Felling a Full-Fledged Forest is Pure Folly

Felling a Full-Fledged Forest is Pure Folly

By Debra Desmoulin.

Please alert everyone to an environmentally-destructive project that Herb Kohler is trying to push through the Department of Natural Resources in the City of Sheboygan, Wisconsin.  Please help Mr. Kohler see the advantage of choosing a less ecologically-sensitive area for his golf course project.

Here are some of the potential negative impacts that this project would engender. There are more concerns, but I will start here:

  • The Black River Forest, a 247-acre full-fledged wildlife habitat, complete with a thriving ecosystem, and a migratory flyway, owned by Herb Kohler, is threatened to be taken down and replaced with a sterile, chemically-treated golf course.
  • Kohler is requesting publicly-funded acreage from the adjacent heavily-used and publicly funded Terry Andrea State Park on the south side of his forest, in order to share the entrance for access to his golf course, even though he wouldn’t have to compromise the State Park’s entrance, because Kohler has land that could be used to enter it on the north side of the proposed golf course.
  • However, there is a quiet little community, in the Town of Wilson, adjacent to his forest on the north side, which will be disrupted by this golf course and the tournaments planned there, if Kohler’s project is allowed to proceed. In addition, Town residents’ wells will most likely run dry as Kohler’s high-capacity wells empty the aquifer, as happened to homes in the Town of Mosel for Kohler’s Whistling Straights golf course further north, but at least, the Whistling Straights land did not destroy a forest.
  • This proposed golf course is right on Lake Michigan on the east side and the Black River on the west side. The Black River is already impaired and Lake Michigan has water quality issues as well. Lake Michigan provides drinking water for the entire Great Lakes Basin, which will suffer from all of the chemical run-off from the course.
  • The Department of Natural Resources has already given Kohler the green light to dry up wetlands on his property and they are rewriting the Terry Andrea State Park Master Plan to legally give away tax-funded public parkland to Kohler, a private entity. The environment will suffer a great impact to: the air quality when all of those trees are felled; the water quality with chemical run-off; and the flora and fauna that live there, including at least a dozen endangered and threatened species. In addition, the Black River forest is a migratory flyway and has Native American mounds in several places.

Please consider working on dissuading Herb Kohler from this environmentally-destructive project and even if he wants to follow through on it, please convince him to choose a different site or even a different project altogether before it’s too late. Golf courses are never a welcome environmental asset and Sheboygan County already has about 11 of them. Environmental activists, let’s defend the trees, plants, and animals that call the Black River Forest their home.

Below, aerial view of Black River Forest, photos of forest and of Lake Michigan beach and dunes next to it:




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City of Madison continues to violate its pesticide policy

City of Madison continues to violate its pesticide policy

Photo: City of Madison employee applies Roundup along edges of Warner Park Community Center parking lot


In a 2014 post, we wrote about how the City of Madison wasn’t following its own pesticide policy. An article by Steve Elbow in this week’s Cap Times indicates that the city continues to violate its policy. An op-ed in this week’s Cap Times by Jim Powell, a MEJO board member, explains more…

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Why “safe” levels of toxic chemicals may not be safe

Why “safe” levels of toxic chemicals may not be safe

“There’s no problem; toxic exposure is too low to cause any harm” is a common response by pubic officials when citizens raise concerns about toxins in the environment, such a PCBs or atrazine.

MEJO board member Kristine Mattis explains why this assurance may not be accurate in this article published at Counterpunch Online:

Toxic Curve Ball: Why Outdated Assumptions to Determine “Safe Levels” of To…

By now, a large number of consumers are aware of the hazards of the synthetic compound bisphenol-A (BPA). Effect… [MORE]


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The City of Madison asks residents to have more environmentally-friendly yards. Many do. A few get prosecuted for it.

The City of Madison asks residents to have more environmentally-friendly yards. Many do. A few get prosecuted for it.

By Janette Rosenbaum, Madison freelance journalist.


In the 1970’s, Madison became the first city to legalize natural yards – that is, yards that feature native plants in natural-style assemblages, rather than a lawn accented by a few ornamental exotics. Any property owner, the law says, may have a natural yard if they apply for and receive a permit from the city. [1]

A property owner attempts to follow the law

Reading this law today, it seems that the intent was only ever to distinguish between deliberate alternative gardening practices and the results of simple neglect. Even so, I was surprised to find it still on the books in the fall of 2013, when I was researching my legal rights and responsibilities in regards to the house I was about to buy.

I thought it was a case of “technically still on the books” – that is, the law still existed but was no longer being enforced. Clearly many people in Madison had natural yards, yet I could hardly find anyone who knew about the law. Their yards were illegal, because they had no permit, but they had never had any problem related to their gardening practices. [2]

To be on the safe side, I contacted the city to get further information on the permit application process, then submitted an application shortly after I moved into my new house, in February of 2014. By May, when the snow finally melted, I had received no response from the city. Taking this as confirmation that the law was no longer being enforced, I went ahead with my gardening plan as I had described it in the permit application.

A full year after that, in May of 2015, I received a letter from the city saying that I was violating the laws related to non-natural yards. [3] The letter indicated that the inspector could be contacted with questions. I contacted her right away, pointing out that I had submitted an application for a natural yard permit, and therefore should be exempt from the laws covering non-natural yards.

That email was immediately forwarded to the supervisor to whom I had submitted my application. He wrote back that he had indeed been in possession of the application for over a year, but had never done anything with it. He forwarded it to another colleague, who is responsible for reviewing the applications, and whose existence had not been mentioned in any of the instructions I had been given.

This colleague wanted to give me feedback on the application in person, but did not tell me where the meeting he proposed would be held. It took multiple follow-ups, both before and after the meeting was supposed to have occurred, to get an answer to that question. This led to further delay in receipt of the feedback.

In the meantime, the inspector proceeded with the fixed schedule of letters and re-inspections related to the alleged violations, as though my application were not under seriously-belated review. This resulted in the issuance of a citation for violating the non-natural yard laws before I received any feedback on the natural yard application I had submitted sixteen months earlier.

Amazingly, the story went downhill from there. Five months later, the application is still under review, and the city is continuing to claim that I am in violation of the non-natural yard laws.

Some city departments enforce the law, others ask people to break it

These laws are not only obsolete, and not only being flagrantly violated by thousands of people all over the city [4] – they are in contradiction to current city policy. While the Sustainability Plan released in 2011 does not mention yards, careful reading and a little knowledge of environmental science reveal that natural yards support the goals of the plan, while non-natural yards contribute to many of the harms the plan seeks to reduce. [5]

In even more recent city policy, Madison released a Pollinator Protection Plan earlier this summer. The recommended actions of this plan can be summarized as four basic practices: less mowing, less pesticide use, more native plants, and more non-plant pollinator habitat. Again, natural yards support these goals; non-natural yards do not.

Under the heading of city policy so new it hasn’t even been released yet, local officials are currently rewriting the laws regarding natural and non-natural yards. While it is not yet known exactly what the new ordinances will look like, it is a safe bet that they will make it easier for property owners to have natural yards legally, and they may even increase the difficulty of having a legal non-natural yard.

Despite all of this, the city is continuing to – occasionally, selectively – enforce the outdated laws. When the owners of natural yards attempt to comply with the laws by obtaining a permit, the city can choose to be uncooperative in the review process. [6] Since it is nearly impossible to obtain a permit under such circumstances, the property owner is left with little choice other than to revert to a non-natural yard – even though the city, through its recent policies, appears to want exactly the opposite – or to continue violating the laws.

Restoring consistency

This situation must change. Residents of Madison must keep the pressure on city officials to update the laws so that they align with, rather than oppose, current policy. Support for progressive new laws can be voiced through this petition.

In addition, between now and the release of the new laws, the city must recognize that the current laws are obsolete and counterproductive. This petition asks city officials to stop enforcing the current laws, in anticipation of their soon being stricken from the books.

Finally, those against whom the current laws are enforced – including me – can suffer significant financial hardship from fighting the enforcement. As a graduate student and freelance journalist, the costs associated with this battle have put me at risk of losing the house where I have put so much effort into doing what the city says it wants everyone to do with their yards. Your support is greatly appreciated.

[1] See Madison General Ordinances 27.05(2)(f) 2, 3, and 5. Technically a permit is only required for tall grass, but a natural yard in Madison will probably involve prairie-style plantings, which will almost certainly include tall native grasses. Thus I refer to the permit being required for natural yards. Note that the form referenced in section 5 seems to no longer exist. There is a booklet containing more information on the application process, but it can only be obtained at the library of the State Historical Society.

[2] The city later told me they receive about two permit applications per year. The numbers clearly don’t add up.

[3] Madison General Ordinance 27.05(2)(f). In short, “mow your lawn”.

[4] A recent survey by an east side neighborhood association found that over 70% of homes were in violation of related ordinances. I extrapolate from their sample size of about 100 properties to the total population of Madison, recognizing that violations are probably not distributed equally across neighborhoods.

[5] For example, the plan includes a goal of improving air quality. Lawnmowers release lots of pollutants. Natural yards don’t.

[6] In my case, they have failed to answer emails, requested information that is already in the plan, claimed they are not responsible for thoroughly reading the plan, and refused to give me the checklist they are allegedly evaluating the plan against.

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International Federation of Gynecology and Obstetrics (FIGO) opinion on reproductive health impacts of exposure to toxic environmental chemicals

International Federation of Gynecology and Obstetrics (FIGO) opinion on reproductive health impacts of exposure to toxic environmental chemicals

On October 1, 2015, the International Federation of Gynecology & Obstetrics (FIGO) published an Opinion in the International Journal of Gynecology and Obstetrics stating that dramatic increases in exposure to toxic chemicals in the last four decades is threatening human reproduction and our planetary health.

See more here

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Links between health problems and endocrine-disrupting chemicals now stronger

Links between health problems and endocrine-disrupting chemicals now stronger
[PCBs, known endocrine disruptors, excavated next to Madison-Kipp]



“The list of health problems that scientists can confidently link to exposure to hormone-disrupting chemicals has grown to include diabetes, cardiovascular disease, and obesity, a new scientific statement suggests. The statement, released today by the Endocrine Society, also adds support to the somewhat controversial idea that even minute doses of these chemicals can interfere with the activity of natural hormones, which play a major role in regulating physiology and behavior.”

See full article from ScienceInsider here.



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Is the City of Madison Following Its Pesticide Policies?

Is the City of Madison Following Its Pesticide Policies?

While in Warner Park on September 8 2014, I saw a Madison Parks employee spraying Roundup[1] near the Warner Park Community Recreation Center (WPCRC), including along sidewalks just a few feet from the center’s bike racks, where many people, including young children, walk, bike, and play. It was a breezy day.[2]

A few hours later, biking through the park again on my way home, I didn’t see any standard warning signs. Two days later, walking through the park, I noticed one sign, under some shrubs, near a raingarden in a corner of the parking lot hundreds of feet from the center’s entrance and bike racks where I had seen Roundup applied two days earlier.[3] It was not at all “readily visible,” as required by the policy. The raingarden was fenced off, and it appeared as if plants in the raingarden were sprayed (presumably to eradicate non-native and/or invasive plants).[4] I walked around the raingarden and saw no other signs.

Madison’s Pesticide Policies

Citizens in many U.S. cities, including New York City, have questioned the use of Roundup and other pesticides in parks and other public places because of growing evidence of their toxic effects on animals, plants, and insects, which can lead to cascading effects on whole ecosystems over the long-term, and the health risks they pose to pets and people (e.g., see herehere, here and here and many more…).

Since at least 1991, Madison citizens have advocated for –and elected officials have passed—various policies restricting pesticides in the city. Unfortunately, it seems that these policies are being ignored, are not enforced, and/or are perhaps “forgotten” over time.

In 1991, the Madison Common Council passed Resolution 47.702, which called for limits on the use of pesticides in Madison.[5] In 2002, citizens raised concerns about the rising use of Roundup in city parks, after which Mayor Bauman issued a moratorium on its use and directed several city committees to review the use and safety of Roundup.

We haven’t yet located records of exactly what these committees decided, but presumably their reviews led to the development of the city’s Integrated Pest Management (IPM) policy in 2004. That year, the Public Health Commission also recommended the formation of a “subcommittee of pesticide experts that could assist staff with the evaluation of plans and pesticide use reports.” This subcommittee was directed, per Madison General Ordinance (MGO) 7.01(1)(a), to meet every year to review agencies pesticide use reports to see how well they complied with the city’s IPM policy and submit these reports to the Board of Health.

It appears that the IPM policy developed in 2004 is still Madison’s current pesticide policy (though the subcommittee was recently dissolved—see below). The purpose of this policy is described as follows:

“The purpose of this policy is to eliminate or reduce pesticide use to the greatest possible extent. The City of Madison agrees with the US EPA that “all pesticides are toxic to some degree, and the commonplace, widespread use of pesticides is both a major environmental problem and a public health issue.” For this reason, all departments will evaluate and give preference to non-pesticide management practices and use reasonably available alternative pest control methods, will minimize their pesticide use through Integrated Pest Management, and will use least risky pesticides as a last resort.” (highlights added).

Further elaborating on the conditions in which pesticides may be used (as a last resort), the document notes, “Chemical pesticide may be considered if: a. The non-toxic methods of pest control, such as Cultural Controls, Physical Controls, Mechanical Controls, and Biological Controls have been shown to be ineffective; And; b. Monitoring has indicated that the pest will cause unacceptable health or safety hazards, or an unacceptable reduction in the intended use of the property.”

Will the small plants growing on the edge of the Warner Park parking lots cause “unacceptable health or safety hazards or an unacceptable reduction in the intended use of the property”? It’s hard to imagine how they would do so. Our guess is that these Roundup applications were done for aesthetic reasons, which is not in line with an IPM approach.

Did Parks staff consider and/or try alternative methods to eradicate the harmless vegetation before resorting to Roundup? Parks staff and volunteers did use alternatives in the past. According to the 2009 IPM report for the Madison Parks Department (see bottom of pg. 17) in 2009 an organic herbicide called Ground Force (made of citric acid, garlic extract vinegar and yucca extract) was used for weeds in the WPCRC parking lot. No synthetic pesticides were used on the WPCRC property at all. What organic alternatives, or other types of strategies, were tried this year before resorting to Roundup?

Regardless of Parks’ rationale for using Roundup in this context, if it was following IPM policy, the non-chemical alternatives that were attempted before resorting to Roundup, and the success/failure of these attempts, should have been recorded. Moreover, the amounts and types of pesticides used in the recent treatment—as well as the amounts of types of all pesticides used during 2014 (to date) in Warner Park and previous years—would be recorded.[6] Were they?

Pesticide Policy Committee eliminated in 2013

It’s not clear how well city agencies are following IPM policies currently, especially since the ongoing oversight process established 2004 is no longer in place. In May 2013, Mayor Soglin and Public Health Madison Dane County decided to eliminate the Pesticide Policy Committee, repealing MGO 7.01(1)(a). A May 30 2013 PHMDC document explains the reason for eliminating the committee:

“The Pesticide Management Advisory Subcommittee has been a great help to the Board of Health and PHMDC staff. With the subcommittee’s help, most City of Madison agencies have become more adept at applying integrated pest management (IPM) principles and have sought out pesticide professionals that support these principles.”

After highlighting this apparent success in implementing IPM, however, the document goes on to hint at problems assuring that all agencies complied with the policy, in part because the subcommittee had little power: “However, PHMDC staff and subcommittee members have been frustrated at times when City agencies have not made changes or improvements identified in the annual reports. The current policy places the responsibility for change on the board, committee, or commission that has oversight over the agency in question (Paragraph 5d). If this body does not support change in the agencies practice based on recommendations of the subcommittee, neither PHMDC nor the subcommittee have authority to pursue further action to ensure compliance.”

Recent documents indicate that the pesticide policy is still in effect despite the dissolution of the committee. The Pesticide Management Report for 2012-2013 states the following:

“…Reduction of pesticide use is important because misuse or overuse of pesticides is both an environmental problem and a public health issue…The Policy on Pesticide Use on City Property will remain in effect and Departments will be required to submit annual use reports/plans to Health, but review of the reports will be internal within Health.  The plan for the future will be a more informal review and to make the reports available for public comment/review, most likely online….While not perfect, it was felt that the majority of City Agencies have adopted IPM principles and practices since the Policy was implemented in 2004, and formal oversight by the committee was not needed.  Also factoring, was the difficulty in maintaining a full committee in recent years.” (underlining added)

If most agencies “have adopted IPM principles and practices” and “formal oversight by the committee” is “not needed,” then PHMDC should have detailed reports of their pesticide uses and amounts for 2014 and previous years, as well as alternatives attempted. We located only one fairly thorough report online from Parks for 2009 (linked to above), but no others. For other departments and years since 2004, we were only able obtain electronic copies of “Pesticide Management Reports.” These reports are not available to the public online as far as we can tell.

Further, the “Pesticide Management Reports” are not IPM reports; they are very brief summaries by PHMDC staff that do not include any pesticide use details. For instance, the 2012-2013 Pesticide Management Report (linked to above), which is similar to all the other reports, simply states “yes” under compliance for the Parks Division, and under “Successes and Commendations” it says “Good use volunteer efforts in non-chemical control.” Under “Concerns,” it says “none.” In 2014, as we recently witnessed, Parks decided that Roundup should be used around Warner Park Center parking lots and raingardens and it is not clear whether non-chemical controls were attempted. We would like to know what the rationale was for these applications, what alternative were considered, what quantities of pesticides were used, and where they were applied.

In sum, if IPM is indeed being followed by City of Madison agencies, then reports with specific IPM details should be available to the public online, with opportunities for the public to comment and provide input on them–the “plan for the future” stated by PHMDC in the 2012-2013 document cited above. At this point we are not aware of online IPM reports or opportunities for citizen comments.

We look forward to online, detailed IPM reports for City of Madison agencies, as well as opportunities to provide comments and input on them. Hopefully this plan will be implemented soon.


[1] The applicator told me what she was spraying.

[2]The pesticide applicator was wearing shorts, a short-sleeved shirt, and no protective gear (not even gloves). This seems inadequate to protect the applicator from dermal, eye, and/or inhalation exposures from pesticide spills or aerial drift. Typical guidelines usually wear latex/rubber gloves, protective eyewear, long pants, long-sleeved shirts, etc.

[3]According to Madison’s IPM policy, “A standard notification plan that provides, at a minimum, readily visible posting for a period of 24 hours prior to a pesticide application (when possible) and a minimum of 48 hours following the application. These time intervals may be extended based on health or safety concerns. For areas that receive pesticide applications on a regular basis, permanent signs will be posted.”

[4]Raingardens are created to facilitate the infiltration of water downward to groundwater—in part, to prevent potentially harmful runoff from going into surface water. It is a good thing to keep pesticides from running off into surface water, but if pesticides are sprayed on raingarden plants (native or not), they and/or their breakdown products (often just as if not more toxic than the active pesticidal ingredients) may filter down into groundwater. This is a troubling tradeoff. What quantities of pesticides were sprayed on this raingarden? What alternatives were attempted?

[5]The details of this policy are uncertain. Some newspaper articles give the impression it restricted pesticide use in the entire city, and others suggest it restricted use only on Madison Metropolitan School District properties. We are still doing research to learn the specifics of this past policy.

[6]According to Madison’s 2004 IPM Policy: All departments will maintain appropriate records on pest monitoring data collected, pest control actions attempted (both non-chemical and chemical), and results of pest control activity. All departments will submit by February 1st an annual report to the Public Health Commission. This report will contain the following information:

a. Completed Pesticide Application Summary for all pesticide applications made in the previous year. Application data must include: purpose, location, and amount of each pesticide product applied, including the amount of active ingredient.

b. Annual summary of non-chemical pest control activities.

c. Estimated size of the total area managed for each pest problem in a given year. The area managed will likely exceed the area treated.

d. A summary of any complaints received regarding use or the perceived need for use of pesticides, including the date complaint(s) was (were) received and thenature of the complaint(s).

e. A pest management plan for the coming year. The plan will contain the following information for each type of pest problem:

1. Definition of Roles. Identify who will: serve as the IPM Coordinator, perform pest monitoring, evaluate pest control alternatives, decide which pest control alternative to use, and implement pest control measures.

2. Pest Management Objectives. Identify the action thresholds (i.e., pest population levels) to be used to decide when some type of action should be taken to control the pest problem.

3. Monitoring Plan. Describe the methods to be used to monitor the pests and the frequency of monitoring.

4. Control Method Selection. Describe the types of pest control methods to be evaluated and the criteria used to choose the appropriate control method.


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Dane County Parks Celebrates Earth Week by Cutting Down Many Large Trees

Dane County Parks Celebrates Earth Week by Cutting Down Many Large Trees

(Cut tree stumps treated with pesticides, Lake View Hill Park, April 23rd)

On Earth Day and the day after, April 22rd and April 23th 2014, contractors hired by Dane County Parks cut down several large, healthy trees near the top of Lake View Hill Park, a county “conservancy” on Madison’s north side, near Warner Park. Some of the trees, just south of the old nurse’s dorm, were mature and productive mulberries that neighborhood children have harvested delicious berries from for years. They were also habitat and favorite food sources for deer, birds, and other wildlife. Sadly, this summer animals and kids who go there for berries will find their beloved trees gone—replaced by pesticide-sprayed stumps. Happy Earth Day from Dane County Parks!

Why? When asked what the rationale was for cutting down all these large trees, Nelson Eisman, Dane County Parks staff who directed the contractors to cut the trees, said that the roots were damaging the old stone wall of the nurse’s dorm, which will be demolished soon. Further, he said, “they’re mulberries”[1] and were “obstructing the view” from the top of the hill.

Yes, you read that correctly. Large trees are being cut down by Dane County Parks, in part, to improve the view for people. In fact, in the last several years, the county has spent many thousands of public dollars [2] slowly clear-cutting the hill for the sake of “the viewshed.” Not long ago, several huge, thriving trees, including some beautiful pines on the hill that were popular nesting sites for hawks and other birds, were cut down. Again—why?

As with the Earth Week tree-chainsawing spree, we were told then that the trees were cut to improve the “the viewshed” from the top of the hill and so that “people driving on Northport Drive can have a better view of the nurse’s dorm.”  What? Really?? Yes, this is what they said. Beautiful, mature trees were cut down so people driving 35+ mph down a county highway can catch a fleeting glimpse of an abandoned, crumbling building on the top of a hill—one that will now be demolished.

Just as ironic and sad, community members involved in focus group discussions last year about the fate of the nurse’s dorm agreed that “healing” was a critical component of what should happen on the land there no matter what became of the building. Focus group participants also agreed that serious stormwater runoff problems in the highly-sloped areas around the nurse’s dorm need to be addressed asap–especially before the building is demolished and the water tower behind it torn down and rebuilt. How is cutting down many large trees going to reduce stormwater runoff? How is this healing the land?

Lake View Hill Park is county public land; it belongs to all of us. Land in this park, especially the large trees, provide precious wildlife food and habitat—habitat that is shrinking and increasingly rare in a city and county where more and more land is being developed, and trees cut down, to make way for roads, condominiums, McMansions and corporate business parks.

Where is the public discussion about what is happening on this public land?  Where is the community discussion about how the many thousands of public dollars per year are spent in this park? Is this really what Northsiders, the broader Madison community, and other citizens of Dane County want—a Lake View hill steeped in toxic pesticides and devoid of trees, so that people have a better “viewshed” from the hilltop and when driving down the road nearby?

It is a sad day indeed when those entrusted with protecting our public park land—in this case, land citizens in the neighborhood worked hard to protect with conservancy zoning—chainsaw down large healthy trees on Earth Day.

For shame, Dane County Parks!


[1] Some mulberry species are native to Wisconsin and others aren’t. At this point, the native and non-native species have hybridized and are very difficult if not impossible to tell apart.

[2] Much of the work in Lake View Hill Park is funded through fees paid to the county by the telecomm companies for having their communication equipment on the Lake View water tower. In the last few years, tens of thousands of dollars of this money have gone to buy pesticides from Dow Agro and other pesticide companies—and to cut down large trees.

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