Regarding the proposal to move Michigan’s wetland permitting and enforcement from the Michigan Department of Environmental Quality (DEQ) to the federal government’s Environmental Protection Agency (EPA) and Corps of Engineers (COE):
Representative Tom Pearce in the March 5, 2009 Rockford Squire stated, “This is an issue that needs to be decided on facts, not emotion.” I agree with that comment, however the “facts” do not support this move.
In February, I provided Governor Granholm, Representative Pearce and Senators Jansen and Hardiman and several other key representatives comments on the proposal and referred them to two federal documents published in late 2008. Those documents are titled Stagnant Waters: The Legacy of the Bush Administration on the Clean Water Act and Decline of Clean Water Act Enforcement Program. Both of these reports conclude the EPA/COE are not doing an adequate job of protecting our nation’s wetlands in their permitting and enforcement process and have insufficient resources to pursue Clean Water Act investigations and enforcement actions.
Most permits are issued by DEQ in less than 90 days. The average permit is issued in 60 days. It is my understanding permits issued by the EPA/COE takes 600 to 700 days with many exceeding that. And, federal law does not protect 930,000 acres of small wetlands presently protected by state law and local ordinances.
I also referenced them to a paper from Grand Valley State University titled Integrated Valuation of Ecosystems Services Tool. The report details the economics of some land uses in a seven-county west Michigan area including Kent County. The report examines the value generated on a per acre basis for the benefits derived from wetlands including recreation, fish and wildlife habitat, nutrient recycling, waste assimilation, erosion control and water supply. The total value for the 58,579 acres of wetlands in the seven-county study area is estimated to be $81,483,097. All of Michiganís wetlands are obviously worth hundreds of millions when all of Michigan’s 83 counties are included.
Following his comments to the Squire on March 5, Representative Pearce on March 10, 2009 introduced HB 4542 for the purpose of turning administration and enforcement of Michigan’s wetland laws back to the federal government. It would appear he already had all the facts of his choosing for a decision.
The conclusion I come to is the EPA/COE are not capable at the present time of protecting Michigan’s valuable wetlands as adequately and in as timely a manner as the DEQ does. It would seem the current $2.1 million dollar cost to administer the Michigan Wetlands Program is a good investment protecting an annual income to Michigan of many millions of dollars.
It would also seem returning wetland regulation to the federal government is not in keeping with President Obama’s commitment to maintain and protect our natural resources and Michigan’s historic commitment to protect our own natural resources without interference from the federal government.
I suggest readers contact Representative Pearce and Senator Jansen or Hardiman’s (or your Representative or Senators) office and ask them to keep administration and enforcement of Michigan’s wetland laws under DEQ. The DEQ should also be adequately funded for those duties that provide significant income to Michigan.
E. John TrimbergeR