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Enviro-Mich message from anne.woiwode@sfsierra.sierraclub.org

The National Governor's Association will be meeting this weekend and is
expected to consider a resolution that seeks significant weakening of the
Clean Water Act.  The Clean Water Network is circulating an alert urging those
of use who care about clean water to contact Governor Engler (actually all
governors) to express concerns about the resolution.  In this election year,
this is one of those "where the rhetoric hits the road" tests -- will the Gov.
be willing to oppose a resolution that threatens health and the economy by
seeking to undermine critical protections of our water quality, in this the
Great Lakes state? The Gov's number is 517-373-3400.

Anne Woiwode


"We believe the (PROPOSED NATIONAL GOVERNOR'S ASSOC.) policies substantially
weaken the Clean Water Act in a number of ways:

*They replace enforceable Clean Water Act programs for stormwater and impaired
waters with a weak watershed planning process that does not provide for
citizen enforcement or effective oversight;

*They oppose national efforts to reduce pollution from large factory
farms that are ruining our rivers, lakes and estuaries;

*They reject national standards to ensure that beach waters are safe for
swimming and fish are safe to eat;

*They provide weak standards for wetland mitigation banks, the assumption of
state wetland permitting programs, and the issuance of general permits for
activities that destroy wetlands; and

*They exempt Clean Water Act permits from the requirement to consult
about the impacts on threatened and endangered species.

In particular, the standard for approving proposed statewide watershed
programs to bring impaired waters into attainment is nonprotective, and
requires the EPA to approve state programs that take 15 years to attain
water quality standards even where attainment can be achieved in shorter
periods of time.  The EPA is given no authority to review and approve
individual water quality attainment plans, nor milestones to determine if
adequate progress is being made toward meeting water quality standards.
Citizens are provided no role in the enforcement of attainment plans despite
the success of the citizen enforcement provisions of the Clean Water Act in
ensuring compliance with the law.

Despite these deficiencies in oversight and enforcement, the proposed NGA
policies would allow states to opt-out of established and enforceable TMDL and
stormwater permitting programs.  It is unclear how the policies affect
existing programs that prevent deterioration of clean waters (such as coastal
nonpoint programs and state antidegradation policies).  However, it is clear
that they weaken enforcement of the NPDES program by limiting the
accountability of point sources to their 'proportionate share' of pollution,
without providing a mechanism - such as a TMDL - to allocate proportionate
shares. Moreover, the policies undermine the carefully crafted compromises in
the Stormwater Phase II FACA agreement.

For these reasons, we urge you to substantially strengthen the draft NGA Water
Resource and Agricultural Policies to protect our nation's water resources."


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