[Date Prev][Date Next][Date Index]
E-M:/ More on the Michigan impaired waters list
- Subject: E-M:/ More on the Michigan impaired waters list
- From: "Alex J. Sagady & Associates" <email@example.com>
- Date: Tue, 29 Jan 2008 01:31:36 -0500
- Delivered-to: firstname.lastname@example.org
- Delivered-to: email@example.com
- List-name: Enviro-Mich
- Reply-to: "Alex J. Sagady & Associates" <firstname.lastname@example.org>
Enviro-Mich message from "Alex J. Sagady & Associates" <email@example.com>
It is impressive how devoted the MDEQ Water Bureau
water quality planning staff is to the current Granholm Administration's
goal of getting Michigan citizens used to living with dirty, impaired
waters and violating the Clean Water Act in the process --
be less worried through being unaware of dirty water problems.
While the Granholm political people, the top management in the
MDEQ and the line workers in the Water Bureau would never
agree to it being described or cast in this way, nevertheless that is what is going on
here with the year 2008 MDEQ Section 303(d) Impaired waters report just
published on January 28:
The purpose of the Section 303(d) report is to delineate which
waters are impaired and are violating water quality standards
and for what reason and what planning and regulatory decisions
must take place to address these problems.
The new year 2008 Draft Impaired Water List has hidden much
of the major policy decisions in a mass of database tables, but
look closely and you may begin to see how MDEQ is using this
process to escape accountability on cleaning up Michigan's
The 2008 report shows many new areas in the first 7 pages of
Appendix D with new dioxin, pathogen and mercury contamination
problems since the 2006 report, but MDEQ's draft 2008 report doesn't show the name of the
watercourses and expects you to take a 14 digit hydrological code
and try to find out yourself where it is. So much for being public
friendly, but I fear the real purpose is to obscure public disclosures
of such impairment. Such obfuscation serves political, corporate, agriculture
and development interests, but not the public interest since it
frustrates a primary purpose for why Congress enacted Section 303(d)
in the first place -- a motivation for public pressure to clean up dirty
waters. It would take hours and hours to go through the first 7 pages
of Appendix D and identify the streams, rivers and lakes where MDEQ
now says there are newly discovered mercury, PCB, pathogen,
chlorinated dioxin/furan and other problems it discovered in the last
A few listings for chlorinated dioxin/furan (PCDD/PCDF) I found in the new problem list....
....PCDD/PCDF in South Branch of Macatawa River, Morrow Lake/Kalamazoo River;
Davis Creek-Kalamazoo River; Spring Brook- Kalamazoo River; Silver Creek -
Kalamazoo River; TRowbridge Dam and Pine Creek - Kalamazoo River; Tannery
Creek - Kalamazoo River; Lake Allegan/Dumont Creek - Kalamazoo River;
Averill Creek, Prairie Creek, Snake Creek and Tittabawassee River;
Lingle Drain, Sarle Drain, Shaffner and Major Drainand Tittabawassee River;
Many new listings in the last two years for mercury, PCBs and other pollutants
are shown, but it would take hours to identify them by the common name
of the river, lake or stream because MDEQ didn't provide that.
Other states produce easily viewed maps graphically showing
impaired water features under Section 303(d) of the Clean Water Act,
but not Michigan -- the Great Lakes state.
In the 2006 report, MDEQ designated 3263 miles of rivers and
streams under Category 4c, which means the fish and biotic communities
are impaired because of so-called "management" through channelization
by drain commissioners. Allegedly, no pollutant is involved, even through
such "management" causes significant turbidity and siltation that destroys
aquatic habitat for fisheries and beneficial aquatic organisms. Michigan
has a rule against causing excessive turbidity and siltation in its narrative
water quality standards. Many southern Michigan rivers are choked with
turbidity from poor practices from agricultural and development sources.
But Michigan isn't showing this to be impaired water quality from a pollutant
for thousands of river and stream miles in Michigan which have these impairments.
Now, in year 2008, MDEQ proposes to designate over 6900 miles of
rivers and streams under Category 4c to be the playland for county drain commissioners to
create agriculture and development sewers out of Michigan's
streams and rivers---- more than a doubling from year 2006.
In year 2006, no other Great Lakes state had anywhere near as many
stream and river miles under category 4c as Michigan had, and now
Michigan DEQ in 2008 proposes to more than double these river and stream
Because MDEQ's water database people mixed the table displays
of categories 5, 4a, 4b and 4c together, it is impossible to easily
determine which streams and rivers
are the ones to be newly condemned to Category 4c and
non-accountability for fish and biotic damage by drain commissioners.
Even though development, agricultural and drain commissioner
activities cause pollution problems with turbidity and sediment,
the failure to designate such watercourses under Category 5
as impaired and needing a total maximum daily load plan means
that all of these entities, as well as industry and municipalities, escape
requirements for water quality based effluent limitations for
total suspended solids.
When MDEQ considers beneficial use impairments for
purposes of partial and total body contact recreation, Water
Bureau water quality planners have put blinders on when
addressing serious water quality problems/impairments from nutrients
in Saginaw Bay and Western Lake Erie.
In MDEQ's 2008 Draft report, the evaluation
process for beneficial use impairments as to partial and
total body contact recreation (i.e. wading and swimming)
is absolutely restricted to two and only two factors....whether
there is the presence of untreated combined sewer overflows/
untreated sewage and the results of e-coli monitoring.
MDEQ water quality planners sitting in Constitutional Hall contemplate
for citizens on the shores of Western Lake Erie and Saginaw Bay
and make no finding that there is no obvious water
quality impairment for partial and total body contact
recreation -- saying it is "Not Assessed".....when it is
quite apparent that such waters are tragically impaired.
They do look at hydrological subunit designated Saginaw Bay beach
areas, but mostly it is either "Not Assessed" or "Insufficient
Since they don't have comprehensive e-coli data on the
beach areas and don't have indications of raw sewage or
untreated CSO's, their decisionmaking calculus fails to
consider the mounds of algae washing up on the shores, and
thus allows an MDEQ finding that there is no water quality
impairment for partial or total body contact recreation in
Saginaw Bay and Michigan waters of Western Lake Erie.
Somehow, MDEQ water quality planner forgot to include
as a criteria for recreational water quality degradation the
aspect of an esthetic recreational experience of water quality....
.....that turbid waters with obnoxious odors and piles of
decaying algae constitute water quality impairments. Any
child visiting Saginaw Bay knows this, but MDEQ Water
Bureau somehow does not....and does not include such
consideration as water quality impairment findings for
Saginaw Bay for impairments affecting recreation.
MDEQ does acknowledge that a toxic algae, microcystist, is interfering
with public water supply intakes....introducing objectionable
tastes and odors from algae brought on by excessive
nutrients. But MDEQ then refuses to say that this
is a Category 5 water quality impairment, saying that
a 27 year old alleged water quality plan for Saginaw
Bay and Western Lake Erie prevents the
need for a total maximum daily load plan for nutrients
in the Saginaw Bay watershed. Thus, MDEQ sets the
stage for refusing to impose water quality based
effluent limitations on municipal, industrial and agricultural
sources of phosphorus pollution that area actually required
under the Clean Water Act.
What illegal bureaucratic nonsense!!
Alex J. Sagady & Associates http://www.sagady.com
Environmental Enforcement, Permit/Technical Review, Public Policy,
Expert Witness Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at: http://www.sagady.com/sagady.pdf
657 Spartan Avenue, East Lansing, MI 48823
(517) 332-6971; (517) 332-8987 (fax); firstname.lastname@example.org
ENVIRO-MICH: Internet List and Forum for Michigan Environmental
and Conservation Issues and Michigan-based Citizen Action. Archives at
Postings to: email@example.com For info, send email to
firstname.lastname@example.org with a one-line message body of "info enviro-mich"