One of the most important arenas for debate about the future
This week, at last, there is increasingly good documentation by the DEQ of the REAL consequences of taking the path advocated in testimony by the Michigan Manufacturers Association, Farm Bureau and others suggesting that there is room to cut a lot more “fat” out of the DEQ budget. Comments at hearings before the Senate Appropriations Subcommittee on Environmental Quality over the past few weeks have contained many jabs at DEQ programs with sweeping and often misleading information.
At yesterday’s hearing DEQ Director Steve Chester and other top level staff presented clear documentation, both written and verbal, about the impact that additional cuts or failure to reauthorize a range of fees charged for permits designed to pay, in some cases entirely, for enforcement, permitting etc. to protect the environment. Many who have watched this list know that the DEQ’s General Fund dollars today are less than 1/3 what that environmental battering ram Russ Harding had to work with when he ran the show. The state is increasingly dependent on fees for a variety of environmental programs to fund programs to prevent and protect us from water pollution, air pollution, etc.
Like an economic perfect storm on top of the overall generic mess of funding state government that is capturing headlines regarding schools, prisons, healthcare, etc., the DEQ is facing the expiration of multiple fees, the drastic underfunding of many programs even with fees, and the problem of raging ideologues for whom the best gov’t appears to be no gov’t at all. Damn the pollution, cut back our fees!
Yesterday, at long last, a compilation of the actual impacts of the thousand small cuts that are causing protection of our land, water and air to bleed to death was provided in a way that helps explain a bit better the real consequences of following the ideologues’ way. Below I have pasted in JUST the wetlands program piece, but this will give a very good idea of what is up. There is also information that I hope DEQ can post and let us know about on Air quality, Groundwater, NPDES programs (including debunking claims on the voluntary MAEAP program vs. CAFO NPDES permitting).
PLEASE take a moment and let the Senate Appropriations
Subcommittee members that
Senator Valde Garcia, Chair, at: SenVGarcia@senate.michigan.gov,
Senator Alan Cropsey at SenACropsey@senate.michigan.gov and
Senator Liz Brater at SenLBrater@senate.michigan.gov)
(The below document was prepared by the Michigan DEQ and submitted at the May 31 hearing of the Senate Appropriations Subcommittee on the Dept. of Environmental Quality budget)
Benefits of Administering a Federally Authorized State Wetland Permit Program
Since 1984, the DEQ has
been approved to administer a combined state-federal wetland permit program
· There is no statutory deadline for
processing of Corps permit applications. The number of days to receive a
permit from the Corps as compared to that in
General Permits 313 49
Individual Permits (Public Notice Required) 788 99
· Legislature would have to repeal Part 303 – Wetlands Protection, of the Natural Resources and Environmental Protection Act.
· Parties who contest regulatory decisions would have more limited appeal options through federal rather than state courts. State and local officials would have significantly less input into permit decisions and timing.
· Even if the state program is eliminated the Corps would still be required to obtain a state water quality certification from the DEQ under Section 401 of the Clean Water Act before a federal permit could issue. Applicants would also have to obtain certification from the DEQ that the projects was consistent with the State’s coastal management program. These processes are currently handled by LWMD as part of the state-administered consolidated permit program.
· The Corps
would still require applicants to coordinate with the U.S. Fish and Wildlife
Service under the Endangered Species Act, and with the State Historic
Preservation Office under the National Historic Preservation Act, prior to
permit issuance. Under the current state-administered program, the DEQ
incorporates coordination with these agencies into its routine permit review.
· The DEQ currently coordinates issuance of permits for transportation projects with the MDOT and other public transportation agencies. State transportation projects would be faced with significant delays.
recent studies highlight the economic value on these wetland benefits:
o As reported
in March 2006, Ducks Unlimited hired an expert economic consultant to help
determine the economic importance of
o In April of
2007, the State of
The bottom line: Return of wetland
regulation to the federal agencies would mean relinquishing control of this
Anne M. Woiwode, State Director, Sierra Club
517-484-2372 fax 517-484-3108 -- email@example.com
Sierra Club Michigan Chapter celebrating our 40th Anniversary on September 9, 2007
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