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Letter to EPA: Detroit River RAP



October 13, 1998

Ms. Jo Lynn Traub, Director
Water Division, Region 5
US EPA

Mr. David Hamilton, Chief
Surface Water Quality Division
MDEQ

Dear Ms. Traub and Mr. Hamilton,

This letter is to raise our concerns about the Detroit River Remedial Action
Planning process and the "Volunteer Sign-Up Form to Join an Ad-Hoc Group" to
"select an implementation structure to implement the recommendations of the
Detroit River RAP".

As you are well aware, the response was very meager compared to the 1000
invitations sent to various members of the public and stakeholders
soliciting their attendance to one of two informational meetings about the
Detroit River RAP.  And, in spite of the low attendance of the informational
meetings, a follow-up "Stakeholders Workshop" was held on October 6th to
ensure the 1000 invited "stakeholders" would have an opportunity to provide
input on "....shaping the future of the [RAP] process."  

The fact that a relatively small group of people who represented various
interests in the Detroit River's remediation attended the Stakeholders
Workshop is not surprising.  This level of public interest, however,
deserves a serious evaluation.

Since 1986, which marked the very beginning of this government-led process,
the public has been fundamentally left out of the picture. For 10 years,
public meetings were usually held four times a year (sometimes less) but the
public was seldom notified of the meetings or encouraged to attend. And, if
they attended, they were only allowed to speak during designated times
(usually 5 minutes at the beginning of the meeting).  The public's input
into this government-led process was treated as a hindrance rather than a
value-added component to the RAP process. When members of the public
voluntarily submitted sections to incorporate into the RAP document, their
work was frequently rejected without explanation. Over time, the expected
role of the public was to simply review and accept (rubber stamp) the
reports that were written primarily by MDEQ.   Meanwhile, the MDEQ funded
irrelevant public involvement efforts, such as the 1994 Day at the River,
which cost over $22,000 and drew less than 50 people to an all-day  event
held at Hart Plaza in downtown Detroit. Such events are designed to control
both the message and the process.

To conclude that the public is simply not interested in the Detroit River or
efforts to improve its environmental quality is tempting but short-sighted.
Do not be mistaken: the public is extremely interested and some very recent
events have clearly demonstrated that.  On Sept 15th over 1000 members of
the Detroit River community attended a public hearing to oppose the
development of the last remaining natural wetland (Humbug Marsh) on the
Michigan side of the Detroit River.  On Sept.19th over 180 people attended a
State of the Detroit River Cruise. On July 7, more than 70 people
participated in the Great Lakes Water Quality Agreement Hearings held at the
Lenox Center in Detroit. On March 3rd, over 200 people attended a conference
on Detroit River habitat.

So, it is not that the public is not interested in the Detroit River.  They
are. What they are not interested in, however, is hearing more half-truths
and trivializations about the environmental problems of the Detroit River
and excuses for making any changes.  A case in point occurred during the RAP
informational meeting held on September 30th in Wyandotte. It was at this
meeting Mr. Robert Sweet, MDEQ's top representative, told the audience that
monitoring on the Detroit River stopped two years ago (1996) because MDEQ
was not detecting any pollutants in the tributaries discharging into the
Detroit River, so there was no reason to monitor the river.  The truth is
that monitoring of the Rouge River, the only tributary  to the Detroit River
that MDEQ monitored, ceased in 1994 and the detection levels used by  MDEQ
were so high that the pollutants found routinely in the river were not
detected. In addition, Mr. Sweet's statement suggests that pollutants to the
Detroit River only come from tributaries, totally ignoring the 30 municipal
and industrial facilities that discharge pollutants directly to the Detroit
River.  Mr. Sweet was corrected by two members of the public who knew the
real story.  

Clearly, there is a critical need to move the Detroit River Remedial Action
Plan from words written on pieces of paper to real, meaningful activities
that will comprehensively and systematically bring the river closer to a
healthy ecosystem.  To accomplish this goal, the emphasis can no longer be
placed on controlling the message and the process.  This approach has been
tried for last 10 years and it has failed. 

Implementing a RAP that will bring measurable environmental  improvement to
the Detroit River in a reasonable timeframe requires a  genuine, wholesale
change in both the message about the problems that need to be faced and the
process underwhich this RAP will be implemented. When we recommended in the
Citizens Guide to the Detroit River RAP (1997) that the U.S. EPA take over
the responsibility of implementing the RAP because the MDEQ failed to
fulfill their responsibility to do this work, we envisioned a different
approach.  Instead, we, as apparently many others from the broader public
sector,  see the same approach being made, the same individuals vying for
control and the same document being presented to implement. 

Because we feel very strongly about the need to move forward on improving
the environmental quality of the Detroit River by implementing a meaningful
RAP, we are more than willing to meet with you in person to discuss the
changes we feel necessary to ensure this happens. Your careful consideration
of this request is most appreciated.

Sincerely,
Mary Ginnebaugh, Downriver Citizens for a Safe Environment
Pegg Roberts, Citizens Environment Alliance of Southeast Michigan
Rick Coronado, Citizens Environment Alliance of Southwestern Ontario		
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