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E-M:/ Dow Chemical gets another F

Dow Chemical’s Work Plans “Fundamentally Flawed” and “Critically Deficient” Says EPA


EPA critical of Dow Work Plans for the City of Midland, Tittabawassee River and Floodplain


Failing to pass scientific scrutiny with EPA, Dow once again submits plans so deficient as to be transparent. No company with the resources that Dow has can consistently submit plans so inadequate and so lacking unless it is by design. Like the Consent Order in 2002, the Risk Assessment in 2002, the Scopes of Work in 2003 and the IRA’s, Dow’s intentions are to deliberately:


  • Ignore compliance with their license
  •  Delay defining the extent of their contamination
  •  Deny the toxicity of dioxin
  •  Rewrite the science to benefit them
  •  Rewrite the laws that govern them
  •  Delay Cleanup


It’s a legitimate question to ask if “voluntary corrective action” really works or if it’s just a burden on the taxpayers as it drains resources and tax dollars within our budget strapped DEQ. Not to mention the natural resource and public health implications associated with deliberate delays created by a corporation that has no interest in being responsible. Under the provisions of voluntary corrective action the State of Michigan has spent years working with Dow to bring them into compliance. Folks it's not working!


Much of what Dow is attempting to do with a rewrite of the science and the law is in an attempt to get out ahead of the release of Dioxin Reassessment at EPA.  


Through sheer political force, lobbying and local philanthropy Dow has been able to outflank regulatory agencies, rules, laws or anything else that constrains their profitability. Dow has been able to ruin the commons and trespass onto personal property and properties owned by the people of the State of Michigan almost with impunity and Dow's dioxin will migrate to Lake Huron poisoning another entire eco-system and economic resource for decades.


You can read EPA's comments at the Tittabawassee River Watch webisite. www.trwnews.net . Or, I would be happy to send them to you.


Michelle Hurd Riddick

Lone Tree Council