Wisconsin’s Fox River has a long cultural history dating back 1000’s of years when Native American cultures relied upon the river’s rich fisheries, waterfowl, and wild rice. With industrial development, the river became an economic engine for the region but it came at a cost with oil slicks, raw sewage, and wastes from the factories and paper mills. With passage of the Clean Water Act the river is considerably cleaner and now attractive for whitewater paddlers who come to enjoy the section downstream of Kaukauna Dam during high spring flows. This dam diverts flow around the natural river channel to the Badger Powerhouse, the first of which was constructed in 1907. With an interest in modernizing the facilities, the local utility is proposing a project to reconstruct the existing powerhouses and has filed a formal license application with the Federal Energy Regulatory Commission (FERC).

American Whitewater recently filed comments on this application. We identified specific deficiencies in the application that included the following:

1) Review of existing recreational opportunities incomplete: We could find no discussion of river-based recreation we know currently occurs in the natural river channel bypassed by the project.
2) Impacts of the project on river flows are not provided: All flow data presented are for areas upstream and downstream of project. A more complete evaluation of impacts of the project on the flow regime in the natural river channel bypassed by project is necessary, and is particularly important given apparent increased capacity proposed for the new project and ability to divert additional flow.
3) No quantified evaluation of instream flow needs for recreation is provided: A recreational flow study is necessary to evaluate project impacts on existing and future recreational opportunities.
4) The Commission must first examine recreational opportunities and mitigation measures, including public access to natural river channel, that have a direct project nexus before considering off-project mitigation.

Several paddlers have filed comments on this application. We encourage anyone who has run this reach to weigh in. Doing so will demonstrate interest in the instream flow needs for this reach for both recreation and overall health of the river. Identifying issues at this stage in the process will give FERC an opportunity to recommend any additional studies that must be completed to conduct an environmental review of project impacts and represents a once-in-a-generation opportunity to examine flow needs in this reach. Anyone can file a letter to the secretary at FERC at the following address:

Ms. Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street North East
Washington, DC 20426

Be sure to include the project name and number in your comments: Badger Rapide Croche Hydroelectric Project, Project No. 2677. You may also eFile your comments which enables you to sign up for notification of steps in the process. Alternatively you can send your comments to American Whitewater and we will get them filed for you.