” meeting with Outreach, Technical, and Ad-Hoc Science Teams
• 10-2-08

145

 Stakeholder & Public Informational Meetings
• 1-23-09 (63 attendees; two sessions, one in the afternoon and one in the evening)
• 12-2-09 (approximately 85 attendees)
Environmental Groups Meeting
• 2-24-09 (18 attendees representing 9 environmental/conservation groups & 5 agencies)
Outreach Planning and Audience Assessment
•
•
•
•

Facilitated Stakeholder Meetings – agricultural groups, October 2007
Facilitated Stakeholder Meetings – municipal stormwater stakeholders, May 2008
Survey of Agricultural Producers, final report dated October 2008
Survey of East River Residents, draft report March 2010 (draft)

Printed Materials
Newsletter Distribution
• September 2008 (171 recipients)
• October 2008 (223 recipients)
• March 2009 (231 recipients)
• March 2010 (250 recipients)
Fact Sheets
• General 4-page version – October 2007
• General 2-page version – November 2008
• Restoration Goals: Lower Fox River Watershed and Green Bay – June 2010
• Understanding and Improving Water Quality Through Watershed Models – June 2010
Direct-Mail Informational Letters
• Mailed 47 letters and two-page fact sheets to state and federal legislators – October 2008
• Mailed 700 two-page fact sheets along with Brown County’s Farm Preservation mailing –
December 2008
• Mailed 950 two-page fact sheets and cover letters to agricultural producers in the Lower Fox
Basin within Winnebago, Calumet, and Outagamie counties – December 2008
• Mailed 47 letters and two-page fact sheets to representatives of environmental groups – January
2009
Media and Web
Media Coverage
• Green Bay Press-Gazette Perspectives Page, “Groups push to reduce pollution entering Fox
River” by Terry Anderson – January 6, 2008
• Green Bay Press-Gazette article, “Sediments, nutrients harm quality: 14 area bodies of water
have problems with excess toxins” by Mike Hoeft – April 19, 2010

146

 Web Sites
• WDNR – “The Lower Fox River and Green Bay TMDL”
http://dnr.wi.gov/org/water/wm/wqs/303d/FoxRiverTMDL/
• UWEX – “Lower Fox River Basin TMDL Outreach” (on-line December 2007)
http://basineducation.uwex.edu/lowerfox/tmdl_outreach.html
Presentations at Conferences and Workshops
Exhibits/Posters/Displays
• Wisconsin Lakes Convention – March 2009
• State of Lake Michigan conference – October 2009
• Friends of the Fox meeting - April 2010
Oral Presentations
• LFR Point Source Dischargers meeting – August 2007 and February 2008
• FWWA Stormwater Conference – 2007, 2008, 2009, and 2010
• Regular updates at Lower Fox River Partners Meetings – 2007 - 2010
• Brown County Conservation Alliance Meeting – February 2008
• Lower Fox River Students Research Symposium – March 2008
• WEF Seminar on TMDL Development and Implementation – September 2008
• Lecture at UWGB Environmental Science (Nicole Clayton) – October 2008
• Clean Lakes and Green Jobs: The Promise of New Federal Funding for Great Lakes Restoration
– August 2009
• WEF TMDL Conference (6-speaker session) Minneapolis MN – August 2009
• Appleton Paper Museum (Erin Hanson) – Winter 2010
• Lecture at Lawrence University (Nicole Clayton) – April 2010

147

 APPENDIX H. RESPONSE TO COMMENTS
A public comment period for the Lower Fox River TMDL began on June 25, 2010 and ended on
Monday July 26, 2010. The Public Notice was distributed via email to more than 200 stakeholders and
was posted on WDNR’s web site (http://dnr.wi.gov/org/water/wm/wqs/303d/Draft_TMDLs.html).
The following items were made available on this website during the public comment period:
•

A copy of the draft TMDL report.

•

The official Public Notice for the draft TMDL report.

•

Information on the Public Hearing, which was held in Grand Chute on July 12, 2010.

•

Instructions for submitting comments on the draft TMDL to WDNR by July 26, 210.

•

Source for additional information on the development
(http://dnr.wi.gov/org/water/wm/wqs/303d/FoxRiverTMDL/).

of

the

TMDL

An informational Public Hearing was held in Grand Chute on July 12, 2010. An open house prefaced the
meeting and a short informational presentation was given prior to the formal comment period. No oral
comments were received on record at the hearing.
The following pages contain a summary of written comments received during the formal comment
period. Comments received were paraphrased and summarized to be more concise followed by the entity
or entities making the comment in parentheses. Similar comments were grouped together. Table 25 lists
all persons, agencies, and municipalities that provided comments on the draft TMDL report.

148

 Table 25. Persons, Agencies, and Municipalities that Provided Comments on the Draft TMDL
Citizen, Organization, Agency Name or Local
Governments

Name or Title

Brick, Dan

Sadoff and Rudov Industries: Manager of Industrial Marketing
and Quality Control
Owner & Manager of Brickstead Dairy LLC

Brown County Planning Commission

Peter Schleinz: Senior Planner

Burkholder, Dr. JoAnn

NC State: Aquatic Ecology Professor

Cellu Tissue

Mr. Kevin French - Operations Manager

City of Appleton

Paula Vandehey : Director of Public Works

City of Appleton

Chris Shaw: Director of Utilities

City of De Pere

Eric Rakers: City Engineer

Dairy Business Association (DBA)

Laurie Fischer

Dolan, Dave

University of Wisconsin - Green Bay; Associate Professor

GBMSD

Tom Sigmund: Executive Director

Harke, Bill

Milk Source (CAFO)

Kaukauna

Midwest Environmental Advocates (MEA) and
Clean Wisconsin
Municipal Environmental Group (MEG)

John Neumeier: Engineer & GIS Specialist
Paul Kent on behalf of League of WI Municipalities: Attorney
Stafford Rosenbaum
Amanda Ley, Betsy Lawton, Jamie Konopacky, Allison
Donenberg, Melissa Mallott
Paul Kent on behalf of MEG: Attorney Stafford Rosenbaum

Ostrom, Jim

Milk Source (CAFO)

Thundercloud, Kelly

Citizen

Vande Hey, Nick

McMahon Group

Vanden Elzen, Ray and Shirley

Farmers

Village of Allouez

Craig L. Berndt: Director, Public Works

Village of Ashwaubenon

Michael W. Aubinger: Village President

Village of Bellevue

William Balke: Public Works

Village of Wrightstown

Stephen M. Johnson

Wisconsin Paper Council
Wisconsin Section Central States WEA
Government Affairs Committee (SCWEA)
WPSC-Pulliam

Ed Wilusz: VP Government Relations

Borsuk, David J

League of Wisconsin Municipalities

Keith Hass (Current Chair); Jane Carlson
Mark Metcalf on behalf of WPSC-Pulliam

149

 Use Designations
1. Comment: The “designated use” and “existing use” terminology in the TMDL report is confusing.
It appears most of the surface waters in the TMDL have not been officially classified into the various
fish and aquatic life subcategories in Wisconsin Administrative Code Chapter NR 102. Chapter NR
102 requires the WDNR to classify all waters by their designated use, and designated uses are integral
part of water quality standards. In our opinion, use classification should occur before an impairment
assessment (303d listing) is made, let alone a TMDL conducted. This might be a matter of semantics
in the draft TMDL report and we suggest it be clarified for the final TMDL report. (CSWEA)
Response: In the context of this report, the “designated use” is that which is specified as the legal
use in accordance with Wisconsin Administrative Code NR 102. Conversely, “existing use” is used in
this report to describe what field biologists know about the current biological, chemical, and physical
condition of the water body and the fish and aquatic life community it is currently capable of
supporting. As noted, many of the surface waters affected by this TMDL are not specifically
identified in Wisconsin Administrative Code NR 102 or NR 104. This is a reflection of the inability
of WDNR to conduct classification studies on every water body in the state. Regardless, the
construct of Wisconsin’s use designation system is to specify the designations only for those waters
that are Coldwater Communities by legal reference (see s. NR 102.04(3)(a)) or are Limited Forage Fish
Communities or Limited Aquatic Life Communities in accordance with the provisions of Wisconsin
Administrative Code NR 104. All other waters are assumed by law to support a fish and aquatic life
use with the applicable water quality criteria being assigned to protect one of three sub-categories of
the Fish and Aquatic Life Use found in pars. NR 102.04(3)(a)-(c).
Targets and Data
2. Comment: Please include raw data (from unpublished data and information used) in appendices of
the report to be more transparent. We strongly encourage WDNR to utilize recent, high-quality data
in the development of future high-impact TMDLs, as required by US EPA guidance and state listing
and assessment methodologies. (CSWEA)
Response: Over the past 30 years, water quality monitoring have been collected in the Lower Fox
River Basin and Lower Green Bay by GBMSD, WDNR, the Lower Fox River Monitoring Project,
UW-GB, UW-Sea Grant, UW-Milwaukee Water Institute and Oneida Nation. These data were
thoroughly evaluated and used in developing this TMDL. Unpublished data and cited works in the
TMDL are available upon request if not already included in the appendices. Raw data may be
provided by the entities referenced in the document.
3. Comment: The 20 mg/L TSS target does not seem well developed. (CSWEA)
Response: Wisconsin currently does not have numeric water quality standards for TSS. Therefore,
the Ad Hoc Science Team formally met 10 times over 2 years to determine the best TSS target for
the TMDL. Additional modeling was completed through contracts with UWGB during this time
period to choose the best targets based on local data. Please see above response for data used, as well
as Table 14 in Appendix A of the TMDL to better understand the correlation between TP, TSS,
EPAR values and corresponding Secchi depth.

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 4. Comment: Using TSS as the target may differ from Impaired Waters Listing Methodology for the
particular water body, too, creating a potential disconnect between the original reason for listing and
the TMDL. (CSWEA)
Response: Many waters are included on Wisconsin’s 303(d) list where “degraded habitat” is the
listed impairment and sediment is the listed pollutant. Historically, these listings were made using the
professional judgment of field biologists who felt that excessive sediment runoff – as often indicated
by elevated TSS – was the cause. The reliance on professional judgment was necessary due to the
fact that Wisconsin does not have promulgated numeric criteria for TSS. This does not diminish the
power of using TSS to develop the TMDL, however, as TSS provides a quantitative measurement
that allows effective and equitable “load reductions” to be calculated that will achieve the narrative
criteria in Wisconsin Administrative Code NR 102. Specifically, using TSS targets to meet
appropriate instream goals – for both tributaries as well as downstream waters – allows load and
wasteload allocations to be derived that will help achieve the goal of “no objectionable deposits” on
the bed of the affected water bodies (see par. NR 102.04(1)(a)).
5. Comment: We support the effort to produce cleaner water including the TSS target of 20 mg/L.
(Cellu Tissue)
Response: Comment noted.
6. Comment: WDNR must relate TMDL targets for TP to production of toxic cyanobacteria and
determine a TP target at a level that will not contribute to cyanobacterial blooms throughout the
summer season. (Burkholder, MEA and Clean Wisconsin)
Response: The listed impairment for Lower Green Bay is not related to the issue of “toxic”
cyanobacteria (aka blue-green algae). The impairment is currently related to low levels of dissolved
oxygen associated with excessive phosphorus, which may manifest itself in impacts to the fish and
aquatic life community of the lower bay. This phenomenon of low dissolved oxygen is often
associated with massive algal blooms and their impacts on oxygen consumption associated with
photosynthesis, as well as decomposition of organic matter. Accordingly, it is expected that
reductions of both the frequency and density of cyanobacteria will have a positive impact on the
dissolved oxygen levels of the lower bay.
Further, while the current listing is not directly related to impacts to the recreational uses of the
bay, it is likely that the reductions of phosphorus may also have two additional benefits: 1) a positive
impact on the concentration of algal toxins that may be released naturally when bloom conditions
exist; and 2) increased visibility of the water due to improved Secchi depth – an indicator of light
penetration. Both of these improvements should have a positive affect on the safety of people that
want to recreate on or in the lower bay.
Section 3.2 describes the process used to establish the targets in Lower Green Bay. Those target
values were very clearly associated with clearer water and better light penetration. As noted above,
using those “indicators” to establish target values will have a very direct correlation with water
quality improvements – more so than setting targets solely on the prevention of the production of
algal toxins.

151

 7. Comment: TMDL targets are needed for TSS in the LFR and tributaries and for TP and TSS in
Lower Green Bay. (Burkholder, MEA and Clean Wisconsin)
Response: Please see response to Comment #3. One benefit of doing a watershed TMDL is that
loads can be allocated equitably throughout the watershed/basin to assure that the most critical
downstream goals are achieved. In the absence of numeric criteria for TSS, WDNR has used the
narrative criterion of s. NR 102.04(1) to attempt to protect the water quality of the tributaries, the
main stem of the Lower Fox River, and Lower Green Bay. Since the lower bay is a dynamic system,
unlike most other Great Lakes’ near-shore environments, development of a single and definitive
numeric target for both TSS and TP would be a huge challenge outside the scope of the TMDL.
Instead, using a narrative approach related to light penetration, as described in Section 3.2 of the
TMDL, significant improvements to the fish and aquatic life community, as well as protected
recreational and wildlife uses, are expected. WDNR fully expects that achievement of the numeric
water quality targets for TP and TSS in the tributaries and main stem of the river will have a direct
correlation with the water quality of the lower bay and will yield significant improvements in water
quality related to fish and aquatic life, recreational uses, and other wildlife uses.
8. Comment: The draft TMDL does not adequately account for seasonal variation and critical periods.
(Burkholder)
Response: As discussed in the TMDL report, critical conditions for phosphorus impairments are
generally during summer months when temperature, flow, and sunlight conditions are conducive to
excessive plant growth. However, loadings throughout the entire year contribute to high phosphorus
concentrations during this critical period. Critical loadings for TSS impairments occur during wet
weather events, which result in upland and stream bank erosion. Wet weather events can occur at
various times during the year, but are especially prevalent in spring and summer.
Seasonal variation in the phosphorus and TSS loads is captured in the SWAT model used for the
TMDL analysis. First, SWAT uses daily time steps for weather data and water balance calculations.
Loads were calculated by SWAT using a 23-year (1977-2000) long-term hydrologic simulation
period, which minimizes the potential influence of climate dependant factors and provides a more
representative estimate of average conditions. Second, output from SWAT is on a daily time step (i.e.
daily basis), but was summarized on an average annual basis for the TMDL analysis. Therefore, all
possible flow conditions are taken into account for load calculations.
Margin of Safety
9. Comment: Why is an MOS for TSS needed? Applying a 10% implicit margin of safety seems
unnecessarily stringent. (Kaukauna, CSWEA, City of Appleton)
Response: An MOS is required by EPA in a TMDL. A 10% MOS was included for TSS to account
for any error that may be associated with the predicted reduction goals for biotic solids in the main
stem of the Lower Fox River (when factoring it into the WLAs). The 10% is applied to the target for
TSS therefore “distributing” the TSS among all the load allocations in the TMDL and not placing
additional stress on one sector vs. another (WLA vs. LA).

152

 10. Comment: WDNR should incorporate additional MOS for TP and TSS to account for uncertainties
in meeting the load reductions, either through reduced load capacity or unallocated loads.
(Burkholder, MEA and Clean Wisconsin)
Response: The current MOS in the TMDL is sufficient for accounting for potential uncertainties in
meeting the load reduction. The MOS can be reviewed in the future as new data become available.
Reasonable Assurance
11. Comment: In order to meet the technical feasibility requirement for load allocations the WDNR
must present a plan to overcome the budgetary and institutional barriers that face the voluntary
nonpoint source program in the state. Otherwise, the WDNR must assume that nonpoint source
loading will stay at baseline levels, and assign the load outside of MOS and future growth to point
sources. (MEA and Clean Wisconsin)
Response: WDNR has worked closely with EPA to ensure that the TMDL meets all applicable
regulatory requirements. EPA has indicated that the federal regulations under 40 CFR Part 132 do
not require “technical feasibility” for load allocations and do not apply to this TMDL (Dave
Werbach, EPA, per. Communication with Nicole Clayton). WDNR has indicated in public meetings
that an implementation plan will be developed after the TMDL is approved. That plan will identify
the necessary actions and activities that can be taken to achieve the nonpoint source allocations. That
plan will also allow for detailed steps to be defined that recognize both the budgetary and
institutional resources available. Development of that plan will occur with broad representation of
affected stakeholders and will strive to remain true to the load and waste load allocations outlined in
the approved TMDL. That being said, adjustments to the allocations may be necessary to achieve the
end goal of meeting water quality on the Lower Fox River Basin and Lower Green Bay.
12. Comment: The TMDL must include a timeline section that incorporates reviewable milestones for
achieving the technical, institutional and budgetary steps necessary to ensure that the agricultural
reductions can in fact be achieved. (MEA and Clean Wisconsin)
Response: Current federal regulations do not require a specific timeline or identifiable milestones
for achieving load allocations to be specified in the TMDL (40 CFR 130). However, WDNR believes
that milestones are appropriate for inclusion in a detailed implementation plan and will assist in the
keeping stakeholders focused on the ultimate goal of achieving water quality standards in the Lower
Fox River Basin and Lower Green Bay. Including this information in the implementation plan will
allow WDNR to utilize the myriad of state and federal assistance programs, policies, funding
sources, and relevant laws available at the time of plan development to most effectively address
pollutant reduction goals.
Upstream Sources
13. Comment: The TMDL should be conducted for the Upper Fox/Wolf Basin to address TP and TSS
loading from Lake Winnebago. (Burkholder, GBMSD, Borsuk, Kaukauna , City of De Pere)
Response: WDNR is working in partnership with other entities, including the United States
Geological Survey to collect relevant data throughout the Upper Fox and Wolf River basins
(including Lake Winnebago) in preparation for the development of a TMDL. WDNR anticipates
completion of this project within the next five years – dependent upon available funding.
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 14. Comment: Please consider using a more equitable reduction (proportional to the loading) for Lake
Winnebago (outlet) until the Wolf River and Upper Fox River TMDLs are complete. (Vande Hey,
CSWEA, City of Appleton, MEG, League of Wisconsin Municipalities)
Response: This was considered early in the TMDL development process. However, based on
conversations with various researchers studying the Lake Winnebago system, a 40% TP reduction
and a 48% TSS reduction are the most munificent reductions we can assume from Lake Winnebago,
since naturally it is a eutrophic/hypereutrophic lake. Reducing the phosphorus concentration leaving
the lake by greater than 40% at the outlet of the lake may not be possible given that part of the
phosphorus input to Lake Winnebago likely originates from internal lake loading (released from
bottom sediment). In addition, many of the subwatersheds within the UFWR Basins have low yields
and encompass vast areas of upland forest and wetlands, where reduction potential is minimal;
although some of the phosphorus from wetlands may be reduced in the long-term if upland
agricultural areas that drain to those wetlands reduce their phosphorus export. In contrast to the
UFWR Basins, land use in the LFR Basin is dominated by agriculture and urban areas, with relatively
few areas that are low contributors (overall, soils and slopes are very similar). Sources of TSS and TP
in the LFR Basin are clearly more concentrated as compared to sources in the UFWR Basins (see
attached yield maps for annual TP and TSS loading on a sub-basin scale). Further studies by the
USGS and WDNR are now being conducted to determine what measures would be needed to
reduce the phosphorus loading from Lake Winnebago by 40% through the development of the
UFWR TMDLs.
Wastewater Treatment Facilities
15. Comment: WDNR has violated federal regulations by allocating reductions to point sources before
determining what nonpoint source reductions will realistically occur. All reductions necessary to
achieve water quality must be allocated to point sources after allocating the LA to nonpoint sources.
(MEA and Clean Wisconsin)
Response: In accordance with the provisions of the Great Lakes Water Quality Initiative,
NPDES/WPDES permits for point sources in the Great Lakes Basin must include appropriate
water quality-based effluent limitations to meet the water quality criteria for toxic pollutants listed in
Tables 1-4 of Appendix F of 40 CFR 132.6. The same federal requirements do not apply to other
pollutants, including those in Table 5 of Appendix F unless state-specific requirements apply.
Neither phosphorus nor TSS are included in Tables 1-4 and therefore are not required by federal
law.
Similarly, federal law does expressly specify a hierarchy of which sources should be reduced “first.”
In reflection of the provisions of 40 CFR Part 130, US EPA guidance (1991) states that “... the
TMDL process is a rational method for weighing the competing pollution concerns and developing
an integrated pollution reduction strategy for point and nonpoint sources” (see Page 15). The EPA
Nutrient Protocol (1999) states on page 7-2 that “an appropriate balance should be struck between
point source (PS) and nonpoint source (NPS) controls in establishing the formal TMDL
components.”
Currently, EPA gives state water quality management agencies the flexibility to determine the
appropriate allocation strategy for the pollutants of concern (considering watershed characteristics)
and “technical feasibility” is to ensure the allocations are not impossible (e.g., a load allocation of
zero, will need some explanation on how that will be achieved).
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 16. Comment: Regulating the point source dischargers will not have an environmental affect on [the
main stem] river quality. The regulatory community should recognize the complexity and impact of
nonpoint sources, and legacy TP and TSS loads. (City of Appleton)
Response: WDNR believes that the best approach to achieving water quality improvements
includes reducing the loads of TP and TSS from all contributors, including point sources, nonpoint
sources, and legacy loads. Current federal and state policies and regulations are in place that require
more immediate and direct action from point sources via the NPDES/WPDES program. WDNR
cannot ignore those regulations on the premise that the regulatory requirements associated with
them will not result in clear and demonstrable changes in water quality in the near term. Recent
changes to Wisconsin Administrative Code NR 217 expand the ability of WDNR and the regulated
community – both point and nonpoint – to collaborate on integrated approaches to achieve the
reduction goals stated in the TMDL.
Regardless of the available regulatory tools, WDNR does recognize the complexity of the different
sources. In fact, the TMDL recognizes the distinction between the relative contributions of point
and nonpoint sources within the Lower Fox River Basin depending on whether or not the focus is
on the main stem of the river, the tributaries, or Lower Green Bay proper. Specifically, information
available to WDNR indicates that point sources make up 81% of the TP load that is directly
discharged to the main stem of the Lower Fox River itself with the remainder being contributed by
other sources. When one considers the total loading to the entire basin, including Lower Green Bay,
the point sources contribute approximately 30% of the TP load. One can infer by these differences
that controlling the point source load to the main stem is of critical importance to facilitating
measurable differences in the water quality of the main stem.
With respect to “legacy” pollutants, WDNR believes that new contributions to the system far exceed
the load attributed to the mobilization of legacy pollutants. When future efforts to control point and
nonpoint sources are implemented successfully, it may be necessary to re-evaluate the contributions
and effects associated with legacy pollutants. In the meantime, on-going and/or new studies to
evaluate the effects of PCB remediation efforts involving sediment removal/capping may be able to
help ascertain the impact of legacy loads on water quality.
17. Comment: We recommend that the daily LAs and WLAs be re-calculated using draft guidance
developed by USEPA in Options for Expressing Daily Loads in TMDLs, Draft, June 22, 2007. Dividing
by 365 is an over-simplification and may lead to confusion on the public and third parties when
loads are exceeded on a daily basis. (CSWEA)
Related Comment: The wasteload allocations for point sources of TP and TSS need to be based on
the WLA per day as a daily maximum, not a daily average. (Burkholder)
Response: WDNR does not envision including daily maximum effluent limitations in WPDES
permits that simply reflect a division of the annual WLA (expressed in lbs/yr.) by 365. WDNR may
express permit limits as daily maximums, weekly averages, monthly averages, or annual totals
consistent with 40 CFR Part 122.44(d)(1)(vii), which does not require permit limits to be expressed
in the same form as wasteload allocations. Federal requirements state that WLA-based permit limits
need only be “consistent with the assumptions and requirements” with the approved wasteload
allocations.
18. Comment: We object to the use of EPA’s Technical Support Document for Water Quality based
Toxics Control to derive WQBELs from the WLAs. The technical support document focuses on
155

 both acute and chronic effects of toxic substances and suggests that effluent limits be set low enough
to prevent acute toxicity. Applying such an analysis to TP would be inappropriate as acute toxicity is
not an issue. (MEG)
Response: The method discussed in the Fox River TMDL deals with converting wasteload
allocations to permit effluent limits. The method is not limited to deriving WQBELs from WLAs for
toxic substances. It may be used to convert WLAs from an approved TMDL. The method deals with
effluent variability and the potential for effluent limit exceedances, not with toxicity.
19. Comment: We recommend that design flows or maximum daily flow rate be used to determine the
WLAs for this TMDL. (CSWEA, WPSC-Pulliam)
Response: If the maximum design flow were used in the TMDL analysis in place of the actual flow,
the WLAs necessary to meet the TMDL would require greater percent reductions for each facility, as
well as a lower concentration for the facilities in the main stem (i.e., 0.135 mg/L instead of 0.20
mg/L).
20. Comment: The current method for calculating TSS for WWTFs penalizes facilities that have already
achieved significant solids removal. It is unfair to penalize the best-performing facilities by imposing
more stringent limits on them than on those currently discharger higher levels of TSS. WWTFs
currently discharge below their current limits. TSS should be evaluated in a different way. (CSWEA,
MEG, Wisconsin Paper Council, WPSC-Pulliam, GBMSD).
Response: The WLAs for TSS in the TMDL were based on the average current discharge from
WWTFs (for the LFR main stem). In many cases, the current discharge is well below each facility’s
current permit limit. Although several comments were received on the current methodology for TSS
allocations, no alternative methods were proposed that would still meet overall TSS water quality
goals for the TMDL. In order to protect downstream uses and adhere to antidegradation policies
outlined in Wisconsin Administrative Code NR 102.01 (3) and NR 104.02 (5), an increased TSS load
is not allowed. It is assumed that as facilities take initiatives to improve their reduction of TP, TSS
will be reduced as part of this effort.
Specific WWTF Comments
21. Comment: WDNR was involved in the Village of Wrightstown early facility planning and is on
record as stating that the existing standard of 1.0 mg/L for phosphorus would not change. With
point source facilities contributing to only 20% of the phosphorus pollution, this does not seem
equitable compared to nonpoint pollution loadings and the cost is far too great. (Village of
Wrightstown)
Response: Technology-based effluent limitations for phosphorus have been included in WPDES
permits dating back to 1991. Those limits are reflective of the level of performance expected with
conventional wastewater treatment practices and are not reflective of the site-specific needs to meet
water quality standards in lakes, rivers, and streams. For the past 30 years, WDNR has been
exploring and actively researching the levels of total phosphorus necessary to protect fish and aquatic
life as well as recreational uses of Wisconsin’s surface waters. In the past five years, WDNR has been
very active in communicating efforts to develop numeric water quality criteria for total phosphorus
and has never gone on record as saying any category of or individual point source facility would be
exempt from meeting those criteria.
156

 On December 1, 2010, water quality criteria were adopted in Wisconsin and will be considered by
WDNR as staff prepare WPDES permits for point sources. In addition, the TMDL expresses WLAs
which must also be included in WPDES permits and those WLAs are based upon meeting in-stream
targets which reflect the Wisconsin criteria.
Regarding the equity of treatment between point and nonpoint discharges, WDNR included
provisions in recently revised administrative rules governing the discharge of phosphorus that
expand the ability of WDNR and the regulated community – both point and nonpoint – to
collaborate on integrated approaches to achieve the reduction goals stated in the TMDL. In the
interim, effluent limits to meet WLAs must be a part of NPDES/WPDES permits issued following
federal approval of the TMDL.
Also, please note that wastewater dischargers contribute nearly 37% of the phosphorus loading in
the entire LFR Basin (see Figure 19); further, wastewater dischargers contribute close to 81% of the
phosphorus loading within just the Lower Fox River main stem sub-basin.
22. Comment: The current annual discharge calculated for the baseline loads of TSS (2003-2007) for
Cellu Tissue was significantly lower than recent years. During 2009, the total annual TSS discharge to
the Fox River was approximately 72,000 lbs. The historical average used for Cellu Tissue does not
truly represent loadings during full operation (as the mill machines were operating sporadically in
fiscal years 2003 and 2004. We request that the waste load allocations for TSS be assigned equal to
our current annual discharge loads (2005-2009), as we understand was the intended procedure
outlined in the TMDL development document. (Cellu Tissue)
Response: Wasteload allocations for Cellu Tissue (Permit #0000680) were adjusted.
23. Comment: Please be more transparent on how “baseline” loads were calculated for WPDES
permittees that do not have limits for TP in their current permits. (WPSC-Pulliam-provided another
methodology in their comments).
Response: Baseline loads were calculated in the same way for all permitted facilities, regardless of
whether or not the facility has limits for TP in its current permits. As discussed in the TMDL report,
baseline loads were calculated using an average of actual loads reported to WDNR in Discharge
Monitoring Reports between 2003 and 2009 (1-7 year averaging period).
24. Comment: When TMDL allocations were developed for WWTFs, sediment was not considered. As
part of the allocations, please consider identifying sediment reductions for WWTFs. Although,
additional phosphorus reductions at WWTFs will also likely result in sediment reductions. (Vande
Hey)
Response: WWTFs only constitute 2.5% of the total TSS loading in the Lower Fox River Basin.
The TMDL does not require additional reductions from baseline loading from WWTFs for TSS
(note: baseline loading is not equivalent to current permit limits, it is equivalent to current discharge
from the WWTFs). As you state, it is expected that if WWTFs install additional treatment for
phosphorus, this will result in additional TSS reductions.

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 Reserve Capacity
25. Comment: Why is the WLA from GW Partners not being used to reduce what other WWTP’s need
to reduce? There is already an MOS and new development should be regulated when it occurs and
will need to meet current WDNR standards and this TMDL as enforced. (Kaukauna)
Response: The GW Partners Facility has an active permit (See WPDES Permit No. 0001121), and
therefore a reserve capacity was set aside to support a new owner of that facility. If that permit
expires, this load or “reserve capacity” will be available for WPDES permits that are new or would
like to expand on the Lower Fox River main stem. This is different than the MOS expressed in the
TMDL, which is a required component of a TMDL to account for potential uncertainty in the
analysis.
26. Comment: The TMDL must allocate a greater amount of reserve capacity for future growth or new
or expanded dischargers cannot be allowed without revising the TMDL. (Burkholder, MEA and
Clean Wisconsin)
Response: Various discussions with stakeholders involved in the TMDL process (especially the
Lower Fox River Technical Team), agreed that because of the load reductions needed, and the
flexibility to potentially trade water quality credits in the basin, additional reserve capacity was not
needed for this TMDL. This is a not a federally-required component of a TMDL. If new or
expanded dischargers would like to obtain a permit (with a WLA greater than zero), the TMDL will
need to be modified, or they will need to seek out an allocation elsewhere in the basin. Because of
Wisconsin’s current rules and regulations (Wisconsin Administrative Code NR 151 and NR 216)
future growth already has a more stringent requirement to meet water quality standards, and
therefore reserve capacity is not needed.
Storm Water and Municipal Separate Storm Sewer Systems (MS4s)
27. Comment: Why is urban MS4 runoff considered a “point source”? (Kaukauna)
Response: The EPA Memorandum “Establishing TMDL WLAs (wasteload allocation) for
Stormwater Sources and NPDES Requirements Based on those WLAs” dated November 22, 2002,
clarifies existing EPA regulatory requirements for establishing WLAs for stormwater discharges. It
states that NPDES-regulated stormwater discharges must receive a WLA in a TMDL. A point
source is any entity or facility that holds an NPDES (CWA §122.1: The NPDES program requires
permits for the discharge of “pollutants” from any “point source” into “waters of the United
States.”) For stormwater permitting this includes MS4s, construction sites, and industrial facilities.
28. Comment: Please consider developing allocations for the Urban (non-regulated) land use category.
Urban (non-regulated) land uses generate 20% of phosphorus and 12% of sediment baseline loads
within urban areas. (Vande Hey, Ostrom, City of Appleton)
Response: Allocations are assigned to the non-permitted urban area through the load allocation.
Wisconsin Administrative Code NR 216 allows the issuance of a permit to urban areas that are
currently not permitted but are determined through a water quality analysis to be a significant source
of pollutants. Issuance of a permit would require the municipality to comply with Wisconsin
Administrative Code NR 151 reductions of 40% for any established urban area.

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 29. Comment: Please consider the most restrictive pollutant when preparing urban (MS4) wasteload
allocations and agricultural load allocations. (Vande Hey, City of Appleton)
Response: TMDLs were independently established for TP and TSS based on what is needed to
meet the numeric water quality targets. WDNR recognizes that there are a few sub-basins in which
achieving the allocation for TP may also result in a greater reduction in TSS than is required in the
TMDL report, however, this is dependent on what methods are used to attain the reductions.
30. Comment: When TMDL allocations were developed for construction sites, phosphorus was not
considered. As part of allocations, please consider identifying phosphorus reductions for
construction sites. 80% sediment reductions at construction sites will also likely result in 60%
phosphorus reductions. The TMDL should also describe a procedure for accounting for the
reduction of TP when agricultural land is converted to urban land. (Vande Hey, City of Appleton,
City of De Pere)
Response: A correlation between TSS reduction and TP reduction is highly variable and is based on
the soil test P values of the soil at the construction site. The 80%-60% cited in this comment is likely
from SLAMM, which does not simulate construction site erosion. Phosphorus generally remains
trapped in the upper ½-inch soil layer and is distributed deeper through tillage operations. This
tillage layer is also generally characterized as the topsoil layer. The first step in most construction
activities is to strip and stockpile the topsoil. This effectively removes much of the phosphorus from
the active portion of the construction site. An alternative to this approach is to require soil testing at
construction sites for each of the different soil profiles exposed during construction and calculation
of any potential phosphorus loss through a modeling exercise for each construction site.
The conversion of agricultural land to urban land is a TMDL implementation issue.
31. Comment: Please consider listing the County and DOT allocations in the TMDL report, similar to
the other Urban MS4s. The MS4 WLA should not reflect the contribution from separate entities
(industry, DOT, county roads) and should not be made the responsibility of the MS4s. (Vande Hey,
City of Appleton, Village of Allouez, Brown County Planning Commission, City of De Pere, League
of Wisconsin Municipalities, Village of Bellevue).
Response: As part of EPA’s stormwater guidance, WLAs for entities may be lumped in a TMDL.
County and DOT allocations were lumped with the Urban MS4 WLAs. During implementation
planning, MS4s will have the option of removing industry, DOT, and county roads when modeling
to see if they are in compliance with the TMDL. This is consistent with current Wisconsin
Administrative Code NR 151 guidance which allows municipalities to take credit or enter into
agreements with industries and WisDOT facilities.
32. Comment: According to the TMDL, the Garners Creek Sub-Basin appears to be 7,037 acres in size.
According to municipal storm sewer system maps and 2 foot contour maps, the Garners Creek SubBasin appears to be 7,552 acres in size or more. As such, the municipal sub-basin appears to be 7%
larger than the TMDL sub-basin. TMDL allocations (lbs/year) are influenced by sub-basin size.
Please consider modifying the watershed size since it will likely be more difficult for the MS4 to
modify allocations after the TMDL is finalized. There may be similar concerns within other subbasins (see maps below). (Vande Hey)
General related comment: The TMDL watershed delineations vary significantly from the actual
watershed boundaries in some cases, especially in urban areas. Since the allocations will be in pounds
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 and not in percent removal, this results in unbalanced allocations. How will this be addressed? (City
of Appleton)
Response: Sub-basins within the TMDL were delineated using SWAT. All land area is accounted
for and assigned to a sub-basin. Depending on how sub-basins are delineated, for example
placement of pour points or detail of the DEM, slight differences can be expected. For purposes of
the TMDL, the TMDL sub-basins should be used and WDNR will not be modifying sub-basin
boundaries.
33. Comment: It is not clear in the report if the TMDL is based on the same average annual baseline
load for each Urban MS4 and each sub-basin (i.e. 275 lbs/acre for sediment and 0.5 lbs/acre for
phosphorus). The Urban MS4 baseline load will vary by municipality. The Urban MS4 baseline load
will also vary by sub-basin. For example, the WinSLAMM baseline TSS load in one sub-basin may be
419 lbs/acre and in another sub-basin the WinSLAMM baseline TSS load may be 237 lbs/acre. In
this example, the municipal-wide average baseline is 272 lbs/acre TSS. Since the baseline loads in
each sub-basin are used to determine the Urban MS4 allocations, it is important that the baseline
loads be accurate within each sub-basin and within each municipality. (Vande Hey, Village of
Allouez, City of De Pere)
Related Comment: The use of average pollutant loads results in unbalanced allocations.
Municipalities and consultants must have access to the model used to develop the TMDL. For urban
subbasins that have WinSLAMM TSS or TP loads less than the average value used in the TMDL, it
will be much more problematic to achieve WLAs. (City of Appleton)
Response: During the development of the TMDL, complete data from all of the MS4 communities
in the Lower Fox River Basin were not available. Also, any available SLAMM modeling for the MS4
communities was only for the established urban areas as required in Wisconsin Administrative Code
NR 151. The TMDL applies to the entire MS4, often including what is characterized as ’new
development’ in Wisconsin Administrative Code NR 151.
The load calculated for the MS4s was used to help proportion the available total allocation between
the major sources – point source, agricultural, urban, and background. The urban load used in the
TMDL represents the best estimate available given the scale of the TMDL and available data. As
implementation proceeds, it is expected that better municipal data will become available. If these
data indicate that modifications to the TMDL are warranted, they can be evaluated at that time.
34. Comment: Is there any guarantee that urban MS4 runoff will not have to follow Point Source WLA
requirements? (Kaukauna)
Response: The WLAs for each MS4 are identified in the TMDL in the tables and also in Appendix
D. MS4 communities will be required to review their existing storm water management plans and
show compliance with the WLAs. Some communities (such as the MS4 of Kaukauna) may drain to
more than one water body, and, therefore, receive a WLA for each water body (Kaukauna MS4
drains to Apple, Kankapot, Plum, and Garner Creeks and the Lower Fox River main stem). The
reductions stipulated in the TMDL need to be met within each subwatershed.

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 35. Comment: Will 2010 census data be used to re-define regulated areas? (Kaukauna)
Response: It was not anticipated that 2010 Census data would identify new MS4 areas to be
assigned WLAs by the TMDL. If in the future, if additional MS4 permits are issued in the basin, the
TMDL WLA and LA numbers may need to be adjusted or amended.
36. Comment: Construction site allocations are based on the annualized change in urban land use from
2001 to 2004. Historic trends for new development may not be a good indicator of future trends.
Also, this methodology does not consider redevelopment construction sites that occur within each
sub-basin. Please consider reviewing WDNR permit databases to determine how many construction
sites were for redevelopment projects versus new development projects. Are the acreage allocations
in Table 4 reasonable? (Vande Hey, Kaukauna, City of Appleton)
Response: Given the highly variable nature of construction sites, WDNR used an average condition
looking at changes in urbanization over a multi-year period.
37. Comment: How does the WDNR justify using wetlands for stormwater clean-up? Are wetlands still
considered “waters of the state”? Isn’t using wetlands for clean-up creating a contaminated area to
be cleaned up in the future (Kaukauna)?
Response: Approximately 42% of the original wetlands in the Lower Fox River Basin have been
lost. Restoration of original wetlands is an option for improving water quality and restoring the
landscape to its natural state. Appendix F defines the potentially restorable wetland (PRW) based on
the presence of hydric soils that were once under saturated conditions (a wetland or water body).
This definition is also predicated on the assumption that wetland restoration is not feasible in urban
areas. This analysis was not intended for stormwater clean-up, but instead focused on the restoration
of PRWs in agricultural areas to reduce pollutant loading and remove sources of pollutants.
38. Comment: Will WDNR have time to gather actual stream bank contributions to calibrate the model
if serious TSS issues are shown to exist in a stream? (Kaukauna)
Response: The calculation of sediment from erosion of stream banks is not considered in the
model; rather, a desk calculation using historic bank locations and erosion rates is included. It is
included in the current TMDL model indirectly through the calibration process with actual
monitoring data.
39. Comment: Was any weight given to newer results with regard to TP data after the fertilizer ban took
effect in WI? Will this change in society satisfy the reduction needs, or in WDNR opinion will there
still be significant requirements to meet MEP in communities? (Kaukauna)
Response: The TP fertilizer ban may help reduce how much phosphorus is being applied in urban
areas. However, the P ban did not immediately turn off all P contributions from lawns. The primary
reason for having a P ban is that the soil already has more than enough P from past practices and no
more needs to be added to sustain a healthy lawn. Until the P in the soil is drawn down, over many
years of not applying additional P, P will still be delivered during rain events that wash off soil from
lawns. As mentioned earlier, MS4s will need to re-evaluate their stormwater management plans to
make sure they are in compliance with WLAs expressed in the TMDL.
MEP does not apply in TMDLs.
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 Monitoring
40. Comment: Adequate future monitoring should be an identified component of the Plan with the
appropriate level of commitment to ensure that sufficient data will be available to measure progress.
(GBMSD Burkholder, MEA and Clean Wisconsin)
Response: Consistent with the Department’s Statewide Monitoring Strategy, follow-up monitoring
is a regular feature of Wisconsin’s efforts to determine if applied management has been successful.
This monitoring is currently referred to as “Tier 3 monitoring” and includes evaluation of the
efficacy of TMDL implementation efforts. In addition, EPA requires states receiving federal Clean
Water Act funds to periodically document the level of success of pollution remediation efforts
supported by those funds. Accordingly, WDNR will dedicate available resources to monitoring to
document any water quality changes associated with eventual implementation of the TMDL.
Agriculture
41. Comment: How will the TMDL impact my dairy operation (CAFO)? (Brick, Harke)
Response: Producers in the TMDL area are currently required to be in compliance with statewide
agricultural performance standards (e.g., meet tolerable soil loss or “T,” eliminate direct runoff to
waters of the state, implement a nutrient management plan) as is currently required under state law
(Wisconsin Administrative Code NR 151.02). In some agricultural areas of the Lower Fox River
Basin, agricultural reductions for TSS and TP will be needed beyond those achieved through
compliance with existing state performance standards. If additional reductions from agriculture are
identified through the TMDL implementation planning process, WDNR will need to create a
targeted performance standard.
42. Comment: We are dead against the WDNR draft TMDL for the Lower Fox River Basin. Why are
you making farms reduce nitrogen and phosphorus levels? It is a known fact that golf courses, parks,
lawns, geese, waterfowl, septic and city water treatment plants are much more disastrous than farm
lands. (Vanden Elzen)
Related Comment: Why is agriculture the primary focus of the TMDL when there are several other
factors? WDNR does little to account for other sources of phosphorus and suspended solids such as
in-stream sediment loads, residential onsite septic systems, golf courses, wildlife, waterfowl, and
domestic pets. (Brick, Harke, DBA)
Response: The draft TMDL only addresses TP and TSS, not nitrogen. The purpose of a TMDL is
to look at all the potential sources of the pollutants causing the impairments (TP, TSS) and then
determine the contribution coming from each source and identify what reductions are needed from
each source. Once the sources are identified, each source is given a reduction in order to meet water
quality goals. The TMDL analysis did quantify what was coming from agriculture, golf courses,
parks, lawns, sewage treatment plants, etc.
In some subwatersheds in the Lower Fox River Basin, agriculture is the primary source of TP and
TSS to local water bodies. Water quality data from the last 30 years show that agriculture is the
greatest contributor of TP and TSS in the Lower Fox River Basin. Given that agriculture is the most
significant contributor to impairments in the LFR Basin, the TMDL identifies that a majority of the
load reductions come from this sector.
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 The additional sources mentioned above were also considered during the TMDL modeling, but they
contribute very small percentages of TP and TSS to local waterways. For example, the amount of
phosphorus coming from golf courses is minimal (0.3% of the load) compared to agricultural
sources in the Lower Fox River Basin (46%).
Pollutant loads from wastewater treatment plants were also quantified and make up ~16% of the
total pollutant load. Over the past 20 years, they have made significant strides in reducing their
discharge due to state and federal regulations. Still, municipalities (stormwater runoff) and waste
water treatment facilities will be required to reduce their loads by significant amounts in this TMDL.
43. Comment: The proposed load reductions assigned to agriculture are clearly not equitable and in
fact, the Department’s explanation of these reductions calls into question the scientific basis for the
entire TMDL. For these reasons, we respectfully request the Department significantly revise the load
reductions assigned to agriculture before finalizing the Draft LFR TMDL. (DBA)
Response: Please refer to the response #41 above, as agriculture does make up the majority of the
contribution of TP and TSS loading, this sector is assigned reductions proportional to the load after
other loading reductions from permitted entities have been made. The allocation strategies are clearly
defined in Appendix C of the TMDL. On December 2, 2009, a stakeholder meeting was held at the
Fox Valley Technical College in Appleton, with an open forum for interested parties to provide
suggestions on how to improve the allocation strategies. More than 80 people attended this meeting,
and small group discussions were beneficial. Based on comments received, the TSS allocations were
adjusted for the final draft TMDL to make sub-basin reductions more equitable.
44. Comment: WDNR should use Snap-plus software to assess nonpoint loading and assign reductions
on a site-specific basis. Because this information is readily available, WDNR must use site-specific
information to establish agricultural load allocations. (MEA and Clean Wisconsin)
Response: The potential for site-specific reductions will need to be addressed via the TMDL
implementation planning process and will depend on the data that are available regarding individual
sites or fields. WDNR agrees that SNAP-Plus software can be an extremely useful tool to identify
potential risk of nutrient loading from cropped fields. While the amount of acreage covered under a
nutrient management plan (NMP) increases every year, a significant portion of the cropped acreage
in the state is not covered under a NMP. In addition, many NMPs can and have been developed
without the use of SNAP-Plus. Over time, the number of farms and amount of cropped acreage
falling under an NMP and developed using SNAP Plus will increase and become more readily
available. Funding for county and WDNR staff to help assist with collecting data and modeling at
this scale of the TMDL is currently needed.
45. Comment: What will be the cost to comply with the TMDL (for Dairy Operations, Farmers)?
(Brick, Harke, Vanden Elzen)
Response: Costs will vary depending on an operation’s current management practices and
associated level of pollutant delivery compared to needed reductions in delivery. Operations that
have poor management practices (high soil erosion, high phosphorus soils, direct runoff from
feedlots to surface waters) are more likely to incur more costs than producers that are already in
compliance with state agricultural performance standards. In addition, operations in subwatersheds
with more significant pollutant contributions may need to implement additional BMPs to reduce TP
or TSS. Cost sharing is available through a variety of federal, state, and local funding programs and
in many cases must be offered before a farmer can be required to meet the required nonpoint
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 pollutant reductions. The Targeted Runoff Management Grant Program is WDNR’s primary
program for funding TMDL-related agricultural projects. Landowners are encouraged to seek lowcost, innovative approaches for water quality improvement. Adaptive management strategies or
phased implementation, as allowed by law, may be recognized as a mechanism to achieve water
quality goals in a cost-effective, equitable manner.
46. Comment: Agriculture should not be responsible for naturally occurring sources of phosphorus and
sediment (Harke).
Response: WDNR does not hold agriculture responsible for natural background sources of TP and
TSS in the TMDL. Before determining load allocations for the TMDL, natural sources of
phosphorus and sediment (background soil levels, sources from wetlands and forested areas) were
determined and the target or goals of the TMDL are not set lower than these natural background
levels (e.g., natural background in this TMDL area is about 0.03 to 0.04 mg/L TP, while the targets
for the streams and rivers are 0.075 and 0.1 mg/L TP, respectively). The load allocations assigned to
agriculture reflected in the TMDL, are from croplands, barnyards (feedlots) and pasture only.
47. Comment: The TMDL report states that the discharge from CAFOs from farm fields is
unregulated, however this is not true since all CAFOs must adhere to a Nutrient Management Plan
to make sure farming practices do not exceed T loss for any given field and that only nutrients
meeting crop needs are applied. The positive influence of nutrient management planning was not
included in the report. (Ostrom)
Response: Section 4.1.4 of the TMDL report states “Land application of manure from CAFOs,
however, is not included in the assumption of zero discharger. “Loading of phosphorus and
sediments from land spreading is accounted for in the nonpoint source loads. WDNR recognizes
that CAFOs are adhering to nutrient management plans. More stringent nutrient management plans
and tillage practices may be needed (on various sizes and types of farms, not just CAFOs) as further
modeling is conducted on a farm-by-farm basis through the TMDL implementation planning
process. If more stringent targeted performance standards are needed, the Department will comply
with existing rules and regulations to implement the TMDL.
Miscellaneous
48. Comment: Any TMDL requirements need to be integrated with the new NR 102 and NR 217 rule
package. The recently passed NRB resolution to establish a TMDL implementation work group
should provide significant assistance in this process. (GBMSD)
Response: TMDLs alone are not regulatory tools. However, implementation of TMDLs does occur
through other state laws and regulations. WDNR recognizes the need to connect newly revised rules
with TMDLs and agrees that the formation of a TMDL implementation work group is needed to
assist in this process.
49. Comment: My concern is that once you reach acceptable water quality, there will still be some
pollution getting in there and nothing more will be done to reduce it since it meets the standards. I
don't want the water quality to simply meet a standard. I want it to be the best it can possibly be!
(Thundercloud)
Response: A TMDL is defined as the total amount of a pollutant a body of water can receive and
still meet water quality standards. Wisconsin’s water quality standards, whether narrative or numeric,
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 are set to meet designated uses (in that people can fish and swim in the waters of the state). It is
important to recognize that even if we shut off all the anthropogenic sources of phosphorus and
total suspended solids, there would still be a small amount in our surface waters because both of
these naturally occur. This is considered “natural background” and also factored in while
determining targets for the TMDL.
50. Comment: I am supportive of the TMDL, especially the application of adaptive management which
will allow flexibility as water quality objectives are approached. Our mass balance model agrees with
the projections outlined in Appendix A; however, estimates over the past 15 years show that the
ratio of loading of total dissolved P to total P has increased in recent years. This may make it difficult
to reach Secchi Depth and blue green algae objectives since the phosphorus still entering Green Bay
will be more available to the algae. (Dolan)
Response: Comment noted. If the narrative water quality goal for Lower Green Bay is not met once
the watershed is meeting target loads outlined in the TMDL, the TMDL may be amended in the
future.
51. Comment: The TMDL allocations do not appear to consider compliance costs. Please consider
developing TMDL allocations based solely on cost. An Optimization Analysis to show the “most
cost effective combination of restoration scenarios that will achieve TMDL targets for TP and
TSS…” was included in the original scope of work by EPA and not included in the final report.
(Vande Hey, CSWEA, City of Appleton, Village of Allouez, MEG, GBMSD)
Response: Costs were considered early in the process as part of TMDL development using cost data
provided by several communities and facilities in the basin. However, after considering several
methodologies, costs could not be the basis of the allocation strategies for the LFR Basin TMDL
because there is a high degree of variability for each municipal and industrial WWTF, MS4, and
agricultural BMP. Regardless, the contractor made some general assumptions and a load and cost
optimization analysis was completed for the TMDL. This resulted in no optimal scenario as
maximum implementation of all of the BMPs in the agricultural sector (~10 being reviewed at
maximum (feasible) implementation rates) could not meet water quality standards. Although
evaluating costs is one of the “approved” methods by EPA for assigning allocations in a TMDL, the
primary goal of the TMDL is to meet water quality standards. Costs may be considered during
TMDL implementation and updating the optimization model may be necessary to find the best
scenarios by thinking outside of the box and getting the “biggest bang for the buck” as we move
forward to meet water quality goals in the LFR Basin.
52. Comment: Pollutant trading may provide a more cost-effective means to meet TMDL allocations.
When does WDNR anticipate completing state-wide statutes, rules, and trading ratios for “pollutant
trading”? (Vande Hey)
Response: WDNR’s July 1, 2011 Water Quality Trading Report to the Natural Resources Board
includes recommendations on statutory changes and guidance development for water quality trading.
Statutory changes need to be made by the Legislature and guidance will be developed over the next
year in consultation with stakeholders. The report recommended against the drafting of rule
language.

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 53. Comment: Overall the draft Fox River TMDL report appears to be a well-developed and thorough
document. We commend the WDNR for the high level of public participation in this TMDL,
particularly in the early stages. (CSWEA)
Response: Thank you. WDNR had many engaged partners (including but not limited to UW-GB,
UW-Extension, UW-Sea Grant, Oneida Nation, GBMSD, and all the Technical Team, Outreach and
Ad Hoc Science Team Members) throughout TMDL development to encourage public participation.
This TMDL has been nationally recognized for its public participation efforts during TMDL
development and we hope this will continue with local support through TMDL Implementation
Planning.
54. Comment: The City does not agree that stakeholder participation and input was adequate for the
development of this plan. Explanation of the plan to those most impacted by it did not occur. We
have been given 30 days, over a holiday, in which to read and try to understand the plan. Multiple
sessions to explain the science, modeling, assumptions, etc. should have occurred for all those
impacted by the plan. (City of Appleton)
Response: WDNR made reasonable efforts to involve stakeholders throughout the development of
the TMDL. Every Technical Team meeting was posted for public noticed on WDNR’s “Meeting
and Hearing Calendar” website. These meetings were open meetings that provided an opportunity
for any interested party to attend to learn more about the TMDL development process. Local
officials (county and city) were sent a letter regarding the TMDL early in the process, which
explained that WDNR would be happy to meet to discuss the TMDL and how individuals may be
impacted. On December 2, 2010, an all-day allocation strategy meeting was held at the Fox Valley
Technical College in Appleton to explain the different components of the TMDL and provided an
opportunity for active participation, including stakeholders’ ability to make informal comments in a
small group setting to WDNR regarding the TMDL. Lastly, WDNR invited the City of Appleton to
participate on the Technical Team. The City declined to participate (letter dated to Sue Olson on
September 22, 2008 and declined, invite further extended to Chris Shaw and declined).
55. Comment: The portion of the title “and Watershed Management Plan” is confusing, particularly
since the implementation plan has not yet prepared for this TMDL. (CSWEA)
Response: As noted in section 7.2, Oneida Nation has been actively involved with the development
of the TMDL. Because TMDLs may not be written within reservation boundaries, the contractor
has included Oneida’s “Watershed Management Planning” effort as part of a chapter of this TMDL.
Additional language was added in the Introduction of the report to further explain the title.
56. Comment: A better map showing rivers and subwatersheds upstream of Lake Winnebago may be
helpful. (CSWEA)
Response: The TMDL was written for the Lower Fox River Basin (from the Outlet of Lake
Winnebago to Lower Green Bay). Upstream sources will be accounted for through the development
of the Upper Fox/Wolf TMDL and the maps requested will be included in that report.
57. Comment: A nitrogen TMDL is needed to protect and restore water quality in the LFR Basin and
Lower Green Bay. (Burkholder)
Response: Currently there are no numeric water quality standards for nitrogen in Wisconsin, and
therefore, no surface waters listed on the 303(d) Impaired Waters List. Adhering to the Clean Water
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 Act, WDNR is required to develop TMDLs for 303(d) Impaired Waters. WDNR recognizes that
nitrogen may be a pollutant of concern caused by anthropogenic sources, but more monitoring data
is needed to determine nitrogen-related impairments in Wisconsin surface waters. In addition, BMPs
installed to implement the TMDL and capture phosphorus may also reduce nitrogen loading to
surface waters.
Implementation Stormwater
58. Comment: Please consider MS4 permits that are in compliance with Phase II requirements in
compliance with the TMDL. (CSWEA)
Response: Meeting Phase II requirements may go a long way toward meeting the TMDL
requirements, however, the Phase II requirements are separate from the pollutant reduction goals
specified in the TMDL. Meeting Phase II requirements does not mean that the water quality goals
specified in the TMDL are being met.
59. Comment: The report should clarify in the text that MS4s should refer to the “Sub-Basin Loading
Summary” chart to identify the required allocations per subwatershed. (Brown County Planning
Commission)
Response: This language is included in section 6.1.2 of the TMDL report. In addition to showing
each MS4’s WLA on pages 42-86, Appendix D includes additional tables to summarize each MS4’s
WLA by subwatershed and in total (for both TP and TSS). This will be important to refer to during
implementation planning.
60. Comment: The Lower Fox River mainstem is significantly high in reduction needs for MS4s. Why is
this? Can this be accomplished and will municipalities have a longer term schedule to get to the
higher percentages needed? Has the Department considered some communities can not meet
requirements in their Phase II permits, yet go above and beyond those requirements as outlined in
the TMDL? (Brown County Planning Commission, City of De Pere)
Related Comment: The City does not support the plan because it sets numeric limits that cannot
be met by current technology, unless the removal of existing affordable housing for the placement of
structural stormwater management practices is considered a technology. New technologies may exist
in 20-30 years, but no plan should go on that long without multiple updates. Until such time as that
technology exists, municipalities and industries are a target for lawsuits. (City of Appleton)
Response: Reductions are higher in the main stem reach of the Lower Fox because of the higher
loadings coming from sources in the Lower Fox main stem sub-basin. The TMDL sets reduction
goals to meet water quality but does not specify implementation methods or timelines. It is
anticipated that extended implementation timelines, pollutant trading, and other implementation
tools will be available to municipalities to help meet TMDL allocations.
61. Comment: Will trading % among the subwatersheds be allowed, since all watersheds drain to Lower
Green Bay the net effect overall is likely the same. (Village of Allouez, City of De Pere)
Related Comment: How will “averaging” for stormwater be accommodated once the TMDL is
approved (example, the municipality is currently meeting 40% by averaging two sets of outfalls-will
this be the case if both sets of outfalls are in two different watersheds?) (Brown County Planning
Commission).
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 Response: TMDL reductions are specified for impaired segments. Municipalities can average
reductions provided that the allocations for specific impaired segments are maintained. Also,
municipalities that drain to the same impaired segment can share loads and reductions provided that
the overall target is met.
62. Comment: It is unclear from the Draft TMDL how the new TSS allocations will be integrated with
WDNR’s recently-approved NR 151 rule package. There is no reference to NR 151 in the TMDL or
how those provisions will be integrated into the NR 151 process. In the absence of an integrated
plan, the TMDL must make clear that the proposed allocations will not be enforceable in MS4
permits until an implementation plan is developed. (League of Wisconsin Municipalities)
Response: The municipal permits already contain language regarding requirements for evaluation
and implementation of TMDL allocations.
63. Comment: Please consider a formal implementation plan to show how draft allocations for MS4s
(up to 65% in some cases) may be met through trading and watershed permitting. (City of De Pere,
League of Wisconsin Municipalities)
Related Comment: We request a graduated approach to water quality improvement be
implemented for the Lower Fox River Basin and an initial [MS4] waste load allocations be
established that is lower than the longer term goal. As reductions are accomplished upstream, further
improvements can be required in the LFR Basin. (Village of Bellevue)
Response: TMDL development is completed to identify the reductions needed to meet water
quality standards. TMDL implementation plans are not required by EPA. However, WDNR
recognizes the need to be flexible and is working on creating a water quality trading framework that
may be used in TMDL implementation planning.
64. Comment: Because of the close proximity of Austin Straubel International Airport (ASIA) within
the Village of Ashwaubenon, and ultimately the Fox River, consideration and clarification needs to
be made on how the FAA recommends wet detention ponds 10,000 ft. from AISA. This greatly
impacts any ability the Village has in meeting mandated water quality goals. (Village of
Ashwaubenon)
Response: WDNR is aware of FAA concerns about wet detention ponds and other possible wildlife
attractants near airports. The FAA Advisory Circular 150/5200-33B dated 8/28/2007, Hazardous
Wildlife Attractants on or near Airports, makes recommendations for existing and new stormwater
management facilities within a specified separation zone. For municipalities affected by the FAA
recommendations, WDNR believes that a thoughtful analysis of stormwater treatment alternatives
that assesses the appropriateness of a given treatment practice within the separation zone will
provide a good balance between FAA concerns and the state’s effort to attain water quality goals. To
that end, WDNR is considering what resources and guidance municipalities need to make
appropriate storm water planning decisions where wildlife attractants are a concern.
65. Comment: The TMDL implementation plan should allow for municipalities and landowners to
receive credit (e.g., through water quality trading) for projects that remove P-laden sediment,
improve habitat, and stabilize stream and river banks. (CSWEA, City of Appleton)
Response: Credit can be given for reductions that occur from sources that are assigned allocations
in the TMDL. This would not include improved habitat but could include removal of P-laden
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 sediment and stabilization of streams and riverbanks. Stabilization of stream and riverbanks may be
viable given that the pollutant loading models used in the TMDL were calibrated to monitoring data
that includes loads from stream and river banks.
66. Comment: Bank Erosion is a major source of TSS in some communities; will WDNR recognize
bank stabilization projects as solutions to TSS requirements and to reduce requirements in upland
areas of the community? (Kaukauna, Vande Hey, Village of Allouez)
Response: A stream naturally moves and may be eroding in one area while depositing sediment in
another. However, in urban settings the flows can become flashy and erosive, scouring out the
stream and speeding up the natural process. Armoring of the banks in critical locations may become
necessary for stability. There are means to calculate the rate of erosion and to estimate the amount of
sediment released to the stream. A requirement under Public Education and Outreach section 2.1.4
in the MS4 permit reads: “Promote the management of stream banks and shorelines by riparian
landowners to minimize erosion and restore and enhance the ecological value of waterways.” The
permit does not require stream bank stabilization because it is focused on TSS which is a surrogate
for pollutants from urban surfaces.
Implementation Wastewater
67. Comment: How will the load reduction goals be translated into individual WPDES permits?
(GBMSD)
Response: As mentioned in Section 7.1.1., once the TMDL is approved by EPA, limits will be
incorporated into permits consistent with Wisconsin Administrative Code NR 217.
68. Comment: We agree that it makes sense to transfer LAs to MS4 WLAs as land is urbanized but
suggest that wording be change to include transfer from LAs to WWTF WLAs too. (CSWEA)
Response: A framework for transferring LAs for agricultural areas to WLAs for urbanized areas or
WWTFs does not currently exist. EPA policy requires a modification of the TMDL for the
reallocation of LAs to WLAs. WDNR has discussed the issue with EPA and is awaiting guidance
from EPA on how to proceed to avoid modification of the TMDL for transfers between LAs and
WLAs.
69. Comment: We oppose the imposition of new permit limits before the formal implementation plan
has been developed. (MEG, City of Appleton, GBMSD)
Related Comment: The implementation procedures must reflect the same flexibility that we are
asking of the Lower Fox River TMDL to accommodate results from the Upper Fox River TMDL. It
appears that the adaptive management provisions included in the final version of proposed changes
to NR 217 could provide for this flexibility. We strongly urge the Department to provide as much
implementation flexibility as possible for WPDES permit holders, including use of adaptive
management. (Wisconsin Paper Council)
Related Comment: It is critical that the final TMDL for the Lower Fox River allow for the
adjustment of load allocations based on completion of the Upper Fox River TMDL. Implementation
of the Lower Fox River TMDL should be delayed until corresponding studies have been completed
for the rest of the Upper Fox/Wolf Basin (Wisconsin Paper Council, MEG, Village of Allouez)
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 Response: Upon federal approval of the TMDL, WDNR will work to seek the maximum flexibility
in timelines associated with implementation of Wasteload Allocations. In doing so, WDNR will
utilize all available tools – including flexible approaches to control pollutants in administrative rules
as well as timing of permit issuances – to ensure that stakeholders can collaborate for the most
effective options to implement the TMDL.
70. Comment: Nonpoint source load allocations cannot be enforced if cost-share funding is not
available. This will be a burden on point sources with little improvement in water quality, since
nonpoint source loading is a significant portion of the loading. With that in mind, TMDL relatedWLA should not be included into permits until after the implementation plan is written and
significant funding is secured for nonpoint source controls. (CSWEA, City of Appleton, GBMSD)
Response: Please see response for Comment #69.
71. Comment: Because of the potential for modifying the TMDL and WLAs in the future, any TMDLrelated WPDES permits limits should be accordingly adjustable and not subject to additional
antidegradation and antibacksliding regulations. (CSWEA)
Response: TMDLs are able to be modified in the future as new science and technology is available.
However, any antidegradation and antibacksliding regulations for impaired water bodies in the State
of Wisconsin would still apply regardless of a TMDL situation.
72. Comment: MEG recommends that the WDNR’s implementation plan include:
•

Maximum flexibility in how load reductions are achieved including watershed based trading.

•

Allow for the application of specific allocation methodologies for particular reaches or
stream segments within the Lower Fox River Basin.

•

Account for the variability in ambient concentrations throughout the Lower Fox River
Basin.

•

Recognize and reflect the impact of legacy phosphorus and sediment loads.

•

Consider cost-effectiveness and the net environmental benefit of alternatives.

•

Include a stepped implementation approach whereby prior load reductions are recognized
and additional reductions from those sectors are not required until all sectors have achieved
required baseline conditions identified as part of the implementation plan.

•

Include a detailed monitoring strategy for determining the impact of load reductions on
water quality and biotic integrity.

•

Contain an implementation schedule and target attainment timelines.

•

Utilize cost-effectiveness and net environmental benefit as overarching considerations in
defining final allocation methods.

•

Consider a watershed based permitting approach to promote cost effective solutions and
promote the likelihood of trading.

Response: Comment noted.

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 73. Comment: We strongly encourage costs to be considered during implementation planning for this
TMDL. (CSWEA, Village of Ashwaubenon, City of Appleton, GBMSD)
Response: Comment noted.
74. Comment: The creation of compliance schedules that allow POTWs to reduce TP and TSS over
multiple WPDES permits would lessen the economic hardship on rate payers and similar to NR 217
setting reduced limit over to 2 or 3 permit cycles would allow for the treatment technology to mature
(to reduce capital and O&M costs). (City of Appleton)
Response: Please see response to Comment #69. WDNR realizes the importance of flexible
schedules to comply with water quality standards and TMDL WLAs in permits.
Implementation Agriculture
75. Comment: The potential that most, if not all, the TP and TSS reductions needed from load
reductions, will likely be imposed on WPDES permitted farms is troubling. It is unlikely there will be
adequate cost share funding to broadly implement TP and TSS reductions on all farms in the LFR
watershed. That leaves 15 CAFOs in the LFR watershed to bear the brunt of any TMDL
implementation measures. (DBA)
Response: As identified in the Reasonable Assurance Section (7.1) of the TMDL report, all crop
and livestock producers in the LFR Basin will be required to comply with state agricultural
performance standards and prohibitions in Wisconsin Administrative Code NR 151. Further
reductions beyond this for CAFOs and non-CAFOs would be identified through the TMDL
implementation planning process.
76. Comment: When WPDES CAFO permits are reissued will they contain additional land spreading
restrictions that are “consistent with” the TP and TSS load reductions assigned to agriculture?
WPDES permitted farms already comply with the most stringent nutrient management planning
requirements (meet T and PI of 6) to meet crop needs. Imposing further limitations on tillage
practices and nutrient application may well render fields in the LFR basin non-farmable which would
have a devastating impact on the already struggling Wisconsin dairy industry. (DBA)
Response: Further limitations on WPDES permitted CAFOs, if needed, will be identified through
the implementation planning process. It should be noted that CAFOs have achieved PI’s less than 6
using current farming BMPs. The impact of further reductions in PI requirements, should they
occur, would be highly dependant on current farming practices and may or may not require
significant changes at an operation.
77. Comment: Firm regulatory requirements and the need for cost-sharing for agricultural dischargers
are necessary and must be implemented if water quality is to improve. (Village of Ashwaubenon,
Village of Allouez, GBMSD, City of De Pere, Village of Bellevue)
Response: WDNR agrees that state and local regulations, in conjunction with cost-sharing to
address agricultural sources of TP and TSS, are a critical component of TMDL implementation.

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 78. Comment: WDNR should work with counties to develop nutrient management plans for priority
farms in each sub-watershed. WDNR should set dates to perform on site monitoring in order to
ensure the plans are being followed. (MEA and Clean Wisconsin)
Response: It is expected that most compliance checks on non-permitted operations will occur
through local agencies (counties, towns) with WDNR monitoring compliance for WPDES-permitted
CAFOs.
Other Implementation Comments
79. Comment: Members of CSWEA-Wisconsin could be a valuable resource to WDNR on
implementation issues such as cost-benefit evaluations, NPDES permit language, water quality
trading and monitoring and would like to be involved as a partner in developing an implementation
plan for the Lower Fox River Basin. (CSWEA)
Response: Comment noted.

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