United States Department of Agriculture
Forest Service
Chequamegon-Nicolet National Forest Supervisor's Office
500 Hanson Lake Road
Rhinelander, WI 54501

Date: September 17, 2018
Trish Bantle President, Pigeon Lake Association
Dear Ms. Bantle:
I want to follow up on the telephone conversation on Friday, August 24, regarding the ongoing issues for home and cabin owners on Pigeon Lake resulting from the 2018 Father’s Day rain event and subsequent precipitation over the summer. While there are no formal monitoring stations established by the federal government or state government, there is no doubt that Pigeon Lake has reached levels not seen in many years. The effects on private landowners and their buildings and other improvements (septic systems, wells, driveways, trees, etc.) is regrettable.
While the USDA Forest Service (USFS) owns riparian land and some improvements (boat launch site) around the lake, the high water levels are not affecting these resources similarly to what is occurring on private lands. The USFS owns land around many natural lakes within the boundaries of the Chequamegon-Nicolet National Forest and accepts the natural fluctuations and their consequences to adjacent forests. The one USFS improvement associated with Pigeon Lake that is affected by the high water levels and which has caused us concern is the road known as West Pigeon Lake Road or FR 394. This road, like many on the National Forest, is cooperatively managed by the USFS and the town in which they are located, in this case the Town of Drummond.
Immediately following the June rain event, FR394 was overtopped by rising water and the two low areas on the north side of the road (see enclosed map) were inundated and rose to essentially the same level as the lake. Soon afterwards, The Town and the USFS worked together to raise the road bed to allow commercial trucks to haul stone from the Eureka gravel pit on the north side of Pigeon Lake to fix road issues from the flood elsewhere in the Delta/Drummond area. The construction materials used rock versus gravel base to lift the road so that water could flow more easily through it if the lake levels remained high. This is occurring as seepage through the road and two low lying areas to the north on the National Forest are receiving this water. The water levels on the north side of the road have recently dropped to a foot or so lower than the levels on the lake and the seepage continues.
We have considered the idea introduced on the August 24 call to consider hastening the flow of water from the lake to those lower lying areas. My engineering supervisor has worked with the Town of Drummond and has spoken with Mr. Lance Ritchie from your Association regarding drainage across FR394. We have discovered a crushed culvert just east of the gravel pit and will be replacing it with our Heavy Equipment Operator crew later this month. I am also willing to invest additional USFS resources to install a culvert further west of the gravel pit on FR394 which would further inundate National Forest lands in the associated low area. Because the “overflow areas” on the north side of the road are not large (approximately 8 and 14 acres), already hold water, and like
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the lake are subject to groundwater movement, we do not expect a significant drop in water levels on the lake from the installation of the culverts. That said, they should help a little.
Our professional hydrologists and soil scientists have also used high resolution imagery, information we already had access to regarding groundwater movement, and their professional judgement to evaluate the situation you are encountering. In summary, Pigeon Lake is a “seepage lake” with no inlets or outlets. Water comes into the lake from precipitation and groundwater movement. The roughly 250 acre lake gets groundwater input from an approximately 5,000 acre area and the lake essentially reflects the water table in this 5,000 acre area. The lake itself sits at one of the lowest elevations within this area (see accompanying high resolution map images) further exacerbating the effects of any increases in water in the overall system. At very high lake levels, a few areas on the west end of the lake also take on water from both lake overflow and groundwater movement (the two areas I referenced above). However, the lay of the land around most of the lake limits where water can go when lake levels are high. I am providing you with several images produced from LIDAR (a surveying technology that measures distance by illuminating a target with a laser light from a low flying aircraft) data which has been collected by Bayfield County over the past decade. My staff have further interpreted and displayed the data to highlight the fine scale topographical situation for Pigeon Lake and the immediate surrounding area.
Based in part on discussions which occurred at the July 31 meeting your Lake Association organized and at which some of my staff were present, as well as discussions at other times, my understanding is that the Association wants to lower the lake level as soon as possible to reduce the effects on the private lands and their improvements. Several proposals along this line were discussed on the August 24 telephone call which included Lake Association members, me and some of my staff, and staff from the Wisconsin Department of Natural Resources (WDNR). On that call, we and the WDNR provided you preliminary feedback to your ideas based on our mutual discussion of them.
The USFS and WDNR are in agreement that to lower the lake level sufficiently to reduce effects on private lands, there would have to be removal of large amounts of water not just from the lake, but from the groundwater area as well, because water removed from the lake would be replaced at least in part by groundwater moving laterally from adjacent lands. To effect a lake level change, removed water would have to be transported outside the 5000 acre area because water deposited in the same area would eventually move back toward the lake. It is important to note here that we do not have a complete understanding of how groundwater moves in this system. We have the benefit of some reasonably recent groundwater studies in the area which inform our professionals, but any conclusions are based on professional judgment given best available information.
As the USFS and WDNR explained on the August 24 call, your proposal to move water out of the lake and deposit it into a stream and wetland area within the National Forest south of Pigeon Lake has numerous logistical, financial, regulatory, and timing complications. The USFS is not a regulatory agency regarding water, but would have to determine if a required Special Use Permit to allow for such an action would be issued for the Lake Association to use National Forest lands by having pipes and associated equipment (pumps, etc.) to transport water. Additionally, if National Forest lands were to be affected by the deposition of removed water, there would have to be analysis and public involvement as required under the National Environmental Policy Act (NEPA). This process would take considerable time (months). Cost Recovery regulations associated with the analysis and the permitting, if we decided to proceed, would also apply. As I stated on the August
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24 call, solutions not involving National Forest lands would be less complicated. Additionally, I would not begin evaluation of a permit proposal or required environmental analysis unless a proposal had a high probability of success, could be financed, and had specifics about timing and duration. I cannot speak on behalf of the WDNR, but they explained other complications from a regulatory standpoint based on state statutes and their legal authority over state waters.
On the August 24 call, I said I would make contact with other entities who have far more expertise and their own network of contacts regarding situations like this. James Yach from the WDNR and I spoke with Mr. Pat Goggin from the University of Wisconsin – Extension who works with lake associations as part of the Wisconsin Lake Partnership. I believe he has been in touch with you and hopefully has information and further contacts who might be able to assist your Association in options you have.
My engineering, hydrology, and soils staff have spent considerable time in the last few months assessing this situation including a number of field visits. At this point in time, the USFS does not intend to take additional actions at Pigeon Lake other than completing culvert work on FR394.
If and when there is a feasible and fundable proposal by the Lake Association to pump groundwater and/or lake water and National Forest lands are part of such proposal, we will give it due consideration quickly, and will also inform the Lake Association about reasonable time lines, costs, etc. associated with required permitting, environmental analysis, etc. As a reminder, there is a plant - Fassett’s Locoweed - found at Pigeon Lake which is on the federal endangered species list with a status of “threatened.” Any action associated with human caused water fluctuation and involving the USFS would require formal consultation with the U.S. Fish and Wildlife Service. Depending on the nature of a proposal, other state, federal, or local government agencies may have authorities which would need their involvement as well. The Wisconsin Lake Partnership would be a good source of this kind of information.
Again, I am empathetic to the situation you and other property owners on the lake are enduring with the excessively high water. I hope the work of my staff to interpret information about the hydrology and topography of the area is useful and that culvert replacement and new installation on FR394 to allow some water to flow more quickly to natural overflow basins is helpful.
If you have any questions, please contact me at 715-362-1323 or by email at pstrong@fs.fed.us.
Sincerely,
/s/Paul I. V. Strong PAUL I. V. STRONG Forest Supervisor
Enclosures (3)
cc: Jamie Davidson, Brad Turberville