The Cuyahoga River AOC Remedial Action Plan

The Cuyahoga River Area of Concern restoration plan and actions are geared toward removal or remediation of Beneficial Use Impairments (BUIs) that either restrict uses of the waterways and Lake Erie (like not being able to swim at beaches) or present obstacles to healthy fish populations (like dams or lack of habitat) or degrade water quality.

In concert with Ohio EPA, the AOC (formerly the RAP – Remedial Action Plan), has developed strategies to address each of the impairments, and is continually updating the list of projects and actions needed to implement these strategies.

In some cases, this involves large-scale actions such as diverting or removing dams, or reducing Combined Sewer Overflows (CSOs) with deep tunnel construction and stormwater green infrastructure. In others, strategically-located smaller-scale projects such as stream restorations, riparian buffers, or sediment capture and reuse can get us closer to our goals. In still other cases, public education and outreach may be the key to instigating the necessary broad-based actions that are needed, such as those to reduce nutrient runoff from fertilized soils.

The table below shows the impairments, the strategies and actions underway, and the status of restoration efforts. For more information on the progress toward addressing specific impairments, click on the impairment.

For more information on the Ohio AOC program and specific metrics for each BUI,
Click here to download the complete updated AOC Delisting Guidance document.

Steps to Delisting =

a. removing a single beneficial use impairment from the list of BUIs when the target for that BUI is reached in all subwatersheds throughout the entire AOC, or
b. removing a subwatershed from the Area of Concern when all targets for all BUIs are met within that subwatershed

Complete Delisting =

Removing the AOC from the list of Areas of Concern when ALL BUI targets are met in ALL subwatersheds throughout the entire AOC.

Support for the Development of Management Actions in the Cuyahoga Area of Concern - This report presents the prioritized list of recommended projects and actions focusing on the aquatic life BUIs.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: Reduce contaminant levels in fish tissue to meet state or Lake Erie consumption advisory levels by removing sources of contamination.

Strategy/Action: Compare contamination to applicable species advisories, where such exist.

REMOVED. This impairment was removed in December, 2018, US EPA having determined that advisories for consuming fish caught in the AOC need be no more stringent than Ohio consumption advisories for fish caught in Lake Erie.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: Raise average scores of fish community surveys – Index of Biotic Integrity (IBI) and Modified Index of Well Being (MIwb) – to state biological criteria targets.

Strategy/Action: Remove barriers to fish passage (dams); improve fish habitat and benthos in ship channel and tributaries.

Habitat projects are underway. Passage – Four dams have been removed on the mainstem upriver of the Area of Concern (Kent, Munroe Falls, and two in Cuyahoga Falls) as well as one in Euclid Creek.

Ohio EPA and partners are working on the removal of the Gorge Dam, and funding is being sought for planning and removal or bypassing of obstructions in tributary watersheds.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: Meet regional or Lake Erie incident rates of Deformities, Eroded Fins, Lesions and Tumors (DELTs)

Strategy/Action: Remediate Old River Channel sediment; Continue monitoring and assessment in ship channel.

*REMOVED*

Some fish with DELTs have been found in the most recent limited sampling. Further sampling will be carried out to determine if instances exceed allowable levels.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: Average scores of Invertebrate Community Index (ICI) are within state biological criteria guidelines.

Strategy/Action: Remove or modify dams; restore habitat in ship channel and tributaries; reduce sediment from tributaries.

Habitat projects and stream restorations are underway.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: To have no restrictions on navigational dredging or disposal activities due to contaminants in sediment, such that sediments are suitable for upland reuse/disposal, OR sediments meet Ohio EPA guidelines for open water disposal.

Strategy/Action: Identify sources of contamination of existing sediment, or of new sediment being carried into channel, to reduce amount of sediment requiring special disposal.

Most of the sediment in the ship channel is suitable for various upland reuse locations, making it likely that this BUI could be delisted soon. The State of Ohio has recently prohibited open lake disposal, and efforts are underway to develop alternative uses for the sediment. The Port is supporting projects that are capturing sediment before it reaches the channel.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: For Riverine waters (upstream of lacustuary,) when conditions are not impaired as a result of excessive algal growth due to sources of nutrients, or no persistent nuisance growth of algae or blooms of blue-green algae have been observed within the last three years due to sources of nutrients from within the AOC.

For Lake affected waters (lacustuary,) when waters meet the minimum and the average dissolved oxygen criteria listed in Ohio Water Quality Standards (WQS) and no persistent nuisance growth of algae or blooms of blue-green algae have been observed within the last three years due to sources of nutrients from within the AOC.

Strategy/Action: Implementation/Completion of Northeast Ohio Regional Sewer District (NEORSD) and City of Akron Long Term Control Plans for Combined Sewer Overflow reduction; Green Infrastructure Best Management Practices to reduce surface runoff into storm sewers; Nutrient reduction from non-point sources through education, outreach, and municipal code enhancements; Vegetated riparian buffer restoration to interrupt/absorb nutrients in surface runoff.

*REMOVED*

NEORSD’s Long Term Control Plan has been approved, measures are underway; Akron is implementing CSO reduction work; This BUI has met all necessary criteria to be removed from the AOC.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: For public bathing beaches (applies to Edgewater, Villa Angela, Euclid Beach, and Shoreby Club,) posted advisory days due to E. coli contamination do not exceed 10% or 19 days of the recreation season, and posted advisory days due to algal toxins do not exceed that same portion of the season; or when bacterial impacts from CSOs are being addressed under an approved long term control plan or other legal agreement. For Cuyahoga River from SR 87 to Lake Erie, segment is not on Ohio’s list of impaired waters due to bacteria, or impacts from CSOs are being addressed under a long term control plan or legal agreement and a TMDL is approved and the State and RAP can document that the level of bacterial contamination is not worse than similar watersheds.

Strategy/Action: Implementation/Completion of Northeast Ohio Regional Sewer District (NEORSD) and City of Akron Long Term Control Plans for Combined Sewer Overflow reduction; Green Infrastructure Best Management Practices and vegetated buffer enhancements to reduce surface runoff of pet and animal waste into storm sewers and streams.

NEORSD Long Term Control Plan has been approved, large tunnel construction and green infrastructure retention measures are underway; Akron is implementing CSO reduction work; Ohio EPA is enabling and funding green infrastructure projects; AOC partners are doing riparian buffer restoration to reduce runoff, impervious surface removal and revegetation projects, and public education on nutrient reduction.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: Access to ship channel and mainstem for recreation and fishing is not impaired. (Note: This BUI is a locally-added impairment.)

Strategy/Action: Increase public park space and greenways in ship channel through completion of Towpath Trail and other sites, and increase fishing access sites in this and other areas.

REMOVED. Having met local goals noting adequate public access improvements, this impairment has been REMOVED from the list of impairments.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: No observed ongoing occurrences of sludge, oil, scum or other objectionable materials that produce color, odor or other nuisances or, if cause is CSO or regulated MS4 discharges, when long term control plan or other legal document is in force. Woody debris, or excessive turbidity after storm events or due to agricultural activity, is not considered an impairment.

Strategy/Action: Identify and remediate sources of materials other than woody debris.

REMOVED. Having confirmed no recent or current instances of aesthetic impairment, the request for removal of this impairment has been APPROVED by U.S. EPA.

Beneficial Use Impairment
Objectives / Strategies / Actions
Progress

Objective: In riverine areas upstream from the lake affected waters (lacustuary), the average Qualitative Habitat Evaluation Index (QHEI) value within an assessment unit does not diverge from state biological guidelines, or in lake affected waters (lacustuary) the average Lake Qualitative Habitat Evaluation Index (L-QHEI) value does not diverge from state biological guidelines. The ship channel has a designation of Limited Resource Waters, for which targets are lnot applicable. However, it is considered necessary to provide habitat where possible to support migrating fish.

Strategy/Action: Dam removals; ship channel and tributary habitat restoration projects including future habitat as part of Franklin Hill (aka Irishtown Bend) stabilization project; ODNR fish habitat monitoring; green infrastructure along ship channel.

Habitat projects are underway. In the ship channel, Scranton Flats provides significant new habitat, while Cuyahoga County Planning and Cuyahoga River Restoration have installed hundreds of habitat structures on the bulkheads that are accumulating organic material. Efforts to create more behind-the-bulkhead habitat areas such as those created by Ohio DOT beneath I-90 and in sections of Scranton Flats, are moving forward, as are strategies for integrating habitat in the design of the Irishtown Bend park project.

Projects in the tributaries are improving habitat. A habitat plan has been developed including projects identified as high priorities in key subwatersheds.

Preliminary plans for the removal of the Gorge Dam are moving ahead.

The Management Actions plan focusing on fish habitat, benthos, and fish passage has identified priority projects for funding.