Cost/Benefit Analysis

An analysis of the costs versus the benefits of the Cullen Bay and Grassy Island wetlands shows that the costs, tangible and intangible, far outweigh the benefits.


The wetland costs consist of both the tangible expenses and intangible costs.



In 2019, ODNR granted $4.8 million of its H2Ohio funding to the Toledo Lucas County Port Authority to fully implement the design, engineering, and construction of the Cullen Park wetland and another $700,000 for the study and design of the Grassy Island wetland. Combined, this was approximately 10% of ODNR’s 2020 H2Ohio allocation.


These wetlands will be constructed and contained within a dike built in the Maumee Bay. All vegetation will be selected based on certain criteria and manually planted. Essentially, the wetlands will be gardens of perennial aquatic plants. To remain healthy and functioning properly, the wetlands will need to be maintained just like any other garden. This maintenance includes:

  • maintaining the vegetation
  • controlling Phragmites and American Lotus (which, to date, has proven to be an impossible feat)
  • removing the biomass to prevent noxious odors
  • removing litter from within the wetland
  • removing the tree trunks and other debris that will wash up on the dike
  • monitoring and controlling the mosquito population to avoid health risks to the residents in the area. 

Currently we don’t have an estimate of how much this will cost on an annual or long term basis.  Once we receive it, we will post it.

For more information about the maintenance the wetlands will require on a regular basis click Here


The Cullen Park and Grassy Island wetlands are being engineered and designed to function at certain water levels. As the lake level goes through its high/low cycles, the wetlands will need to be recontoured. In other words, the different levels within the wetlands will need to have soils added or removed and reshaped to raise or lower the elevations of different zones to adjust then to the new lake levels.

The sediments in a wetland have limited phosphorous storage capacities.  Once this limit is reached, the sediments must dredged out to create new capacity for phosphorous retention. This is an expensive undertaking that must be done on a periodic basis for as long as the wetlands exist.

The wetlands are being designed to the current atypically high water level. Due to this, extensive recontouring will likely be necessary within the first 5 years to adjust the sediment levels and lower them to below the water line so that they may function. For more information of the periodic capital improvement expenses and why the current designs will likely necessitate costly capital improvements sooner rather than later click Here


In addition to the tangible financial cost, the Cullen Park and Grassy Island wetlands come with intangible costs with respect to their impact on the health and safety of the community and other societal and environmental impacts.


Currently, harmful algal blooms (HABs) blow into the western end of the Maumee Bay and Cullen Park from Lake Erie. The Cullen Park and Grassy Island wetlands have the potential to concentrate these HABs, making them more toxic in the local  area.  They also have the potential to create localized HABs even after the HAB problem in Lake Erie has been resolved.  For more information on these risks and the authorities to support them, click Here 

The Grassy Island wetland will also create health and safety risks to boaters For more information on these conditions click Here.


The primary use of the western end of the Maumee Bay is aquatic activity with body contact. For safety reasons, when HABs occur Cullen Park and the western end of the Maumee Bay are closed to aquatic activities and the public is no long able to enjoy them.  When an HAB dies off, it emits an odor so foul that nearby residents avoid outdoor activities.

The Grassy Island wetland will fill in a large part of the main portion of the western end of the Maumee Bay, which is the home ice of the Toledo Ice Yacht  Club.  Many members of TIYC compete in North American, European, and World Championships.  TIYC members have won all three championships and the Maumee Bay is where they train, practice, and teach those new to the sport how to sail.  It is also the meeting place for those who sail simply for the fun of it and those who don’t sail at all.   If the Grassy Island wetland is constructed, there will no longer be enough area to set a regulation race course.

These are TIYC members who regularly using the Maumee Bay during the winter.

The Cullen Park causeway is a popular hiking destination.  The current high water has made some of it impassable, but when water levels return to normal the causeway trail will be passable again.  Hikers who make it to the end are rewarded with a sandy beach and fantastic view.

Boating will also be detrimentally affected by the wetlands. You can find a comprehensive explanation of boating impacts by clicking Here.   


Cullen Park is a very popular park and not just for boaters.  Many come to enjoy the views offered there.  Directly across from the boat launch is Bayview Park, which contains a natural category 2 wetland that attracts a variety of rare birds.  The Port of Toledo can also be observed from Cullen Park and many come to watch the freighters go in and out.  The park is also a popular place to take senior pictures and wedding photos.  The Cullen Park wetland will block most of these views, replacing them with a dike wall. 

Likewise, the Grassy Island wetland will replace homeowners’ lake front views with a dike wall.


It must be noted that removal of accumulated sediment within the wetland is part of wetland maintenance.  However, that maintenance does not include sedimentation occurring outside of the wetland walls.  

When the US Army Corps of Engineers constructed the Cullen Park causeway to build Grassy Island and have a place to contain dredge spoils from the navigation channel, it changed the flow at the mouth of the Maumee River by blocking most of the flow into the western end of the Maumee Bay.  This dramatically changed the sedimentation rates along the waterfront.  The deep-water docks and diving boards that existed in front of waterfront homes have been replaced with sediment, litter, and debris.

This debris field used to be deep water with a dock and diving board. This sedimentation occurred because the Cullen Park causeway changing the flow of the Maumee River.

The Cullen Park and Grassy Island wetlands will disrupt the Maumee River flow even further, causing sedimentation in the area to worsen and spread. 


Another cost of these wetlands is the loss of natural habitat.  Normally, restoring or constructing wetlands will improve natural habitat. That is not the case with these wetland projects.  There are already more than 15 acres of good quality, well established, natural, forested category 2 wetlands surrounding the Cullen Park wetland site.  There are forested wetlands on the Cullen Park causeway that are category 3. With the exception of Phragmites encroachment, these naturally existing wetlands have proven their ability to survive and thrive without the need for maintenance. The Cullen Park and Grassy Island wetlands will be built right in front of the natural wetlands, cutting them off from their water supply.

Cullen Park is also a popular spot for the birders who come from far and wide every spring to observe the large number of rare species that stop in the currently existing natural wetlands. The Cullen Park and Grassy Island wetlands will be treeless aquatic gardens and, as such, will not attract more birds.  However, if the natural wetlands are lost because their access to the local water supply is altered by the Cullen Park constructed wetland, many of the birds currently stopping on their migration will leave to find more favorable locations.


Boating helps support to the economy of Toledo in many ways. Examples include supporting:

  • restaurants along the Maumee and Ottawa Rivers,
  • yacht clubs, boating clubs, and marinas on both the Ottawa and Maumee Rivers,
  • fishing tournaments and derbies that bring in fishermen from all over Northwest Ohio and beyond,
  • local gas stations are used to fill the tanks of boats being trailered to the launch site at Cullen Park,
  • the downtown docks when events are held there
  • retail establishments like Bass Pro and West Marine.
  • local carry outs and convenience stores selling beer, pop, ice, and snacks.

This economy will be disrupted if the HABs become more concentrated or become localized.  If it is not safe to engage in aquatic recreation here, boaters will take their business elsewhere or find a new form of recreation altogether.


The size and shape of the wetlands will reduce the amount of flow being diverted from the Maumee River into Cullen Park and the Maumee Bay.  This will cause the flow of the Maumee River to increase as it passes the mouth.  This will allow less time for sediment to settle out of it as it passes Grassy Island.  As a result, more sediment laden sediment will be carried out to settle in the lake.  Click Here for a thorough explanation of this process and the authorities to support it. (this link is still in process it should be up in the next 24-48 hours)


Most of the above constitute beneficial use impairments.  The Maumee River is listed as an Area of Concern.  To be delisted, beneficial use impairments must be remediated.  The intangible costs of the Cullen Park and Grassy Island wetlands do nothing to remediate the impairments.  They only add to them.


One more factor that needs to be emphasized in this analysis is that these wetlands are a permanent solution to a temporary problem.  The excess nutrient  problem is temporary.   At some point a solution will be found and the nutrients will be reduced enough to minimize or eradicate the HABs in Lake Erie.  Natural coastal wetlands that are restored in their natural settings can be let go to continue to exist naturally without regular maintenance.  Not so with the Cullen Park and Grassy Island constructed wetlands.  These are not natural, they are not in a natural setting, and they do not mimic a natural or a coastal wetland. If the Cullen Park and Grassy Island wetlands are left without proper maintenance they will degrade and become toxic, smelly swamps.

When the H2Ohio funding runs out, who will make sure this maintenance gets funded?  If it gets funded, who will make sure it gets done properly?  Who can be held responsible if proper maintenance and capital improvements do not get done?  It was difficult for the Port Authority to locate a partner willing to take on the responsibility for the first 10 years of maintenance, a requirement for getting a permit to construct the wetlands. What it will cost and how hard it will be to find one willing to take over when the first 10 years are up?

Ten years is a drop in the bucket in comparison to how long these wetlands will impact the local community. Construction of these wetlands should not be considered, much less begun, unless and until these questions are answered with more than a “we’ll cross that bridge when we come to it” attitude.



The main benefit these wetlands are supposed to provide is a reduction in nutrients entering Lake Erie. Any attempt to estimate what this nutrient reduction might be is pure speculation.

There is still much to learn about the actual nutrient removal capacities and efficiencies of wetlands. The use of constructed wetlands for nutrient reduction is still in an experimental learning phase. The Cullen Park and Grassy Island wetlands will have multiple access points where water can flow in both directions. Currently there is no proven method to calculate or test the nutrient reduction efficiency of this type of wetland after is has been constructed and is operational. If there are no nutrient reduction efficiencies of currently functioning similar wetlands to refer to, it is impossible to estimate with any accuracy what the future efficiency of the Cullen Park or Grassy Island wetlands will be.

All we know is that, based on hydrodynamic flow studies, it is estimated that 1% of the Maumee River flow will enter Cullen Park and be available to the Cullen Park wetland. 1% of the phosphorous load in the Maumee River between 2013 and 2019 ranged from 12.68 to 39 tons. That is all that would have been available to the wetland.

Even if 100% of the 39 tons had entered, and been removed and retained by, the wetland, it would only have reduced the phosphorous entering Lake Erie from its Ohio tributaries by 0.26% (26/10,000ths), a miniscule amount no matter how you look at it. It shrinks even further when you consider that it is impossible for a wetland to remove 100% of the nutrients entering it. To learn more about this, click Here.

As the agriculture best management practices evolve and additional wetlands are constructed throughout the Maumee River basin, the nutrients that the Cullen Park wetland available to the wetland for removal will diminsh. In other words, The Cullen Park wetland will start by giving, at best, a miniscule return on the investment of H2Ohio funds, and this return will diminish every year even if the wetland remains healthy and fully functional.

It is also possible that the wetlands could actually cause an increase in the nutrients entering Lake Erie. To learn more about how these wetlands could cause a net increase in the nutrients entering Lake Erie, click Here. (This analysis is still being drafted. The link will posted in the next 24-48 hours).

As such, we ask that ODNR reallocate the funds that would be put towards the Cullen Park and Grassy Island wetlands and apply them to other H2Ohio projects that will provide a good return on the investment of those funds.


It has been suggested that these wetlands will provide intangible benefits in the form of new recreational opportunities that will benefit the community, specifically paddling, fishing, hiking, and viewing.  The community does not see any of these as new opportunities or potential benefits. These opportunities already exist.  They will not be improved by the wetlands, but they may be reduced or eliminated by them.

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