    [From the U.S. Government Printing Office, www.gpo.gov]

             ENGINEERS

               GB
               991
               .W6
               B56
               1993
               CA
             MILLER

                                                                                    5308 South Twelfth Street
                                                                                   Sheboygan, Wisconsin 53081
                                                                                          414-458-6164

                                                      Acknowledgement

                Funding for this project was made possible through a grant provided by the National Oceanic and
                Atmospheric Administration's Office of Ocean and Coastal Resource Management. The Coastal
                Management Section of the Wisconsin Department of Administration administers the Wisconsin
                Coastal Management Program.

                                                  Black River Wateished
                                                  .8.  Town of Wilson
                                                Park and Forestry Commission
                                                Sheboygan County, Wisconsin

                                                       Job No. 10531C2

            IZI
                PREPARED FOR:                                                     PREPARED BY:

                Town of Wilson                                                    Miller Engineers & Scientists
            ZQ Park and Forestry Commission                                       *5608 South Twelfth Street
                4809 Moenning Road
                                                                                  Sheboygan, WI 53081
                Sheboygan, WI 53081                                               Telephone: 458-6164
                (414) 458-2000                                                    FAX: (414) 458-0369

             C,
                                                     September 20, 1993

                               Copyright 0 1993 by J. Roger Miller and Associates, Inc. d/b/a NULLER
                               ENGR,TEERS & SCIENTISTS. This document may not be reproduced in
                               whole or in part by any means whatsoever, nor may it be quoted or
                               excerpted except for purposes of review or scholarly research, without the
                               express written consent of the copyrighter.

                                                        Table of Contents

                           EXECUTIVE SUMMARY          .....................................                i

                           1.     INTRODUCTION        .....................................                I
                                  1.1    Black River Watershed General Information    .............        1
                                  1.2    Black River Watershed Characteristics   .................         I

                           2.     RECORD REVIEW AND BACKGROUND INFORMATION                      ......     2

                           3.     SUBWATERSHED CHARACTERISTICS               ....................          3
                                  3.1    Northern Segment  ................................                3
                                         3.1.1 General Description   .........................             3
                                         3.1.2 Land Use and Political Boundaries    ...............        3
                                         3.1.3 Hydrologic Information    .......................           4
                                         3.1.4 Erosion/Water Quality  ........................             5
                                  3.2    Southern Segment  ................................                6
                                         3.2.1 General Description   .........................             6
                                         3.2.2 Land Use and Political Boundaries    ...............        6
                                         3.2.3 Hydrologic Information    .......................           7
                                         3.2.4 Erosion/Water Quality  ........................             8

                           4.     WATERSHED ASSESSMENT            ............................             8
                                  4.1    Northern Segment  ................................                9
                                         4.1.1 Water Retention    ............................             9
                                         4.1.2 Water Quality    .............................            10
                                         4.1.3 Critical Areas  ..............................            11
                                  4.2    Southern Segment  .................................             12
                                         4.2.1 Water Retention    ............................           12
                                         4.2.2 Water Quality    .............................            13
                                         4.2.3 Critical Areas  ..............................            14

                           5.     REGULATORY AND NON-REGULATORY MANAGEMENT
                                  OPTIONS      ..........................................                14.
                                  5.1    Current Regulatory Programs  ........................           15
                                  5.2    Local Regulatory Alternatives   .......................         18
                                  5.3    Non-Regulatory Alternatives  ........................           19
                                  5.4    Other Municipality Examples  ........................           20

                           6.     CONCLUSIONS/RECOMMENDATIONS                ....................        20

                           7.     CLOSURE      ..........................................                22

               MILLER
               E N G I N E E R S

                                         Table of Contents (Continued)

                      Figures .............................................    F-I to F-4

                      Tables .................................................       T-1

                      Appendix ..............................................      12 pp.

              MILLER
              E N G I N E E R S

                     EXECUTIVE SUMMARY

                     The objective of the Black River Watershed assessment was to evaluate how past, current, and
                     future land uses affect characteristics of the watershed that provide control of flooding and
                     sedimentation; and to recommend means and methods to preserve and improve the quality of the
                     watershed as pressures of urbanization increase.

                     The study divides the Black River Watershed into two key subwatersheds, each having unique
                     characteristics. The subwatersheds were labeled as the Southern Segment which is relatively
                     undeveloped; and the Nor&ern Segment which is undergoing a phase of rapid urbanization. The
                     Northern Segment includes the Fisherman's Creek Watershed, which is predominantly a developed
                     area that was evaluated in a previous report. Each watershed was evaluated from the following
                     perspectives:

                            � Each subwatershed was characterized with respect to land use, political
                               boundaries, flooding potential, and erosion potential.

                            �  The factual characterization of the watershed was combined with field
                               observations to provide an assessment of critical areas which are most susceptible
                               to flooding, erosion, and water quality degradation.

                            �  Government regulations and programs regarding land use practices which affect
                               the quality of the watershed were outlined.

                            �  Local regulatory and nonregulatory options available to the Town are presented
                               along with examples from area towns and villages.

                     Several recommendations are provided to assist the Town in developing a plan for the watershed,
                     which may include preserving critical areas, enforcing existing regulations, initiating local
                     regulatory or non-regulatory processes, monitoring water quality at key locations, and educating
                     landowners and users of the importance of best management practices.

                                                                   Forward

                     The Wisconsin Coastal Management Program was established in 1978 to direct comprehensive
                     attention to the state's 820 miles of Lake Michigan and Lake Superior coastline. The WCMP
                     analyzes and develops state policy on a wide range of Great Lakes' issues, coordinates the many
                     governmental programs that effects the coast, and provides grants to stimulate better state and local
                     coastal management. Its overall goal is to preserve, protect, and develop the resources of
                     Wisconsin's coastal areas for this and succeeding generations.

                                                                       i

                     1. INTRODUCTION

                     1.1     Black River Watershed General Information

                     A watershed is an area of land surface that contributes surface water runoff to a given point along
                     a stream, river, or lake. The Black River Watershed is the area that contributes surface drainage
                     to the mouth of the Black River at Lake Michigan (refer to Figure 1: Black River Watershed).
                     The Black River is unusual for rivers in this region of Wisconsin because it primarily flows in a
                     northerly direction and is parallel to Lake Michigan. The headlands of the Black River Watershed,
                     including its tributaries, consist mainly of fine-textured soils, with the river and tributaries often
                     cutting gullies into the soil. The velocity of the river in this headland region is much greater that
                     the main portion of the river, which flows slowly north until discharging into Lake Michigan. The
                     downstream part of the basin, parallel to Lake Michigan, can exhibit stream velocities that are less
                     than the easterly ground water underflow and at times is stagnant.

                     The purpose of this study is to evaluate conditions of the Black River Watershed; past, present,
                     and future, as they relate to water quantity and quality. This study also recommends means to
                     preserve the integrity of the watershed as pressure to urbanize increases. To accomplish this
                     objective, the watershed has been divided into two subwatersheds with differing developmental
                     stages, namely, the Northern and Southern Segments, as described in Chapter 3. The Northern
                     Segment includes Fisherman's Creek, the northermost tributary of the Black River. For specific
                     information relating to condition of Fisherman's Creek, refer to the Fishennan's Creek Watershed
                     Study by Miller Engineers September 9, 1991.

                     1.2    Black River Watershed Characteristics

                     The Black River Watershed encompasses an area of approximately 18 square miles in eastern
                     Sheboygan County. It is roughly bordered by Humboldt Avenue in Sheboygan on the north, near
                     Lake Michigan on the east, along C.T.H. KK up to and including parts of Oostburg on the south,
                     along C.T.H. A and Wilson Lima Road on the southwest, and along Interstate Highway 1-43 on
                     the northwest. Approximately 75 percent of the total watershed is contained in the Town of

                 MILLER
                 ENGINEERS
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                     Page 2

                     Wilson. Other areas containing much smaller proportions include the Town of Holland, the Town
                     of Lima, the Village of Oostburg, and the City of Sheboygan (refer to Figure 2: Political
                     Boundaries).

                     2. RECORD REVIEW AND BACKGROUND INFORMATION

                     Nfiller Engineers & Scientists conducted a review of existing information directly related to the
                     Black River Watershed. This included the following:

                             - Historical information on the rate of commercial/industrial/residentiaI

                               development within the watershed

                             - Information on previous hydrologic studies of the watershed

                             - Regional watershed information

                             0 City of Sheboygan and Town of Wilson zoning

                             0 City of Sheboygan storm sewer plans

                             0 Other information pertinent to water quality and flood management

                     A list of publications that are referenced in this watershed study are presented in the Appe     ndix.
                     Contacts for agencies and personnel which can provide further assistance regarding the watershed
                     are also listed in the Appendix.

                 MILLER
                 E N G I N E E R S
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                    Page 3

                    3. SUBWATERSHED CHARACTERISTICS

                    In order to evaluate the Black River Watershed, it was divided into two parts, the Northern and
                    the Southern Segments (refer to Figure 3: Black River Subwatersheds). Each segment has similar
                    geologic and hydrogeologic conditions. However, the political boundaries and rates of past,
                    present, and anticipated development vary widely for the two subwatersheds. By design, the
                    northern watershed is developed, or is developing quickly, and is greatly influenced by the City
                    of Sheboygan (especially the far north end). The southern watershed is largely undeveloped and
                    is mainly governed by the Town of Wilson.

                    3.1    Northern Segment

                    3.1.1 General Description

                    The Northern Segment is located at the downstream portion of the Black River Watershed. It is
                    most closely bordered on the south by C.T.H. V. There are approximately 6,000 acres (9.4 square
                    miles) in the Northern Segment. This area is defined mainly as an area of rapid development. The
                    Fisherman's Creek, studied previously, is included in the Northern Segment.

                    3.1.2 Land Use and Political Boundaries

                    Current land use in the northern segment can be divided into three categories:

                             Nearly 35% of the entire segment is residential/commercial. This area is
                             predominately on the far north end of the segment and includes nearly all the
                             land governed by the City of Sheboygan and that land in the Town of Wilson,
                             which is adjacent to the City of Sheboygan.

                MILLER
                ENGINEERS

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                             � Along Lake Michigan there is a band of heavily forested land. This land makes
                               up approximately 15% of the Northern Segment. Some residences are located
                               within this area, but they are scattered.

                             � The remaining 50% of the land in this segment is agricultural land. The majority
                               of the area has been cleared of all trees and natural vegetation, with the exception
                               of a few narrow grass swales along streams.

                     Approximately 30% of the Northern Segment is within the limits of the City of Sheboygan. This
                     area has largely been developed as residential and commercial/industrial. The remaining 70% of
                     the northern segment is within the Town of Wilson. This area is largely agriculture, however,
                     there is a strong trend toward residential development.

                     3.1.3 Hydrologic Information

                     The Black River has a distinct channel with numerous gentle meanders. It flows north and nearly
                     parallels the shore of Lake Michigan. At times, this lower northern portion of the river has very
                     slow stream velocities. These velocities can even be less than the easterly ground water flow
                     which can cause the river to become stagnant. At times, the mouth of the river is temporarily
                     closed by sand deposited from Lake Michigan wave action.

                     Distinct drainage corridors leading to the Black River are evident throughout most of the northern
                     segment. There are slight exceptions to this near Fisherman's Creek and in the City of Sheboygan,
                     where overland flow is controlled by storm sewers and roadside ditches. The Fisherman's Creek
                     at one time exhibited a large degree of meandering. Much of this original meandering was lost
                     when the stream was channelized during development. Stream meandering is vital to its integrity.
                     Meanders in a stream reduce water velocities which in turn reduces erosion along stream banks
                     and bottoms and improves the water quality. Stream and drainage corridors near the south end of
                     the north watershed show less meander, therefore, water can move quicker and with more sediment

                     to the Black River.

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                     Several properties in this area have small man-made ponds. These ponds, if properly constructed
                     and maintained, can improve water quality by retaining the water long enough for sediment to
                     settle out. They also serve to retain water during heavy rains which reduces the seventy of
                     downstream flooding.

                     3.1.4 Erosion/Water Quality

                     Soils in the Black River Watershed can be broken down into various hydrologic soil groups which
                     reflect the ability of soils to retain runoff from storms after the soils have been thoroughly wetted.
                     The different soils groups are defined in Table 1: Hydrologic Soil Groups. The soil groups are
                     based on information obtained in the Sheboygan County Soil Survey.

                     The majority of the soil on the west half of the Northern Segment is fine textured, with very slow
                     infiltration rates (Soil Group C). These soils generally impede downward water movement and
                     increase erosion during heavy storm events. Erosion is particularly a problem during spring rain
                     when the frost may not be out of the ground and crops are not planted, leaving exposed soil. The
                     quality of storm water runoff reaching the main branch of the Black River from these areas is
                     greatly diminished due to the erosion. During periods of heavy precipitation, turbidity and
                     sediment load in the creeks increases significantly. The sediment does more than cause the water
                     to become cloudy. Turbidity and sediment also impairs feeding and breathing processes of aquatic
                     organisms, eliminates or covers spawning beds, increases water temperature, and acts as a transport

                     mechanism for unwanted nutrients and chemicals.

                     The second major soil grouping includes land that is well drained with high infiltration capacities
                     (Soil Group A). In natural conditions, these soils allow for a major portion of precipitation to
                     infiltrate the soil and not contribute to surface runoff. These soils are mainly located in a band
                     approximately 1/2 mile wide along the main branch of the Black River. There is also a large
                     deposit of type A soils located south of the confluence of Fisherman's Creek and the Black River.

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                    The remaining soils are generally Soil Group B, moderately well-drained soils. These soils are
                    generally spot located in the City of Sheboygan and along the border between the type A soil at
                    the Black River and the type C soils to the west.

                    In the Northern Segment, much of the area is urbanized, especially that in the City of Sheboygan.
                    These areas likely contribute many of the common urban runoff constituents such as pesticides and
                    fertilizers from lawn application, salts and petroleum from streets, and organic (leaves and grass)
                    and particulate matter from storm runoff.

                    3.2     Southern Segment

                    3.2.1 General Description

                    The Southern Segment is the upstream portion of the Black River Watershed. It is most closely
                    bordered on the north by C.T.H. V and on the south by Oostburg. There are approximately
                    5,500 acres (8.6 square miles) in the Southern Segment. This area is mainly rural, with the
                    majority of the land used for agriculture.

                    3.2.2 Land Use and Political Boundaries

                    Current land use in the Southern Segment consists mainly of agricultural land. Except for
                    woodlots, most of this land has been cleared of all natural vegetation. Narrow grass swales are
                    visible along some of the inter    mittent streams. There is also a naturally vegetated Swale
                    approximately 118 mile wide near highway 1-43. This vegetation protects the Black River along
                    an area with extremely steep banks. Along the Lake Nfichigan shoreline, there is a band
                    approximately 1/4 to 1/2 mile wide that is heavily forested. A majority of this land comprises
                    Kohler Andrae State Park. Some residences are located within this band, but they are very limited.

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                 ENGINEERS
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                    Development in the Southern Segment is primarily near Oostburg and around 1-43 and C.T.H. V.
                    Near Oostburg the development is mainly residential, with some commercial. Along 1-43, the
                    development is nearly all commercial.

                    Approximately 20% of the Southern Segment is outside the Town of Wilson. This land is
                    governed by the Town of Lima, Town of Holland, and Village of Oostburg. The majority of this
                    land is agricultural. However, the Village of Oostburg is a growing residential and commercial
                    community. The remaining 80% of the Southern Segment is within the Town of Wilson. This
                    area is largely agriculture, with some commercial development near 1-43.

                    3.2.3 Hydrologic Information

                    Water flow within the Southern Segment of the Black River is very distinct, following the valleys
                    of ravines of wide wetlands. An especially deep valley is located due north of Oostburg near
                    C.T.H. OK and 1-43. There are many areas along the river that accommodate floodwater. The
                    ravines near C.T.H. OK and 1-43, a large wetland near the crossing of Wilson-Lima Road, and
                    much of Kohler Andrae State Park, serve as such buffers.

                    Drainage corridors, typically extending from 1-43 to the Black River, are intermittent throughout
                    most of the Southern Segment. For the most part, the drainage corridors have not been altered,
                    and run along grassed channels through farm fields. The grassed channels, although narrow, do
                    provide a buffer zone between the farm fields and the intermittent streams. This allows some
                    sediment to settle out and limits other sediment from reaching the stream.

                    In other areas, particularly around Oostburg, the drainage corridors are being channelled into
                    drainage ditches and culverts. There are also storm sewers in Oostburg which direct storm water

                    runoff to the Black River Watershed.

                    Effluent from the Oostburg Wastewater treatment facility is discharged to the Black River
                    Watershed and effects the hydraulic load to the Black River.

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                    3.2.4 Erosion/Water Quality

                    Hydraulic soil groups and related infiltration rates in the Southern Segment are very similar to
                    those in the Northern Segment. The majority of the west half of the segment is Soil Group C; fine
                    textured soils with very slow infiltration rates. These soil characteristics contribute greatly to
                    surface runoff. Along with fine-textured soils and sloping land, this soil type has a high potential
                    for surface erosion, sedimentation, and the formation of rills and gullies.

                    The soil surrounding the main channel of the Black River is very similar in both the Southern and
                    Northern Segments; mostly Soil Group A, which has high infiltration capacity. However, unlike
                    the Northern Segment, the Southern Segment has a wide strip of variable soils located between the
                    Black River and Lake Mchigan. Generally, these soils are cut and fill or alluvial deposits (soils
                    mainly deposited by meandering streams) and are too variable to be rated.

                    Soil Group B, moderately well-drained soils, are generally located along the western reach of the
                    river. These soils make up only a small fraction of the total area.

                    Near Oostburg, a large amount of the area is Soil Group D. Type D soils are clayey and/or
                    restrictive soil with very slow infiltration rates and a high water table. These soils impede the
                    downward movement of water during the course of a precipitation event. This condition increases
                    the degree and frequency of erosion, sedimentation, and increased hydraulic loading in the

                    watershed.

                    4. WATERSHED ASSESSMENT

                    The Black River watershed is located predominately in the Town of Wilson and is rapidly being
                    developed. This development often has significant impacts on the watershed. The northern most
                    branch of the Black River, the Fisherman's Creek, provides an example of degradation from
                    agricultural practices and development without consideration of the effect on the watershed.

                MILLER
                E N C I N E E R S

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                    Information from the Fisherman's Creek Watershed Study, along with the information gathered
                    from this investigation, provide insight for improving development standards throughout the Black
                    River watershed. The following sections discuss the key characteristics of both the Northern and
                    Southern Segments of the watershed. Site Photographs in the Appendix emphasize some the key
                    characteristics, both positive and negative with respect to water quality.

                    4.1     Northern Segment

                    As mentioned previously, many areas in the Northern Segment have already undergone significant
                    development while other areas are still seeing rapid development. Man-made changes throughout
                    the segment have had impacts on the watershed. If properly planned, future changes in these areas
                    may provide opportunities to reduce sediment loads in the river, minimize flooding, and improve
                    the overall water quality.

                    4.1.1 Water Retention

                    Many of the streams that lead to the Black River will naturally exhibit tendencies to flash flood
                    due to their west-east orientation and the slow infiltration soil types in the west half of the
                    watershed. In addition to this, man-made changes have also influenced the water retention rates..

                    The most significant change to the watershed is caused by the conversion of woodland to farmland
                    and the farmland to urbanization. These conversions increase the hydrologic load and reduce the
                    time it takes for the runoff to reach the river.     Where water is no longer slowed down by
                    vegetation, it can reach a stream faster and is less likely to infiltrate the soil. This results in
                    increased peak flow rates during rain events.

                    Another factor affecting the peak flow rate is the reduction of meander in the streams that lead to
                    the Black River. This effect is most noticeable near the Fisherman's Creek. Where meandering
                    has been reduced in a stream, flood storage is decreased and water velocity increases.

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                     Channelizing storm water runoff through storm sewers and roadside ditches has a similar effect
                     as reducing meanders in the stream. It allows storm water to quickly reach the river without
                     slowing the water to promote natural infiltration.

                     Wetlands and lowlands provide a natural flood buffer zone. Unfortunately, with increased
                     urbanization, lowlands and small wetlands are often filled, eliminating this buffer. Fortunately,
                     several flood buffers still exist. City, county, and state parks, as well as golf courses, often provide
                     areas where streams can safely overflow their banks without damaging residential or commercial
                     development. Some areas along the Black River have development set back from the waterway,
                     avoiding damage when the river overflows its banks.

                     Several properties and business parks in the Northern Segment have small ponds. Whether
                     designed as retention ponds or not, these ponds increase the retention time of storm water which
                     decreases the peak flow in the main channel.

                     4.1.2 Water Quality

                     Water quality can be adversely affected by two primary sources sedimentation and chemicals.
                     During periods of heavy precipitation, sedimentation due to dosion increases. Sediment can
                     change the biological, aesthetic, and physical properties of the stream. This not only makes the
                     water clou dy, it impairs feeding and breathing for aquatic organisms, eliminates or covers spawning
                     beds, increases the water temperature, and carries unwanted nutrients and chemicals. In the
                     Northern Segment, sedimentation is increased due to construction erosion and increased water flow
                     rates with channelization. As flow rates increase, the water will scour the land increasing sediment
                     loads. Wetlands and retenfion ponds can act as a buffer to slow the water and allow the sediment
                     to settle out. Silt fences along construcfion sites can also prevent the sediment from reaching the
                     streams. However, silt fences which are not properly maintained offer little help. Where water
                     velocity cannot be slowed to reduce erosion and sedimentation, riprap and vegetative cover crops,
                     such as grass, can reduce scouring.

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                     Page I I

                     Increased chemical loads not only have potential to create toxicity problems, they can also cause
                     nutrient and chemical loading to a stream that results in secondary effects. Nutrient additions
                     enhance biological growth of foreign organisms. This change in the population and character of
                     microorganisms can shift the food chain, decrease the oxygen content, and eradicate many native
                     species. Chemical loads for the Northern Segment are predominantly caused by urban storm water
                     runoff. Urban property typically includes such chemicals as: fertilizers and pesticides from
                     residential runoff, synthetic organics like gasoline, oil, and rubber from streets; road salts; and
                     other miscellaneous pollutants.

                     4.1.3 Critical Areas

                     Critical areas have been identified throughout the watershed and are shown on Figure 4: Critical
                     Watershed Areas. There areas generally include:

                             - Shoreland Districts

                             - Floodplain Districts

                             0 ShorelandAVetland Districts
                             - WDNR Wetland Designations (areas less than 2 acres are not shown for clarity)

                             0 Areas with elevations less than 600 feet

                             - 75 foot wide vegetative corridors along tributaries
                             a Southern most tributary of the Black River

                     In the Northern Segment, as Sheboygan continues to develop, the northern most tributaries will
                     need to be protected. Some negative effects of development are already visible along C.T.H. EE
                     as small wetland areas are filled in for development and construction sites do not maintain erosion
                     structures.   Other critical areas include the Arthur Jerving Conservancy at C.T.H. EE and
                     Lakeshore Drive. As mentioned previously, natural vegetation and wildlife can be very sensitive
                     to increases in hydraulic or chemical loading (refer to Figure 4 for locations of other critical
                     areas).

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                 ENGINEERS

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                    4.2     Southern Segment

                    The Southern Segment is still largely agricultural. Without careful planning, agricultural land often
                    has two effects on local waterways; it increases the sediment in the water due to erosion, and
                    increases the chemical loading due to pesticides and fertilizers. However, with careful planning
                    and well managed stream corridors, the streams can be improved to promote a natural habitat for

                    fish and wildlife.

                    4.2.1 Water Retention

                    Water retention in the Southern Segment is similar to the Northern Segment. Intermittent streams
                    that lead to the Black River have a tendency to flood due to their orientation and soil types.
                    Significant sheet flow across agricultural land in spring and fall is also a problem since, without
                    a cover crop, there is little to no vegetation to slow the water flow rate. Increased urbanization
                    in Oostburg will also increase flow rates if specific measures are not taken to retain the water that
                    is discharged into the Black River.

                    Historically, there has not been major flood damage in the Southern Segment, especially compared
                    to that near the Fisherman's Creek. This is mainly due to the lack of development in the area@
                    combined.with the significant buffer zones that exist throughout the segment. Kohler Andrae State
                    Park (sometimes referred to as Terry Andrae State Park) offers protection to the downstream
                    properties by allowing the river to flood its banks and retain the increased water load. There are
                    also several other large wetlands throughout the segment, including the wetland near the east end
                    of Wilson Lima Road. The deep valley near C.T.H. OK and 1-43 is another good example of a
                    buffer that has not been altered development. These buffers offer some flood moderation.
                    Therefore, with increasing development, care should be taken to protect and preserve these areas
                    or duplicate their capabilities elsewhere.

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                    4.2.2 Water Quality

                    In the Southern Segment, as in the Northern Segment, streams are being adversely affected by both
                    increased sediment and chemical loads. However, in the Southern Segment, the primary source
                    of sediment is from agricultural fields. Fields are most susceptible to erosion during the early
                    spring and late fall, when there is no cover crop. This is especially true for soils in the western
                    watershed which allow limited infiltration. Therefore, much of the precipitation will become

                    surface runoff.

                    However, there are several conditions in the Southern Segment that improve the sedimentation
                    problem. Cover crops and grass filter strips in the agricultural fields greatly reduce the amount

                    of sediment that reaches the streams. There are also numerous wetland buffers that allow the water

                    to slow down and settle out much of the sediment. In particular, Kohler Andrae State Park offers
                    a very large buffer zone.

                    Chemical loads are also influenced by activities in the Southern Segment. Again, agricultural
                    farmland adds pesticides and fertilizers to the streams. Livestock and barnyard runoff also add to
                    the increased nutrient loads. Although regulated, treated wastewater from Oostburg has potential

                    to increase chemical loads.

                    Increased urbanization in Oostburg, like that in Sheboygan, is adding similar urban storm water
                    runoff to the streams. This may become a significant impact on the southern most reaches of the
                    Black River (like the in the Northern Segment) Fisherman's Creek, if proper management steps are

                    not taken.

                    Although large wetland buffers in the Southern Segment can help reduce the chemical and
                    sediment load in the streams and river by natural biodegradation, care must be taken to not rely
                    only on the wetlands to clean the water. Many native species of plants and animals are very

                    sensitive to their environment.

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                     4.23 Critical Areas

                     Critical areas in the Southern Segment have been identified according to the general guidelines
                     outlined in the northern section. In this segment, special attention should be given to the southern
                     most tributary due to its special characteristics; steep slopes, significant meandering, and high
                     hydraulic load and erosion potential. Preservation buffers in this area should possibly extend
                     several hundred feet wide, particularly between Minderhaud Road and C.T.H. KK Special control
                     should also be considered on lands near Oostburg, since they are directly upstream of this sensitive
                     area. As in the Northern Segment, critical areas include wetlands.

                     5. REGULATORY AND NON-REGULATORY MANAGEMENT OPTIONS

                     The characteristics and assessment of the Black River Watershed (Section 3 and 4) indicate a
                     significant potential for water quality and quantity concerns. The impacts of current land use in
                     the watershed are already causing degradation. Future demands on the land within the watershed
                     could have compounding effects on flooding and sedimentation due to excess and uncontrolled

                     runoff.

                     Four steps for the town to control impacts and improve management strategies within the

                     watershed are:

                            - Recognizing that a potential problem exists
                            - Becoming familiar with Best Management Practices (BMPs)
                            - Educating land stewards of the impacts of using or not using BMPs
                            - Developing a method of ensuring that the BMPs are being implemented

                     The fact that the Town of Wilson has been proactive in evaluating the Black River Watershed
                     indicates that the first step (recognition of problem) has been realized by town officials. This

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                E N G I N E E R S

                    Page 15

                    report and the Fisherman's Creek Watershed Study further emphasize that a problem does exist and
                    could be magnified by encroaching urban development.

                    Becoming familiar when and where BMPs should be implemented is a vital part of the
                    management of the Black River Watershed. This responsibility ultimately lies with the land
                    stewards. However, local, county, state, and federal government must play a role in educating the
                    landowners (and users) and developing management regulations when necessary.

                    The task of educating and/or enforcing BMPs does not need to be the sole responsibility of one
                    group (i.e., Town of Wilson). A significant amount of current and pending legislation exists which
                    has an impact on land use and BUTs. The pertinent regulations which effect management of the
                    watershed are briefly described in this section. In addition, appropriate contacts for the various
                    regulations and other informational sources are listed in the Appendix.

                    5.1     Current Regulatory Programs

                    Wisconsin Shoreland Management Program (NRI 15)-The Wisconsin Shoreland Management
                    Program was initiated in the late 1960s. The purpose was to require counties to adopt zoning and
                    subdivision regulations for protection of all shorelands in unincorporated areas.

                            "Shoreland" (def per NR 115) m eans lands w ithin the follow ing distances from the
                           ordinivy high-water mark of navigable waters: 1,000 feetfrom a lake, pond, or
                           flowage; and 300 feet from a river or strewn or to the landward side of the flood
                           plain, whichever distance is greater

                    Wisconsin Floodplain Management Program M1 16 WI STATS 87.1%--The purpose of the
                    Floodplain Management Progrum is to protect human life, health, and minimize property damages
                    and economic losses. Municipalities (county, city, village) are required to develop and maintain
                    floodplain zoning maps and administer and enforce reasonable floodplain zoning ordinances.

                MILLER
                E N G I N-E E R S

                    Page 16

                            "Floodpladn" (def per NR116) means that land which has been on or may be
                            covered by flood water during the regional flood (100 year return).

                    Some of the prohibited uses in a floodplain area include:

                            9  Development causing obstruction of flood flow
                            0  Development causing increase in regional flood discharge

                            0  Human inhabited structures

                            0  Structures prone to flood damage
                            0  Storage of buoyant or dangerous materials
                            *  Sewage systems

                            0  Potable wells

                    Any new land use or change in building use within a floodplain must be authorized by the local
                    floodplain zoning administrator. Local floodplain zoning administrators within the Black River
                    Watershed are listed under Contacts in the Appendix.

                    Wetland Mgpping Units have been developed by the State of Wisconsin Department of Natural
                    Resources (WDNR) and several federal agencies, for the purpose of conserving the natural values
                    of wetland resources. The definition of a wetland can vary depending on the governmental agency,
                    however, wetlands are typically defined by a combination of soil characteristics, existence of
                    aquatic or hydrophytic vegetation, and the presence of surface water for a specified duration. The
                    wetland areas delineated typically only include individual wetlands which have an area of two
                    acres or more, however, restrictions can apply to any size wetland.

                    Any land use which could potentially have adverse effects on a wetland must undergo an analysis
                    to determine if other land use alternatives exist. If no practical alternatives exist, a wetland
                    assessment must be completed to determine if the functional values of a wetland (as outlined in
                    NR103) can be preserved.

                 MILLER
                E N G I N E E R S

                    Page 17

                    Priorily Watersheds-Voluntary participation in BNTs can be up to 70% cost shared if land is
                    designated as being within a non-point priority watershed. The Black River Watershed is not
                    currently a "prionity" watershed, but has a "high" ranking within it's local basin. The Sheboygan
                    County Land Conservation Department (LCD) can recommend watersheds rated "high" for
                    consideration as a future priority watershed.

                    Barnyard Runoff Program-Funding exists to assist farmers in constructing structures which
                    minimize effects of barnyard runoff.

                    Farm Conservation Plans-Farm compliance plans are required on all farms which have significant
                    amounts of highly erodible land. The plans are also required for farmers to remain eligible for
                    United States Department of Agriculture (USDA) assistance programs.

                    Conservation Reserve Program (CUJ-Farrns are eligible for payments when land that is easily
                    erodible or in floodplains is taken out of production for a period of at least 10 years. An approved
                    conservation plan is required for land in the CRP program.

                    Farmland Preservation Program-Farmland preservation is art agreement between the state and the
                    owner to jointly hold rights to develop the land. Agricultural land of 35 or more contiguous acres
                    can be eligible. State tax credits and exemptions from local government assessments are provided
                    to the owner to ensure that farmland is not developed in areas susceptible to development. In
                    addition to encouraging land to remain in agricultural production, the tax credits counterbalance
                    increased property taxes due to escalating land values.

                    Construction Site Erosion Control and Storm Water Mannement Ordinances-Nfinimum standards

                    for controlling erosion and storm water runoff have been developed by the state. The ordinance
                    provides regulation of any construction activity which is conducted by a state agency and:

                            0 Involves disturbance of 4,000 or more square feet of land
                            * Involves excavation/filling of 400 or more cubic yards

                MI    LLER
                E N G I N E E R S

                    Page 18

                            �  Involves road construction/reconstruction

                            �  Involves a development of 3 or more acres
                               Is likely to result in storm water runoff exceeding existing drainage facility
                               capacity; cause undue channel erosion; increase water pollution, or endanger;
                               downstream property

                    The WDNR and University of Wisconsin-(UW-Ex) are available to assist the town in developing

                    local construction site erosion control and/or storm water ordinances.

                    The regulations that have been listed in this section are the most common programs that could
                    potentially effect methods of land use. Several new regulations and changes to existing regulations
                    that could effect the management of a watershed are currently pending at the state and federal
                    levels, and should be monitored for applicability to the Black River Watershed.

                    5.2     Local Regulatory Alternatives

                    The Town of Wilson has the authority to initiate regulatory actions which will assist in preserving
                    the quality of the Black River watershed. The main regulatory avenues available to a town are
                    policy statements, zoning, and ordinances.

                    Policy statements by the town, although not directly enforceable, can provide a means of publicly
                    portraying the objectives, goals, and intent of the town in regard to management of the watershed.

                    Specialized zoning districts within the town can be developed to assist in managing the quality of
                    the watershed. An example of a district that can be formed is a storm water runoff district. The
                    formation of a specialized district can be beneficial when a drainage area involves more than one
                    political unit. A storm water runoff district also allows for fees or taxation which can be directly
                    used for implementation and enforcement of the district policies and management plans. Because
                    the Black River Watershed is mostly within the Town of Wilson and encompasses a majonity of

                 MILLER
                E N G I N E E R S

                     Page 19

                     the Town's land, policies or ordinances covering the entire town may be more advantageous than
                     creating a specialized district for the Black River Watershed.

                     Some examples of town zoning/ordinances that could potentially benefit the watershed are:

                            - New zoning to define "critical areas" to promote beneficial land uses and restrict
                               land uses causing degradation

                            -  More stringent ordinances for use of shorelands, wetlands, and/or floodplains

                            9  Ordinances requiring that all farms develop conservation plans

                            0  Ordinances requiring that all development provide approved drainage, erosion,
                               and water quality plans

                     5.3    Non-Regulatory Alternatives

                     Although regulatory programs can be effective because they are enforceable, they also can be quite
                     unpopular, especially at a local level. Several non-regulatory alternatives exist which can be a
                     means of achieving the same objectives without forcing mandatory compliance. Several non-
                     regulatory alternafives for local governments are explained below:

                            Land Preservation-Preservafion of land by the means of purchase or long-term lease
                            can be the best method of ensuring proper management of critical land areas. A
                            land acquisition plan can be coordinated with interested non-profit organizations and
                            other government agencies to minimize the financial burden on the town.

                            Economic Incentives-Economic incentives could include local cost sharing or tax
                            credits for implementing BMPs similar to the non-point source priority watershed

                MILLER
                E NGIN E E R S

                     Page 20

                             program. Under this scenario, the town would provide cost sharing or tax credits
                             to landowners that implement approved BUTs.

                             Economic Disincentives-Economic disincentives in the form of fees, fines, or taxes
                             could be implemented on those practices which have potential for impacting the
                             quality of the watershed.

                             Performance Bonds-Requiring that water quality performance bonds be posted for
                             activities which could potentially impact the watershed is an innovative technique
                             to ensure compliance of existing regulations. Failure to protect the quality of the
                             watershed would result in partial or complete loss of the bond. This could be
                             particularly effective for large construction or development projects.

                             Education/Information-Educating individuals who own or utilize lands within the
                             watershed can be an effective tool in ensuring that current regulations and BNIPs
                             are being followed and implemented. Distributing appropriate information can be
                             accomplished using numerous forums.

                     5.4     Other Municipality Examples

                     Several municipalities in the State of Wisconsin are facing similar demands on their land. It may
                     be beneficial for the Town of Wilson to investigate the initiatives of other municipalities regarding
                     local non-point pollution and runoff programs. Several municipalities (and contacts) with current
                     innovative programs are listed in the Appendix.

                     6. CONCLUSIONS/RECOMMENDATIONS

                     The Black River Watershed is undergoing increasing urbanization.              Some of the natural
                     characteristics of the watershed are highly vulnerable to degradation which can have temporary or

                MILLER
                E N G I N E E R S

                    Page 21

                    permanent effects on the ability of the watershed to control flooding and minimize sedimentation.
                    It is in the Town's interest to preserve and improve these characteristics in the course of future
                    changes in land use. If properly managed, future land use changes can occur with minimal
                    impairment, and in some cases improvement, to the quality of the watershed. Toward an
                    appropriate balance of short-term cost and long-term land and community quality, MILLER
                    recommends that the Town consider the following actions:

                               Land acquisitions or long-term leases wherever practical to preserve the following

                               11critical areas":

                                      0 Approximately 75 feet on each side of designated streams and
                                        drainage ways

                                      0 An area of approximately 300 feet either side of the southern most

                                        branch of the Black River between Minderhaud Road and C.T.H. KK

                                        (north-south)

                                      0 Land with elevations less than 600 feet U.S.G.S. paralleling the main

                                        channel of the Black River

                               When "critical area" lands are developed, action should be taken to restore the
                               land's ability to reduce runoff and sedimentation over both short-term and long-

                               term use of that land.

                            -  Provide educational materials on Best Management Practices (BMPs) that are
                               readily available to landowners/users and provide instruction on the significance

                               of BMPs

                            a  Coordinate with the Sheboygan County LCD office and VrDNR to lobby for
                               "priority watershed" status for the Black River

                MILLER
                ENGINEERS

                  Page 22

                         0 Cooperate with other governmental agencies to enforce those regulations which
                           are intended to protect water quality

                         - Initiate local regulatory and non-regulatory methods to preserve and improve the
                           quality of the watershed

                         - Develop water quality monitoring plan to measure the results of land use
                           practices

                  7.     CLOSURE

                  NULLER has appreciated the opportunity to provide the Town of Wilson with an assessment of
                  the Black River Watershed. Being located within the watershed, MILLER has a strong interest
                  in preserving and improving the quality of the Black River. We commend the Town's

              MILLER
              F N C. I N F F R r,

                   Page 23

                   proactive position regarding the watershed and will eagerly provide assistance to the Town
                   regarding any further management strategies.

                   Prepared by,

                   MELLER ENGINEERS & SCIENTISTS

                   Tammy L. Kuehlmann, E.I.T.                            Roger G. Miller, P.E.
                   Civil Engineer                                        President

                            C'
                   Rick C. Wietersen, M.S.
                   Soil Scientist

                   TLK/bij

                   WILS31C2.WSR

               MILLER
               - - - I I @ I

                                                               Figures

                    Black River Watershed (pocket)     .........................................                F-1
                    Political Boundaries  ..................................................                    F-2
                    Black River Subwatersheds:   .............................................                  F-3
                    Critical Watershed Areas (pocket)   ........................................                F-4

                MILLER
                ENGINEERS
                r @ & r - -, r @ r

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                    MILLER
                    E N.G I-N-E. E R S

                                                      Hydrologic Soil Groups
                        Soil Group                     Characteristics                    Infiltration Rates
                             A           Well-drained and excessively drained soils             Mgh
                             B           Moderately well drained                              Moderate
                             C           Fine-textured soils impede downward water              Slow
                                         movement

                             D           Clay soils and/or restrictive layer, high           Very Slow
                                         water table

                         Variable        Cut and fill or alluvial deposits, too variable      Variable
                                         to classify

                 MILLER
                E N G I N E E R S
                c,- i r ro-ri C TC

                                                                   Appendix

                   List of References                                                                  (Green Sheets)

                   List of Contacts                                                                    ( Yellow Sheet)

                   Site Photographs                                                                    (Colored Photos)

                   WILS31CIAPP

                  MILLER
                  E N G I N E E R S

                                                    LIST OF REFERENCES

                   Bay-Lake Regional Planning Commission. Sheboygan Urbanized Area Sewer Service Plan.
                   October 1989.

                   Bay Lake Regional Planning Commission and Sheboygan County Planning and Resources
                   Department. Town of Wilson, Sheboygan County, Wisconsin. Aerial Photographs. 18 April
                   1990.

                   Craven, Scott, et al. The Benefits of Well-Managed Stream Corridors. Department of
                   Agricultural Journalism, University of Wisconsin-Madison. 1987.

                   Department of Natural Resources Bureau of Water Regulation and Zoning. Wisconsin Wetlands'
                   Inventoiy--Sheboygan Coun!y T15N R23E and T14N R23E. April 1987.

                   Donohue & Associates, Inc. Flood Control Plan for Fisherman's Creek Watershed. 27 February
                   1985.

                   Donohue & Associates, Inc. Indian Meadows Detention Basin Study. February 1990.

                   Federal Emergency Management Agency. Flood Insurance Study: Sheboygan Coun!Y, Wisconsin
                   (UnincoEporated Areas). 16 December 1988.

                   Ferguson, Bruce K. "Urban Stormwater Infiltration: Purposes, Implementation, Results."
                   Journal of Soil and Water Conservation. November-December 1990: 605-609.

                   Land Conservation Departments of. Sheboygan, Fond du Lac, Manitowoc, and Calumet
                   Counties, et al. A Nonpoint Source Contrgl Plan for the Sheboygan River Watershed. October
                   1990. Draft copy.

                   Miller Engineers. Black River Water Level Study. February 1977.

                   Miller Engineers. Fisherman's Creek Watershed Study. 9 September 1991.

                   Miller Engineers. Indian Mound Bridge Hydrologic Spdy. 1975.

                   Peterson, Gary L., and Associates. General Plan: The Official Plan of the Town of Wilson
                   Sheboygan Coun!y, Wisconsin. February 1977.

                   Soil Conservation Services. Aerial photographs. 1990.

                   Sheboygan, City of Storm Sewer Plan.

                   Sheboygan, City of Zoning Districts Mgp. 12 December 1991.

                   Sheboygan County Planning and Resources Department. Sheboygan Counjy Comprehensive
                   Outdoor Recreation and Open Space Plan. September 1975.

               MILLER
               E N G I N E E R S
               c, C I F N T I 1@ T'@

                                               11ST OF REFERENCES (Continued)

                   Sheboygan County Planning and Resources Department. Shoreland--Floodplain Ordinance for
                   Sheboygan Counjy. 18 April 1989.

                   Sheboygan County Planning and Resources Department. Zoning District Mgp for Town of
                   Wilson T14N R23E. 26 December 1990.

                   Sheboygan River Priority Watershed. Steps for Urban Areas to CaU Out the Sheboygan River
                   Watertshed Plan.

                   United States Department of Agriculture Soil Conservation Service in Cooperation with Researcl.
                   Division of the College of Agricultural and Life Sciences, University of Wisconsin. Soil Survey
                   of Sheboygan Counjy, Wisconsin. January 1978.

                   United States Department of the Interior Geological Survey. Sheboygan South Quadrangle:
                   Wisconsin-Sheboygan Counjy. Photorevised 1973.

                   United States Department of the Interior Geological Survey. Shebagan Falls Quadrangle:
                   Wisconsin-Sheboygan Counjy. Photorevised 1973.

                   University of Wisconsin-Extension and Wisconsin Department of Agriculture, Trade and
                   Consumer Protection. Nutrient and Pesticide Best Management Practices for Wisconsin Farms.
                   June 1989.

                   Wisconsin Department of Natural Resources. "Fisherman's Creek Tributary (Black River
                   Tributary No. 1)." Black River Watershed. BECI and BEC2 computer software. 3-1/2" disk.

                   Wisconsin Department of Natural Resources. Wisconsin Construction Site Best Management
                   Practice Handbook. June 1990.

                   Wisconsin Department of Natural Resources, et al. A Nonpoint Source Control Plan for the
                   North Branch Milwaukee River Priorijy Watershed Project. July 1989.

                   Wisconsin State Statutes.

                   Wisconsin Adminstratative Codes. Department of Natural Resources.

                   Wisconsin Coastal Management Program. Wisconsin Great Lakes Coastal Needs
                   Assessment-Executive Summga. 1991.

                   U. S. Environmental Protection Agency. January 1993. Coastal Nonpoint Pollution Control
                   Program: Program Development and Approval Guidance.

               MILLER
               E N G I N E E R S

                                                                     Contacts

                     Other TownNillaze Promans

                             Town of Caledonia, Marcel Dandeneau (414) 639-6209
                             Town of Norway, Jeanne Branzolewski (414) 895-6335
                             Village of Grafton, Mark Gottlieb (414) 375-5325
                             Muskego/Wind Lake Watershed, Kathleen Aron (414) 895-6457

                     Flooblain/Shoreland Administratois

                             Sheboygan County Zoning Administrator, Chuck Mayer (414) 459-3060
                             Southeast District VvDNR, Kathy Karmasz (414) 263-8682

                     State Wedand Coordinator

                             State Wetland Inventory Coordinator (608) 266-8852

                     Avicultural Related Promms

                             Sheboygan County Land Conservation Department, Pat Miles (414) 459-4360
                             Soil Conservation Service, Dexter Porter (414) 459-3148
                             WDNR, Jim Baumann, Priority Watersheds (608) 266-9277
                             WDNR, Jim D'Antuono, Priority Watersheds-S.E. District (414) 263-8696
                             Wisconsin Department or Agriculture, Trade, and Consumer Protection (DATCP) (608) 273-6280

                     Construction Erosion Control/Storm Water Runoff

                             Sheboygan County Land Conservation Department, Pat Miles (414) 459-4360
                             Southeast District UWEX (414) 547-6721
                             Southeast District VvDNR, Kathy Karmasz (414) 263-8682
                             Sheboygan County, Michael DeMaster (414) 459-3060
                             City of Sheboygan, Lloyd Reilley (414) 459-3394

                     Adjacent Municipalitie

                             City of Sheboygan, Lloyd Reilley (414) 459-3394
                             Village of Oostburg (414) 564-3214
                             Town of Holland (414) 668-6696
                             Town of Lima (414) 564-3263

                     Other Pertinent Contacts

                             Wisconsin Coastal Management Program, Gary Schultz (608) 266-9269
                             Kohler Andrae State Park (414) 452-3457
                             WDOT-District 3, Green Bay (414) 492-5717
                             Army Corps of Engineers, Howard Ecklund (414) 547-6986
                             SEVY'RPC, Don Reed (414) 547-6721

                MILLER
                E N G I N E E R S

                                                                      Black River Watenshed                                           105310

                                                             xk
                                                    .7

                                              _W_

                                                                                       _.'Ah

                                          Construction erosion sediment increases

                                                                                                                          N,

                                          Erosion/water quality      concerns involving farm fields         and livestock

                                                                                                                                             P-1

                    MILLER
                    F N G I N F F R
                    S C I F N T'I S I

                                                                            Mack Mveir Wateashed                                                   105310

                                                                        Ilk

                                              Loss of wetlands        due to filling reduces flooding buffer zones and natural filters.

                                                                                   jot-,

                                                                                                                            -93
                                                                         J,

                                               Runoff from       cultivated fields      is a major contributor of sediment in waterways.

                                                                                                                                                            P-2

                       MLLER
                       F_ N G I N F E I`
                       s C I L N T-1 S_ I

                                                             Black Mveir Watenshed                                   1053AC2

                                 M7
                                                            7",
                                                    - 41

                                                                                              -77 777-7-

                                                     V11

                                                                              1.7 -

                                    Urban storm water runoff reduces water quality.

                                                                    7,77

                                                                                                           S1,

                                                                                                9 3
                                     Channelization and rerouting caused by flooding.                                      P-3
                                                                                                      AMM,W,W @Z:__

                  MLLER
                  L N C I N E  K
                  S C I L N T-I

                                                                      Boack EUveir Watenhed                                           10531C2

                                                                                                                  Effective...

                                                                    lk

                                                     7

                                                                          I ftwt

                         and erosion susceptible
                         hydraulic structures

                                                                                                                                             P-4

                    MLLER
                    [ N G I N I- E R S
                    S C 11: N T I S TS

                                                                                   Mack River Watenshed                                                         105310

                                                  Cover crops        established in drainage            ways reduce        erosion.

                                                                                                                                 V N

                                        Retention (by a pond on the other
                                              of the road) and natural
                                       s
                                       filtration improve water quality.

                                                                                                                                                                         P-5

                         MEER'
                         E-- N G I N I- F R
                           C__ 1 1: N I'l @ I

                                                                 31121ck EUveir Wateushed                                   10531C2

                                                =4

                                                                                               Y-

                                       Flooding, zones store and pss flood waters.

                                                                                                                                   P-6

                    MLLER
                    F N G I 1NI I I R
                     C I L JNj i I ") I

                                                                          BRack Mveir Wateushed                                                105310

                                                                                              'ap

                                                                                             4r

                                                                                                  IP

                                            Slit fences on construction sites reduce sediment                in the   river channels.

                                                                                                                -It@ 411, 4

                                                                                                              N'k

                                            Grass filter strips     reduce sediment        in water.

                                                                                                                                                      P-7

                     MILLER'
                     F N C, I N F -F R
                     S C I E INT 1 1) 1

                                                           Black Riveir Watenshed                               105310

                                     Ot

                                   Natural wetland buffers provide filtration and reduce flooding in populated areas.

                                                                                                                      P-8

                 MLLER
                 E N G I N 1: E R' S
                 SC I E N TI S -i's

                                                                                                                36-668 14     100  6546
                                                                    MLLER
                                                                    ENGNEERS

                                                                   5308 South Tweffth Street
                                                                 Sheboygan, Wisconsin 53081
                                                                        414-458-6164