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E-M:/ Comments from MDEQ on Trading issue



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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Forwarded bounced message from Dave Batchelor, MDEQ Surface Water Division.....

Date: Wed, 25 Aug 1999 10:22:00 -0400
From: "David Batchelor" <batcheld@state.mi.us>
To: <enviro-mich@great-lakes.net>, <greenscreen17@hotmail.com>,
        <jgriess@provide.net>, <ajs@sagady.com>
Subject: Re: E-M:/ Sierra Club does not support Jeffords bill
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Dear Friends

Thanks for the comments on what trading should and should not be.  We have
been working with other environmental groups and citizens and have come up
with a trading framework that meets almost all of your suggestions, in whole
or for the most part.  The only exception is #8.  We are not requiring NPS
to conduct monitoring.  There are many reasons why, including resources,
credible data and intregration into a ambient monitoring program conducted
by the state.  We do REQUIRE THE STATE to conduct Program Evaluations.  The
results and recommendations are subject to public review and comments.

If you are interested, please take a look at the DRAFT rules on our home page:
www.deq.state.mi.us/swq/trading/temp5x.htm.

I would be happy to answer any questions you may have.  We plan to begin the
formal rulemaking process in the next 3 or 4 months.

Regards,  Dave

>>> "A. FRIEND" <greenscreen17@hotmail.com> 08/20 8:59 AM >>>
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Enviro-Mich message from "A. FRIEND" <greenscreen17@hotmail.com>
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Julie,

Thanks for the informative post.  However, I still am confused.  The policy 
statement states opposition to trading (with no rationale given) and then 
provides a very detailed and thoughtful recipe for a quality program.  Why 
not limit their support to programs that meet this criteria?


[SNIP]



>From: "Julie Griess" <jgriess@provide.net>
>Reply-To: "Julie Griess" <jgriess@provide.net>
>To: "Alex J. Sagady & Associates" <ajs@sagady.com>,        
><enviro-mich@great-lakes.net>
>Subject: Re: E-M:/ Sierra Club does not support Jeffords bill
>Date: Thu, 19 Aug 1999 21:48:46 -0400
>
>-------------------------------------------------------------------------
>Enviro-Mich message from "Julie Griess" <jgriess@provide.net>
>-------------------------------------------------------------------------
>
>Here's what I found at
>http://tamalpais.sierraclub.org/policy/conservation/trading.html 
>
>Sierra Club Conservation Policies
>Pollution Trading Policy
>  The following policy on pollution trading has been adopted by the Sierra
>Club Board of Directors February 20-21, 1999.
>Pollution Trading
>
>The Sierra Club opposes use of trading. In all cases, if a program is
>initiated, there must be full public notice, disclosure, participation,
>oversight, accountability, verification, and effective enforcement, with
>rights of appeal for affected citizens and administrative and judicial
>remedies.
>
>The following conditions must apply:
>
>(1) that the trade produces overall gains in ambient environmental
>conditions;
>
>(2) that such gains satisfy goals set forth in approved government plans;
>
>(3) that reductions for trades are beyond current legal requirements, with
>indicated reductions being greater than 1:1 as a hedge against uncertainty
>and non-compliance;
>
>(4) that the required reductions be new (e.g., not be taken from unused
>allowances);
>
>(5) that trading should be limited to pollutants of the same kind;
>
>(6) that no credit be granted for reductions from sources closed down prior
>to the proposal for the trade;
>
>(7) that the trade occur within the same local physiographic unit (e.g.,
>watershed or airshed), except that for the purposes of carbon dioxide, the
>entire atmosphere is the
>airshed*; ----------------------------------------------
>
>*However, a CO2 trade should not be allowable if air quality could be
>worsened locally or regionally as a result of the trade (because of
>associated pollutants such as NOx). [That outcome would violate various
>other provisions of this policy (e.g., it would like run afoul particularly
>of either #1, C, or D.).] -----------------------------------------------
>
>(8) that in all cases monitoring be provided by the seller, with results
>reported to regulators and made public, to assure that the required
>reductions actually occur; increased costs to the public of surveillance
>should be covered by permit fees;
>
>(9) that data on these reductions is provided to the public in an easily
>understood format (electronically as well as in hard copy);
>
>(10) that whoever cheats be punished by severe fines that are applied
>automatically and that surety bonds be provided, where appropriate, as an
>incentive to perform; and that buyers who rely on unwarranted credits also
>be subject to fines;
>
>(11) that information on violations remain public information and not be
>subject to "audit privilege" or other forms of confidential business
>information; and that compliance records for all firms engaging in trading
>be made available to any member of the public (and not be subject to "audit
>privilege"), including records on inspections and violations;
>
>(12) that violators will have their allowable releases reduced in the year
>following the violation by the amount of their excess releases; where the
>amount of this excess is unknown, it should be assumed to be the maximum
>physically possible;
>
>(13) that the trader be competent to make the required reductions and that
>firms that have contributed materially to ambient problems not be eligible
>to engage in trading;
>
>(14) that chronic cheaters be excluded from trading programs;
>
>(15) that the government retain the right to further limit allowable
>releases, without needing to compensate the releasor. Permission to trade
>must not establish a right to pollute, nor any property interest in 
>material
>that is released.
>
>Under no circumstances should trading arrangements lead to the following:
>
>A. Violation of ambient standards, expanded pollution at grandfathered 
>sites
>(i.e., from old sites granted legal exemption from meeting standards), nor
>significant deterioration in the quality of air and water which has been
>good, nor degradation of soils, ecosystems or other public values;
>
>B. Increased releases of any of the following categories of toxics 
>(measured
>at the point of release): -- heavy metals -- neurotoxins -- known or
>suspected carcinogens -- known or suspected endocrine disrupters -- known 
>or
>suspected mutagens, or -- persistant or bioaccumulative agents;
>
>C. Backsliding on pollution control obligations, nor on best management
>practices, nor facilitate irresponsible conduct;
>
>D. Build up of levels of pollution in Clean Air Act non-attainment areas,
>nor make conditions worse in such areas;
>
>E. Monopolization of pollution allowances;
>
>F. Trading in, and between, communities that disapprove of trades that
>affect them. Trading should never proceed without assessing the cumulative
>impact on communities subject to trading that involves multiple sources;
>public review and participation should be provided.
>
>G. That any community be disproportionately burdened by the results of the
>trade, especially those communities that are already disproportionately
>burdened by toxics, or other noxious land, water or air pollutants.
>


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