The objectives of the 1992 Great Lakes 5 Year
Strategy are unlikely to be met in the Black River Area of Concern (AOC) unless there is a
thorough evaluation of what role contaminated sediments are having on the system. The
Black River Remedial Action Plan (RAP) Strategy Plan (1997 - 2001) and 1997 Draft Annual
Plan state that contaminated sediments and related toxicity are a significant issue in the
system, yet no studies have been developed for assessing sediment toxicity. The
Black Rivers infamous history of severe sediment contamination from polycyclic
aromatic hydrocarbon (PAH) below USS/Kobe Steel and associated impacts on the fish
community, the land use and hydrologic characteristics which result in extensive sediment
loading and deposition, and past and present pollution sources clearly suggest sediments
may, in fact, be the dominant stressor in the system. Controls are being
implemented (through the RAP process) to reduce sediment and contaminant loading. However,
the effectiveness of any controls or past dredging, the contribution of existing sediment
contamination to use impairment, or documentation for use impairment delisiting, cannot be
accurately assessed without a comprehensive assessment of sediment toxicity.