Sunday, May 5, 2013

WI Wildlife Federation Condemns DNR Plan To Trim, End Basic Project Reviews

George Meyer, formerly a career DNR employee and Secretary of the agency under Gov. Tommy Thompson, has submitted comments to the DNR, on behalf of the Wisconsin Wildlife Federation that argue against the DNR's sweeping plan to whittle down basic environmental impact and other project reviews now called for by Wisconsin law known as NR 150.

Wrote Meyer:

"The Federation is greatly concerned about the proposed changes to NR 150 because of the reduced analysis of projects that have the potential to cause significant harm to the state’s valuable natural resources and just as importantly, we are concerned about the many changes in the proposed NR 150 that reduce transparency on proposed projects and the opportunity for input into decisions by our members. Unfortunately, the Federation sees this as a dangerous trend in the actions of the Department and the Wisconsin Legislature."
The comment period, first noted here, ended last Friday.

I would echo Meyer's observation that the DNR plan reflects "a dangerous trend in the actions of the Department and the Wisconsin Legislature:

Here is the Wisconsin Wildlife Federation statement in its entirety:

                                     Wisconsin Wildlife Federation
Jeff Schimpff, DNR                                                                       ETEA/7
PO Box 7921
 Madison WI 53707
Dear Mr. Schimpff:

The Wisconsin Wildlife Federation is comprised of 184 hunting, fishing, trapping and forestry-related organizations in the state with a combined membership of over 100,000 individuals.
The Federation is dedicated to conservation education and the advancement of sound conservation policies. We are particularly interested in the sound management of habitat for fish and wildlife species. The Environmental Impact and Analysis process of NR 150 is clearly integral to the long-term conservation of fish and wildlife habitat in the state.

The Federation is greatly concerned about the proposed changes to NR 150 because of the reduced analysis of projects that have the potential to cause significant harm to the state’s valuable natural resources and just as importantly, we are concerned about the many changes in the proposed NR 150 that reduce transparency on proposed projects and the opportunity for input into decisions by our members. Unfortunately, the Federation sees this as a dangerous trend in the actions of the Department and the Wisconsin Legislature.

More specifically, the Federation strongly objects to (1) the elimination of environmental assessments of Type 2 actions and (2) the misguided notion that individual permitting statutes are in fact “equivalent analyses” of the full environmental impacts of many individual projects.

Many base regulatory statutes are media specific and do not take into consideration other environmental impacts of individual projects. In the sake of brevity the Federation is not listing all of the current Type 2 actions that will now pass under the public radar screen while still having significant adverse impact on the quality of the human environment.

The purpose of section 1.11, Wisconsin Statutes, is for the agency to disclose all environmental impacts of a project regardless if it has regulatory authority to deal with the environmental issue.

This allows policy makers to gauge whether new regulations are appropriate to deal with any significant unregulated adverse impacts of a project or, in other cases, to provide other agencies or units of government the information that they will need to use their regulatory powers to protect the public from environmental harm.
The proposed rules inappropriately narrow the scope and value of the Wisconsin Environmental Policy Act. While we appreciate the DNR’s stated intent to reduce its workload, that is not a valid and legal reason for the agency to thwart the specific wording and intent of section 1.11, Wisconsin Statutes.

We respectfully request that the agency revise the proposed regulations to once again require that environmental assessments be completed for all Type 2 actions. If the agency no longer feels that any particular Type 2 action should not be so assessed, they should make that case and propose to delete that action or actions from the list.

Respectfully submitted by George Meyer, Executive Director, Wisconsin Wildlife Federation on May 4, 2013

2 comments:

Anonymous said...

George Meyer and his group of radical environmentalists are being removed from the process because they have become a nuisance rather than a credible source of useful input. Their knee jerk liberal opposition to the mining bill with no basis identifies them and other such groups as being nothing more than another wacko environmentalism group. Thankfully, he no longer heads the DNR.

These groups have turned public hearings into circus acts of protesting and drum pounding. Good riddance to them and perhaps they can be considered to be included once they learn to behave themselves.

Anonymous said...

" Their knee jerk liberal opposition to the mining bill"

Back when conservatives had somethign approaching intellectual rigor on their side, Thomas Sowell used to challenge people to "specify, do not characterize."

The mining bill not only prevents meaningful analysis of mining permit applications before the start of work, it prevents the DNR from halting a mine's operation when (not if, when) pollution begins, and relieves the mine owners from liability for the resulting pollution.

The GOP is literally poisoning wells around Wisconsin. Thanks to the DNR's inability to supervise megafarms, there are now portions of rural Wisconsin where it is unwise to let a child drink tap water. And these changes will make things even worse.