GLIN==> To TMDL, or not to TMDL -- That is the question

["Alex J. Sagady & Associates" <ajs@sagady.com>]

Bay City Times examines Michigan DEQ's failure to list the
Saginaw Bay watershed as being impaired for pollution 
by nutrients and failure to require total maximum daily loads
and water quality based effluent limitations required
by the Clean Water Act to control phosphorus.   Front page article....

http://blog.mlive.com/bctimes/2008/02/saginaw_bay_doesnt_have_an_algae_problem_deq_says.html

Note, there are other issues raised by MDEQ's latest
draft listing under Section 303d of the Clean Water Act:

1.  Dioxin contamination in parts of the Kalamazoo River Watershed

2.   Michigan DEQ newly listing about 3800 new river and stream 
miles as being presumed as impaired because of drain commissioner
activities where there will be no pollution-based water quality planning.

3.  Failure to have a placeholder in the evaluation process for all
violations of narrative water quality standards.

4.   Failure to consider that excessive turbidity, odors, nuisance algae and other narrative 
water quality standard violations cause impairment to total and partial 
body contact recreation and impairment of water-based recreational esthetics, 
including failure to enforce Michigan narrative water quality standards for 
turbidity.

5.  Failure to adopt numerical water quality standards for nutrients, like 
phosphorus and nitrates, recommended by US EPA for the distinct 
eco-regions in Michigan.

6.   Failure to impose water quality based effluent limitation in Michigan's
general permit system for concentrated animal feeding operations, stormwater, etc.

====

See

http://www.michigan.gov/deq/0,1607,7-135-3313-184170--,00.html

for the draft public notices.....DEADLINE IS FEBRUARY 25 FOR COMMENT....

The Michigan Department of Environmental Quality is accepting written comments until Feb. 25 on a draft Water Quality and Pollution Control in Michigan, 2008 Sections 303(d), 305(b), and 314 Integrated Report. 

The report, issued every two years, describes the status of water quality in Michigan and includes a list of water bodies that are not attaining Michigan Water Quality Standards and require the establishment of pollutant Total Maximum Daily Loads. 

Comments may be submitted to Sarah LeSage, Michigan Department of Environmental Quality, Water Bureau, 525 West Allegan Street, P.O. Box 30273, Lansing, MI 48909-7773.

Comments also can be sent by e-mail to <mailto:lesages@michigan.gov>lesages@michigan.gov 


==========================================
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); ajs@sagady.com
==========================================  

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