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Re: E-M:/ wetland protection



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Enviro-Mich message from "Alexander J. Sagady" <ajs@sagady.com>
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Cut completely Michigan's "clean corporate citizen" program

Significantly reduce education and training
functions aimed at Michigan regulated parties, as 
these entities can employ consultants privately to 
achieve the same result, or otherwise increase 
the fees to cover all of the actual costs of these functions.

Enact fees sufficient to cover costs for issuance of 
air, water, wetlands and other permits like other states have done.

Granholm's idea that somehow it is better to cut
programs than increase fees shows very little understanding
of what it takes to get needed regulation and environmental 
control achieved.

Require better methods of fashioning facility compliance reports
in order to increase the effectiveness of MDEQ field 
enforcement staff.

Bring annual regulated party certification of compliance requirements to 
all environmental permitting programs.

On the issue of wetlands and drains, make the drain commissioners
comply with the clean water act.

If enviros let Granholm do this on wetlands, the next thing that might
be proposed is to remove all agriculture facility regulation from 
MDEQ.....no one in this camp wants that....(this is being done down 
in Ohio).


At 12:17 PM 02/03/2009, you wrote:
>In response to earlier questions, here is my understanding:
>
>* If in fact the proposal is to repeal the state wetlands law, local authority over wetlands via ordinance is at risk, unless that specific part of the statute is not repealed. Any local government with a current or proposed wetlands conservation ordinance should speak out.
>
>* Unless the federal Clean Water Restoration Act is passed, millions of acres of wetlands nationally are under uncertain regulatory authority, thanks to a maze of conflicting Bush-era court decisions and EPA guidance. That would affect what the Corps and EPA could protect in Michigan.
>
>* The Corps would have to double or triple its staff in Michigan to provide anything close to the program Michigan provides.
>
>* It is unclear how the proposal squares with Michigan's recently released ambitious Great Lakes strategy. You can't restore the Great Lakes by amputating wetlands.
>
>* It is likely that major losses of wetlands in Michigan will occur if repeal is in fact the proposal.
>
>
>
>
>----------
>Windows Live? Hotmail®:?more than just e-mail. <http://windowslive.com/explore?ocid=TXT_TAGLM_WL_t2_hm_justgotbetter_explore_012009>Check it out. 

==========================================
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 

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(517) 332-6971; ajs@sagady.com
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