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Re: E-M:/ trading nightmares



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Enviro-Mich message from "Charles Cubbage" <CubbageC@state.mi.us>
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Dave, 
As you know, I have been directly involved in the discussions on the development of Water Qual Trading and the Kalamazoo WQT pilot from the ag regulatory sector.  You also know I have a strong env ethic. With that said, I would offer the following comments. 

The help the work group has received from yourself and others in the env community has been very important to the development of the draft rules.  I only wish you could be cloned so that you could have been a larger part of the ongoing process.  However, regarding "any governmental program is potentially dangerous."  It is the delivery that makes the difference.  It would be helpful to the workgroup if you would be specific regarding "trading as practiced by the current Mich regime...."  The air trading program was the initial starting point.  

Regarding the monitoring need, I agree that the more the better.  Too bad we don't have a better baseline.  I agree with you also on accountability too.  Where we differ is with respect to the level needed compared to the cost.  Now before jumping to conclusions let me add another component.  There are few who would argue that filter strips, stream bank stabilization, catchment basins, wetland enhancement, (and the list of functional options can go on) have no impact on watershed resource protection and improvement.  The real question is how much impact and over what time scale and where does it need to be geographically.  Now back to the "cost" comment.  We (all of us) need to assess what level is affordable, who should do it, how often, where, etc.  If funds and staff are available, then who would have problems with having DEQ do the job?  If on the other hand the job could be done reliably at  the cost by multiple partners, would it not be socially more responsible to go that route, even if the money were available? 

Dave, regarding the "privilege of dumping wastes into our waters,  we all contribute and as long as one sector talks about others needing to pay there way, we will not get to where we need to go.  This is not an us versus them issue.  It is a WE issue.  I have been critical of my environmental friends when that approach is taken.  The discussions that have been taking place in the rule drafting discussions and in the Kalamazoo pilot has been about the "we are all part of the problem, but we are also all part of the solution".  I offer praise to you and others for the effort to keep the risks of poorly designing govt regimes.  I also encourage you to use, as often as you can, the opportunities to make a better and more cost effective way of handling resource protection and enhancement.  

You do, however, too broadly paint the majority of by ..."Exactly what the regulated community wants...."  My observation is that most people really want a level playing field.  We all are angered by and want to get the irresponsible actors. But to paint the regulated communty ---- well (who of us is not regulated).  

Your last comment puzzles me.  I agree with you that the industry should and can do a much better job of inviting enviro advocates (env justice interests, etc ) to the table but you seem to also imply that it is not appropriate for regulators and industry reps tout their views on enviro-mich.  I thought that was already happening....  -----  We all need to join the tasks at hand and  not to see ourselves as separate from each other in the reach for a sustainable world.   I am concerned that some might interpret your last comment as an excuse to engage in a zero sum risk game (as long as I'm ahead of you, I don't care if we are getting to the goal or not) .  I know that is not what you stand for.  

Dave, thanks again to you and Alex and the many others on enviro-mich for targeting the needs and urgency surrounding resource protection. 

Chuck

>>> Dave Dempsey <davemec@voyager.net> 08/26 1:44 PM >>>
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Enviro-Mich message from Dave Dempsey <davemec@voyager.net>
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In theory, trading is fine.  Trading, as practiced by the current Michigan
governmental regime, is dangerous.  Please note that the one "minor"
element lacking from the proposed water quality trading scheme is
comprehensive monitoring by the responsible parties.  Without monitoring,
there can be no measurement of whether trading works, hence no
accountability.  Exactly what the regulated community wants.  Excuses about
lack of resources dodge the point. Those who want to use trading should pay
for the monitoring in exchange for their privilege to dump wastes into
Michigan's waters. 

Further, without enforcement, which has come to a standstill in Michigan,
trading results in reduced environmental protection.

I have noticed no dogma on enviro-mich;  alternative points of view are
heard.  When industry e-mail lists actively invite membership and
discussion by environmental advocates, then it will perhaps be appropriate
for regulators and industry representatives to tout their views on
enviro-mich.



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==============================================================
ENVIRO-MICH:  Internet List and Forum for Michigan Environmental
and Conservation Issues and Michigan-based Citizen Action.   Archives at
http://www.great-lakes.net/lists/enviro-mich/

Postings to:  enviro-mich@great-lakes.net      For info, send email to
majordomo@great-lakes.net  with a one-line message body of  "info enviro-mich"
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