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E-M:/ Great Lakes Bottomland Endangered - Public Comment Needed

Enviro-Mich message from "Scott McEwen" <scott@watershedcouncil.org>

Great Lakes Bottomland Endangered
Public Comment Must be Provided to MDEQ by May 15

The Michigan Department of Environmental Quality's Land and Water Management
Division is proposing to issue a general permit under Part 303 of Wetlands
Protection and
Part 325 of Great Lakes Submerged Lands to allow the construction of a
“temporary” access
walkways by filling across beach swales with standing water on exposed Great
Lakes bottomlands.

It is our opinion that this proposed general permit will have a significant
cumulative impact
on the wildlife and water quality of the Great Lakes.  Coastal wetlands and
near- shore
bottomlands are some of the most biologically productive and ecologically
ecosystems in the Great Lakes. Periodic low water levels are critical for
the healthy
rejuvenation of coastal marshes and wildlife populations.  In the Northern
Lower Peninsula
we have seen significant use of these exposed bottomlands recently by
shorebirds for feeding,
loafing, and nesting.  Manipulation of these bottomlands, which will be
greatly expedited under this
general permit category, will have a significant impact on this critical

Most coastal wetland plants reduce coastal erosion.  The dense root mats of
plants hold surface sand during storms.  Disturbing these areas by dredging
and filling during
low water will weaken or kill these plants resulting in increased erosion
during high water.
The areas proposed for permitting  is the zone where the greatest wave
action occurs.
Another downside of such bottomland disturbance is that the disturbed soil
conditions where exotic plant species can better gain a foothold.

Ironically, the MDEQ was one of four co-sponsors for a recently published
brochure "Protecting
Wetlands along the Great Lakes Shoreline."  This excellent brochure, which
can be found on the
Michigan Natural Features Inventory website, offers an excellent rationale
as to why we need
to protect coastal wetlands and bottomlands.  This proposed general permit
category is contrary
to all the stated benefits of why we should protect Great Lakes bottomlands.

Finally, the permit requires that the applicant utilized dredge spoils and
material from the
the riparian’s bottomland.  While this is a noble attempt to minimize
impacts of this proposal, in
some areas of the Great Lakes such as Saginaw bay, Lake St. Clair, the
Detroit River, and at
the mouths of other rivers, it may have the unintended consequence of
disturbing contaminated

Please send your comments by May 15 to:

Mr. Hal Harrington
Great Lakes Shorelands Section
Land and Water Management Division
Michigan Department of Environmental Quality
P.O. Box 30458
Lansing, MI  48909 - 7958

You can read the full copy of the proposed general permit by clicking on:


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