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E-M:/ Water Quality for Streams that Drain Commissioners Touch



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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Michigan has established a list of stream/river segments considered
to be "highly modified" where MDEQ has decided that it will not do
any areawide management for water quality in the form of total maximum
daily load plans.     These area areas where water quality standard violations
for either numerical standards or narrative standards could exist, but MDEQ
says:

"Highly modified rivers consist mainly of water bodies maintained
by Michigan's County Drain Commissioners and are impacted
due to channel and habitat modification activities. "

Here is the 18 page list of Michigan's kissed-off watercourses where MDEQ hasn't even listed
if any water quality standards are violated....merely deferring to the "highly
modified" designation and thus the expectation that the state won't have to
write plans to solve any water quality standard violations these waterbodies might have. This means,
for example, that these waters could have excessive nutrients and pathogens, but
the state won't commit to a cleanup plan merely because drain commissioners
have some jurisdiction to change these watercourses.


http://www.deq.state.mi.us/documents/deq-wd-swqas-intrepapp12.pdf

The question I have is did anyone comment on this at the time that
the MDEQ published its draft year 2004 "303d" list for public comment
whenever it came out?   If so, please send me a copy of the comments you
submitted and whether you have information on if MDEQ responded to your
comment.

According to MDEQ, highly modified rivers comprise approximately 52% (3,009 miles)
of the total 5,768 river miles not attaining water quality standards.


This situation is a continuing legacy of the agriculture/drain commissioner sector's stranglehold over
certain Michigan waters in an attempt to continue alleged rights to pollute, impair and
destroy water resources, primarily in rural agricultural areas, with little or no
interference from environmental regulatory agencies.


Alex Sagady
Environmental Consultant


========================================== Alex J. Sagady & Associates http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Evidence Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf

PO Box 39,  East Lansing, MI  48826-0039
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com
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