[Document title] - Gun Lake Tribe · Kalamazoo River at New Richmond, which in turn flows to Lake Michigan (FTCH 2009). The Gun River watershed encompasses 73,272 acres in Allegan

Match-E-Be-Nash-She-Wish Band of Pottawatomi

Indians Nonpoint Source Assessment Report

Prepared for: Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians 2872 Mission Dr. Shelbyville, MI 49344

[Document title]

Kieser & Associates, LLC

536 East Michigan Ave, Suite 300

Kalamazoo, MI 49007

January 2, 2019

Table of Contents Overview ....................................................................................................................................................... 1

Introduction and Background ....................................................................................................................... 1

Water Resource Summary ........................................................................................................................ 3

MBPI Watersheds Summary ................................................................................................................. 3

MBPI Surface Water Resources ............................................................................................................ 6

MBPI Groundwater Resources .............................................................................................................. 7

MBPI Wetlands and Natural Features .................................................................................................. 8

Water Quality Assessment ............................................................................................................................ 9

Purpose ..................................................................................................................................................... 9

Method for Conducting Nonpoint Source Assessment ............................................................................ 9

Land Base and Land Uses Summary ........................................................................................................ 10

Land Use and Land Cover .................................................................................................................... 10

Ecoregions ........................................................................................................................................... 12

Bedrock Geology ................................................................................................................................. 13

Topography ......................................................................................................................................... 14

Climate ................................................................................................................................................ 18

Jurisdiction and Land Use Authority ....................................................................................................... 18

Nonpoint Source Pollution Categories .................................................................................................... 19

Agriculture .......................................................................................................................................... 19

Roads, highways and bridges .............................................................................................................. 19

Urbanized Areas (Development) ......................................................................................................... 19

Hydromodification .............................................................................................................................. 19

Effects of Nonpoint Source Pollution ...................................................................................................... 20

Sediments ........................................................................................................................................... 20

Nutrients ............................................................................................................................................. 20

Pathogens ........................................................................................................................................... 20

Toxicants ............................................................................................................................................. 20

Thermal Stress..................................................................................................................................... 21

Trash .................................................................................................................................................... 21

Water Quality Goals ................................................................................................................................ 21

Existing Water Quality Monitoring Program........................................................................................... 24

Other Water Resource Monitoring Projects ........................................................................................... 26

Hydrologic Modeling Analyses ................................................................................................................ 27

HAWQS Watershed Analysis ............................................................................................................... 27

Event Mean Concentration Analysis ................................................................................................... 30

Discussion of Results ................................................................................................................................... 33

Ingerson Lake (Jijak Camp) ...................................................................................................................... 34

Herlan Lake (Jijak Camp) ......................................................................................................................... 36

Unnamed Stream (Jijak Camp) ................................................................................................................ 36

Pierce County Drain Extension ................................................................................................................ 37

Buskirk Creek (Gun Lake Casino) ............................................................................................................. 39

Casino Detention Pond 1 & Outfall to Buskirk Creek (Gun Lake Casino) ............................................ 43

Casino Retention Pond & Seasonal Wetland (Gun Lake Casino) ........................................................ 44

Unnamed Stream (Gun Lake Casino) ...................................................................................................... 44

Casino Detention Pond 2 & Outfall to Unnamed Stream ................................................................... 45

Indian Lake (The Settlement) .................................................................................................................. 45

Moore Lake ............................................................................................................................................. 47

Boot Lake (Luella Collins Community Center) ......................................................................................... 48

Selkirk Creek Extension (Reno Drive) ...................................................................................................... 49

Reno Drive Detention Ponds ............................................................................................................... 50

Selection of Best Management Practices (BMPs) ....................................................................................... 55

Summary of Water Quality Assessment ................................................................................................. 55

Process for Selecting BMPs ..................................................................................................................... 57

Existing Nonpoint Source Control Programs (BMPs) .............................................................................. 57

Allegan Conservation District .............................................................................................................. 57

Kalamazoo River Watershed Council .................................................................................................. 58

Michigan Department of Environmental Quality Nonpoint Source Program .................................... 58

US Environmental Protection Agency ................................................................................................. 58

US Department of Agriculture Natural Resources Conservation Service ........................................... 58

Nonpoint Source Control Core Participants ............................................................................................ 58

Public Participation ................................................................................................................................. 59

Conclusions ................................................................................................................................................. 59

References .................................................................................................................................................. 62

List of Tables

Table 1: Summary atlas of MBPI Water Resources....................................................................................... 3

Table 2: Watersheds and contributing waterbodies crossing through MBPI lands ..................................... 4

Table 3: Waterbodies bordering and crossing through MBPI lands ............................................................. 6

Table 4: Soil types and distribution of soil types found on MBPI Lands ..................................................... 17

Table 5: State of Michigan Designated Uses and draft MBPI Desired Uses for Tribal waters .................... 22

Table 6. MBPI referenced surface water quality protection criteria values ............................................... 23

Table 7: MBPI Environmental Department water quality monitoring site locations ................................. 24

Table 8: MBPI water quality monitoring sites and parameters .................................................................. 26

Table 9: Summary of watersheds sediment and phosphorus load contributions ...................................... 27

Table 10: Results from the EMC analysis for MBPI land use types ............................................................. 31

Table 11: Results from the EMC analysis for MBPI land use types. ............................................................ 32

Table 12: Results from the EMC analysis for MBPI land use types. ............................................................ 40

Table 13: MBPI Nonpoint Source Assessment summary of NPS pollutants, sources and severity. ...... 51-52

Table 14: MBPI Nonpoint Source Assessment summary of impaired and threatened designated and desired uses and threat sources. ........................................................................................................... 53-54

List of Figures

Figure 1: Overview map of MBPI parcels, including Trust/Fee parcel delineation....................................... 2

Figure 2: Watersheds and subwatersheds map of MBPI waterbodies ......................................................... 4

Figure 3: Overview of natural features and wetland types of the MBPI ...................................................... 8

Figure 4: Regional land cover in the area of the MBPI lands ...................................................................... 11

Figure 5: Percentage of land cover specific to MBPI lands ......................................................................... 12

Figure 6: Topography of the MBPI lands and region .................................................................................. 14

Figure 7: Regional soil types of the MBPI area ........................................................................................... 15

Figure 8. Soil types found on the MBPI properties ..................................................................................... 16

Figure 9: Climatic averages for Wayland, MI .............................................................................................. 18

Figure 10: MBPI Environmental Department water quality monitoring sites ............................................ 25

Figure 11: Modeled subwatershed flow contributions to the Rabbit River ............................................... 28

Figure 12: Modeled subwatershed phosphorus contributions to the Rabbit River ................................... 28

Figure 13: Modeled subwatershed flow contributions to the Gun River ................................................... 29

Figure 14: Modeled subwatershed phosphorus contributions to the Gun River ....................................... 29

Figure 15: TP concentration comparisons at BC1 and BC2 ......................................................................... 41

Figure 16: E. Coli concentration comparisons at BC1 and BC2 ................................................................... 41

Figure 17: TKN concentration comparisons at BC1 and BC2 ...................................................................... 42

List of Acronyms

Acronym Definition

AOC Area of Concern

BIA GLRI Bureau of Indian Affairs Great Lakes Restoration Initiative

BMP Best Management Practice

CD Conservation District

CIP Conservation Incentive Program

CWA Clean Water Act

D.O. Dissolved Oxygen

EMC Event Mean Concentration

EPA US Environmental Protection Agency

FWS US Fish and Wildlife Service

GIS Geospatial Information Services

HAWQS Hydrologic and Water Quality System

HUC Hydrologic Unit Code

K&A Kieser & Associates, LLC

KRWC Kalamazoo River Watershed Council

LCCC Luella Collins Community Center

LID Low-Impact Development

MBPI Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians of Michigan

MDEQ Michigan Department of Environmental Quality

MDNR Michigan Department of Natural Resources

MDOT Michigan Department of Transportation

MNFI Michigan State University’s Natural Features Inventory

NLCD National Land Cover Database

NPDES National Pollutant Discharge Elimination System

NPS Nonpoint Source

NWQI National Water Quality Initiative

QAPP Quality Assurance Project Plan

SESC Soil Erosion and Sediment Control

SWAT Soil and Water Assessment Tool

TAS Treatment as a State

TKN Total Kjeldahl Nitrogen

TMDL Total Maximum Daily Load

TN Total Nitrogen

TP Total Phosphorus

TSS Total Suspended Solids

USDA United States Department of Agriculture

USGS United States Geological Survey

WMP Watershed Management Plan

WQBEL Water Quality Based Effluent Limitations

WWTP Waste Water Treatment Plant


536 E . M ich igan Ave . , Su i t e 300 , Ka lamaz oo, M I 4 90 07

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Overview

This Nonpoint Source (NPS) Assessment Report has been created for the Match-E-Be-Nash-

She-Wish Band of Pottawatomi Indians of Michigan (MBPI), also known as the Gun Lake Tribe,

to fulfill the United States Environmental Protection Agency (USEPA)’s requirements for a

Clean Water Act Section 319 program. Nonpoint source (NPS) pollution is the leading source of

water quality degradation in the United States (USEPA 2010). Kieser & Associates, LLC an

environmental science and engineering firm based in Kalamazoo, Michigan, was retained by the

MBPI to assist with this assessment as the MBPI Consultant. This report is a culmination of

these efforts. It assesses the impacts of NPS pollution on waters within the boundaries and

regions of the MBPI. The report follows specific EPA guidelines for these types of assessments

identified in the Handbook for Developing and Managing Tribal Nonpoint Source Pollution

Programs Under Section 319 of the Clean Water Act (USEPA 2010). As of January 1, 2019,

MBPI lands include approximately 605 acres of Trust land and 558 acres of Fee land in

Southwest Michigan. The MBPI Nonpoint Source Assessment Report analyzes, discusses and

summarizes the effects of NPS pollution problems for waters of MBPI lands as wells as lands

and waters that effect MBPI waters.

The MBPI NPS Assessment Report utilizes information from a broad range of current and

historic sources to determine priorities for nonpoint source pollution prevention. This includes

water quality data gathered by staff and volunteers of the MBPI’s Environmental Department,

conducted with EPA-approved Quality Assurance Project Plans (QAPPs) (MBPI 2010, 2015). It

also draws on current State of Michigan approved nine element Section 319 Watershed

Management Plans from the Rabbit River watershed (HUC: 0405000308), Gun River watershed

(HUC: 0405000307) and Kalamazoo River watershed (HUC: 04050003). The report identifies

relevant categories and subcategories of NPS pollution and specifies nonpoint sources which

contribute significant pollution to navigable and non-navigable waters of the MBPI. While NPS

pollution does affect water quality on MBPI lands, all relevant navigable waterbodies are

currently expected to maintain referenced water quality standards and goals of the MBPI, as well

as the requirements of the Clean Water Act (CWA).

The goal of this Assessment Report is to identify impairments and threats to MBPI waterbodies

caused by NPS pollution, thoroughly assess their causes and severity and identify opportunities

to control, reduce and monitor NPS pollutants in order to protect and improve water quality. This

NPS Assessment Report serves as guidance for the development of a Nonpoint Source

Management Program Plan (Plan) to address long-term needs for the MBPI and its waters.

Identification of best management practices (BMPs) for the Plan will include intergovernmental

coordination and public participation to address existing NPS pollution issues. BMPs will build

on existing MBPI and regional programs for controlling NPS pollution as further discussed in

this report.

Introduction and Background

The MBPI works to “maintain our elders’ vision, integrity, spirituality, culture and economic

self-sufficiency by protecting our sovereignty, treaty rights, traditions, land and natural resources

for our future generations.” The MBPI’s Government Campus is located south of Wayland in



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Allegan County, Michigan. The MBPI’s Land spans multiple, non-contiguous land parcels

throughout Allegan County totaling approximately 1,163 acres of both Fee and Trust Land. The

MBPI’s service area includes Allegan, Barry, Kalamazoo, Kent and Ottawa Counties.

Federal environmental laws like the Clean Air Act, Clean Water Act and Safe Drinking Water

Act allow the EPA to treat eligible federally recognized Indian Tribes in the same manner as a

state (TAS) (USEPA 2018). The MBPI currently has Treatment as a State (TAS) for Section 106

of the CWA for a 146 acre parcel in Wayland Township and is working to gain 106 TAS on

additional Trust Lands. The TAS is described for trust lands where the MBPI holds certain and

legal jurisdiction. This Assessment Report focuses on all waters on MBPI Tribal properties,

including Trust and Fee lands, and preliminarily identifies waters upstream and downstream that

effect MBPI Tribal Water Resources. The Nonpoint Source Management Program Plan will

describe how the MBPI will work with nearby land owners to implement the program. The NPS

Program will also allow for work in upstream and downstream areas effecting MBPI Tribal

waters, considered a voluntary aspect of the program (Janette Marsh, personal communication,

2018).

Figure 1 delineates MBPI Trust parcels from Fee parcels. All maps provided in this report

include this distinction.

Figure 1: Overview map of MBPI parcels, including Trust/Fee parcel delineation



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Water Resource Summary

Waters on MBPI lands are a part of the Rabbit River and Gun River watersheds, both part of the

Kalamazoo River watershed. The Rabbit River watershed encompasses approximately 187,200

acres and is located primarily in Allegan County but also extends into Barry, Ottawa and Kent

Counties. The Rabbit River begins east of Wayland, Michigan, and flows westerly into the

Kalamazoo River at New Richmond, which in turn flows to Lake Michigan (FTCH 2009). The

Gun River watershed encompasses 73,272 acres in Allegan and Barry Counties, Michigan. The

Gun River flows from Gun Lake through Otsego Township, Allegan County, where it unites

with the Kalamazoo River above Lake Allegan (FTCH 2004). Table 1 provides a summary atlas

of MBPI water resources. Table 1: Summary atlas of MBPI water resources

Resource Description Trust Lands Fee Lands All MBPI Lands

Land Surface Area (ac) 604.4 558.5 1162.9

Rivers/Streams (km) 1.6 2.8 4.3

Lakes/Reservoirs/Ponds (#) 3.0 5.0 8.0

Lakes/Reservoirs/Ponds (ac) 20.3 56.4 76.7

Wetlands (ac) 62.5 43.4 105.9

The MBPI’s land and waters provide a range of habitat for a variety of flora and fauna. Water is

an important resource and cultural element for the MBPI and its members. Nmé (sturgeon) is a

top fish clan to Native Americans and is found in the lower Kalamazoo River below Lake

Allegan (Smith 2010). The MBPI works with the Michigan Department of Natural Resources

(MDNR), the United States Fish and Wildlife Service (FWS), Grand Valley State University and

the Kalamazoo Chapter of Sturgeon for Tomorrow for rehabilitation efforts to protect and

increase populations of lake sturgeon (Acipenser fulvescens) through a streamside rearing facility

operated by the MBPI Environmental Department (MBPI, Environmental Projects 2017). The

MBPI also considers mnomen (wild rice – Zizania aquatica and Zizania palustris) an important

natural resource both culturally and ecologically and works to restore mnomen beds throughout

the region.

The MBPI has made concerted efforts to identify and protect MBPI lands and waters which

support other animals of cultural significance (e.g., sandhill cranes, herons, ducks, otters and

turtles). The MBPI is actively participating in the conservation of turtles (mshike) through the

Mshike Conservation Project, where they monitor, conserve and improve turtle populations on

MBPI properties (MBPI, Environmental Projects 2017). The MBPI has also prioritized the

mitigation of invasive species on MBPI lands and wetlands through physical removal and the use

of biological controls.

MBPI Watersheds Summary

The majority of the MBPI’s subwatersheds drain to the Rabbit River via Miller Creek, Bear

Creek, Buskirk Creek and the Fales Drain (FTCH 2009). One of the MBPI’s subwatersheds

flows from Boot Lake to Gun Lake, the headwaters of the Gun River. The Rabbit River

watershed and the Gun River watershed are a part of the greater Kalamazoo River watershed,



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which discharges to Lake Michigan at the City of Saugatuck (KRWC 2011). Table 2 displays

these watersheds and subwatersheds, their Hydrologic Unit Code (HUC) and the applicable

waterbody on MBPI property which contributes to each subwatershed. Figure 2 provides an

overview of watersheds and subwatersheds of the MBPI’s waterbodies.

Table 2: Watersheds and contributing waterbodies crossing through MBPI lands

Hydrologic Unit Code (HUC)

Watershed/Subwatershed Contributing MBPI Waterbodies Scale

04050003 Kalamazoo River All Big

0405000308 Rabbit River Buskirk Creek, Selkirk Creek, Bear Creek, Miller Creek, Fales Drain

0405000307 Gun River Gun Lake-Gun River (via Boot Lake)

040500030805 Buskirk Creek-Rabbit River Buskirk Creek, Selkirk Creek

040500030804 Bear Creek Ingerson Lake, Herlan Lake, Unnamed Creek (Jijak Camp)

040500030803 Miller Creek Pierce County Drain Extension, Unnamed Creek (Gun Lake Casino)

040500030802 Fales Drain-Rabbit River Indian Lake, Moore Lake

040500030701 Gun Lake-Gun River Boot Lake Small

Figure 2: Watersheds and subwatersheds map of MBPI waterbodies



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The Kalamazoo River watershed drains approximately 1,292,800 acres, spanning a broad array

of land uses in southwest Michigan. Watershed land cover is predominantly agricultural (47%),

unmanaged terrestrial uplands (30%), lakes and wetlands (15%) and developed urban and/or

residential areas (8%). An EPA-approved Watershed Management Plan (WMP) for the

Kalamazoo River watershed was published in 2011 and will be due for a technical update in

2021, though it is unknown if an update is currently planned. Known and suspected impairments

to State of Michigan Designated Uses for the Kalamazoo River Watershed include 1) indigenous

aquatic life and wildlife, impaired by nutrients, sediment, habitat degradation or fragmentation

and unstable flows; 2) warmwater fisheries, impaired by oil, grease and petroleum hydrocarbons;

3) coldwater fisheries, impaired by temperature; and 4) total and partial body contact recreation,

impaired by pathogens and bacteria (KRWC 2011).

The Kalamazoo River has been recognized as an Area of Concern (AOC) by the United States

and Canadian Governments since 1987, due to the presence of PCBs, primarily from historic

paper mill discharges. Eight impairments were recognized in the Kalamazoo River AOC. In

August 2016, the Kalamazoo River Natural Resource Damage Assessment, administered to

determine the extent of injuries to natural resources caused by releases of toxic PCBs, published

its Final Restoration Plan and Programmatic Environmental Impact Statement for Restoration

(Abt Associates 2016).

Since 1998, a Total Maximum Daily Load (TMDL) has been in place for excessive phosphorus

in the upper Kalamazoo River and its largest impoundment, Lake Allegan. At that time, the Gun

River Watershed was identified as the third-largest contributor of phosphorus loads to the

Kalamazoo River. The Gun River Watershed exemplifies an area affected predominantly by

agricultural NPS pollution (FTCH 2004). The lower reaches of the Kalamazoo River are

designated by the State of Michigan as Wild and Scenic River under Part 305, Natural Rivers, of

the Natural Resources and Environmental Protection Act 451 of 1994. The Rabbit River empties

into a stretch of the Kalamazoo River included in this priority protection area, which includes the

Allegan State Game Area (FTCH 2009).

The Rabbit River watershed encompasses approximately 187,200 acres. Land types in this

watershed are primarily agricultural, forested and urban, though the majority of the watershed is

rural. The Rabbit River experiences water quality impairments mainly due to instable and flashy

flows and has several reaches listed on the TMDL for biota (FTCH 2009). NPS impairments for

this watershed include sediments, nutrients, pathogens and pesticides from agriculture and

nutrients and pathogens from residential areas (FTCH 2009). The Rabbit River flows into the

Kalamazoo River at New Richmond.

The Gun River watershed encompasses 73,272 acres in Allegan and Barry Counties and flows

from Gun Lake through Otsego Township where it unites with the Kalamazoo River. NPS

impairments in this watershed include: Sediment and nutrient loading from agriculture; nutrients,

pathogens, hydrocarbons, exotic species, hydrology and habitat fragmentation from residential

areas; and E. coli and nutrients from recreational areas (FTCH 2004). EPA-approved WMPs

were established for the Rabbit River watershed in 2009 (FTCH 2009) and for the Gun River

watershed in 2004 (FTCH 2004).



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MBPI Surface Water Resources

This NPS Assessment Report focuses on waterbodies on, bordering or crossing through MBPI

lands. Waterbodies on, bordering or crossing MBPI lands include approximately 4.3 km of

streams and five lakes which total approximately 96 acres of open water (Homer et al. 2015).

These parcels also border wetlands totaling approximately 520.7 acres and contain several

engineered wet ponds functioning as man-made wetlands as well as stormwater detention

totaling approximately 5.2 acres of open water.

Table 3 lists the navigable and non-navigable waterbodies which border or cross through the

MBPI lands, with reference to their MBPI property ID and Allegan County Parcel Identification

Numbers (PINs), assigned to each parcel in the county for zoning, planning and tax purposes.

Table 3: Waterbodies bordering and crossing through MBPI lands

HUC-12 Watershed ID

MBPI Waterbody Name Navigable MBPI

Property Identifier

Allegan Co. PIN(s)

040500030805 Buskirk Creek-Rabbit River

Buskirk Creek No

Gun Lake Casino 24-019-026-30 Casino Detention Pond 1 No

Casino Retention Pond & Wetland

No

Selkirk Creek Extension No Reno Drive

56-007-013-10 56-007-013-20 56-007-017-30 Reno Drive Ponds No

040500030804 Bear Creek

Ingerson Lake Yes

Jijak Camp 10-032-001-30 10-032-001-31

Herlan Lake Yes

Unnamed Stream No

040500030803 Miller Creek

Pierce County Drain Extension

No Government Campus & Parcels to West

24-019-029-10 24-019-029-20 24-019-032-00 24-019-032-20 24-019-033-00 10-024-004-00

Unnamed Stream No Gun Lake Casino & Parcel to West

24-019-026-30 10-024-002-00 Casino Detention Pond 2 No

040500030802 Fales Drain-Rabbit River

Indian Lake Yes The Settlement 24-021-023-00 24-021-024-00 24-021-023-60

Moore Lake Yes Moore Lake 24-028-013-10

040500030701 Gun Lake-Gun River

Boot Lake Yes Luella Collins Community Center (LCCC)

24-027-018-00 24-027-015-00

According to the Strahler Stream Order (Strahler 1952) classification method, streams on MBPI

properties are considered first order streams. Buskirk Creek, the Pierce County Drain Extension,



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the Selkirk Creek Extension and those flowing from Camp Jijak and Gun Lake Casino are all

first order streams since they have no tributaries.

Most of the lakes and wetlands in the Kalamazoo River Watershed occupy glacial kettles,

depressions formed by the melting of glacial ice (KRWC 2011). Boot Lake receives water from

Mill Pond and drains into Gun Lake which drains into the Gun River. This lake has surrounding

wetlands with some forested land and agriculture in proximity (FTCH 2004). Indian Lake is a

part of the headwaters to the Rabbit River. Indian Lake will soon receive water from nearby

Selkirk Lake, as a county drain is being constructed to control water levels in Selkirk Lake.

Ingerson Lake is a groundwater-fed lake with one outlet and Herlan Lake is groundwater fed

with one small inlet and an outlet which confluences with the Ingerson Lake outlet, a tributary of

Bear Creek. Moore Lake is surrounded by forested wetland bordered by agriculture and low

density residential developments and has no inlets or outlets.

The MBPI’s Environmental Department currently monitors water quality in Buskirk Creek,

Pierce County Drain Extension, Boot Lake, Indian Lake and Ingerson Lake. Parameters collected

at Buskirk Creek and Pierce County Drain Extension sites include dissolved oxygen, pH, specific

conductivity, temperature, turbidity, E. coli, nitrates, nitrites, total Kjeldahl nitrogen, phosphorus,

total suspended solids and chlorides. Parameters measured at one-meter depth increments for the

pond and lakes include dissolved oxygen, pH, specific conductivity, temperature and turbidity.

Monitoring has also occurred on Selkirk Lake and Mill Pond, outside of MBPI lands (MBPI

2010, 2015). These water quality monitoring efforts are discussed in greater detail in the

“Existing Water Quality Monitoring Program” section. Graphical depictions of water quality

graphs developed from MBPI monitoring data are included as Attachment A.

MBPI Groundwater Resources

Groundwater is considered an abundant resource in southwest Michigan and provides drinking

water for many public and private utilities throughout the state. While irregular geologic

formations can sometimes result in unpredictable aquifer sizes and locations, groundwater

resources in the region of the MBPI Lands tend to be relatively evenly distributed. Static

groundwater levels in this region are typically found 3-5 m below the ground surface

(Groundwater Statistics 2018). Groundwater quality is, however, susceptible to nonpoint source

pollution, with certain land uses producing greater threats to groundwater quality than others.

Examples include road salting for snow and ice control seeping into groundwater aquifers as well

as infiltration of nitrates from septic systems and agricultural fertilizers.

The MBPI currently owns and operates one non-transient non-community water system that

serves the Gaming Facility and the Government Campus and two transient non-community

systems; one at the Noonday Market and one at Jijak Camp. The MBPI also owns and operate

additional wells used for observation, drinking water and irrigation. The MBPI is currently

working to update its Source Water Protection Plan, to include all water sources, pending

completion in September 2019. The MPBI offers incentives to qualifying residences to conserve

water with low-flow appliances and rain barrels, as well as septic system inspection and

pumping, through its current Conservation Incentive Program (CIP). The MBPI also offers

drinking water testing for bacteria, nitrates, nitrites, dissolved solids, pH, lead, copper, sulfates,



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hardness, arsenic, fluoride, iron, manganese, sodium and zinc through the CIP (MBPI,

Environmental Projects 2018).

MBPI Wetlands and Natural Features

The MBPI Tribal properties, including trust and fee lands, include 106 acres of woody wetlands

(Figure 3). These waterbodies represent a range of important ecological resources including

water filtration, water storage and habitat for many amphibians, birds, fish, mammals and plants.

Natural Features Inventories help to identify areas in a watershed that warrant conservation and

protection because of their rare features.

Figure 3: Overview of natural features and wetland types of the MBPI

Information on the plant and animal communities within Allegan County was obtained from

Michigan State University’s Natural Features Inventory (MNFI, no date). MNFI indicates the

presence of many threatened, endangered or special concern species and/or communities

dependent on water within the MBPI Tribal watersheds. Allegan County is home to 133 state

listed threatened (57), endangered (19), and special concern (57) species. Of these, 108 species

rely on water resources which include amphibians (2), birds (13), fish (8), insects (5), mammals



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(2), mussels (9), plants (59), reptiles (7), snails (3). The MBPI currently works to monitor,

conserve and restore habitat for threatened and endangered species such as lake sturgeon

(Acipenser fulvescens), wild rice (Zizania aquatica) and the spotted turtle (Clemmys guttata).

Water Quality Assessment

Purpose

This assessment of the MBPI’s water resources serves to identify MBPI waterbodies of high

quality or cultural significance and to protect these from future threats of impairments. The

assessment identifies MBPI water bodies currently impacted by NPS pollution to target for

restoration. Nonpoint source pollution is widespread, occurring wherever anthropogenic

developments and natural functions disturb the land or water and often cannot be traced to a

single location or source.

Such disturbances can cause adverse changes to the ecology and hydrology of waterbodies by

way of pollutant transport and deposition into creeks, rivers, lakes and other aquatic systems,

including groundwater. Agriculture, forestry, grazing, urban runoff, construction, septic systems,

careless use or disposal of toxic and household chemicals, recreational boating, physical changes

to stream channels and habitat degradation are common examples of NPS pollution causes and

sources. The USEPA considers NPS pollution to be the leading source of water quality problems

throughout the nation (USEPA 2010).

Method for Conducting Nonpoint Source Assessment

This Nonpoint Source Assessment Report draws on water resource information provided by the

MBPI’s Environmental Department, existing information on watershed and land use

characteristics, on-site reconnaissance efforts and modeling efforts to characterize the impact of

NPS pollution on MBPI waters. These efforts were coordinated by the MBPI’s Environmental

Department and the MBPI’s Consultant. The team held a kick-off meeting on 26 March 2018 to

strategically plan and organize the approach for conducting the NPS assessment and to outline

the desired outcomes of the MBPI’s Environmental Department. The MBPI Consultant staff

joined the MBPI’s Environmental Department staff for an introductory tour of MBPI properties

and waterbodies.

Preliminary site assessment of land cover and land use was performed via current and historic

aerial images using Google Earth Pro and public maps provided by Allegan County Geospatial

Information Services (GIS) (Allegan County GIS 2018). Further GIS analyses and spatial data

layering confirmed preliminary analyses by mapping MBPI properties against watersheds,

subwatersheds, water features, wetlands and natural features, soils and land cover, at multiple

spatial scales.

Analyses of land use and land cover on MBPI land and surrounding areas indicate that relevant

NPS pollutant categories affecting MBPI waters include:



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Agriculture

Roads, highways and bridges

Urbanized (developed) areas

Hydromodification and habitat alterations

Potential wetland/riparian concerns

On 6 June 2018, the MBPI Consultant field staff performed detailed onsite assessments of the

MBPI lands and waterbodies and windshield surveys of MBPI lands and non-MBPI contributing

lands. Several areas of concern regarding NPS pollutants were identified and documented by

field staff during this reconnaissance. These areas, as well as examples of existing NPS pollutant

controls, are visually identified against aerial images for each applicable MBPI parcel in

Attachment B.

Field surveys were then compared and contrasted with water quality data provided by the MBPI

Environmental Department. Water quality data collected under an EPA-approved QAPP was

summarized and is graphically illustrated as Attachment A (MBPI 2010, 2015). The coordination

of this information allowed for both general and site-specific assessments of NPS pollutant

impacts on the MBPI’s water resources. The MBPI Consultant also conducted modeled

hydrologic analyses of targeted streams and watersheds to assess current conditions and long-

term trends in the stream network bordering select MBPI properties.

NPS modeling analyses included an Event Mean Concentration (EMC) approach to estimate

runoff volume, sediment loss and phosphorus loss for each parcel. Each parcel was delineated

into land-cover types via aerial images. Analyses also utilized HAWQS (Hydrologic and Water

Quality System) for a broad watershed analysis for the seven 12-digit HUC watersheds in which

the MBPI properties reside. HAWQS is an online tool run by the EPA that uses the SWAT

model to analyze 8-, 10-, or 12-digit HUC watersheds. The method, limitations and discussion of

results for these modeling analyses are detailed in the “Hydrologic Modeling Analyses” section.

Land Base and Land Uses Summary

Land Use and Land Cover

Landcover in the region of the MBPI Lands prior to European settlement was diverse and highly

influenced by the glacial outwash plain. In the easterly regions, coarse soils of the outwash plain

supported a large concentration of dry tallgrass prairies and some wet prairies. Fires were

frequent across the dry prairies and savannas, with oak savanna preferring gentle slopes with

frequent fires and hickory forest preferring steeper areas with greater moisture and fewer fires.

Oak-dominated forests gave way to mainly beech and sugar maples in the westerly regions, more

influenced by lake effect climates and supported by clay loam and sandy loam soils. Hemlock

also occurred in poorly drained soils and depressions (USEPA 2007).

Much of the land use in this region from the 1800s to 1978 changed to urban or agricultural land

use; however, there are still some areas of vegetation including Pine and Central Hardwood

forests which remain unchanged since that time (MSUE). Since gaining federal recognition in

1999, some land use changes have occurred as development has taken place on MBPI properties.



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11

For example, parts of the Jijak property which now host a summer camp and large-scale cultural

events were formerly farmed fields or mowed lawns. The MBPI Casino property, a large

development, was constructed on a former agricultural and industrial property as well as a small

area of wet woodland. The MBPI Government Campus, The Settlement and Luella Collins

Community Center (LCCC) were all also constructed on former agricultural lands. Other MBPI

properties remain in agriculture or have been converted from agriculture to secondary

succession. Most MBPI developments have included low-impact development (LID) practices or

stormwater Best Management Practices (BMPs) in their design and construction.

Present day land uses throughout the MBPI properties include agricultural lands, woodlands,

wetlands, grasslands and developed areas. The map in Figures 4 displays regional and MBPI

Tribal-property-specific land cover types. Agriculture is the dominant land use for the region and

MBPI properties.

Figure 4: Regional land cover in the area of the MBPI lands



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12

The chart in Figure 5 displays the percentage of land use specific to MBPI properties. Of the

approximate 1,163 acres of MBPI property, 44% are Cultivated Crops (506 acres), 17% are

Deciduous Forest (194 acres), 14% are Hay/Pasture (164 acres), 10% is Low Intensity

Development (113 acres), and the remaining 15% is made up of Open Space Development,

Woody Wetlands, Herbaceous, Open Water, Medium Intensity Development, Barren Land,

Shrub/Scrub, High Intensity Development and Emergent Herbaceous Wetlands.

Figure 5: Percentage of land cover specific to MBPI lands

All land uses can have certain impacts on waterbodies. Some land uses, such as developed areas

and agriculture, can substantially increase the chances of NPS pollutant impacts through

stormwater runoff and accelerated erosion. New development pressures will lead to increased

pollutant loading unless policies exist to mitigate the impacts of such developments with BMPs

and NPS pollutant controls.

Ecoregions

The USEPA utilizes Ecoregions to denote ecosystems of generally similar type, quality and

quantity of natural resources, for assessment, management and monitoring. Ecoregions may be

identified through the “analysis of patterns of biotic and abiotic phenomena, including geology,

physiography, vegetation, climate, soils, land use, wildlife and hydrology” (USEPA 2017).

Ecoregions are labeled with a Roman numeral hierarchy defining the coarseness of their detail,

from Level I as the coarsest to Level IV as the most refined.

The MBPI lands lie in the Level III Ecoregion 56, “Southern Michigan/Northern Indiana Drift

Plains.” This Ecoregion tends to be less agricultural than those to the south (54, 55) and better

44%

17%

14%

9%

2%10%

2%1% 1% 0% 0% 0% 0%

Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians Property Percent Land Cover (NLCD 2011 Data)

Cultivated Crops

Deciduous Forest

Hay/Pasture

Woody Wetlands

Developed, Open Space

Developed, Low Intensity

Herbaceous

Open Water

Developed, Medium Intensity

Barren Land

Shrub/Scrub

Developed, High Intensity

Emergent Herbaceuous Wetlands



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drained with more consistent lakes than those to the east (57). Ecoregion 56 is characterized by

an abundance of lakes and marshes, as well as a broad array of landforms and soil types and

textures. Common land uses include feed grain, soybean and livestock farming, woodlots,

quarries, recreational developments and urban-industrial areas. Historic land cover was

predominantly oak-hickory forests, northern swamp forests and beech forests. The broad till

plains of this Ecoregion include thick and complex deposits of drift, paleobeach ridges, relict

dunes, morainal hills, kames, drumlins, meltwater channels and kettles. (USEPA 2007).

MBPI Tribal properties span Level IV Ecoregions 56b, “Battle Creek/Elkhart Outwash Plain”

and 56f, “Lake Michigan Moraines.” MBPI Tribal waterbodies within Ecoregion 56b include

Boot Lake, Moore Lake and Indian Lake. Ecoregion 56b is characterized as a broad, flat plain

that served as a drainage way for the recession of Pleistocene glaciers, where rivers and streams

now occupy outwash channels. Underlying sands and gravels are coarse and permeable,

providing ample groundwater. The region’s streams and rivers typically experience stable flows.

Channelization and riparian vegetation removal have degraded aquatic and terrestrial habitats,

favoring silt-tolerant fish species as sediment deposition has buried gravel substrates. Lakes are

distributed numerously but less densely than other regions and often serve as headwaters of

streams. (USEPA 2007).

MBPI Tribal waterbodies within Ecoregion 56f include Ingerson Lake, Herlan Lake, Buskirk

Creek, Pierce County Drain Extension, Selkirk Creek, Reno Drive Ponds and two unnamed

streams, which all drain to the Rabbit River watershed. Landforms of this ecoregion are mainly

end and ground moraines resulting from an advance of the Michigan lobe of the Wisconsin

Glaciation. Soils include a mix of well-drained sandy loams and poorly-drained clay loams.

Much of the region is cultivated with areas amenable to fruit production and others tending

toward row crops. Some kettle lakes are present and streams are prevalent. (USEPA 2007).

Bedrock Geology

A complex bedrock geology underlies the glacial depositions in the region of the MBPI lands

and waters. The bedrock surface of Allegan County includes the Michigan Formation, Marshall

Sandstone and Coldwater Shale. The Michigan Formation, a confining unit, is composed of

discontinuous siltstone and sandstone, shale, carbonate and evaporite (Apple and Reeves 2007).

The Marshall Sandstone is made of an upper and lower unit and underlies the Michigan

Formation at a maximum thickness of 52 m. The upper unit, referred to as the Napoleon

Sandstone Member, is composed of upper quartzarenite to sublitharenite and is separated from

the lower Marshall Sandstone by layers of shale, siltstone and carbonate. The lower Marshall

Sandstone is composed of quartzarenite to sublitharenite and the basal unit is composed of fine-

to-medium-grained litarenite. The Marshall Sandstone contains permeable sandstones which

make up the Marshall aquifer, ranging in thickness between 23 and more than 61 m thick and

yielding fresh water in Allegan County (Apple and Reeves 2007).

The Coldwater Shale underlies the Marshall Sandstone and ranges from 213 to 262 m thick when

found beneath Marshall Sandstone. The Coldwater Shale consists of shale, including cherty shale

containing dolomite crystals, chert bands and dolomitic lime, sandstone, siltstone and carbonates.

Layers of limestone provide water to wells in areas of Allegan County (Apple and Reeves 2007;

MCGI 2005).



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Topography

The geology, topography and landforms of the region of Michigan containing the MBPI’s lands

were mainly influenced by the Wisconsin Glaciation, occurring about 10,000 years ago. (FTCH

2009). The topography of this region contains a range of slopes from level ground to steep hills.

Many of the wetlands which formerly existed in the region of the MBPI’s lands were drained for

agricultural use. These agricultural drains are still predominant throughout the region. Figure 6

illustrates topographic elevations of the MBPI lands and region.

Figure 6. Topography of the MBPI lands and region

Hydrologic Soil Groups

Soils were deposited overtop of the bedrock formations as glacial ice receded from the MBPI

Lands. Deposition by water resulted in layered soils of sands, loams and gravel, while glacial

deposition resulted in unsorted glacial till (FTCH 2009). Glacial deposits resulted in complex

lateral and vertical depositional layers. Surficial deposits in the central and east areas of Allegan

County consist of lacustrine deposits of primarily sand and gravel, outwash and small amounts of

http://goog_913204403/

http://goog_913204403/



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post-glacial alluvium composed mainly of sand and gravel and till ranging from fine to coarse

grained. Aquifers in the glacial deposits consist mostly of sands and gravels varying in thickness

and permeability (Apple and Reeves 2007).

Soils in Ecoregion 56b and 56f are typically coarse and permeable sands and gravels underlying

the outwash plain and low moraines, which are typically sources of groundwater. These well-

drained sandy loams can be subject to drought or wind erosion. Sandy loams are often cultivated

in corn, soybeans and grain. Well-drained soils are of an eolian origin and are prone to wind

erosion if tilled. Poorly drained sandy soils are typically found in depressions, often drained for

vegetable production (USEPA 2007).

The map in Figure 7 provides a regional overview of soil types in the area of the MBPI Lands.

Figure 7: Regional soil types of the MBPI area

Figure 8 includes a map of soils within MBPI properties only, as well as a list of the soils

represented therein. Table 4 lists the type and distribution of soils found on MBPI properties.



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Figure 8: Soil types found on the MBPI properties



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17

Table 4: Soil types and distribution of soil types found on MBPI Lands

Soil Types on MBPI Tribal Properties Area (m2)

Area (acres)

Detour flaggy loam, 0 to 3 percent slopes 778,539 192.4

McGinn loamy sand, 0 to 6 percent slopes 684,521 169.1

Michigamme-Rock outcrop complex, 0 to 8 percent slopes 439,181 108.5

Onota variant channery sand, 0 to 4 percent slopes 406,817 100.5

Ingalls fine sand, 0 to 3 percent slopes 379,601 93.8

Munising loamy sand, 1 to 8 percent slopes 295,573 73.0

Graycalm-Rubicon sands, 0 to 6 percent slopes 258,838 64.0

Onaway fine sandy loam, 2 to 6 percent slopes 137,446 34.0

Deford muck, 0 to 2 percent slopes 117,617 29.1

Loxley peat 112,194 27.7

Emmet-Montcalm complex, 6 to 12 percent slopes 111,456 27.5

Copper Harbor very gravelly coarse sand, 3 to 9 percent slopes 104,373 25.8

Water (Inland) 90,442 22.3

Quetico-Peshekee-Rock outcrop complex, 6 to 34 percent slopes, very stony 74,019 18.3

Quetico-Peshekee-Rock outcrop complex, 5 to 27 percent slopes, very stony 72,702 18.0

Burt muck 70,901 17.5

Allendale-Rudyard complex, 0 to 3 percent slopes 70,135 17.3

Entisols, flooded 53,998 13.3

Plainfield sand, lake plain, 0 to 6 percent slopes 44,744 11.1

Rubicon sand, 0 to 6 percent slopes 39,781 9.8

Kinross muck 37,923 9.4

Beach, gravelly 34,996 8.6

Deer Park sand, 1 to 10 percent slopes 34,126 8.4



Tekenink loamy fine sand, 6 to 12 percent slopes 31,637 7.8

Kalkaska loamy sand, 0 to 6 percent slopes 31,199 7.7

Gay-Pleine complex, 0 to 1 percent slopes, stony 21,865 5.4

Assinins-Skanee complex, 0 to 3 percent slopes 21,447 5.3

Kallio cobbly silt loam, 8 to 15 percent slopes 18,036 4.5

Skandia-Burt complex, 0 to 2 percent slopes 10,879 2.7

Waiska-Copper Harbor complex, 0 to 10 percent slopes, very stony 10,291 2.5

Lupton and Tawas soils, 0 to 1 percent slopes 7,210 1.8

Skanee cobbly fine sandy loam, 0 to 3 percent slopes, stony 3,603 0.9

Michigamme-Rock outcrop complex, 15 to 35 percent slopes 2,856 0.7

Pits, gravel 1,887 0.5



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Climate

The regional climate of the MBPI Area is relatively warm compared to the rest of Michigan.

Positioned on the east side of the Lake Michigan Moraines Ecoregion, this area experiences little

lake temperature moderation, though it does receive some lake effect snow (USEPA 2007).

Figure 9 illustrates monthly averages for temperature and precipitation in Wayland, Michigan

(Intellicast 2018).

Figure 9: Climatic averages for Wayland, MI

Jurisdiction and Land Use Authority

No formal exterior boundaries exist for the MBPI Reservation. MBPI lands are delineated as

“Fee Parcels” or “Trust Parcels”. The boundaries of each property are delineated in line with

distinct property parcel identification numbers assigned by Allegan County. The land use

authority rests within the Tribal Council of the sovereign MBPI government, with oversight from

the MBPI Tribal Government Committees.



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Nonpoint Source Pollution Categories

Analyses of local land uses, land use changes, soil types and water systems, show that several

general categories of NPS pollution affect the lands and waters of the MBPI. These categories,

summarized below, include: agriculture, roads, highways and bridges, urbanized areas and

hydromodification, including riparian habitat alterations.

Agriculture

Improper fertilizer application, pesticide and herbicide use and soil erosion are agricultural

activities that can cause nonpoint source pollution. Nutrients and sediments from these activities

can run off into streams, lakes and other surface waters especially if a conservation plan is not

established. Nutrient pollution can also affect groundwater through infiltration, posing a risk to

drinking water resources. Agricultural modifications of land to increase drainage or irrigation

can exacerbate these risks.

Roads, highways and bridges

Construction and maintenance of roads, highways and bridges contribute pollutants to waterways

via runoff from rain and snowmelt, along with dry-weather transport via wind. Erosion from

construction can contribute sediments to streams, lakes and other surface waters. Road salt and

other deicing products, along with contaminants from vehicles including oil, grease and

antifreeze, can also make their way into waterbodies, potentially impacting aquatic biota as well

public health (USEPA 2016b). Improperly-sized culverts or stream crossings can contribute to

erosion and create barriers to fish and wildlife.

Urbanized Areas (Development)

Pavement, parking lots, rooftops and other impervious surfaces do not allow water to naturally

infiltrate into the soil, thus increasing the velocity, volume and temperature of stormwater runoff.

Concentrated flows of stormwater can pose problems with streambank erosion and flooding.

Contaminants, such as oil and grease from motor vehicles and parking lots, can be easily washed

into waterways where they can harm aquatic life. Bare soils during construction activities can

increase runoff volumes, leading to soil erosion and sediment deposition into adjacent waterways

(USEPA 2016b).

Hydromodification

Channel modification, channelization and streambank and shoreline erosion are examples of

hydromodification activities that can impact streams. Hydromodification can result when land

uses are changed. Channelization increases the velocity and temperatures while decreasing the

residence time of flowing water, leading to streambank erosion, habitat alterations and increased

nutrient and sediment transport downstream. These changes can negatively affect instream and

riparian habitats for fish and wildlife.



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Effects of Nonpoint Source Pollution

Onsite assessments and evaluation of water quality data suggest that the most common NPS

pollutants on the MBPI’s land are nutrients and sediments. Other relevant common NPS

pollutants include pathogens and thermal stress. NPS pollution can lead to degradation of

waterbodies to an extent that impairs them beyond water quality standards or designated uses,

such as swimming, fishing, drinking water, aquatic and riparian habitat for wildlife and more.

Sediments

Erosion resulting from agricultural and construction activities can cause excess turbidity and

temperature increases in aquatic systems and reduce the amount of sunlight reaching aquatic

plants. Sediments can also harm fish by depleting oxygen, clogging gills, smothering habitat and

suffocating larvae (USEPA 2005). Sediments also can transport nutrients and metals into aquatic

systems. Land uses accelerating sediment erosion on MBPI lands include road-stream crossings,

stormwater drainage ditches and culverts, construction and development areas and agricultural

runoff.

Nutrients

Fertilizers and manure applied on agricultural fields are rich in nutrients and can be a source of

nutrient pollution. Nutrients also originate from soil erosion, agricultural practices, urban runoff,

onsite septic systems, wildlife and atmospheric emissions. Excess nutrients can cause algal

blooms creating aesthetic and health related problems. When the algae die, the decomposition

process consumes oxygen, which may result in anoxic (oxygen-depleted) conditions and possible

fish kills. Other impacts of excess nutrient loading are reduced water clarity and eutrophication.

Some algae/cyanobacteria release toxins (harmful algal blooms, HABs) harmful to pets and

humans. Excess nitrates in drinking water can also cause significant health problems, especially

in infants.

Pathogens

Pathogens are disease-causing viruses, bacteria and protozoans, which can result in short-term as

well as life-threatening illnesses in humans. The State of Michigan uses Escherichia coli (E. coli)

as the method for determining pathogen levels and water quality. Pathogenic NPS pollution is

commonly associated with problematic septic or sewage treatment systems, pet waste, livestock

or waterfowl waste.

Toxicants

Toxic substances can be harmful to aquatic and human life. Toxicants are toxic man-made

products introduced to the environment. Common toxicants found as NPS pollutants include

petroleum byproducts, heavy metals and pesticides, which are generally resistant to degradation

and tend to bioaccumulate. Sources of toxicants relevant to the MBPI lands and waters may

include contaminants from automobile emissions and maintenance, pesticides and herbicides

commonly used in agriculture and roadway and parking lot maintenance and atmospheric

deposition.



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Thermal Stress

Impervious surfaces prevent rain and snow melt from infiltrating into the ground. These heat-

absorbing impervious surfaces, like roads and parking lots, can elevate the temperature of

stormwater runoff as it flows toward storm sewers or other drainage areas. Thermal stresses are

further exacerbated by removal of riparian vegetation, impoundment of shallow waters and

decreased baseflows where impervious surfaces have replaced areas where natural infiltration

occurred. This NPS pollutant stressor is most relevant to development at the MBPI’s Casino

property, where large parking areas and rooftops are prevalent. Thermal stress can harm native

flora and fauna while helping non-native species to thrive (Kieser et al. 2003).

Trash

Trash is a common NPS pollutant that can harm aquatic life and diminish the recreational and

aesthetic value of water resources. Illegal dumping and street litter, including plastics, metals and

tires, are the most relevant sources of trash effecting the MBPI lands and waters.

Water Quality Goals

Water plays an important role in the MBPI Tribal community for culture and recreation. The

mission of the MBPI Environmental Department is to “promote environmental and human health

through conservation and management, improving sustainability of our natural and

environmental resources for the next seven generations.” The MBPI’s water quality goals

directly reflect this mission to lead and to demonstrate environmental stewardship and natural

resource conservation (MBPI, Environmental 2017). This is accomplished through the

implementation of environmental education and outreach, culturally-based conservation projects

and services and direct monitoring of water quality through a monitoring plan with an EPA-

approved QAPP (MBPI 2010, 2015). Individual goals for Tribal waterbodies are reflected in the

Tribe’s formal QAPP and expounded upon in the Tribe’s NPS Management Program Plan.

To fulfill its mission in relation to water resources, the MBPI continues to implement and

develop its water program to monitor waters of importance to the MBPI. These efforts will

inform and guide the MBPI in its pursuit to develop Water Quality Standards specific to the

MBPI. This NPS Assessment Report and pending Management Plan will also serve to guide the

development of those Tribe-specific standards. Until those standards are fully developed and

implemented, the MBPI will reference the Water Quality Standards and reference values

specified by the MDEQ and the EPA to assess MBPI-Waterbodies. Where discrepancies exist

between these reference values, the MBPI will use the more protective of the two values.

Tables 5 and 6 outline the relevant designated uses for Michigan waters of the state and example

desired uses of the MBPI as well as referenced surface water quality criteria values.



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Table 5: State of Michigan Designated Uses and draft MBPI Desired Uses for MBPI waters

HUC-12 Watershed ID

MBPI Waterbody Navigable MI Designated Uses1

and MBPI (Draft) Desired Uses 2

040500030805

Buskirk Creek-

Rabbit River

Buskirk Creek No

Agriculture

Navigation

Industrial water supply

Warmwater or coldwater fishery

Other indigenous aquatic life and wildlife

Aquatic and terrestrial habitat

Subsistence fishing/hunting/foraging

Cultural and Spiritual uses

Wild Rice Habitat

Partial body contact recreation

Total body contact recreation

Casino Detention Pond 1, Retention Pond & Wetland

No

Selkirk Creek Extension No

Reno Drive Ponds No

040500030804

Bear Creek

Ingerson Lake Yes

Herlan Lake Yes

Unnamed Stream (Jijak Camp)

No

040500030803

Miller Creek


No

Unnamed Stream (Gun Lake Casino)

No

Casino Detention Pond 2 No

040500030802

Fales Drain-Rabbit River

Indian Lake Yes

Moore Lake Yes

040500030701

Gun Lake-Gun River

Boot Lake Yes

1 "Designated use" means those uses of the surface waters of the state of Michigan as established by R 323.1100 whether or not they are being attained (MDEQ 2006). 2 Draft MBPI-specific Desired Uses are in bold.



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Table 6: MBPI referenced surface water quality protection criteria values for sampled parameters

Parameter Reference Value Source Comments

Dissolved Oxygen Coldwater fishery: 7 mg/L

Warmwater fishery: 5 mg/L Michigan DEQ

Water Temperature

Coldwater Fishery, Not to Exceed (°C): May: 18.3, Jun: 20, Jul: 20, Aug: 20, Sep:

17.2 Warmwater Fishery, Not to Exceed (°C): May: 24.4, Jun: 28.9, Jul: 29.4, Aug: 29.4,

Sep: 26.1

Michigan DEQ

pH Between 6.5 and 9.0 Michigan DEQ

Specific Conductance No rule under Michigan Water Quality

Standards. Michigan DEQ

Can fluctuate seasonally based on impacts from road salt at crossings

Turbidity Should not exceed 14.5 NTU USEPA CWA

304(a) Ecoregion VII Subecoregion

56

Total Suspended Solids

Settleable and suspended solids should not reduce the depth of the compensation point for photosynthetic activity by more than 10% from the seasonally established

norm for aquatic life.

USEPA CWA 304(a)

Total Phosphorus Should not exceed 0.03125 mg/L USEPA CWA


56

Total Nitrogen Should not exceed 1.15 mg/L USEPA CWA


56

Nitrate/nitrite Should not exceed 0.41 mg/L USEPA CWA


56

Ammonia Should not exceed 1.9 mg/L USEPA CWA

304(a)

Aquatic Life Ambient Water Quality Criteria for

Ammonia- Freshwater 2013

Total Kjeldahl Nitrogen

Should not exceed 0.58 mg/L USEPA CWA


56

E.coli No greater than 1000 E. Coli per 100 ml

Partial Body Contact Standard Michigan Rule 323.1062(1)

Chloride 230 mg/L USEPA CWA

304(a)

Chlorophyll a Should not exceed 3.50 µg/L USEPA CWA

304(a)

Ecoregion VII Subecoregion 56 Measured using

Fluorometric method with acid correction



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Existing Water Quality Monitoring Program

The MBPI’s Environmental Department implemented, and continues to develop, a water quality

monitoring program of MBPI Tribal waters. A formal QAPP for the MBPI’s monitoring program

was approved by the EPA in September 2010 that included sampling Indian and Boot Lake sites

as well Buskirk Creek. Prior to 2010, water quality data had been collected by the MBPI at Boot

Lake and Indian Lake (since 2007). In 2015, a new QAPP was approved that added Ingerson

Lake. Data collected under the EPA-approved QAPPs is utilized as a part of this NPS pollutant

assessment, while data collected prior to an approved QAPP will be considered only for

historical reference.

The purpose of the MBPI’s water quality monitoring program is to gather information and assess

current conditions in order to develop MBPI water policies and land development guidance. The

program intends to assess the current water quality status of MBPI lands and waters and its

change over time (MBPI 2015). As the MBPI’s land holdings have increased over recent years,

the MBPI is currently working to amend the QAPP and add additional sites.

As the population and development of MBPI and surrounding lands increase, the demands on the

water resources may increase and be subject to additional NPS loading. For example, the Gun

Lake Casino, its associated parking areas, and water and wastewater treatment facilities were

constructed on former factory and petting farm lots in 2011. While these changes eradicated

certain types of NPS pollutants, they also introduced potential new NPS pollutants. Baseline

water quality data will allow the MBPI to understand the rate of change of erosion,

sedimentation and eutrophication throughout the MBPI lands and waters and how to address

these changes with long-term management implementations.

The MBPI’s Environmental Department currently monitors water quality at six unique sampling

locations on waterbodies associated with MBPI properties held in trust. The sampling location

names, GPS coordinates, and associated waterbodies are listed in Table 7. These locations are

displayed on a map in Figure 10.

Table 7. MBPI Environmental Department water quality monitoring site locations

Site ID Waterbody Location (GPS Coordinates)

BC01 Buskirk Creek 42.635724, -85.652766

BC02 Buskirk Creek 42.635685, -85.653352

Cmp1 Pierce County Drain Extension 42.625493, -85.649966

Indian Lake Indian Lake 42.626118, -85.620571

Boot Lake Boot Lake 42.616231, -85.588306

Ingerson Lake Ingerson Lake 42.604876, -85.748987



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Figure 10: MBPI Environmental Department water quality monitoring sites

Table 8 lists these monitoring sites with their associated water quality parameters and sampling

frequency. Parameters measured in-field by Environmental Department staff include: dissolved

oxygen, temperature, pH, specific conductance, turbidity, velocity/discharge rates, waterbody

depth/width and Secchi depth. Water samples for all other parameters are analyzed by Prein &

Newhof of Grand Rapids, Michigan.

Trends and standout issues identified for each waterbody by the MBPI’s water quality

monitoring data are fully addressed in the “Discussion of Results” section.



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26

Table 8: MBPI’s water quality monitoring sites and parameters

Site

Sam

plin

g Fr

eq

ue

ncy

Dis

solv

ed

Oxy

gen

(D

.O.)

Tem

pe

ratu

re

pH

Spe

cifi

c C

on

du

ctan

ce

Turb

idit

y

Ve

loci

ty/D

isch

arge

Rat

es

De

pth

/ W

idth

Tota

l Su

spe

nd

ed

So

lids

(TSS

)

Tota

l Ph

osp

ho

rus

(TP

)

Tota

l Nit

roge

n (

TN)

Nit

rate

Nit

rite

Am

mo

nia

TKN

Cal

ciu

m

Mag

ne

siu

m

Sulf

ate

E.co

li

Ch

lori

de

Ch

loro

ph

yll a

Ph

eo

ph

ytin

a

Secc

hi D

ep

th

BC01 Monthly X X X X X X X

BC01 Quarterly X X X X X X X

BC02 Monthly X X X X X X X

BC02 Quarterly X X X X X X X

Cmp1 Monthly X* X* X* X* X* X* X*

Cmp1 Quarterly X* X* X* X* X* X* X* X*

Indian Lake Monthly** X X X X X X X

Indian Lake Quarterly X X X X X X* X X* X* X* X* X* X* X*

Selkirk Lake Monthly** X* X* X* X* X* X*

Selkirk Lake Annually X* X* X* X* X* X* X* X* X* X* X*

Boot Lake Monthly** X X X X X X X

Boot Lake Annually X X X X X X X X

Ingerson Lake Monthly** X X X X X X X

Ingerson Lake Annually X X X X X X X

* Not covered by latest QAPP. **When accessible due to safe ice conditions.

Other Water Resource Monitoring Projects The MBPI’s Environmental Department also monitored limited water quality parameters on Mill

Pond between 2007 and 2010. Mill Pond is not bordered by a MBPI property but it does flow

into Boot Lake. The pond sits approximately 0.89 km northwest of Boot Lake, just south of 129th

Avenue. Parameters monitored included D.O., temperature, pH and conductivity.

The MBPI also monitored limited water quality parameters in Selkirk Lake. While the lake does

not border MBPI lands, a county drain construction project currently underway to control water

levels in Selkirk Lake will drain waters from Selkirk Lake to Indian Lake. Limnological

assessments were also performed on Selkirk and Indian Lakes in 2016 by Progressive AE as part

of the MDEQ permit review process for construction of the county drain. These issues are

detailed more fully in the “Discussion of Results” section.



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Hydrologic Modeling Analyses

HAWQS Watershed Analysis

HAWQS (Hydrologic and Water Quality System) was used for a broad watershed analysis for

the five 12-digit HUC watersheds on which the MBPI properties reside. HAWQS is an online

tool run by the EPA that uses the SWAT model to analyze 8-, 10- or 12-digit HUC watersheds.

HAWQS is limited in its ability to perform model calibration beyond what is built in. To

compensate for this, HAWQS predicted flow rates and phosphorus loads were modified with

adjustment coefficients. The flow adjustment coefficient is based on US Geological Survey

(USGS) stream data. Flow data from the model run (1990-2010) was compared against measured

flow data (USGS station 04108600) to determine the coefficient value. No such continuous

measured phosphorus data exists in the area, so an area-based event mean concentration (EMC)

analysis was run to predict total phosphorus loading for the combined watersheds. This approach

has worked well for previous projects throughout the Kalamazoo River Watershed.

The EMC calculated total was then compared against the HAWQS output to determine the

phosphorus adjustment coefficient. Adjusted model output was compared against previous

modeling work done for the Gun River (Non-Point Source Modeling of Phosphorus Loads in the

Kalamazoo River/Lake Allegan Watershed for a Total Maximum Daily Load, K&A, 2001) as a

cross-check for accuracy and was found to only differ by 2.7% for predicted seasonal

phosphorus loads.

Data were analyzed for both temporal (monthly averages throughout the year) and spatial

(differences between the seven watersheds) trends. Table 9 provides a summarized breakdown of

the seven watersheds and their sediment and phosphorus load contributions downstream.

Table 9: Summary of watersheds sediment and phosphorus load contributions

Watershed Area (ac) Sediment loss

(Mg/yr) Phosphorus loss (kg/yr)

Sediment loss (Mg/ac/yr)

Phosphorus loss (kg/ac/yr)

Gun Lake 21,903 865 1,978 0.0 0.1

Fales Drain 13,719 2,156 2,586 0.2 0.2

Buskirk Creek 19,421 3,202 4,312 0.2 0.2

Miller Creek 12,867 2,005 4,743 0.2 0.4

Bear Creek 11,693 4,622 5,404 0.4 0.5

Subtotal Rabbit River 57,701 11,985 1,7046 0.2 0.3

Total Gun + Rabbit 79,604 12,850 19023 0.2 0.2

In general, the five Rabbit River watersheds had higher modeled per acre sediment and

phosphorus losses than the two Gun River watersheds. The area is dominated by agriculture,

with that land use making up 56% of the total land and 75% of the total phosphorus load. This is

also reflected in the average monthly phosphorus loadings, which peak during the early months

of the year when agricultural fields have low crop cover, high nutrient inputs and are subject to



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snowmelt driven runoff. Figures 11-14 illustrate the modeled average subwatershed

contributions of flow and total phosphorus to the Rabbit River and Gun River watersheds,

respectively.

Figure 11: Modeled subwatershed flow contributions to the Rabbit River

Figure 12: Modeled subwatershed phosphorus contributions to the Rabbit River

0

0.5

1

1.5

2

2.5

3

3.5

4

1 2 3 4 5 6 7 8 9 10 11 12

Ave

rage

flo

w (

cms)

Month

Avg. Subwatershed Contributions to Rabbit River Flow by Month, 1990-2010

Fales Drain Buskirk Creek Miller Creek Bear Creek

0

500

1000

1500

2000

2500

3000

3500

4000

1 2 3 4 5 6 7 8 9 10 11 12

TP L

oad

(kg

/mo

nth

)

Month

Avg. Subwatershed Contributions to Rabbit River TP Load by Month, 1990-2010

Fales Drain Buskirk Creek Miller Creek Bear Creek



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Figure 13: Modeled subwatershed flow contributions to the Gun River

Figure 14: Modeled subwatershed phosphorus contributions to the Gun River

0

0.5

1

1.5

2

2.5

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3.5

4

1 2 3 4 5 6 7 8 9 10 11 12

Ave

rage

Flo

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Month

Avg. Subwatershed Contributions to Gun River Flow by Month, 1990-2010

Gun Lake

0

500

1000

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2500

3000

3500

4000

1 2 3 4 5 6 7 8 9 10 11 12

TP L

oad

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Avg. Subwatershed Contributions to Gun River TP Load by Month, 1990-2010

Gun Lake



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Event Mean Concentration Analysis

Modeling analyses of MBPI lands and waterbodies included an Event Mean Concentration

(EMC) analysis to determine runoff volume, sediment loss and phosphorus loss for all MBPI

Tribal parcels. Parcels were delineated into land-cover types via aerial images. Runoff and

sediment/TP loads were calculated as follows:

ML = EMCL x RL (Eq. 1)

Where:

ML = Loading factor from land use L (kg/year)

EMCL = Event mean concentration of runoff from land use L (mg/L)

RL = Total average surface runoff from land use L computed from Eq. 2 (Ml/year)

Runoff Equation:

RL = [CP + (CI – CP ) x DCIAf x IMPL ] x AL x I x K (Eq. 2)

Where:

RL = Total average annual surface runoff from land use L (Ml/year)

CP = Pervious area runoff coefficient

CI = Impervious area runoff coefficient

DCIAf = Fraction of impervious area that is directly contributing

IMPL = Fractional imperviousness of land use L

AL = Area of drainage unit (acres)

I = Long term average annual precipitation (mm/year)

K = Unit conversion factor of .00405

Coefficients used are as follows:

I 1000.0

Cp 0.1

Ci 0.9

DCIA-f 0.5

Land Use IMP-L EMC-L

TSS TP

Commercial 0.5 - 1 77 0.33

Medium Density Residential 0.3 - 0.33 81 0.28

Low Density Residential 0.1 - 0.3 81 0.28

Agricultural 0.005 145 0.37

Open/Scrub 0.005 51 0.11

Forested 0.005 51 0.11

Water 0 6 0.08



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Results from the EMC analysis shows that the majority of the parcels analyzed were predicted to

have relatively low phosphorus loss loads. Of the forty-one parcels analyzed, the five with the

highest loads made up 59% of the total phosphorus load across all parcels. Of these five parcels,

three are agricultural fields. These include the Nowak parcel (Allegan County Parcel

Identification Number (PIN: 10-024-003-00), the Zanbergen parcel (PIN: 24-019-029-10) and

the North 130th parcel (PIN: 24-018-010-00), the latter of which already has a detention pond in

place. Agricultural land is expected to have higher nutrient loading due to fertilizer inputs.

The parcel with the third-highest predicted phosphorus load is the government campus parcel

(PIN: 24-019-029-20). While stormwater reductions were part of the calculations on this parcel,

the true impact of the BMP’s in place require validation from on-site measurements in order to

be accurate. The actual phosphorus load from this parcel may well be lower than the predicted

load if the BMP’s are performing well.

The parcel with the highest predicted phosphorus load is the Jijak Camp main parcel (PIN:10-

032-001-30). Unlike most of the other parcels with developed land uses, this parcel lacks any

significant stormwater BMP’s. Together with the adjacent Jijak Camp parcel (PIN: 10-032-001-

31) they are responsible for 31% of the total predicted phosphorus load across all parcels. These

parcels present the best opportunity for reducing total phosphorus loads via the installation of

new stormwater BMP’s.

Table 10 illustrates the results of the EMC analysis for all MBPI parcels. All parcels were

included in the EMC analyses for the sake of continuity and comparison of loads.

Table 10: Results from the EMC analysis for MBPI land use types

Land Use Area (ac)

Runoff (Ml)

Sediment loss (Mg)

TP loss (kg)

Developed1 310.5 181.1 14.5 53.4

Agricultural 467.2 164.0 23.8 60.7

Open/Scrub 142.9 59.0 3.0 6.5

Forested 207.8 85.8 4.4 9.4

Water 46.5 16.3 0.1 1.3

Total 1175.0 506.1 45.7 131.4

1: Combined category for Commercial and Residential Land Uses

Table 11 illustrates the EMC analytical results for each land type relative to all MBPI lands.

While some parcels are estimated to contribute only a small volume of stormwater runoff or

pollutant load, the cumulative effect of these contributions has significant impacts on the quality

of the receiving waters. For the purposes of this analysis, lands containing stormwater BMPs are

assumed to reduce stormwater runoff volume and treat pollutant loads to some extent through

volume capture, retention, infiltration, and vegetative uptake. Table 11 notes where such BMPs

currently exist on Tribal parcels. Importantly, the Tribe’s NPS Management Program Plan

includes monitoring to verify the assumed effectiveness of existing BMPs.



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Table 11: Results from the EMC analysis for all MBPI parcels

HUC-12 Watershed ID

MBPI Property Identifier

Allegan Co. PIN Area (ac)

Runoff (Ml)

Sediment loss (Mg)

TP loss (kg)

040500030804 Bear Creek

Jijak Camp 10-032-001-30 156.8 102.0 6.8 22.3

10-032-001-31 19.9 16.1 1.3 4.5


Government Campus 24-019-029-203 41.6 37.8 2.9 12.5

House in front of Govt. Campus

24-019-029-00 0.9 0.4 0.0 0.0

24-019-045-00 1.0 0.6 0.0 0.2

Former RTC 24-019-033-00 16.2 6.7 0.3 0.7

Former RTCa 24-019-032-102 9.6 2.4 0.1 0.3

Former RTCb 24-019-032-00 36.5 15.1 0.8 1.7

Plummers 24-019-032-11 3.8 1.6 0.1 0.2

24-019-032-20 9.3 5.3 0.4 1.0

Zanbergen 24-019-029-10 75.4 31.1 4.5 11.5

Nowak 10-024-004-00 130.8 54.0 7.8 20.0

1217 129th Ave 10-024-002-00 4.2 2.0 0.1 0.4


The Settlement

24-028-015-40 12.4 5.1 0.7 1.9

24-028-015-80 19.9 13.0 0.9 2.9

24-028-015-90 13.7 8.9 0.6 2.0

2801 Odawa Trail 24-021-017-90 7.7 5.0 0.4 1.1

Indian Lake

24-021-023-00 11.9 4.9 0.3 0.5

24-021-023-60 0.6 0.2 0.0 0.0

24-021-024-00 2.9 1.2 0.1 0.1

24-028-015-00 10.6 4.4 0.2 0.5

24-028-015-30 10.2 4.2 0.2 0.5

Moore Lake 24-028-013-10 33.6 14.8 0.7 2.2

6th Street 24-021-041-10 20.1 8.3 0.4 0.9

129th Ave 24-022-030-00 9.9 4.1 0.2 0.4


Gun Lake Casino 24-019-026-002 26.2 0.0 0.0 0.0

24-019-026-302 122.9 15.2 2.0 5.0

1113 129th Ave 24-019-027-00 1.5 1.8 0.1 0.6

North 130th 24-018-010-001 139.6 28.8 4.2 10.7

24-018-011-00 9.7 4.7 0.3 1.0

Reno Drive Parcels

56-007-013-00 2.0 1.1 0.1 0.3

56-007-013-10 2.0 1.1 0.1 0.3

56-007-013-20 3.9 1.6 0.1 0.2

56-007-013-40 1.0 0.6 0.0 0.2

56-007-017-30 24.7 10.2 0.4 1.0

1159 132nd Ave 24-007-007-00 3.0 1.7 0.1 0.5

1144 132nd Ave 24-018-008-00 40.8 18.8 2.3 6.2

1186 132nd Ave 24-018-009-00 48.4 22.3 2.4 6.3

1168 132nd Ave 24-018-009-10 19.5 8.5 1.1 3.0

040500030701 Gun Lake

Luella Collins Community Center (LCCC)

24-027-018-003 42.4 24.5 1.5 4.8

24-027-015-00 27.9 16.0 1.0 3.0

Totals 1175 506 46 131

Green rows indicate parcels with stormwater BMP’s present

1: Detention pond was assumed to handle half of the field

2: Stormwater detention areas assumed to remove loads from developed portions of parcel for this analysis

3: Stormwater treatment areas with native plantings and detention areas decrease loads from developed portions of parcel



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Discussion of Results

The following sections discuss results for the assessment of NPS pollution affecting each

individual MBPI property and its waters. This includes summations of each waterbody, the

contributing MBPI lands and land uses and the receiving waters and watershed land uses. These

discussions include summarizations of monitoring efforts and notable trends in water quality data

collected by the MBPI’s Environmental Department. Observations from the MBPI Consultant

field reconnaissance and modeling analyses, as well as information from existing sources are

also noted. Based on these assessment efforts, NPS pollution impairments, threats and existing

controls are identified and discussed for each waterbody and contributing MBPI property.

Identification of NPS pollution issues also includes general suggestions for potential future water

quality monitoring and BMP implementations.

Overall, the lands of the MBPI are well suited to control or mitigate NPS pollution in order to

protect and improve receiving waters. Developed lands of the MBPI contribute the most

potential NPS pollution to receiving waters. This is mainly in the form of untreated stormwater

inputs causing erosive conditions leading to sediment and nutrient NPS pollution. The Jijak

Camp property particularly lacks adequate NPS controls for stormwater. Though NPS controls

exist on the Gun Lake Casino property, many NPS pollutants are contributed to the two detention

ponds, which do contribute flows to receiving waters. The pollutant treatment efficiencies of two

detention ponds at the Reno Drive property and the frequency of their overflow or discharge to

the Selkirk Creek Extension are unknown. The Luella Collins Community Center and MBPI

Government Campus contain NPS stormwater controls but their treatment efficiencies are also

unknown at this time. Visual monitoring of the ponds and BMPs will be included in BMP

management plans as outlined in the Tribe’s NPS Management Program Plan.

Streams on MBPI properties are also affected by hydromodification causing streambank erosion.

This condition is exacerbated by stormwater inputs from developed lands and from lands used

for agriculture. NPS pollution from agricultural fields is the predominant issue affecting streams

crossing through or originating on MBPI lands. Agricultural NPS pollution particularly affects

downstream areas. This includes sediment and nutrient pollution from surface water runoff and

tile drainage.

NPS pollutant inputs from roadways, parking lots, bridges and culverts also impact MBPI

properties, many of which are in close proximity to these types of developments both on and off

MBPI lands. Such developments contribute NPS pollutants in the form of toxicants, thermal

stresses and trash, and can cause accelerated sediment and nutrient transport through erosion.

References to the MBPI Environmental Department’s water quality data and to the MBPI

Consultant field reconnaissance observations are included throughout the following discussion of

results. Relevant water quality data and field photos are graphically illustrated in Attachments A

and B, respectively. Table 13 provides a summary of NPS pollutants, sources and severity, while

Table 14 summarizes impaired and threatened designated and desired uses, as well as potential

future NPS pollutant source threats to MBPI waters. These tables are located at the end of the

“Discussion of Results” section.



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Ingerson Lake (Jijak Camp)

Ingerson Lake is a eutrophic lake, with mucky sediments and a recorded maximum water depth

of approximately 8 m. This approximately 16-acre lake is surrounded mostly by the MBPI’s

Jijak property. The MBPI utilizes this parcel for cultural purposes. It is home to Jijak Camp, a

youth summer camp. The Jijak property also houses the MBPI’s Pow Wow Arena and Sacred

Fire Pavilion, with large fields dedicated to hosting visitors for the annual cultural events.

Overnight accommodations include bunkhouses with modern bathrooms and a rustic

campground although no water or sewer hook ups are provided at the campground. Other

cultural resources on site include community gathering sites, maple tree tapping with a sugar

shack for processing syrup, black ash basket weaving and a community garden. The MBPI uses

Ingerson Lake and its surrounding area for fishing, birding, hiking, canoeing, kayaking,

picnicking, hunting and other recreation (MBPI 2015).

The Jijak property accounts for approximately 1,019 m. of Ingerson Lake’s shoreline, while

approximately 200 m of shore are outside of the MBPI property. Approximately 45 m of

shoreline has been cleared and sanded for beach use by campers and visitors to the Jijak

property. On the lake’s western shore, outside of the MBPI’s property, a small channel was

developed for agricultural irrigation. The majority of the shoreline remains undeveloped,

however, with abundant, dense wetland vegetation and woodlands throughout the hilly upland

areas. In these woodlands, the MBPI Environmental Department has focused on physical

removal and biocontrol efforts to mitigate invasive species including autumn olive, honeysuckle

and the emerald ash borer.

One natural outlet exists on Ingerson Lake’s northwest corner, which flows through a small

wooded area before passing into a mostly channelized ditch flowing through row-cropped

agricultural lands. It joins with the outlet from Herlan Lake south of 126th Avenue. A small

unnamed stream, which also originates on the MBPI’s Jijak property, joins the Ingerson and

Herlan Lakes outlet near 22nd Street. This outlet ultimately discharges to Bear Creek, southwest

of the town of Hopkins. The Bear Creek watershed, a tributary of the Rabbit River, produces

relatively high losses of sediment and phosphorus compared to other Kalamazoo River

subwatersheds, at 0.4 Mg/ac/yr of sediment and 0.5 kg/ac/yr of phosphorus, per the modeling in

this report.

Since 2012, the MBPI Environmental Department has recorded monthly field measurements in

Ingerson Lake including D.O. profiles, temperature, pH, conductivity, Secchi depth and

turbidity. Data show Secchi disk depths, recorded between 2012 and 2018, range from 0.5 m to

3.0 m, averaging 1.7 m. D.O. tends to drop below the referenced WQS of 7 mg/L for supporting

coldwater fisheries, throughout the water column, from mid-summer into autumn. D.O. tends to

drop below the referenced WQS of 5 mg/L for supporting warmwater fisheries in waters deeper

than 3 m during the same time period. During mixing conditions in early spring and late autumn,

D.O. measurements are typically well above 7 mg/L and as high as 15.6 mg/L in waters

shallower than 5 m. Surface water temperatures during the hottest months have been recorded as

high as 29.47 °C but typically remain well-below the referenced WQS for supporting warmwater

fisheries, not to exceed 29.4 °C in July and August.



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Measurements for pH have typically been within the referenced WQS range of 6.5-9.0 pH, with

the exception of measurements recorded from 2013-14, which consistently showed >9.0 pH.

Turbidity measurements tended to increase in waters deeper than 4 m, especially during the

summer months. Turbidity measurements consistently exceeded the referenced WQS of 14.5

NTU in bottom water measurements recorded from 2012-14 but no exceedances have been

recorded since July 2015.

The MBPI has also conducted semi-annual collection of samples for analysis, since 2012, of E.

coli, nitrate-N, nitrite-N, total Kjeldahl nitrogen (TKN), total nitrogen, total phosphorus (TP),

total suspended solids (TSS) and chloride. TP concentrations collected from the surface between

July 2012 and 2018 averaged 0.0246 mg/L, with some exceedances of the referenced WQS of

0.03125 mg/L, and a maximum concentration of 0.050 mg/L recorded in October 2016.

Similarly TKN measurements have ranged from 0.11 mg/L to 5.51 mg/L, averaging 1.64 mg/L,

well above the referenced WQS of 0.58 mg/L. Data collected to date is insufficient to compare

TKN measurements to other nitrogen parameters nor to outline seasonal trends.

While most data for E. coli are well below the applicable water quality standard of 1,000

counts/100ml, one sample, collected on 16 June 2015, exceeded the standard at 1,400

counts/100ml (Environmental Department 2018). MBPI Environmental Department staff noted

that a filamentous algae bloom took place on Ingerson Lake in late May and early June 2018 and

that multiple additional E. coli samples collected at the beach during the summer of 2018 were

near or above the water quality standard of 1,000 counts/100ml (Wieten personal communication

2018).

No substantial stormwater BMPs exist on the Jijak property to control NPS pollutants carried

through stormwater discharges. While some small rain gardens and gravel areas exist around

stormwater inlets near the Arena and Sacred Fire Pavilion, these do not significantly slow nor

lessen the quantity of stormwater discharging to a problematic outfall near Ingerson Lake.

Erosion caused by high volumes and flows of stormwater discharging from this outfall has led to

accelerated sediment and nutrient transport.

This problematic outfall discharges stormwater to riparian wetlands on Ingerson Lake’s

southeast corner. Significant gully erosion is occurring at the outfall and along the length of the

approximately 90 m drain. The gully runs through the wooded upland before dissipating into the

natural wetland area. The outfall discharges stormwater from three drainage areas in the uplands

developed to host the Arena and Sacred Fire Pavilion and several small buildings. The 18-in

stormwater outfall discharges immediately south of the gravel driveway.

The discharge has created a large, 1 m-deep plunge pool with scoured exposed banks as deep as

1 m in some areas. The deeply scoured, exposed banks continue for nearly 35 m, before the gully

converges with the smaller stormwater ditch and bends sharply to the east. Some stone

protections have been installed to protect banks, but these are mostly failing. The gully remains

up to 1 m deep in some areas, with exposed tree roots and sharp bends. As the gully becomes

shallower and more sinuous, some surface washouts occur, nearing the wetland area. This is

currently the main NPS pollutant issue on the Jijak property.

Event Mean Concentration (EMC) modeling corroborates this finding. Jijak Camp had the

highest predicted phosphorus load compared to other MBPI parcels. Jijak Camp therefore



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presents the best opportunity for reducing total phosphorus loads through the installation of new

stormwater BMPs. These could include erosion protection measures below the outfall and upland

stormwater BMPs to slow and reduce the flow and quantity of stormwater discharging to the

outfall as well as channel restoration where appropriate. Limited monitoring of water quality

during wet weather before and after the improvements could provide helpful data in correlating

the effectiveness of various stormwater BMPs on MBPI properties.

Other NPS pollutant issues on the Jijak property include large numbers of geese producing

nutrient-rich droppings around the Jijak Camp beach and surrounding mowed grass areas. A

small stormwater drain, leading from the upland area to a wooded area near the beach, is not

currently showing signs of erosion but should be monitored. MBPI Environmental Department

staff also noted that herbicides are used to reduce vegetative presence on gravel parking lots and

driveways which can also produce stormwater runoff. North of the Pow Wow Arena and Sacred

Fire Pavilion, a small baseball diamond is showing signs of rill erosion, with water flowing

northeast toward an upland wooded area. Another outfall transports stormwater from the grassy

field north of the Arena and Sacred Fire Pavilion, to this upland wooded area as well.

Herlan Lake (Jijak Camp)

The MBPI’s Jijak property also borders a very small section (approximately 15 m of shoreline)

of Herlan Lake, immediately southwest of Ingerson Lake. The MBPI’s access to Herlan Lake is

via an infrequently used trail which winds through the woodlands within the Jijak property. The

shoreline of Herlan Lake is mostly natural vegetation with the exception of one small residential

development on the lake’s southwest peninsula. There is a small inlet on the lake’s south side

and an outlet on the lake’s northwest side.

Herlan Lake’s outlet flows due north through a wooded area before its confluence with the

Ingerson Lake outlet, south of 126th Avenue. From this point of convergence, the waterbody

enters a mostly channelized ditch passing through row-cropped agricultural lands. This drain

ultimately discharges to Bear Creek.

The MBPI’s Environmental Department does not currently conduct water quality studies on

Herlan Lake. Anecdotally, MBPI Citizens do not often use Herlan Lake for recreational purposes

as access through Jijak Camp is challenging (Wieten personal communication 2018). If access is

improved and Citizens begin to utilize the lake, sampling may occur in the future. The MBPI’s

shoreline is naturalized and the upland area consists of protected, managed woodlands. As such,

no nonpoint source pollutant contributions of note exist from the MBPI’s Jijak property. The

main NPS issue identified outside of MBPI’s property on Herlan Lake is residential shoreline

development and potential septic field drainage from the residential development on the lake’s

southwest peninsula.

Unnamed Stream (Jijak Camp)

A small, unnamed stream also originates within the MBPI’s Jijak property, with headwaters in

the low-lying wet woodlands at Jijak’s northeast corner parcel near the corner of 20th Street and



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126th Avenue. This unnamed stream flows northward exiting the MBPI’s property as it passes

beneath 126th Avenue. Approximately 190 m of this stream exists on the Jijak property. From

there, the stream flows roughly northwest through a row-cropped agricultural field and winds

through a small woodland before entering a channelized agricultural ditch. This stream joins with

the outlet from Ingerson and Herlan Lakes near 22nd Street ultimately draining to Bear Creek.

While the headwaters of this unnamed creek remain undeveloped, they lie in very close

proximity to 20th Street, within 12 m of the road in one area and averaging a distance of 30 m

from the road where the shoulder is regularly mowed. Immediately to the west, the MBPI has

maintained an unmowed native prairie which buffers the stream from the nearest parking area on

the Jijak property. Near 126th Street a small area of prairie has been converted to a community

garden within 15 m of the unnamed stream. While this small area is well-graded and buffered by

the woods, care should be taken, particularly before planting and after harvest, to prevent loose

soils from eroding toward the stream.

South of this headwaters area, a large area of grass lawn on the Jijak property is regularly mowed

to within 15 m of the headwaters. Consideration could be given to maintaining a larger un-

mowed buffer zone in this area. Field surveys confirmed reports of legacy trash disposal in the

wooded southwest area of the unnamed stream’s headwaters. This midden included household

appliances, scrap metal pieces and various discarded plastics. To prevent any further pollutants

from entering surface waters, fully removing this legacy trash midden and remediating the small

area of woodland is recommended.


An extension to the Pierce County Drain originates in wetlands and wet woodlands to the south

and southeast of the MBPI Government Campus. Approximately 2.4 km of this stream passes

through MBPI lands. From the Government Campus, the stream flows due west passing through

the MBPI Zanbergen parcel currently leased for row-crop corn and soy agriculture and two

MBPI Former RTC parcels in secondary succession. The stream then passes beneath US-131

highway and continues to flow west, passing through the MBPI Nowak parcel, a field leased for

row-crop agriculture, before flowing southwest mainly through agricultural ditches. The Pierce

County Drain Extension passes through MBPI lands which exemplify the range of land uses

currently existing on the MBPI’s properties including new developments, active row-crop

agriculture and fields converted to secondary succession.

The water ultimately discharges to Miller Creek, a tributary of the Rabbit River. The HAWQs

watershed analysis suggests that Miller Creek subwatershed experiences high rates of sediment

and phosphorus loss relative to other subwatersheds of the Rabbit River. Critical sources of NPS

pollutants in Miller Creek include streambank erosion, lack of riparian buffer, and agricultural

surface water runoff, tile outlet erosion and livestock access sites (FTCH 2009). Miller Creek

sediment loss is estimated at 0.2 Mg/ac/yr and phosphorus loss estimated at 0.5 kg/ac/yr.

The MBPI Government Campus, built in 2015, serves as the MBPI’s Capital. This is the MBPI’s

administrative hub which functions to improve the lives of MBPI Citizens and their families

while educating the community on the history and culture of the MBPI. The campus was built on



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former agricultural fields. Its design incorporated Low-Impact Development (LID) BMPs

including nonpoint source pollutant controls like vegetated parking lot swales, a stormwater

retention area and native plantings.

Event Mean Concentration (EMC) analyses suggest that the government campus parcel may

produce relatively high phosphorus loads in stormwater runoff. These modeled results, however,

do not specifically reflect the positive impact of the BMPs in place at this setting. The results

require validation from on-site measurements in order to accurately understand phosphorus and

sediment transport and capture during wet-weather events. The actual phosphorus load from this

parcel is expected to be lower than the predicted load if the BMPs are performing well.

West of the MBPI’s Government Campus, the Pierce County Drain Extension passes beneath a

railroad bed and flows for approximately 400 m through the Zanbergen parcel, MBPI trust land

currently leased for row-cropped corn and soy agricultural use. This section of creek is highly

susceptible to NPS pollution (sediment and nutrient loading) through accelerated erosion and

agricultural runoff. Although it appears this parcel appears to be tilled via aerial photographs, it

has not been confirmed to still be functioning. Four locations are particularly susceptible: the

railroad bridge crossing; an agricultural equipment bridge crossing; and two locations where

surface water runoff from the agricultural fields enters the creek during wet weather.

To the west of these parcels, the Pierce County Drain Extension flows another 400 m through the

MBPI’s Former RTC parcels before passing beneath the highway US-131. These parcels

immediately east of US-131 are of mixed use. The southern-most parcel remains in mature

secondary succession, hosting a variety of flora and fauna. Wet areas in this parcel drain toward

the Pierce County Drain Extension via a swale which parallels US-131. The northern-most

parcels host some wooded areas where two older buildings are utilized by the MBPI for

equipment storage. A small trash midden was noted around one of these buildings. A gas station

was constructed on these parcels in 2017 along 129th Avenue. NPS pollutant control practices

including a stormwater retention pond, were implemented. Minor erosion on the banks of this

retention pond was noted during field visits in 2018.

West of US-131, the Pierce County Drain Extension enters the MBPI’s Nowak parcel (10-024-

003-00), currently leased for row-crop corn and soy agriculture. The creek receives pollutant

contributions from ditches draining stormwater between US-131 and 12th Street at this point.

This area could be prone to future erosive conditions via rill and streambank erosion. Between

12th Street and 13th Street the waters enter an agricultural ditch with steep banks, flowing west

through the Nowak parcel which is leased for agricultural use. The EMC analyses show that the

Nowak parcel is likely contributing the second-highest pollutant load relative to all other MBPI

parcels. The steep banks and poor riparian buffers make this stretch highly susceptible to

sediment and nutrient pollutant loading through accelerated erosion and agricultural surface

water runoff. Erosive conditions caused by surface water runoff were noted in-field near the 13th

Street road-creek crossing during field visits in 2018.

Accelerated erosion is the main NPS pollutant issue affecting the MBPI parcels through which

the Pierce County Drain Extension flows, most notably in stretches passing through row-cropped

agricultural parcels. Nutrient pollutant contributions might also come from tile drainage in the

agricultural parcels. Because the presence or absence of tile drains is unknown at this time, the



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NPS Management Program Plan will include recommendations for surveying tile drain outlets,

prioritizing MBPI Ag parcels. One private gravel road crossing in the Former RTC parcel, where

the creek nears US-131, should also be monitored for future erosive conditions. Erosion is

exacerbated by the channelization of this watercourse where dense tree stands, including

invasive species, cling to steep banks often with roots exposed. Pollutants from the federal

highway are also a notable concern, particularly in the downstream portion which flows through

the MBPI’s Nowak parcel west of the highway. These pollutants include sediments, nutrients,

toxicants and litter from automobile traffic all of which can be carried by stormwater runoff to

the waterway.

The MBPI Environmental Department staff has monitored water quality parameters in the

extension of Pierce County Drain within the Government Campus parcel (CMP1) since 2016.

There are currently not enough data available to corroborate the modeled EMCs with actual

conditions in the waterway. The Environmental Department should continue monitoring physical

and chemical parameters to determine the extent of NPS pollutant impacts from the Government

Campus.

Buskirk Creek (Gun Lake Casino)

Buskirk Creek is a shallow stream which flows along the northern edge of the MBPI’s Casino

property and along their property immediately to the north, currently leased for row-crop corn

and soy agricultural use. The creek originates at Doans Lake, an approximately 11-acre lake to

the northeast of the Casino property. From Doans Lake, the creek flows beneath 10th Street (M-

45) before winding more-naturally through woodlands to the south and west. Water

accumulating in these woodlands also contributes to Buskirk Creek, which flows beneath a

railroad right of way before entering the Gun Lake Casino property.

Immediately beyond MBPI lands, Buskirk Creek makes two 90-degree bends along the US-131

MI Department of Transportation (MDOT) right of way before flowing west under the highway.

From there, Buskirk Creek flows for approximately 5 km through mostly channelized

agricultural ditches until it joins the Rabbit River. HAWQs analysis shows that the Buskirk

Creek subwatershed contributes relatively average sediment and phosphorus loads compared to

other subwatersheds of the Kalamazoo River, at 0.2 Mg/ac/yr sediment loss and 0.2 kg/ac/yr

phosphorus loss.

The approximately 756 m stretch of Buskirk Creek flowing through MBPI property is highly

channelized, with steep banks (1 to 2 m tall), areas of scouring and exposed tree roots. One

particularly notable area of scouring occurs as Buskirk Creek emerges from beneath the railroad

bridge and enters MBPI property. The MBPI Environmental Department monitors flows and

water quality parameters monthly at this site (BC1). Monthly monitoring data collected at BC1

since 2010, including flows, show typical seasonal fluctuations, with some anomalies, occurring

throughout the year at this location in Buskirk Creek.

Flows recorded from 2013-17 were typically highest from May-June with an average for those

months of 0.036 m3/s and a maximum of 0.118 m3/s, resulting from snow melt and spring rains.

Flows were lowest during the drier summer and winter months, with an average of 0.009 m3/s in



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the summer months and a recorded minimum discharge of 0.005 m3/s. These measurements

suggest that Buskirk Creek experiences fairly flashy flows during periods of intense wet weather,

which can increase the risk of scouring and streambank erosion and negatively affect aquatic life.

Temperature measurements show, with one exception recorded June 30, 2015, that in-stream

temperatures are adequate for supporting a warmwater fishery. This is likely because the

immediate upstream stretch of Buskirk Creek is comprised of well-shaded woodlands. Seasonal

fluctuations of specific conductance were generally consistent throughout the monitored period.

D.O. measurements also show fairly consistent seasonal trends, within the referenced WQS’s for

supporting warmwater fisheries, since 2016 but several erratic periods were measured prior to

2016. This includes two periods of very low D.O., less than 4 mg/L, recorded consistently from

July 2011 to April 2012 and again in May and June of 2014. Conversely, in June and July of

2015, D.O. was recorded at greater than 19 mg/L. pH measurements have been consistently

recorded within the referenced WQS, between 6.5-9.0 pH, since July 2014. Several spikes in pH

were recorded prior to July 2014, with a maximum of 10.7 pH recorded in June 2014 and a

measurement of 9.62 pH recorded in September 2013. Continued future monitoring will provide

insights into these recorded anomalies and their possible causes.

Approximately 25 m downstream of BC1, the MBPI’s private wastewater treatment plant

(WWTP) discharges treated effluent. The Environmental Department also monitors flows and

water quality parameters at BC2, immediately downstream of the WWTP discharge. The WWTP

received an NPDES permit with water quality based effluent limitations (WQBEL) in 2009. The

treatment plant discharges approximately 257,408 liters per day or 93,953,876 liters per year. At

a standard treatment effluent concentration of 0.5 mg/L total phosphorus (TP), this creates a

yearly load of 47.0 kg TP. Annual loads at different treatment levels are listed in Table 12.

Table 12: Typical WWTP treatment efficiencies.

Treatment Type mg/L TP kg/yr. TP

Standard 0.500 47.0

Enhanced Secondary 0.200 18.8

Tertiary 0.075 7.0

MBPI water quality data at the monitoring stations upstream (BC1) and downstream (BC2) of

the WWTP discharge showed total phosphorus (TP) concentrations to be relatively similar at

BC1 and BC2, with a few exceptions. TP concentrations measured since February 2011 have

averaged 0.063 mg/L at BC1, with a recorded maximum concentration of 0.132 mg/L. At BC2,

TP concentrations since February 2011 have averaged 0.066 mg/L, with a recorded maximum

concentration of 0.152 mg/L. Average TP concentrations at BC2 have measured 0.003 mg/L

higher than concentrations at BC1 (Environmental Department 2018). Measured TP

concentrations have consistently exceeded the referenced water quality standard of 0.03125

mg/L at both monitoring sites. Figure 15 illustrates these trends.

E. coli and total Kjeldahl nitrogen (TKN) concentrations measured in Buskirk Creek also tended

to be similar between BC1 and BC2, with a few exceptions and with some exceedances of

referenced water quality standards. E. coli levels at both stations in Buskirk Creek on 29 July

2011, 26 May 2016 and 31 July 2017 exceeded EPA’s daily maximum geometric mean of 1,000

E. coli per 100 ml for partial body contact. On average, E. coli concentrations upstream of the



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WWTP at BC1 typically measured slightly higher than immediately downstream at BC2. Figure

16 illustrates this trend.

TKN concentrations have been consistently reported at higher concentrations than the referenced

water quality standard of 0.58 mg/L, although these values show a decreasing trend overall since

monitoring began in 2011 (Environmental Department 2018). On average, TKN concentrations

upstream of the WWTP at BC1 typically measured slightly higher than immediately downstream

at BC2. These trends are illustrated in Figure 17.

Figure 15: TP concentration comparisons at BC1 and BC2

Figure 16: E. Coli concentration comparisons at BC1 and BC2

0

0.02

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Sampling Date

Buskirk Creek Stations BC1 & BC2: Total Phosphorus (TP)

BC1 BC2 Reference Water Quality Standard

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Figure 17: TKN concentration comparisons at BC1 and BC2

Two additional discharges enter Buskirk Creek along this stretch. An agricultural ditch about 200

m downstream of the WWTP discharge contributes wet-weather flows from the MBPI parcel

currently in row crop agriculture on the north side of Buskirk Creek. The other discharge flows

intermittently from the 2-acre detention pond capturing stormwater runoff from approximately

40-acres of the Casino property. This stormwater outfall is contributing to erosive conditions on

the south bank of Buskirk Creek. These conditions are detailed fully in the description of the

Casino Retention Pond 1.

The monitoring data for BC1 and BC2 suggest that significant pollutant contributions are

occurring in Buskirk Creek upstream of the Gun Lake Casino property. Continuing to assess

pollutant concentrations against in-stream flows, rainfall, and WWTP discharge data, if

available, may help to explain occasional spikes and differences between BC1 and BC2, and

long-term seasonal trends. The MBPI Environmental Department could consider adding

additional monitoring sites in Buskirk Creek. This could include a site downstream of the Casino

Detention Pond 1 outfall to further understand NPS pollutant contributions from the agricultural

ditch and stormwater pond outfall. It could also include an upstream monitoring site, for

example, at the 10th Street road-creek crossing, to help identify upstream pollutant sources.

Targeting sampling events to capture wet- and dry-weather conditions for flow and pollutant

loading comparisons could also provide important insights into pollutant source conditions.

Existing NPS pollution controls on the MBPI properties contributing to Buskirk Creek are the 2-

acre Casino Detention Pond 1 and the 1-acre Casino Retention Pond and Wetland area. These

wet ponds are designed to capture stormwater runoff and treat it through infiltration and nutrient

uptake by vegetation. They were integrated into soil erosion and stormwater control (SESC)

measures implemented during each phase of construction of the Gun Lake Casino and will

remain as permanent stormwater controls. There is currently no maintenance plan in place for

0

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Buskirk Creek Stations BC1 & BC2: Total Kjeldahl Nitrogen (TKN)




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these BMPs. Visual monitoring of the ponds and BMPs will be included in BMP management

plans as outlined in the Tribe’s NPS Management Program Plan.

NPS pollution contributions to Buskirk Creek exist in various forms from the Gun Lake Casino

property and the MBPI’s agricultural property, part of the Gun Lake Casino parcel 24-019-026-

30, to the immediate north. At the most-upstream side of the property, erosive conditions exist

around the railroad right of way causing bank scouring and sediment loading. The row-cropped

agricultural field immediately north of Buskirk Creek contributes sediments and nutrients from

edge of field runoff to the agricultural ditch which flows during wet weather.

The Casino Detention Pond 1 is contributing to erosive conditions and wet-weather flows at its

outfall. Runoff from the Casino property may contain littered trash, toxicants and heavy metals

from automobile traffic, as well as excess sediment and nutrients from earth-moving practices

during construction and thermal inputs from impervious surfaces. While these pollutants are

treated by infiltration and vegetative uptake in the detention pond, some level of pollution may

still be contributed through the pond’s outfall.

Downstream, toxicant and litter inputs exist from highway traffic while potentially erosive

conditions exist along the highway right of way where Buskirk Creek makes two 90-degree

bends. Further downstream, surface water runoff from agricultural row cropping contributes

sediments and nutrients at the edge of field and through tile drainage.

Future NPS pollutant controls and BMP implementation on the Gun Lake Casino property

should focus on addressing existing soil erosion areas and their causes. Increasing infiltration on

the Casino property by integrating low-impact development (LID) strategies such as vegetated

parking lot swales will help to slow and pre-filter stormwater before it enters the detention

ponds. MBPI Environmental Department staff expressed interest in helping the MBPI integrate

LID practices into the Casino property by offering them a simple suite of appropriate practices

such as those exemplified on the MBPI’s Government Campus. NPS pollutant controls and BMP

implementations on the MBPI’s agricultural field north of Buskirk Creek should focus on

conservation buffer strips and conversion of low-lying areas to fallow wetlands.

Casino Detention Pond 1 & Outfall to Buskirk Creek (Gun Lake Casino)

This permanent two-acre detention pond, herein called “Casino Detention Pond 1,” was created

in 2009 during Phase I construction of the Gun Lake Casino. It detains all stormwater runoff

contributed from approximately 40-acres of MBPI land consisting of casino buildings, driveways

and parking lots (JCJ 2018). An earthen berm separates the detention pond from Buskirk Creek,

which flows east to west, approximately 25 m north of the pond.

Casino Detention Pond 1 was created and has functioned as an integral component of the soil

erosion and sediment control (SESC) plans during each phase of casino construction and

expansion, ongoing since 2009. It is the main NPS pollutant control BMP for the contributing

area of the casino property. Prior to construction of the Gun Lake Casino, this area was a mostly

flat agricultural field in row crops where planting and harvesting occurred less than 10 m from

the banks of Buskirk Creek. An industrial complex and petting zoo existed where the

contributing Gun Lake Casino buildings and parking lots currently reside.



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Casino Detention Pond 1 captures stormwater from the casino property which infiltrates to

groundwater and is taken up by dense vegetation. Vegetation consists predominantly of the

aquatic invasive species narrow-leaf cattail (Typha angustifolia L.) and phragmites (Phragmites

australis). Surface water that is unable to infiltrate through the detention pond flows into Buskirk

Creek. The detention pond has an overflow spillway at its northwest corner and an outlet

discharge pipe approximately 20 m east of the spillway. This 12-inch discharge pipe carries

water approximately 25 m to an outfall on the south bank of Buskirk Creek. Visual monitoring of

the ponds and BMPs will be included in BMP management plans as outlined in the Tribe’s NPS

Management Program Plan.

The pond’s outfall to Buskirk Creek was constructed on a very steep grade where the

approximately 1.5 m bank was reinforced with erosion matting and large stone. During site visits

in June 2018, the MBPI Consultant field staff noted several areas of exposed erosion matting

where a few of the largest stones had become dislodged. One significant area of bank erosion is

now occurring on the western edge of this outfall. Erosive conditions contribute NPS pollution

through sedimentation and nutrient transport which will likely worsen if not addressed.

Modeled EMCs for the Gun Lake Casino property assume that all stormwater runoff from the

contributing area is captured and treated through Casino Detention Pond 1. Wet-weather

outflows, erosive outfall conditions and temperature inputs from parking lots and rooftops,

however, may warrant further investigation of NPS pollutant contributions from the detention

pond discharge. As previously noted, the MBPI Environmental Department should consider

adding a third monitoring site in Buskirk Creek, downstream of this outfall.

Casino Retention Pond & Seasonal Wetland (Gun Lake Casino)

There is a small retention pond and seasonal wetland area on the Gun Lake Casino property

immediately west of Casino Detention Pond 1 and within 12 m of Buskirk Creek’s south bank.

The 0.5-acre retention pond and the roughly 0.5-acre low-lying seasonal wetland area have

served to retain stormwater runoff from the contributing area since before construction of the

Gun Lake Casino. These NPS pollutant controls were integrated into the SESC blueprints during

each phase of construction and expansion on the Casino property (JCJ 2018). The majority of

stormwater runoff originating on the property, however, is currently directed to Casino Detention

Basins 1 & 2. No known surface water flows are contributed to Buskirk Creek from these

waterbodies.

Unnamed Stream (Gun Lake Casino)

A small, unnamed stream originates on the southwestern edge of the Gun Lake Casino property

and flows west-southwest crossing under US-131 into a channelized agricultural ditch. The

stream emerges briefly on the west side of US-131 before entering a culvert beneath 12th Street

and flowing along the northern border of the MBPI’s 1217 129th Ave parcel (10-024-002-00).

Approximately 205 m of this stream exists on MBPI property. Beyond MBPI land, this unnamed

stream makes several ninety-degree turns, flowing west-southwest through an agricultural ditch,

before meeting Pierce County Drain Extension just west of 13th Street. The Pierce County Drain

Extension discharges to Miller Creek, a tributary of the Rabbit River.



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Historical aerial photos suggest that this stream once originated in the wet woodlands where

parts of the Gun Lake Casino were constructed. This unnamed stream now originates from the

Casino Detention Pond 2. Prior to crossing under US-131, the stream receives additional wet-

weather flows from an approximately 320 m long ditch within the highway right-of-way which

parallels the US-131 entrance ramp. Between US-131 and 12th Street, the stream receives NPS

pollutants from stormwater runoff along steep roadside banks, where erosion is likely occurring.

Beyond 12th Street, the streambanks are steep and well vegetated along the MBPI’s 1217 129th

Ave parcel but poorly vegetated on the north bank, bordered by a large agricultural field used for

row cropping corn and soy.

The approximately 2.4-acre detention pond from which this unnamed stream originates receives

stormwater runoff from casino parking lots, driveways and rooftops. Runoff from the Casino

property may contain toxicants and heavy metals from automobile traffic as well as excess

sediment and nutrients from earth-moving practices during construction and thermal inputs from

impervious surfaces. NPS pollutants are captured and treated by the detention pond. These

conditions are detailed further in the description of the Casino Retention Pond 2. Downstream,

NPS pollutant impacts include sediment and nutrient transport through surface water and tile

drain runoff from non-MBPI agricultural fields and toxicants and litter from highway traffic.

Casino Detention Pond 2 & Outfall to Unnamed Stream

This approximately 2.4-acre permanent detention pond, herein called “Casino Detention Pond

2,” was created in 2014 during the second-phase of construction of the Gun Lake Casino and its

associated buildings and parking lots. Casino Detention Pond 2 was created and has functioned

as an integral component of the soil erosion and sediment control (SESC) plans since 2014. It

detains stormwater runoff contributed from 40-acres of the Casino property (JCJ 2018).

Modeled EMCs for the Gun Lake Casino property assume that all stormwater runoff from the

contributing area is captured and treated through Casino Detention Pond 2. The detention pond

captures stormwater from the casino property, which infiltrates to groundwater and is taken up

by dense vegetation. Vegetation consists predominantly of the aquatic invasive species narrow-

leaf cattail (Typha angustifolia L.). Surface water that is unable to infiltrate through the detention

pond feeds the unnamed stream through a large outfall. No erosive conditions were noted during

field visits at this site. NPS impacts to the detention pond include thermal inputs and toxicants

from automobile emissions in runoff flowing from impervious parking lots and rooftops.

Indian Lake (The Settlement)

Indian Lake is a secluded, approximately 10-acre, eutrophic lake with a maximum water depth of

5 m and a total of 1.1 km of shoreline (Progressive AE 2016). The lake is surrounded by wooded

wetlands and steep hillside with underlying limestone geology. The lake is not easily accessible

and has no public access. Indian Lake is currently the headwaters of the Fales Drain (Sager Lake

Drain), which flows north. The HAWQs watershed analysis suggests that the Fales Drain

subwatershed contributes sediment at 0.2 Mg/ac/yr and phosphorus at 0.2 kg/ac/yr, an average

contribution compared to the contributions of other watersheds in Table 9.



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Three MBPI properties account for approximately 445 m of the Indian Lake shoreline, with one

pedestrian access trail, boardwalk and dock. MBPI uses Indian Lake and its surrounding area for

fishing, birding, hiking, canoeing, kayaking, picnicking, hunting and other recreation. Indian

Lake also contains large stand of Mnomen (Wild Rice; Zizania palustris) that fluctuates

annually. Three neighboring MBPI parcels southeast of Indian Lake, totaling 45 acres, were

developed into a residential neighborhood for MBPI citizens, known as The Settlement, since

2011. A road and ditch system appears to carry stormwater runoff to a small dry detention pond

on the east side of The Settlement neighborhood. Several other MBPI parcels including a

cemetery exist in the uplands surrounding Indian Lake to the south.

The MBPI Environmental Department has monitored Indian Lake since 2007. Secchi depths

recorded between 2008 and 2018 show an average of 2.3 m, with a minimum of 0.75 m and

maximum of 4.0 m. Mid-summer surface total phosphorus (TP) concentrations recorded by the

Environmental Department between 2011 and 2018 show an average concentration of

0.031mg/L, very near the referenced water quality standard for TP. TP concentrations exceeded

the referenced WQS value of 0.03125 mg/L in October of 2016 and 2017.

Nitrate-nitrogen and total Kjeldahl nitrogen (TKN) concentrations in surface water samples

collected since 2011 regularly exceeded the reference WQS values of 0.31 mg/L and 0.58 mg/L,

respectively. Nitrate-N concentrations have averaged 1.05 mg/L since 2011, with a maximum

nitrate-N concentration of 1.98 mg/L recorded in July 2011. TKN concentrations have averaged

0.945 mg/L since 2011, with a maximum concentration of 3.1 mg/L recorded in July 2014.

Ammonia, Chloride, and E. coli concentrations have been consistently recorded well below the

referenced WQS’s.

This lake becomes partially-stratified through the summer months, but is too shallow to be

strongly stratified (Progressive AE 2016). Water quality profiles collected by the MBPI’s

Environmental Department from 2008-17 show that D.O. and temperature are adequate to

support a warmwater fishery. In July and August, though, D.O. regularly dropped below the

referenced value for supporting warmwater fisheries, 5 mg/L, in waters deeper than 3 m.

Temperatures throughout the water column ranged from 8.66°C to 26.3°C between May and

September, within the referenced value range for supporting warmwater fisheries. Turbidity

measurements have been consistently recorded below the referenced WQS of 14.5 NTU, with

the exception of measurements recorded at the lake bottom, likely a result of bottom sediments

being disturbed by the probe.

A significant concern for the MBPI has been the development of a county drain from Selkirk

Lake to Indian Lake. In 2011, residents of nearby Selkirk Lake petitioned for the creation of a

county drain to prevent flooding of riparian residences. Selkirk Lake, located approximately 800

m south of Indian Lake, is a 92-acre eutrophic, all-sports recreational lake which receives

drainage from Geneva Lake but has no natural outlet. The final permit request for the drain

construction was submitted to MDEQ in 2016. The drain project, currently under construction,

will construct an outlet to control lake levels in Selkirk Lake with an 18-in pipe designed to

dissipate a 10-yr, 24-hr rainfall event (Medamar and Eng Engineering 2016).

In September 2016, Progressive A&E was hired by Eng., Inc. to perform a final limnological

assessment of Indian Lake and Selkirk Lake as part of the MDEQ permit review process for



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drain construction. The study included volumetric mapping, water quality sampling and an

aquatic vegetation survey of both lakes. Water quality sampling at Indian Lake occurred at the

deepest point (5 m). The study, consistent with findings of the MBPI Environmental Department,

found high levels of total phosphorus and chlorophyll a, though E. coli bacteria levels were well

below MDEQ standards for total body contact. The study found abundant aquatic macrophyte

growth in Indian Lake but did not detect any submersed or floating-leaved invasive species

(Progressive AE 2016).

Significant objections were raised by the MBPI Tribal Council during the drain design and

permitting petition process regarding the pipe design being located on MBPI properties. Several

alternative designs were considered but ultimately MDEQ approval was granted to discharge the

drain into Indian Lake outside of MBPI properties. Construction began in late fall, 2017 (Drain

Presentation, Eng. 2016).

The MBPI Environmental Department has expressed additional concerns about the potential

negative effects on Indian Lake water quality including the spread of invasive species (Wieten

personal communication 2018). Past vegetation surveys performed by MDEQ and other

consultants have documented invasive Eurasian water milfoil (Myriophyllum spicatum), curly-

leaf pondweed (Potomogeton crispus), phragmites (Phragmites australis) and purple loosestrife

(Lythrum salicaria) in and around Selkirk Lake. Aquatic herbicide treatments in Selkirk Lake

have targeted Eurasian water milfoil and curly-leaf pondweed (Progressive AE 2016). Mnomen

has been found to be very susceptible to pesticide residue and should be monitored closely

within Indian Lake.

The MBPI Environmental Department should continue their water quality monitoring program

for Indian Lake following the EPA-approved QAPP to distinguish natural seasonal variations

and identify trend deviations. The department should continue conducting annual surveys of

aquatic vegetation as well. Continued monitoring will allow the MBPI to track change over time,

particularly regarding concerns about the Selkirk Lake county drain project.

Moore Lake

Moore Lake is a semi-secluded 6.4-acre lake with approximately with 600 m of shoreline and

dense emergent vegetation in the shallows, leaving approximately 5-acres of open water in the

summer months. Moore Lake has no surface water inlets nor outlets. The MBPI’s land, parcel

24-028-013-10, encompasses the entirety of Moore Lake and the surrounding woodlands

extending southwest to 127th Ave. A house and several outbuildings exist on this parcel. The lake

is not easily accessible, surrounded by steep wooded hills which drop approximately 15 m in

elevation from the surrounding area.

Low-density residential properties with mowed lawns surround the MBPI’s land to the

northwest, northeast and east, all within 90 m of Moore Lake. An agricultural field, row-cropped

for corn and soy, borders the MBPI’s land to the south within 40 m of Moore Lake’s southern

shore. Historical aerial imagery shows that two of the residences to the east of Moor Lake were

constructed recently, one in approximately 2003 and another in 2017. These properties were

formerly used for agricultural.



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The MBPI Environmental Department has not yet established a water quality monitoring

program for Moore Lake. Future monitoring should include the standard set of water quality

parameters conducted at regular intervals on the MBPI’s other lakes. Residential and agricultural

land uses, including recent and potential future land use changes to the riparian areas, are the

most significant NPS pollutant categories of concern for protecting water quality in Moore Lake.

Boot Lake (Luella Collins Community Center)

Boot Lake is an approximately 40-acre lake with approximately 1.7 km of shoreline. The lake

surrounded by woodlands to the west and north, residential and MBPI community developments

to the south and a large wetland complex to the east. Boot Lake receives drainage from Mill

Pond and from the wooded area to the west and southwest. The lake drains through the wetland

complex to the east before entering a channelized ditch flowing east-northeast which then enters

Gun Lake at its northwest corner. The Gun River, a tributary to the Kalamazoo River, flows from

Gun Lake.

The entirety of Boot Lake’s shoreline remains undeveloped with one small access point on the

MBPI lands and another on private lands to the west. MBPI owns approximately 80 acres

adjacent to Boot Lake housing the Luella Collins Community Center (LCCC). The LCCC,

named after respected former Tribal Councilwoman Luella Collins, was designed as a multi-use

community center to serve a wide range of needs for the MBPI community. These MBPI lands

cover approximately 314 m of the Boot Lake’s southern shoreline. MBPI uses Boot Lake and its

surrounding area for fishing, birding, hiking, canoeing, kayaking, picnicking, hunting and other

recreation. Additionally, MBPI is working to restore shorelines on Boot Lake with Mnomen.

Boot Lake and the surrounding wetlands contain communities which support plants and animals

of sacred value to the MBPI. These include sandhill cranes, herons, ducks, turtles and otters. The

MBPI’s Environmental Department has been involved in enhancing turtle habitat along the

shores of Boot Lake. Upland prairies have also been carefully managed to establish and enhance

native vegetation. The MBPI converted nearly 40 acres of these lands from agriculture to native

prairie. The MBPI Environmental Department has identified invasive phragmites (Phragmites

australis) on neighboring parcels and has treated a small stands of Phragmites and Japanese

Knotweed (Fallopia sp.) on MBPI property and noted this as an ongoing concern (Wieten

personal communication 2018).

The LCCC was constructed in 2006. As part of this project, a former residential lawn was

naturalized with native plants. Additionally, a picnic area, boardwalk and fishing pier were

constructed.

The MBPI Environmental Department has monitored Secchi disk depths in Boot Lake since

2007. Secchi depths ranged from 1.25 m (24 August 2011) to 3.25 m (28 September 2017),

averaging 2.07 m. Water quality parameters measured monthly since 2008 include D.O.,

temperature, conductivity, pH and turbidity profiles. Overall, D.O. and temperature profiles

show that Boot Lake meets referenced WQS’s for supporting warmwater fisheries throughout the

year. In depths greater than 4 m, D.O. typically drops below 2 mg/L during the summer months.



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Recorded measurements of pH, conductivity, and turbidity are well within the range of the

referenced WQS’s throughout the year.

Total nitrogen (TN) and TKN have been measured semi-annually since 2008. TN measures

ranged from 0.025 mg/L to 0.15 mg/L, averaging 0.071 mg/L, consistently below the referenced

water quality standard of 1.15 mg/L for TN. TKN measures ranged from 0.37 mg/L to 5.92

mg/L, averaging 2.4 mg/L. TKN concentrations have been consistently reported at higher

concentrations than the referenced water quality standard of 0.58 mg/L.

MBPI has also collected semi-annual measures of E. coli, TP, TSS and chloride since 2015. TP

concentrations since 2015 averaged 0.02 mg/L and have not exceeded the referenced water

quality standard of 0.03125 mg/L, with one exception, a measure of 0.04 mg/L recorded 31

October 2016. No exceedances of referenced WQS’s for E. coli and chloride have occurred

(MBPI WQ Monitoring Data, 2018). Continued monitoring of all regularly measured water

quality parameters is suggested to understand long-term trends in Boot Lake.

The LCCC was designed and built utilizing several NPS pollutant controls. These include two

stormwater retention areas and a vegetated parking lot swale. Proper maintenance of vegetation

in these NPS controls is the only notable concern in this regard.

Modeled EMCs for the LCCC properties predict approximately 70.3 Ml of runoff per year,

producing 2.5 Mg of sediment and 7.8 kg of TP loss per year. These modeled results do not

specifically reflect the positive impact of the BMPs in place at this setting. The results require

validation from on-site measurements in order to accurately understand phosphorus and sediment

transport and capture during wet-weather events. The actual phosphorus load from this parcel is

expected to be lower than the predicted load if the BMPs are performing well.

Selkirk Creek Extension (Reno Drive)

The Selkirk Creek Extension flows north to south for approximately 590 m, making three

distinct bends, through the MBPI’s Reno Drive parcels. Several small drains in this area make up

the northern-most branches of the Selkirk Creek Extension, which also receives waters from a

number of agricultural drains to the south. These various ditches form six distinct, mostly-

straightened ditches which confluence into Selkirk Creek on the west side of US-131 highway,

east of 13th Ave, and roughly parallel with 132nd Ave. From this point, Selkirk Creek flows west-

northwest through row-cropped agricultural lands before entering a wooded area and flowing

into the Rabbit River, east of 16th Street and north of 132nd Ave.

The branch of the Selkirk Creek Extension flowing through MBPI lands originates in the area to

the northeast and is piped underground before reemerging from beneath 133rd Ave on the

MBPI’s Reno Drive properties. The MBPI parcels are held in secondary succession and also

contain two detention ponds of 0.8 acres and 2 acres size, described in the next section. The

stretch of the creek which runs through MBPI lands is well buffered with no immediate

development in the riparian areas other than the detention ponds. The MBPI has not conducted

water quality monitoring in the Selkirk Creek Extension.



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The surrounding land uses include light industrial buildings to the east, developed since 2001,

and row-crop agriculture. Reno Drive was extended south of 133rd Street in 2005 to

accommodate the industrial development. The entirety of the industrial development was

constructed on former agricultural fields and several agricultural drains were modified to

accommodate the development. In 2015, the southern section of this industrial development was

constructed, including a large railroad spur and several wetpond areas interspersed throughout

the development. One surface water drain still flows west from this industrial area, between the

Reno Drive detention ponds and meets the Selkirk Creek Extension on MBPI lands. Allegan

County GIS maps show the lands north and east of the MBPI’s Reno Drive property, within

Wayland City, as zoned for planned industrial development. The maps show future land use

plans for lands to the immediate south, within Wayland Township, to be agricultural and

industrial (Allegan County GIS 2018).

Immediately south of the Reno Drive MBPI lands, the creek bends to the west and flows beneath

US-131, where it enters a poorly buffered stretch bordered by a large industrial parking lot to the

north and a large row-crop agricultural field to the south. The downstream stretches of the creek

are generally poorly buffered and likely highly impacted by nonpoint source pollutant inputs

from industrial and agricultural land uses. Future water quality monitoring and potential project

implementations by the MBPI could therefore focus on understanding the impacts of surrounding

land uses and opportunities to protect upstream water quality and improve downstream water

quality.

Reno Drive Detention Ponds

Two detention ponds exist at the Reno Drive MBPI properties, within Wayland City limits,

immediately south of 133rd Ave, east of US-131, and west of Reno Drive. The northernmost

pond spans roughly 0.8 acres with a perimeter of 240 m. The southernmost pond spans roughly 2

acres with a perimeter of 345 m. The ponds are immediately west of the Selkirk Creek

Extension, which flows north-south through the Reno Drive MBPI properties. The MBPI lands

are currently held in secondary succession. Historic aerial photos suggest that the Reno Drive

detention ponds were fully developed by 2011. It is not currently known whether surface water

overflows from these ponds occur. No erosive conditions were noticed during the 2018 survey

but future monitoring for erosion at the berm separating the ponds from the Selkirk Creek

Extension is suggested. No water quality monitoring has taken place or is planned to take place

at the Reno Drive ponds.



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Table 13: MBPI Nonpoint Source Assessment summary of NPS pollutants, sources and severity.

HUC-12 Watershed ID

Waterbody Name & Stream Length

Property Identifier

NPS Pollutant(s) Pollutant Source(s) Severity1

040500030805

Buskirk Creek-Rabbit River

Buskirk Creek ~ 756 m

Gun Lake Casino

1. Sediments & Nutrients 2. Pathogens 3. Trash 4. Thermal Stress 5. Toxicants

1. Hydromodification (detention pond outfall and erosive streambanks) 2. Wastewater discharge 3. Roadway littering 4. Parking lot runoff 5. Roadway and parking lot pollutants

1. Severe 2. Moderate 3. Slight 4. Slight 5. Slight

Casino Detention Pond 1 & Outfall to Buskirk Creek

Gun Lake Casino

1. Sediments & Nutrients 2. Trash 3. Thermal Stress 4. Toxicants

1. Parking lot and construction runoff and Hydromodification (erosion at outfall) 2. Parking lot litter 3. Parking lot runoff 4. Parking lot pollutants

1. Severe 2. Slight 3. Moderate 4. Slight

Casino Retention Pond Gun Lake Casino 1. Sediments & Nutrients 1. Construction runoff 1. Slight

Selkirk Creek Extension ~ 590 m

Reno Drive 1. Sediments & Nutrients 2. Toxicants

1. Agricultural and parking lot runoff 2. Roadway pollutants

1. Slight 2. Slight

Reno Drive Ponds Reno Drive 1. Sediments & Nutrients 2. Toxicants

1. Agricultural and parking lot runoff 2. Roadway pollutants

1. Slight 2. Slight

040500030804

Bear Creek

Ingerson Lake Camp Jijak 1. Sediments & Nutrients 2. Pathogens 3. Toxicants

1. Erosion at stormwater outfall 2. Excessive waterfowl 3. Pesticides & Herbicides

1. Severe 2. Slight 3. Slight

Herlan Lake Camp Jijak N/A N/A N/A

Unnamed Stream ~ 193 m

Camp Jijak 1. Trash 2. Sediments & Nutrients

1. Legacy trash midden 2. Roadway pollutants

1. Moderate 2. Slight

040500030803

Miller Creek

Pierce County Drain Extension ~ 1,609 m

Government Campus & Parcels to West

1. Sediments & Nutrients 2. Trash 3. Toxicants

1. Agricultural runoff, hydromodification (erosive streambanks) 2. Roadway littering 3. Roadway pollutants

1. Moderate 2. Slight 3. Slight



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040500030803

Miller Creek Unnamed Stream ~ 96 m

Gun Lake Casino


1. Hydromodification, roadway pollutants 2. Roadway littering 3. Parking lot runoff 4. Roadway and parking lot pollutants

1. Slight 2. Slight 3. Slight 4. Slight


Gun Lake Casino


1. Parking lot and construction runoff 2. Parking lot litter 3. Parking lot runoff 4. Parking lot pollutants

1. Severe 2. Slight 3. Moderate 4. Slight

040500030802

Fales Drain-Rabbit River

Indian Lake The Settlement N/A N/A N/A

Moore Lake Moore Lake N/A N/A N/A

040500030701

Gun Lake-Gun River

Boot Lake Luella Collins CC N/A N/A N/A

1Severity levels were determined as slight, moderate, or severe using a number of quantifiable and subjective indicators and are relative to the waterbodies assessed in this

report. Severity indicators included measurements and observations taken by K&A staff during the 6 June 2018 field surveys, data collected by the Gun Lake Tribe’s

Environmental Department, visual identification of contributing source areas through aerial photographs, the pollutant contribution results of the HAWQS and EMC analyses,

impaired or threatened designated and desired uses of the waterbody and identified potential future source threats.



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Table 14: MBPI Nonpoint Source Assessment summary of impaired and threatened designated and desired uses and threat sources

HUC-12 Watershed ID

Waterbody Name & Stream Length

Property Identifier

Relevant Use(s) Impaired Relevant Use(s) Threatened1 Potential Future Source

Threats2


Buskirk Creek ~ 756 m

Gun Lake Casino Partial body contact

recreation

Warmwater fishery Other indigenous aquatic life and

wildlife Aquatic and terrestrial habitat

Cultural and spiritual uses

Development (stormwater infrastructure)

Agricultural surface runoff Hydromodification (erosive

streambanks) Roadway pollutants

Casino Detention Pond 1 & Outfall to Buskirk Creek

Gun Lake Casino Aquatic and terrestrial

habitat Other indigenous aquatic life and

wildlife


Hydromodification (erosive streambanks)

Casino Retention Pond & Wetland



wildlife Development (stormwater

infrastructure)

Selkirk Creek Extension

Reno Drive Unknown Partial body contact recreation

Warmwater fishery Cultural and spiritual uses


Non-MBPI agricultural surface runoff (downstream) Roadway pollutants

Reno Drive Ponds Reno Drive Aquatic and terrestrial


wildlife Development (stormwater

infrastructure)

040500030804 Bear Creek

Ingerson Lake Camp Jijak None None Development (stormwater

infrastructure)

Herlan Lake Camp Jijak None None Non-MBPI riparian septic tanks


Camp Jijak None

Warmwater fishery Aquatic and terrestrial habitat Partial body contact recreation


Roadway pollutants Non-MBPI agricultural surface

runoff (downstream)


Pierce County Drain Extension ~ 1,609 m

Government Campus & Parcels to West

None Warmwater fishery

Aquatic and terrestrial habitat Partial body contact recreation

Agricultural surface runoff Hydromodification (erosive

streambanks)



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Roadway pollutants


Gun Lake Casino Unknown

Warmwater fishery Other indigenous aquatic life and

wildlife Aquatic and terrestrial habitat Partial body contact recreation



Non-MBPI agricultural surface runoff (downstream) Hydromodification Roadway pollutants




wildlife


Hydromodification (erosive streambanks)


Indian Lake The Settlement None Wild Rice Habitat Aquatic habitat degradation Development runoff (Selkirk

Lake)

Moore Lake Moore Lake Unknown Unknown Non-MBPI agricultural surface

runoff Non-MBPI riparian septic tanks

040500030701 Gun Lake-Gun River

Boot Lake Luella Collins CC None Wild Rice Habitat

Non-MBPI agricultural surface runoff (downstream)


1 MBPI-specific desired uses are in bold. 2 Includes potential NPS threats to MBPI waterbodies from non-MBPI contributing areas.



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Selection of Best Management Practices (BMPs)

This assessment of NPS causes and pollutants on the MBPI lands will ultimately guide the

selection of recommended BMPs to address observed conditions. Site conditions such as soils,

existing developments and property ownership, as well as treatment efficiencies and costs will all

eventually be considered. Potential BMP options are introduced here as a backdrop to those that

will ultimately be designed for and included in the MBPI Nonpoint Source Pollution

Management Plan. The Plan is a separate effort from this assessment report.

BMP implementation on MBPI lands will be achieved using a variety of existing NPS programs,

funding sources and education and outreach programs. MBPI may work with a number of

agencies and organizations to implement BMPS on MBPI lands. These may include but are not

limited to:

Bureau of Indian Affairs

US Environmental Protection Agency (EPA)

US Fish and Wildlife Service (FWS)

Indian Health Services

Natural Resource Conservation Service

Allegan County Conservation District

Barry County Conservation District

Kent County Conservation District

Ottawa County Conservation District

Michigan Department of Environmental Quality (MDEQ)

Michigan Department of Natural Resources (MDNR)

Kalamazoo River Watershed Council

Grand Valley State University

Michigan State University Extension

Pierce Cedar Creek Institute

West Michigan Cooperative Invasive Species Management Area (CISMA)

BCK CISMA

Outdoor Discovery Center

The MBPI Environmental Department will work closely with the MBPI Governmental bodies as

appropriate, to ensure BMPs are being effectively employed on MBPI lands to address current

NPS as well as those that could be potentially caused by any new development.

Summary of Water Quality Assessment

MBPI continues to develop its water program to monitor and protect its waters. The Tribe’s NPS

Management Program Plan and most recent propsed QAPP update address those areas currently

lacking sufficient monitoring data. These efforts will guide the MBPI in its development of

Water Quality Standards specific to the MBPI. The MBPI NPS Assessment Report will serve to

further help the MBPI develop these standards. The MBPI references Water Quality Standards



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from the MDEQ and EPA until Tribe-specific standards are in place. MDEQ Part 4 Water

Quality Standards for waters of the state are referenced as the values to identify impairments to

of MBPI waters until Tribe-specific Water Quality Standards are established. Draft Tribe-

specific Desired Uses also apply for these waters.

Navigable waters of the MBPI with sufficient data are currently meeting referenced Water

Quality Standards and Designated and Desired Uses. These high-quality waterbodies include

Ingerson Lake, Herlan Lake, Indian Lake and Boot Lake. Future sampling is needed to

characterize Moore Lake as no sampling has taken place. While NPS pollutant sources do occur

on MBPI lands bordering these waterbodies, relevant Designated and Desired Uses are not

impaired nor threatened. Potential future pollutant threats from MBPI lands are mainly untreated

stormwater discharges to upland and riparian areas. This is most relevant for Ingerson Lake at

the Jijak property. Potential future aquatic habitat degradation is the greatest threat to desired

uses for Indian Lake.

Creeks and streams bordering, crossing through or receiving waters from MBPI lands do not all

currently meet referenced standards. These non-navigable waters include Pierce County Drain

Extension, Buskirk Creek and two Unnamed Streams, one of which confluences with Pierce

County Drain Extension and the other with the Ingerson and Herlan Lakes outlet to Bear Creek.

Future sampling is needed to characterize Selkirk Creek as no sampling has taken place. NPS

threats to water quality in these creeks include pollutant contributions through stormwater inputs

from developed areas, surface water drainage from agricultural areas, hydromodification causing

erosive streambanks and roadway pollutants.

Water quality in Pierce County Drain Extension is currently meeting Water Quality Standards

and Designated and Desired Uses where it passes through the MBPI Government Campus.

Further downstream, agricultural NPS pollutant inputs from MBPI lands and non-MBPI lands

threaten water quality in Pierce County Drain Extension. The Unnamed Stream which originates

from the Casino Detention Pond 2 and flows into Pierce County Drain Extension also contributes

to threatened Designated and Desired Uses (Table 14). This includes fisheries, aquatic and

terrestrial habitat, partial body contact recreation and cultural and spiritual uses. Sufficient water

quality monitoring data does not currently exist to quantify deficiencies toward referenced Water

Quality Standards in these downstream sections of Pierce County Drain Extension and the

Unnamed Stream.

While sufficient water quality data also does not exist to quantify deficiencies toward referenced

Water Quality Standards in the Unnamed Stream originating on the Jijak property, identified

NPS pollutants suggest its Designated and Desired Uses are threatened(Table 14). These uses

include fisheries, aquatic and terrestrial habitat, partial body contact recreation and cultural and

spiritual uses. Nonpoint sources contributing pollutants to the Unnamed Stream include roadway

pollutants, a legacy trash midden in the headwaters area and downstream surface water runoff

from non-MBPI agricultural properties.

Water quality in Buskirk Creek is currently not meeting referenced Water Quality Standards for

TP, TKN and intermittently for E. coli, as demonstrated through monitoring data collected at



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BC1 and BC2. Because BC1 is at the most-upstream point of MBPI property on Buskirk Creek,

it is assumed that water quality is impaired in the upstream sections of Buskirk Creek as well.

Additional NPS pollutant inputs on MBPI property include moderate to severe streambank

erosion areas due to hydromodification and stormwater inputs, WWTP effluent discharge and

intermittent flows from the agricultural ditch to the north and the Casino Detention Pond 1.

Threatened uses include fisheries, aquatic and terrestrial habitat, other indigenous aquatic life

and wildlife, partial body contact recreation and cultural and spiritual uses.

Process for Selecting BMPs

Sources and type of NPSs will be considered in the selection of BMPs in the context of treatment

efficiencies, costs and inputs from identified stakeholders within the watershed. Existing NPS

programs in the Kalamazoo River watershed and commonly-accepted BMP practices will be

considered for selecting appropriate, site-specific management practices. Coordination with

property owners will take place prior to implementing BMPs. Prioritization will be given to

BMPS on/near MBPI Lands. Additional BMPs will be addressed on non-MBPI lands that impact

waters on MBPI Lands.

Existing Nonpoint Source Control Programs (BMPs)

The MBPI’s Environmental Department will oversee the implementation of new BMPs as well

as the maintenance of existing BMPs on MBPI lands. Continued collaboration with other

agencies/stakeholders particularly within the Kalamazoo River watershed, Rabbit River

subwatershed and Gun River subwatershed, will be encouraged throughout the process

specifically for BMPs not on MBPI Lands. The NPS Assessment Report and Management Plan

will be the basis for the selection and implementation of such BMPs.

Allegan Conservation District

The Allegan Conservation District (CD) located in Allegan, Michigan, is a local unit of State

government that uses state, federal and private sector resources to address conservation

problems. The CD administers the Gun River and Rabbit River Watershed Management Plans

(WMPs) as these watersheds are predominantly located in Allegan County. The Gun River WMP

identifies sediment and nutrients as the primary NPS pollutants. The Rabbit River WMP

identifies sediment originating from row crops and livestock as the primary NPS in the

watershed. BMPs will therefore focus on:

Agriculture

Road stream crossings

Rill/gully erosion

Streambank erosion

Livestock impacts

Tiling erosion

Construction impacts



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Filter and buffer strips have been the main focus of BMPs in the agricultural setting. The Allegan

CD provides technical assistance and administers grants for BMPs in the watershed.

Kalamazoo River Watershed Council

The Kalamazoo River Watershed Council (KRWC) in Kalamazoo, Michigan, is a public

nonprofit organization whose mission is to work collaboratively with the community,

government agencies, local officials and businesses to improve and protect the health of the

Kalamazoo River, its tributaries and its watershed (KRWC, 2018). The KRWC completed the

Kalamazoo River WMP in 2011 which identifies nutrients, sediment and pathogens as the

primary NPS pollutants. The KRWC provides some technical assistance and grant administration

for BMPs in the watershed.

Michigan Department of Environmental Quality Nonpoint Source Program

The MDEQ Nonpoint Source Program assists multiple entities to reduce nonpoint source

pollution statewide. The Nonpoint Source Program consists of five parts:

Technical assistance

Information and education

Grant funding for NPS controls

Compliance and Enforcement

Monitoring and field investigations

Annually, NPS grant proposals are competitively solicited by the state. Once the Tribe is eligible

for federal 319 funds, the state of Michigan will not fund the Tribe’s NPS implementation

projects but will be able to partner on local projects submitted for funding by others.

US Environmental Protection Agency

In 1987 Section 319(h) (§319), aimed at controlling NPS, was enacted under the Clean Water

Act. Through §319, the EPA provides states, territories and Tribes with guidance and grant

funding to implement their nonpoint source (NPS) programs (USEPA 2016). The “319” grant

funds are passed through to the state of Michigan with partial distribution for NPS control

projects noted above.

US Department of Agriculture Natural Resources Conservation Service

In 2012, the National Water Quality Initiative (NWQI) was enacted by the US Department of

Agriculture (USDA) Natural Resource Conservation Service (NRCS) to reduce NPS in high-

priority watersheds in each state. The NRCS has many programs outside of the NWQI, which

targets states, to target on-farm BMPs that will provide the greatest water quality benefits.

Funding assistance is available to farmers and landowners for implementation.

Nonpoint Source Control Core Participants

The NPS Assessment Report and forthcoming Management Plan will be reviewed by the MBPI

Environmental Department along with all applicable governing bodies within the MBPI,



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including the Environmental Committee and the Tribal Council, prior to submittal to the EPA.

The document review will also include inputs from the MBPI’s legal counsel.

The MBPI will continue to address NPS on its properties through collaboration with community

stakeholders and MBPI members, as appropriate.

Public Participation

Upon completion of the MBPI Nonpoint Source Assessment Report and forthcoming

Management Plan, a 30-day Public Notice will be issued to the community for review and

comments. Paper copies will be available upon request from the Environmental Department and

electronic copies will be available on the website (https://gunlaketribe-nsn.gov/). Further

information could be provided on the MBPI’s media outlets, including online outlets, as deemed

appropriate. A record of all public comments and responses will be maintained at the

Environmental Department office.

In addition to the Public Notice, stakeholder input will be sought during the review process.

Feedback from the stakeholders will be incorporated into the Nonpoint Source Assessment

Report and Management Plan. The Environmental Department will present the completed

documents upon completion in 2019.

Conclusions

Nonpoint source pollution can occur wherever anthropogenic developments occur. Overall, the

MBPI has developed their lands in ways which minimize impacts of NPS pollutants and protect

water quality. The largest development with the most potential for NPS pollutant impacts is the

Gun Lake Casino. The two detention ponds and one retention pond are considered suitable

controls to protect Buskirk Creek and the Unnamed Stream from NPS pollutants carried across

the property in stormwater runoff. Casino Detention Pond 1, however, is contributing to

sediment and nutrient NPS pollution through accelerated erosion along the banks of Buskirk

Creek near the pond outfall. Addressing erosive areas and implementing upland LID infiltration

practices across the large impervious areas of the gaming property are recommended strategies

for protecting the Casino Detention Ponds and their receiving waters.

Other recent developments such as the MBPI Government Campus and the Luella Collins

Community Center (LCCC) were constructed using some LID strategies. Vegetated parking lot

swales and vegetated stormwater retention basins capture and treat stormwater on both

properties. The effectiveness of these BMPs for capturing and treating NPS pollutants in

stormwater runoff on MBPI lands is currently unknown. Similarly, the pollutant reduction

effectiveness of the Reno Drive detention ponds and their contribution to the Selkirk Creek

Extension is currently unknown.

Adequate riparian buffers exist on most MBPI lands with some exceptions. The MBPI

Government Campus parcel, for example, provides significant riparian buffers with no-mow

zones dedicated to native plantings. Similarly, the undeveloped Former RTC parcels bordering

https://gunlaketribe-nsn.gov/



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US-131 provide excellent riparian habitat to protect the creek from NPS pollutants on MBPI

land. The Zanbergen and Nowak MBPI parcels, however, between and downstream of the

aforementioned parcels, respectively, lack adequate riparian buffers to protect the Pierce County

Drain Extension from NPS pollutants carried through agricultural surface runoff. All MBPI lake

shorelines are also adequately vegetated to protect the riparian areas of MBPI lakes. One

exception is the small beach area at Jijak camp where abundant waterfowl contribute nutrient and

bacteria through droppings. Nonetheless, the MBPI has made efforts to reduce the presence of

this waterfowl population using flagging and “scarecrow” tactics on the beach. Vegetated

riparian buffers are also suitable deterrents where these do not impede recreational access.

The MBPI Environmental Department has identified waterbodies on MBPI lands and

implemented a water quality monitoring program suited for understanding NPS impacts on those

waters. Because of the large amounts of new land managed by MBPI, continued and expanded

monitoring following the MBPI’s monitoring plan will be necessary to demonstrate any trends or

significant changes to water quality in MBPI waters. Nonetheless, historic data collected prior to

the EPA-approved QAPP provides a helpful reference for these long-term tracking needs.

Future water quality monitoring could improve MBPI’s understanding of NPS impacts from

MBPI lands by including an additional monitoring site downstream of existing monitoring sites

in Buskirk Creek and the Pierce County Drain Extension. Adding monitoring sites with standard

parameters on the Selkirk Creek Extension, Reno Drive ponds, and Moore Lake is also

recommended. Additionally, monitoring water quality entering and exiting existing and potential

future stormwater control structures would provide MBPI with a clearer understanding of

stormwater BMP efficiencies. This could provide unique insights and comparisons to existing

knowledge in order to guide the future implementation of BMPs on MBPI lands.

Continuing regular surveys of aquatic vegetation in MBPI Lakes is highly recommended,

particularly in Indian Lake to assess impacts of recreational boating and drainage connections on

aquatic habitats. Invasive species management should continue to be a top priority to protect the

unique ecologies of MBPI lands and waters. Conducting macroinvertebrate studies, per the

MBPI Environmental Department’s monitoring plan, may also provide key insights into NPS

pollutant inputs and long-term changes to aquatic systems.

The NPS Assessment Report will serve as the foundation for the development of a Nonpoint

Source Management Program Plan to address long-term needs for MBPI and its waters. Listed

below are some of the available resources for selecting/designing best management practices for

NPS prevention and remediation. While this list is not all-inclusive, it provides representation

from a number of key federal and state programs.

1. “Controlling Nonpoint Source Runoff Pollution from Roads, Highways, and Bridges.” EPA-

841-F-95-008a

2. “EPA Tribal Green Building Toolkit.” EPA-909-R-15-003

3. “Managing Nonpoint Source Pollution from Agriculture.” EPA-841-F-96-004F

4. “Managing Nonpoint Source Pollution from Forestry.” EPA-841-F-96-004H

5. “Management Measure for Physical and Chemical Characteristics of Surface Waters – II.

Channelization and Channel Modification Management Measures.” EPA



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6. “Forest Management Plans, and technical service providers.” NRCS CAP 106

7. “NRCS Conservation Practice Standard Codes.”

8. “Protecting Water Quality from Urban Runoff.” EPA-841-F-03-003

9. “Protecting Natural Wetlands.” EPA-843-B-96-001

10. “National Water Quality Initiative.” USDA NRCS National Water Quality Initiative (NWQI)

11. “Streambank and Shoreline Protection Management for Hydromodification.” EPA 840-B-92-

002

12. “Temporary Stream and Wetland Crossing Options for Forest Management.” USDA Forest

Service General Technical Report NC-202 1998

13. “Michigan Nonpoint Source Best Management Practices Manual.” Michigan DEQ

14. “Stormwater Management Guidebook.” Michigan DEQ, available online at:

https://www.michigan.gov/documents/deq/wrd-stormwater-guidebook_560012_7.pdf

15. “Michigan Forestry Best Management Practices for Soil and Water Quality.” Michigan

DNR, available online at:

https://www.michigan.gov/documents/dnr/IC4011_SustainableSoilAndWaterQualityPracticesOn

ForestLand_268417_7.pdf

16. “Pollutants Controlled Calculation and Documentation for Section 319 Watersheds Training

Manual.” Michigan DEQ, available online at:

https://www.michigan.gov/documents/deq/wrd-nps-pollutants-controlled_575549_7.pdf

17. “Low Impact Development Manual for Michigan.” SEMCOG, Michigan DEQ, available

online at: https://semcog.org/Reports/LID/files/assets/basic-html/page-3.html

http://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/programs/financial/eqip/?cid=stelprdb1047761

https://www.michigan.gov/documents/deq/wrd-stormwater-guidebook_560012_7.pdf

https://www.michigan.gov/documents/dnr/IC4011_SustainableSoilAndWaterQualityPracticesOnForestLand_268417_7.pdf

https://www.michigan.gov/documents/dnr/IC4011_SustainableSoilAndWaterQualityPracticesOnForestLand_268417_7.pdf

https://www.michigan.gov/documents/deq/wrd-nps-pollutants-controlled_575549_7.pdf

https://semcog.org/Reports/LID/files/assets/basic-html/page-3.html



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References

Abt Associates/Stratus Consulting Inc. 2016. Final restoration plan and programmatic

environmental impact statement for restoration resulting from the Kalamazoo River natural

resource damage assessment. Prepared for MI DNR, MI DEQ, Michigan Attorney General,

USFWS and NOAA. Available online at:

https://www.fws.gov/midwest/es/ec/nrda/KalamazooRiver/pdf/RestorationPlanPEISKalRiverAu

gust2016Final.pdf

Allegan County GIS Services. 2018. Allegan County GIS portal. Accessed 30 April 2018 at:

https://gis.allegancounty.org/portal_webadaptor/home/index.html

Apple, B.A., and H.W. Reeves. 2007. Summary of hydrogeologic conditions by county for the

state of Michigan (Open-File Report 2007-1236). Reston, VA: United States Geological Survey.

https://pubs.usgs.gov/of/2007/1236/pdf/OFR2007-1236.pdf

Fishbeck, Thompson, Carr, and Huber, Inc. (FTCH). 2004. Gun River watershed management

plan. MDEQ Nonpoint Source Program.

Fishbeck, Thompson, Carr, and Huber, Inc. (FTCH). 2009. Rabbit River Watershed Management

Plan. MDEQ Nonpoint Source Program.

Groundwater Statistics. 2018. DEQ Fact Sheet. Available online at:

https://www.michigan.gov/documents/deq/deq-wd-gws-wcu-

groundwaterstatistics_270606_7.pdf

Gun Lake Tribe. Committees. 2017. Accessed September 16, 2018. https://gunlaketribe-

nsn.gov/about/committees/

Gun Lake Tribe. Environmental. 2017. Accessed September 17, 2018. https://gunlaketribe-

nsn.gov/departments/administration/environmental/

Gun Lake Tribe. Our Heritage. 2017. Accessed September 16, 2018. https://gunlaketribe-

nsn.gov/about/our-heritage/

Gun Lake Tribe. Environmental Projects. 2017. Accessed September 16, 2018.

https://gunlaketribe-nsn.gov/departments/administration/environmental/environmental-projects/

Gun Lake Tribe. Language & Culture. 2017. Accessed September 16, 2018. https://gunlaketribe-

nsn.gov/departments/administration/language-culture/

Gun Lake Tribe Environmental Department (Environmental Department). 2018. Draft Water

Quality Data: All Sites and Draft Secchi Disk Data: All Sites. Unpublished.

Homer, C.G., Dewitz, J.A., Yang, L., Jin, S., Danielson, P., Xian, G., Coulston, J., Herold, N.D.,

Wickham, J.D., and Megown, K. 2015.Completion of the 2011 National Land Cover Database

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Documents

[Document title] - Gun Lake Tribe · Kalamazoo River at New Richmond, which in turn flows to Lake Michigan (FTCH 2009). The Gun River watershed encompasses 73,272 acres in Allegan