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E-M:/ Water Pollution Trading - last chance to comment on a bad program



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Enviro-Mich message from "Jeff Surfus" <jeffsurfus@mediaone.net>
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Michigan Water Quality Trading Program

Deadline for comments:  October 31, 2001

Send comments electronically to:  KOHLHEPA@state.mi.us

Background:  Over the past year, DEQ has been developing rules under which
the Water Quality Trading Program will operate.  Similar to air trading,
this program will allow those point and nonpoint sources who have
discharge or loading reductions beyond any required levels to sell those
reductions as credits that can be purchased by those sources who are
unable to meet their required discharge or loading reduction levels.

DEQ claims that this is "a market-based approach to improving water
quality on a watershed basis. The proposed rules establish a statewide
program that can reduce the cost of achieving and maintaining water
quality standards and implementing programs required under the federal
Clean Water Act (CWA). The proposed rules provide greater operational and
regulatory flexibility. The proposed rules establish economic incentives
for pollutant reductions greater than those required by federal and state
regulations."

Clean Water Action has serious concerns about this program.  Through an
earlier public comment period, Clean Water Action, EPA Region 5, and other
organizations submitted comments to DEQ, which by and large were dismissed
in DEQ's response document and the revised rules.  The comments and
response document can be viewed at:
http://www.deq.state.mi.us/swq/trading/phr.htm  The revised rules can be
viewed at:  http://www.deq.state.mi.us/swq/trading/formalrulesmay.htm

Clean Water Action has developed 12 criteria against which we measure
trading programs.  In our judgment, DEQ has failed to meet ANY of the
following criteria in the program:

-TRADES MUST TAKE PLACE WITHIN A SMALL AREA WITHIN THE SAME WATERSHED -
failed
-A WATERSHED MUST HAVE A TMDL IN PLACE BEFORE TRADING SHOULD BE
PERMITTED - failed
-REQUIRED REDUCTIONS MUST BE SUBSTANTIALLY GREATER THAN THE INCREASES
ALLOWED - failed
-DECREASE DISCHARGES UNDER TRADING PROGRAM OVER TIME - failed
-STRONG ACCOUNTABILITY AND ENFORCEMENT PROVISIONS - failed
-EXPANDED MONITORING IN A TRADING WATERSHED - failed
-STRONG PUBLIC PARTICIPATION - failed
-NO CROSS POLLUTANT TRADING - failed
-POLLUTERS PAY FOR EXTRA COSTS - failed
-SAFEGUARDS FOR ECONOMICALLY AND ENVIRONMENTALLY DISADVANTAGED
COMMUNITIES - failed
-NO TRADING FOR HISTORICAL COMPLIANCE VIOLATORS - failed
-NO TRADING OF TOXIC OR BIOACCUMULATIVE CHEMICALS - failed

Please contact Clean Water Action if you require any more information on
the dangers of this program.

Please take a few minutes to let DEQ know how you feel about the new
trading rules at the location listed above.

And remember, while you are reading this there are polluters out there
right now preparing for the new rules so they can get paid to reduce their
discharges or loads when they should have been doing it under the law
anyway.  Others are going to be willing to pay them so they can continue
to pollute our hundreds of streams which are already polluted or impaired.

It just doesn't make sense.

Jeff Surfus
Clean Water Action




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