DEPARTMENT OF ENVIRONMENTAL QUALITY

L.'\NSING

JENNIFER M GRANHOLM
(;;'OVEI1NOn

Dill
STEVE:N E. Ct-lESTER
,)IPECTOP

t/317/j/

July 10. 2006

Mr. Kevin Montgomery Commandant (G-PSR-1) United States Coast Guard Room 1400 2100 2nd Street SW Washington DC 20593 Dear Mr. Montgomery: We are in receipt of Mr. Anthony Homan's letter of April 24, 2006, to Mr. Ken DeBeaussaert, Director, Michigan's Office of the Great Lakes, regarding the development of regulations goveming the discharge of dry bulk cargo residue into the Great Lakes. The Office of the Great Lakes has referred your letter to the Department of Environmental Quality (DEO), Water Bureau, for response. The Federal Register requested public comments on this matter by July 31, 2006. The DEO was not aware of the historical practice of discharging dry cargo residuellitter into the Great Lakes from bulk-carrier vessels. Such discharges appear to be in violation of Michigan's Natural Resources and Environmental Protection Act. 1994 PA 451, as amended (NREPA), and not consistent with the provisions of the feaeral Clean Water Act. The discharge of litter from water craft or commercial vessels is prohibited under Part 95, Watercraft Pollution Control, of the NREPA. The Act defines litter in part, as waste material, debris. or other foreign substance of every kind and description. The DEQ also has some additional questions: Where are the United States Coast Guard (USCG) approved debris disposal areas in the Great Lakes? Do the other Great Lakes states have environmental protection laws similar to Michigan that may prohibit the discharge of cargo residue into the Great Lakes? What is the estimated number of vessels conducting the subject disposal
method?
If there are existing laws in place that prohibit such discharges, is an
Environmental Impact Statement necessary?

CONSTITUTION HALL' 525 WEST ALLEGAN STREET' PO BOX 302n. LANSING. MICHIGAN 489097773

www.m.en'gan gov' (517)

241 1300

Mr. Kevin Montgomery Page 2 July 10,2006

We suggest the USCG initiate a stake holders collaboration on the vessel discharges in question and include regulatory agencies from all the Great Lake states. The workgroup would provide input to assist the USCG in making a detennination on the appropriate action to take in regulating the debris that is currently being discharged into the Great Lakes from dry cargo vessels. Thank you for bringing the above issue to our attention and the opportunity to comment. Should you require further infonnation, please contact Mr. William Creal, Chief, Permits, Section, Water Bureau, at 517-335-4114, or you may contact me.

Richard A. Powers, Chief Water Bureau 517-335-4176 cc: Mr. Ken DeBeaussaert, Director, Office of the Great Lakes Mr. Stanley F. Pruss, Deputy Director, DEQ Mr. William Creal, DEQ