Say "No" To Giving Coal-Ash Dumping Ship "Landmark" Protection

                                            And aren't landmarks on land?

I am happy to circulate these groups' timely opposition to an outrageous end run of federal regulations and common sense Lake Michigan health management.

(Some additional history, here)

Alliance for the Great Lakes---Clean Water Action (Michigan)---Clean Wisconsin---Freshwater Future-----Midwest Environmental Advocates---Natural Resource Defense Council---National Wildlife Federation---RENEW Wisconsin---River Alliance of Wisconsin--Sierra Club (John Muir Chapter)---Sixteenth Street Community Health Center (Milwaukee)—Town and Country Resource Conservation and Development----Waukesha County Environmental Action League---Wisconsin Wildlife Federation

November 7, 2011

Mr. Ronald James, Chair
Landmarks Committee
National Park Service Advisory Board

Dear Chairman James:

The Landmarks Committee of the National Park Service Advisory Board will be reviewing a nomination listed under the State of Michigan to designate the S.S. Badger car ferry from Ludington, Michigan as a National Historic Landmark.

The undersigned organizations have just become aware of this nomination and are requesting that the decision on recommending this nomination be tabled at this time.

The S.S. Badger on a daily basis of its normal operation on from Ludington, Michigan to Manitowoc, Wisconsin discharges 3.8 tons of fly ash into Lake Michigan. This fly ash has concentrated levels of mercury, lead and arsenic. On an annual basis, the cumulative amount of fly ash deposited into Lake Michigan is over 570 tons a year.

The Federal Clean Water Act Vessel Discharge Permit issued by the U.S. Environmental
Protection Agency requires the S.S. Badger to convert its operations in a manner to cease discharging into Lake Michigan by December 11, 2012. Designation of the S.S. Badger as a National Historic Landmark is likely to make it very difficult for the S.S. Badger to alter its operation and comply with the Clean Water Act. This will result in the long-term discharge of heavy metals such as mercury, lead and arsenic into waters of the United States.

The undersigned organizations do not believe the National Park Service, through its
National Historic Landmark designation process, should prevent the S.S. Badger from
complying with the nation’s water pollution abatement laws. We respectfully request that
the S.S. Badger designation nomination be tabled until such time as the National Park
Service has an opportunity to consult with the EPA and the U.S. Fish and Wildlife
Service.

Thank you for your consideration of this request.

Sincerely yours,