2020 Amendment to the
2009 Kalamazoo River Area of Concern Restoration Plan for the
Loss of Fish and Wildlife Habitat and Degradation of Fish and Wildlife Populations

Beneficial Use Impairments

INTRODUCTION

This amendment to the 2009 Kalamazoo River Area of Concern Restoration Plan for the Degradation of
Fish and Wildlife Populations and Loss of Fish and Wildlife Habitat Beneficial Use Impairments
(Restoration Plan) was prepared to reflect: the progress of restoration efforts in the Areas of Concern
(AOC) program, work that has been implemented and is being planned by the Superfund program, and
anticipated funding availability for the foreseeable future. It also adds restoration projects to the list of
actions required to remove the Fish and Wildlife BUIs.|

Significant progress has been achieved since the 2009 Restoration Plan was established. The primary
goals of completing contaminated sediment remediation throughout the AOC/Superfund site and
removing obsolete dams to restore a free-flowing river system remain. Secondarily, establishing stable,
high-gradient stream channels with natural design features, along with river connectivity to the
floodplain at current and former dam sites remain high priorities for restoration.

The objective of this document is to provide updated realistic, measurable, and achievable targets for
the restoration of the Fish and Wildlife Beneficial Use Impairments (BUIs). When the original Restoration
Plan was being developed, the targets were aspirational. There was not a clear path leading directly
toward the removal of the four dam structures identified, and there were no obviously available funding
sources for such expensive projects. A great deal has changed since then.

Relevant government agencies have developed collaborative relationships among each other, with the
Kalamazoo River Natural Resource Damage Trustee Council, with responsible parties to the Superfund
site, with the Kalamazoo River Watershed Council and with other involved stakeholders. The 2009
Restoration Plan was developed prior to the creation of the federal Great Lakes Restoration Initiative.
Since then, the stakeholders mentioned above have demonstrated a willingness and ability to
cooperate, sequence, and successfully execute dam removals in the Kalamazoo River, in coordination
with remedial activities overseen by the U.S. Environmental Protection Agency (EPA) Superfund
program. A more recent development is that the City of Allegan has changed its position regarding its
dam since 2009 (see Fig. 1 for location). The City Council voted in 2019 to remove the structure and
spillway, and to begin planning for downtown riverfront revitalization.

Following successful implementation of the restoration projects listed in Table 1 of this document and
completion of Superfund remedial efforts, the Fish and Wildlife BUIs will be considered restored. In part,
this will result in nearly 50 miles of free-flowing main stem miles of the Kalamazoo River, for the first
time since the mid-1800s.

PROGRESS SINCE 2009

In 2009, the Plainwell dam sill was removed as part of a Superfund Time Critical Removal Action (TCRA).
However, the spillway was left in place. A stable, natural stream channel design with connection to the
floodplain was not achieved as part of this effort. In 2018, removal of the Otsego Township dam
structure and spillway were completed in conjunction with a Superfund TCRA. Stable, natural channel
design features were incorporated there, including floodplain access during flood flow events.


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2020 Amendment to the Kalamazoo River Fish and Wildlife BUI Restoration Plan

Figure 1. Map of Kalamazoo River Superfund site with AOC restoration project locations identified. Image courtesy of US EPA Superfund
program.

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2020 Amendment to the Kalamazoo River Fish and Wildlife BUI Restoration Plan

Removal of the Trowbridge dam is currently being conducted in phases, beginning with efforts in 2019.
The first phase, shoring up the structure to ensure stability during Superfund TCRA remedial efforts, is
complete. The next phases are currently being designed, with removal of the structure and spillway
expected to be complete in 2023/2024.

As part of the Superfund Record of Decision for Area 2 of the River, the Otsego City dam is planned for
removal by responsible parties implementing the remedial design, which is expected in 2027/2028.

RESTORATION TARGETS

Fish and Wildlife restoration targets will be achieved via projects implemented through the AOC and
Superfund programs. In 2020, the required project list was revised (see Table 1) with input and
consultation from the Kalamazoo River Watershed Council (KRWC), EPA's Great Lakes National Program
Office, EPA Superfund, Michigan Department of Natural Resources (DNR) Wildlife and Fisheries
Divisions, Michigan Department of Environment, Great Lakes, and Energy (EGLE) Water Resources and
Remediation and Redevelopment Divisions, and the Kalamazoo River Natural Resource Damage Trustee
Council, consisting of representatives from EGLE, DNR, the Michigan Department of Attorney General,
the U.S. Fish and Wildlife Service (US FWS) and the National Oceanic and Atmospheric Administration
(NOAA). This 2020 Amendment adds two barrier removal projects, the Plainwell #2 diversion dam
structures and the Allegan City dam, in addition to removing the spillway and restoring floodplain
wetlands at the former Plainwell dam site. In total, completion of the suite of restoration projects will
re-create approximately 50 miles of free-flowing main stem Kalamazoo River.

As a reminder, the 2009 restoration targets were as follows:

1)	Superfund cleanup processes are completed in the AOC at the Allied Paper Inc./Portage
Creek/Kalamazoo River site.

2)	Dams are removed at the following sites: Plainwell, Otsego City, Otsego Township, and
Trowbridge.

3)	High-gradient river channel habitat and its connection to the floodplain is restored at the
following sites: Plainwell, Otsego City, Otsego Township and Trowbridge.

4)	Expected fish community diversity is achieved as habitat becomes restored at the dam removal
sites and their upriver areas of influence.

5)	"Bird or Animal Deformities or Reproductive Problems" and "Degradation of Benthos" BUIs have
been removed.

Restoration Objectives

It is important to define the expected outcomes from the implementation of each of the restoration
projects. It is not enough to simply construct the required projects. It is also necessary to spell out
what the final ecological conditions should be and how they should function. The goal in identifying
these objectives is to design projects that result in a high-gradient river channel habitat, improved
floodplain connection, and improved fish community assemblages at each of the project locations.
The remaining projects will be designed and constructed with input from state, federal and local
partners to ensure that, when feasible, these restoration objectives are incorporated into the
designs.

Restoration designs at current and former dam locations will provide improved ecological and
alluvial river functions with the necessary constraints to prevent undesirable erosion. The following
objectives are to be considered as part of the design criteria for all restoration projects:

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2020 Amendment to the Kalamazoo River Fish and Wildlife BUI Restoration Plan

•	Improve ecological function through the use of appropriate morphology/topography (e.g.
similar as practicable to a natural, stable* channel and floodplain, including some degree of
heterogeneity), natural materials, and native species;

•	Prevent excessive aggradation or degradation of stream banks using "soft engineering
techniques" such as: large woody debris structures, root wads, rock vanes and riffles, and
establishment of native trees and shrubs;

•	Allow the river access to portions of its floodplain during the peak two-year flood flow
occurrence interval and, where practicable, increase floodplain storage capacity of the
reach;

•	Prevent erosion of potentially contaminated materials left in place after remediation; and

•	Restore upstream passage of native fish species (adults and juveniles) under a wide range of
flow conditions.

*ln this context, "stable" is meant to indicate natural dynamic stability of the river channel, as
opposed to some type of mechanical bank armoring, for example.

Restoration Projects

A comprehensive list of past and future Fish and Wildlife BUI restoration projects, including
approximate costs, funding sources, timing, and status is in Table 1 below. As of this writing, five
restoration projects remain to be constructed.

1)	Plainwell - removal of the spillway and restoration of that footprint, plus restoration of in-
stream habitat and high-gradient stream channel and banks with natural design features,
and reconnection to the floodplain as described above.

2)	Trowbridge dam - removal of the dam structure (part of planned TCRA under Superfund
authority) and restoration of high-gradient stream channel and banks with natural design
features, and reconnection to the floodplain as described above.

3)	Plainwell #2 - remove diversion dam and mill race dam structures and restore high-gradient
stream channel and banks with natural design features in main stem and mill race as
described above.

4)	Otsego City dam - removal of the dam structure (part of planned response activity under
Superfund authority) and restoration of high-gradient stream channel and banks with
natural design features, and reconnection to the floodplain as described above.

5)	Allegan City dam - removal of the dam structure and restoration of high-gradient stream
channel and banks with natural design features, and reconnection to the floodplain as
described above.

REVISIONS TO 2009 RESTORATION TARGETS

In order to more specifically define the restoration endpoints, this document revises some of the
original 2009 target language, while adding project requirements. See Table 2. For example, high-
gradient river channel habitat is now specifically described as being characterized by stone, cobble
and/or bedrock substrates, to demonstrate the removal of soft sediments at former dam sites as well as
the creation of suitable streambed habitat. The expected change in fish community diversity is now

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2020 Amendment to the Kalamazoo River Fish and Wildlife BUI Restoration Plan

more specifically defined as a shift toward communities dominated by lotic species, which are those
preferring moving water habitat.

The requirement to remove the Bird or Animal Deformities or Reproductive Problems and the
Degradation of Benthos BUIs as a required step toward Fish and Wildlife BUI removal was eliminated.
The rationale for this is that each of those BUIs has its own independent restoration criteria. Removal of
PCB contamination from the river system through the completion of Superfund remedial activities
should provide the basis for their removal. Those same remedial activities will simultaneously provide
great benefit to fish and wildlife populations. However, given that progress toward removal of the
habitat and populations BUIs is driven largely by the construction of several significant and costly
projects listed in Table 1, it is no longer seen as appropriate to delay the Fish and Wildlife BUI removals
until other BUI restoration criteria are also met. These changes break the link between pairs of BUIs to
introduce more independence in BUI status assessments.

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2020 Amendment to the Kalamazoo River Fish and Wildlife BUI Restoration Plan

Table 1 - Projects required to remove the Fish and Wildlife BUIs

Project Areas - Upstream to Downstream

GLRI Funding
Requested

GLRI Funding
Expended

Superfund

Project Status

Portage Creek Stream/Habitat Restoration



$3,350,000



Completed 2013

Plainwell #2 Removal of Dam Structures and Stream/Habitat Restoration

$4,000,000





2023+

Plainwell Dam Removal





X

Completed 2009

Plainwell Spillway Removal and Stream/Habitat Restoration

$2,000,000-
$5,000,000





2021/2022

Design Plans for Otsego City and Township Dam Removal and
Stream/Habitat Restoration



$1,070,000



Completed 2012 and 2014

Otsego City Dam Removal





X

2027/2028

Otsego City Stream/Habitat Restoration

$500,000 -
$4,000,000





2027/2028

Otsego Township Dam Removal





X

Completed 2018

Otsego Township Spillway Removal and Habitat Restoration



$ 275,000



Completed 2018

Trowbridge Dam Removal





X

2023/2024

Trowbridge Stream/Habitat Restoration

$500,000 -
$4,000,000





2023/24

Allegan City Stream/Habitat restoration, including removal of any dam
structures that are not addressed through Superfund remedial actions.

$1,000,000-
$10,000,000





2028+

Future Funding Request sub-total

$8,000,000-
$27,000,000







GLRI Funding Expended sub-total



$4,695,000





Future Funding Request sub-total

$8,000,000-
$27,000,000







Approximate Total GLRI Funding Requested

$13,000,000-$32,000,000

Uncertainty of cost estimate ranges and timelines provided are due to several factors, including: 1) potential for funding contributions from
stakeholders, 2) extended time horizons that are contingent on the schedule of Superfund remedial actions, and 3) dam structure removal
and/or restoration components implemented as part of the final Superfund remedies.

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2020 Amendment to the Kalamazoo River Fish and Wildlife BUI Restoration Plan

Table 2 is the 2020 amended list of BUI restoration targets to be achieved with the construction of
projects in Table 1. The restoration targets in this table include revisions to the original 2009 restoration
targets, plus the implementation of projects at Plainwell, Plainwell #2, and Allegan City. These targets
also include measures of free-flowing river miles that will be reconnected following the barrier
removals.

Table 2 - 2020 Amended BUI Restoration Targets

1)

Superfund cleanup processes are completed in the AOC at the Allied Paper Inc./Portage Creek/Kalamazoo



River site.



2)

High-gradient river channel habitat characterized predom

nantly by stone, cobble and/or bedrock substrates,



and its connection to the floodplain is restored at the following sites: Plainwell, Otsego City, Otsego



Township, Trowbridge, and Allegan City.



3)

A shift in fish community makeup to those dominated by lotic species is achieved as habitat becomes
restored at the dam removal sites and their upriver areas of influence.

4)

Construction is completed on all Restoration Projects included in Table 1.

5)

Free-flowing main stem river miles are re-connected through implementation of the Restoration Projects



listed in Table 1:





Morrow dam to Plainwell dam #2:

~18 miles



Plainwell dam #2 to Plainwell dam:

~3.3 miles



Plainwell dam to Otsego City dam:

~1.8 miles



Otsego City dam to Otsego Township dam

~3.3 miles



Otsego Township dam to Trowbridge dam

~4.6 miles



Trowbridge dam to Allegan City dam:

~9.2 miles



Allegan City dam to Calkins dam:

~8.4 miles



Total:

~48.6 miles
river miles, plus all the tributary mileage
(including Portage Creek) this connects

MONITORING

Following successful implementation of the restoration projects listed in Table 1 of this document and
completion of Superfund remedial efforts, the Fish and Wildlife BUIs will be considered restored.

General functional stream restoration objectives are expected to result from barrier removals and
stream channel naturalization efforts and are identified below. Natural resource agencies may choose to
evaluate some or all these objectives following project implementation to document ecological uplift
resulting from these efforts.

High-gradient river channel habitat restored, including placement of large woody debris.

> Will include stable stream channel geometry and a shift from channel substrates comprised
largely of soft sediment to those made up predominantly of stone, cobble and/or bedrock;
characterized by a diversity of macroinvertebrate populations, shifting toward species
indicative of good water quality. Increased stream velocity due to stream bed angle at
former dam sites.

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2020 Amendment to the Kalamazoo River Fish and Wildlife BUI Restoration Plan

River banks naturalized and stabilized.

>	Characterized by a shift from undersized stream widths and banks with a tendency to
undercut and erode to more appropriate channel widths and banks that have a gradual
slope and are more stable, with native vegetated erosion control.

Floodplain connection and habitat restored.

>	Re-established connection to the floodplain at Plainwell, Otsego City, Trowbridge, and
Allegan City; includes increased flood storage capacity and improved native vegetation
community composition for wildlife habitat value.

Fish community responses to barrier removals.

>	DNR anticipates conducting fish community assessments before, and three and five years
after dam removal at each of the project locations. Shifts in fish community makeup
towards populations dominated by lotic species are expected. Lotic species were identified
in a list compiled by DNR Fisheries in 1995, which is available upon request, and were
derived from research conducted by Becker (1983), Trautman (1981), Scott and Crossman
(1973), and Roth (1994).

CONCLUSION

This amendment to the 2009 Fish and Wildlife Restoration Plan is designed to identify required
restoration projects and specific endpoints for removing the Loss of Fish and Wildlife Habitat and
Degradation of Fish and Wildlife Populations BUIs. It was developed with the assistance of numerous
individuals representing natural resource agencies and other entities, including: KRWC, EGLE, DNR, US
FWS, EPA, and NOAA. Many thanks to the individuals who contributed to the development of this
document, including: Dr. Kenneth Kornheiser, KRWC; Mark Mills, Jay Wesley, Brian Gunderman, and
Matt Diana, DNR; Ralph Reznick, and John Riley, EGLE; Dr. Carly Eakin, Mandy Annis, and Dr. Lisa
Williams, US FWS; and Sue Virgilio, EPA.

August 2020

REFERENCES

Becker, G. C. 1983. Fishes of Wisconsin. University of Wisconsin Press, Madison.

Roth, N. E. 1994. Land use, riparian vegetation, and stream ecosystem integrity in agricultural
watersheds. M.S. Thesis, University of Michigan, Ann Arbor.

Scott, W. B., and E. J. Crossman. 1973. Freshwater fishes of Canada. Fisheries Research Board of Canada
Bulletin 184:1-966.

Trautman, M. B. 1981. The fishes of Ohio: with illustrated keys. Ohio State University Press, Columbus.

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