October 8, 2026
A Comprehensive Plan Must Begin With the People
Statement to the Sheboygan Plan Commission
Commissioners,
I am asking you not to recommend adoption of the August 2026 Comprehensive Plan in its present form.
A Comprehensive Plan is supposed to be much more than a land-use map and a strategy for future development. It should express the collective vision of a community: What kind of city do we want Sheboygan to be 20 years from now? What do we value? What must we protect? And what policies will ensure that future generations inherit the city we envisioned?
Those questions should be answered through a meaningful planning process involving residents and stakeholders—not simply by asking people to comment on a plan largely developed for them.
We understand that approximately 300 people participated or provided comments in a city of roughly 50,000. That is about six-tenths of one percent of our population.
That number alone does not establish that the process was inadequate. But it should cause this Commission to ask whether the participation was broad, representative and sufficient to establish a genuine community vision.
There is an enormous difference between collecting public comments and allowing the public to help shape the policies that will govern its future.
The August draft contains extensive information about Sheboygan and considerable direction for land use and development. It also recognizes our natural resources and records residents' concerns about Lake Michigan, groundwater, wetlands, trees, flooding, air quality and environmental protection.
But recognition is not the same as commitment.
Too often, environmental priorities are expressed in language such as support, encourage, explore and enhance, without equally clear policies explaining how those priorities should guide future City decisions.
Development is an important part of a city's future. But so are public health, safe neighborhoods, clean air, clean water, conservation, economic security, public infrastructure and quality of life.
A Comprehensive Plan must bring these priorities together. It cannot allow development policy to become the organizing principle while other community values remain largely aspirational.
And there is an additional concern. As Sheboygan considers changes that would place more development decisions in administrative hands, the clarity of the policies guiding those decisions becomes even more important.
Commissioners, Wisconsin's Comprehensive Planning Law requires written public-participation procedures designed to foster public involvement at every stage of preparing a plan. It calls for open discussion, public meetings, communication and opportunities for written comments and responses.
Public participation is not supposed to be an event at the end of planning. It is supposed to be part of how the plan is created.
I ask this Commission to recommend that the City undertake additional work before adopting this Plan:
First, establish a structured, widely publicized community visioning process that reaches residents throughout the city—not merely those who attend a few meetings.
Second, bring together residents, neighborhood organizations, businesses, environmental groups, public-health representatives, educators and other stakeholders to identify what Sheboygan should become and what it must preserve.
Third, use that vision to develop clear policies across all elements of the Plan, including natural resources, public health, neighborhood quality of life, infrastructure and development.
Fourth, return a revised draft to the public, showing how its priorities were incorporated, and provide meaningful opportunities for further review.
This is a decision about the next 20 years of Sheboygan's future. It deserves more than a few meetings and a collection of comments. It deserves a genuine community planning process.
Commissioners, you have an important responsibility. You are being asked to recommend a document that will influence decisions long after today's officials and staff have left office.
Please do not recommend adoption yet. Return this Plan for meaningful community participation, a shared 20-year vision, and the clear policies needed to make that vision real.
Before you vote to recommend this Plan, will you ask staff to produce the City's adopted public-participation procedures, document how those procedures were carried out at each stage, and show how residents' expressed priorities were translated into the policiesof this Plan?
A city should not merely plan where it will develop.
It should first decide, with its people, what it wants to become—and what it refuses to lose.
Mary Faydash
President
Friends of the Black River Forest
friendsblackriverforest.org
Lake Michigan Stewardship must be a Sheboygan priority.
Letter to the Sheboygan Common Council
Friends has reminded the Common Council and the Mayor that Sheboygan's responsibilities lie far beyond city borders.
On January 19, 2026, the Council will vote on removing the permitting of the Kohler golf course (with no submitted plan) from review by the Planning Department and the Plan Commission putting it in the hands of one Zoning CSAR. Friends will be challenging this highly improper action. It is anti-community and alarmingly myopic in its view of how our environment works
February 27, 2025
Dear Alderman_______
I am writing you today as a representative of Friends of the Black River Forest (FBRF), to update you on the most recent City Plan Commission activity regarding the proposed Kohler golf course.
FBRF’s mission is to preserve the integrity of the Kohler Andrae Lakeshore through education as to this ecosystem’s significance, and to hold State agencies, the City, and the Kohler Company to the same rule of law that applies to every citizen.
FBRF has been active since 2013, acquiring Federal, State, and City documents which have evidenced ignoring and violating regulations at City, state and Federal levels to procure for the Kohler Company the right to use its land and our state park in ways that were illegal and would contaminate and destroy our natural resources for Kohler’s private gain.
We have received awards from the Sierra Club, Fresh Water Future and the Wisconsin Society for Ornithology for our efforts to preserve and protect Lake Michigan and the coastal ecosystem of this east central shore.
We believe the public deserves to know about the Plan Commission’s and the City’s actions in allowing a developer to skirt the law which can eventually affect our common resources and our health. We also believe the public should know the developer has agreed to pay legal fees up to $200,000 incurred by any challenges to the city’s actions. This, in itself, is a choice made by this city to prevent the average citizen who is not a billionaire from having any redress against threats to their health and welfare.
The ethics of this agreement tarnished the Plan Commission’s actions and Common Council decisions on the proposed Kohler Company golf course in 2020 and continues to do so.
In 2020, the City of Sheboygan Plan Commission (PC), issued a Conditional Use Permit (CUP) for the Kohler golf course project. Actions taken by the PC violated city procedures, ordinances and the responsible exercise of a plan commissioner’s duties.
No lawsuits by citizens ensued because the City illegally stipulated requirements for standing which precluded citizens from bringing suit. (01.Freehill letter to City)
FBRF filed a lawsuit to revoke the DNR- issued Wetland Permit for the golf course. We prevailed in this lawsuit. It was this revocation of the Wetland fill Permit which left the company unable to build the course it had presented to the DNR and to the City Plan Commission for its CUP application.
The Kohler golf course project has once again come before the City Plan Commission. On October 28, 2024, the PC received a request from a Kohler Company attorney to extend the 2020 Conditional Use Permit (CUP) for the golf course plan whose Wetland Fill Plan was revoked in 2019 and whose CUP had expired. Kohler submitted a letter listing changes to the old plan which were significant. ( 02. Kohler extension request letter to PC).
As you may know, the City requires every applicant for a CUP to apply for a new CUP when changes are made to the original plan. This is because a permit is site plan specific. This mandate is listed on the bottom of every CUP application.
At the November 12, 2024 meeting, the Plan Commission took up Kohler’s request and voted to extend the company’s 2020 CUP for a permit which was expired and had been revoked by the courts.
The actions of the Chair, Mayor Sorenson, the PC members and City Attorney Charles Adams, resulted in several violations of city ordinances, state law and Plan Commission ethics. (Westerberg letter to PC ).
Attorney Adams led some members to believe they had to vote for an extension.
Adams stated to members at the November 12, 2024 meeting:
“What I would say is this, you cannot relitigate the issues that were ligated in 2020. You are here today just simply to determine whether the extension is appropriate. In considering whether the extension is appropriate you can consider the fact that you have put these restrictions on the conditional use permit, the various restrictions that you placed there the most key of thinking they had to vote for the extension which is the requirement to have all the required permits. If you believed that that condition is no longer meetable that that would be one thing. Here the issue is for you to decide not so much to relitigate what you have already decided but whether the Kohler Company is capable of continuing with the project as you approved it and is an extension appropriate in that regard.”
Very simply put, Kohler attorneys wanted to use an expired permit issued for a particular site plan that was granted a CUP in 2020 declined to show the new site plan to the Plan Commission. A new CUP would necessitate public comment and a more scrutinized permit than the one permitted in 2020.
The newly designed course plan had been:
a. described to the Army Corps of Engineers (04. FOIA ACOE pg. 7)
b. shown to Mayor Sorenson and a few city officials at a private meeting
c. described by attorney Tomczak in the Kohler Oct. 28 request for an extension.
However, on November 12 , Attorney Tomczak stated:
“No change, no amendment in front of you today, we are not proposing anything different than what was approved in 2020 at this point.” (see Nov. 12 recording https://youtu.be/6eHYsfSXMIc?si=pVxwwC-sjJ8lOmkb
Mayor Sorenson, knowing he had seen a newly designed course months earlier, asked if a year extension were sufficient for the company and proceeded to vote for the extension all the while neglecting to mention to Ms. Tomczak that he had seen the newly designed course plan and he knew it had changed.
Later in an interview with the Wisconsin Law Review on December 16, 2024, Mayor Sorenson expressed frustration with what had gone down, in spite of having voted for the extension.
“But (Kohler) showed me the plan. This is my frustration. City officials met with Kohler and they showed us their whole new plan. They (Kohler) are trying to find some legal maneuvers to get this (golf course) approved…”
Now, in a most recent article in the Sheboygan Press on February 24, 2025, Sorenson states:
“I still have many outstanding questions about the overall potential changes in the project," Sorenson said. The Plan Commission needs to better understand the impact of clearcutting a forest right on Lake Michigan, right next to a state park. The environmental and wetland impact needs to be thoroughly examined, and we still do not know how the changes will impact the Native American burial grounds. Additionally, the city needs to better understand the longer-term impact on the infrastructure costs for this project, he continued. These are all factors we can consider in the state statutes. In the next steps, the applicant will have to be transparent about these matters."
Steadfast in his voting for a defunct and expired extension, Sorenson lists all the considerations that should have been considered in 2020. He believes these will be answered when they could only be addressed if a new CUP had been required. Mayor Sorenson believed there would be an opportunity to introduce new issues into this 2020 CUP.
Roger Miller addressed the Sustainability Task Force soon after the November PC meeting. Mr. Miller provided them with information on the many violations of the 2020 CUP and the extension vote. He requested they share this with the Common Council. However, we have the impression that the Common Council has not been provided with this information. (05. Miller Comments to Task Force).
The actions on November 12 prompted two appeals to the Sheboygan Board of Adjustment (BOA) one by Roger Miller, a citizen, and one by FBRF, joined by a Sheboygan city resident.
The appeals asked the BOA to review and invalidate the decision made by the PC on November 12, 2024. (06. Kohler CUP Appeals)
Attorney Adams next advised the BOA that it was not the proper venue for the appeal but rather the Circuit Court. This was a misreading of the state statute and also a conflict of interest of Attorney Adams. The BOA should have retained outside counsel in responding to citizens since it is a body which acts independently of the City of Sheboygan.
Roger Miller along with seven other individuals, has now brought a complaint to the Circuit Court asking that the CUP extension be declared invalid. (07. Summons and Complaint).
Today an old script is replaying with another Plan Commission that is not being led to understand its responsibility to be knowledgeable on the specifics of a development, city ordinances and the law. Conflicts of interest seem to be glossed over when it comes to Kohler. Mayor Sorenson neglected to address the conflict of interest that Mr. Belanger, a Plan Commissioner, had as an employee of the Kohler Hospitality division that manages golf course planning. As during the annexation vote, when alders employed by Kohler believed they did not have to recuse themselves because they would do the right thing, there was no understanding of recusal evident in the actions of the Chair. Usually one recuses himself not because he will act with bias, but because he wants to avoid any perception of bias to demonstrate to his constituents his concern for integrity. Mr. Belanger’s later comments indicating he was free from a conflict of interest are a conflict of interest in themselves.
Why is FBRF providing you with this information?
First, citizens deserve government officials who educate themselves as to their responsibilities and hold everyone to the law. Those who serve on committees and the Plan commission deserve to be trained so that they act based on knowledge rather than opinion. The PC did not know what it was being asked of them at the November 12 meeting.
The elephant in the room, an agreement with Kohler in which the company will pay for litigation fees up to $200,000 incurred by the city related to Kohler’s project, would appear to be tainting decisions by the Plan Commission and the City.
A Finance Committee member commented on being between a rock and a hard place between a
lawsuit from citizens over the illegal extension of the CUP and a lawsuit from Kohler Company if it didn’t get its way.
Attorney Adams responded “In my opinion, there is a little bit of a rock and a hard place
situation here but the decision that was made was the better decision and so I think it’s going to be much more defensible given that.”
Meaning it was much easier to choose to be sued by the citizens than the Kohler Company which expected the city to fall in line and had huge resources to prevail in endless court challenges.
One issue to consider when skirting and violating the law for a developer is Sheboygan’s responsibility as a city located on the second largest freshwater body within the United States.
Mayor Sorenson, Vice Chair of the Great Lakes and St. Lawrence Cities Initiative understands the activities that threaten and contaminate Lake Michigan. As Chair of the PC, when he receives a new CUP application a critical review of impacts to our health and common resources is necessary.
From the GLSLCI website: “The Great Lakes and St. Lawrence Cities Initiative is a
multinational coalition of municipal and Indigenous government executives representing communities in the Great Lakes and St. Lawrence River Region. Together, they are working to promote economic prosperity in their communities and protect fresh water for the benefit of current and future generations. The Cities Initiative and local officials integrate environmental, economic and social agendas and sustain a resource that represents approximately 20 percent of the world’s surface freshwater supply, provides drinking water for 40 million people, and is the
foundation upon which a strong regional economy is based.”
The City willingly ignores the health of this resource when it ignores impacts of development such as the mandate that site plans be included when a project changes.
As an example of what this development will entail:
It is estimated that a Wisconsin golf course uses 21,000-32,000 lbs of nitrogen fertilizer per year. (This does not include other fertilizers such as phosphorous or potassium, nor fungicides, and pesticides). An estimate of how much nitrogen alone, FBRF has kept out of our Lake and groundwater, since 2014, is 200,000 - 350,000 lbs. An estimate of the amount of water kept from being pumped out of La Michigan sent to the Kohler course as contaminated and returned to the Lake is 770,000,000 gallons.
We are proud of our efforts which have forestalled this contamination which leads to algal blooms, cyanobacteria and ultimately dead zones. However, we call on the City to do its part with critical oversight.
Kohler spokesperson and vice president of Golf, Landscape and Retail for
Kohler Hospitality, Dirk Willis, stated after the vote to extend the defunct CUP:
“Our company has an established record of environmental stewardship, and at our golf courses we use industry-leading and sustainable practices. We continue to focus on improving the quality
of life for residents and guests visiting Sheboygan County. Like the American Club, Blackwolf Run, and Whistling Straits, these types of investments elevate our community and increase the region’s tourism profile,”
Those in charge of safeguarding the public might ask:
1. Could Mr. Willis list the specific elements of environmental stewardship that have established this record?
2. Has any of their previous actions as environmental stewards involved clearcutting 170+ acres of a forest including old growth and fragmenting a state park forest?
3. Has any of them resulted in critical habitat removal which sustains an important migratory bird stopover?
4. Has any of them resulted in applying toxic chemicals such a glyphosate on a shallow sand- based aquifer along a Great Lake, threatening water quality and local drinking water?
5. In the Kohler environmental impact report there was no mention of their industry leading and sustainable practices used at their courses. In fact, in any golf course marketing materials pro-environmental practices have never been mentioned. Can they list specifically what they are?
6. Apart from the Kohler community contributions, how specifically do the American Club, Blackwolf Run, Whistling Straits elevate the region’s tourism profile? And whatever
elevation that might be, is it a fair trade for being allowed to contaminate water, our air and our land right here along the Sheboygan shoreline?
7. Kohler’s claim of economic benefits to the state and city has never been verified. Now we hear from Kohler that its world class championship course has been scaled down to a regular 18 hole course and the promises of hundreds of thousands of spectators from around the world has
evaporated. Kohler’s own economic report from 2014, claims a 19 million dollar boost to the state. Data shows Kohler Andrae State Park provides the same economic benefit to the state and with 4 other parks supports the entire state park system. Should the residents of Wisconsin accept that Sheboygan’s unverified economic benefits are more important than our state park system?
8. And from other Kohler comments about 200 jobs for the city, no one in City leadership has ever asked what the 200 jobs are that Kohler touts as a benefit to the city. Can they list them?
We hope this provides some basic information as a catalyst to ethical and informed decision making on the part of the city government. We are available to provide any documents that will help you with understanding the impacts of Kohler’s proposed golf course on the health and welfare of our citizens and our Great Lake.
Sincerely,
Mary Faydash
President, Friends of the Black River Forest
Link to the documents cited. https://www.dropbox.com/scl/fo/s4n9yw6lglc6tsjvvsdxs/AKloF5YLiCdfYXE1YgwbFxo?rlkey=planhwxo8hl8raw69w2u47qpr&st=87f8p072&dl=0