The LaMP is available for review at the EPA web site.

There is a public comment period available for this portion of the LaMP.  Detailed below are some talking points that NWF has come up with.  Please take a moment to scan through these and write a letter to the governments reflecting your concerns and/or the concerns listed below.
 

• U.S. Public and agency comments are being accepted by Janet Pellegrini at U.S. EPA (WU-16J) 77 W. Jackson Blvd., Chicago, IL 60604-3590 , or via email until January 10, 2000.

• Canadian Public and agency comments are being accepted by Darrell Piekarz at Environment Canada, 4905 Dufferin Street, Toronto, Ontario, M3H 5T4, or via email until January 10, 2000.

• Please send a copy of your comments to Tony DeFalco at National Wildlife Federation, 506 E. Liberty Street, Ann Arbor, MI 48105, or via e-mail.

Talking points for Stage 3 (Chemicals Portion)
Lake Superior Lakewide Management Plan
 

• Scatter-gun approach to reductions.  Rather than looking at each source and determining what needs to be done in order for that source to eliminate toxic discharges and emissions, the document is simply a list of everything that could be done and might help.

• Missing information.  The estimates for dioxin emissions cover such a wide range that they are essentially meaningless.  We still don't know where HCB and OCS come from.  Although burn barrels are thought to be a significant source, no one knows how significant.  There needs to be an aggressive monitoring plan for sources to fill in the blanks.  Reaching zero discharge is impossible if sources are unknown or unmonitored.  Also, the section on monitoring is disappointing.  Although it names all of the monitoring that could be done, it commits the governments to nothing.

• Reliance on voluntary agreements.  It is unrealistic to believe we will reach zero discharge wholly through voluntary agreements.  While such agreements can result in significant reductions at specific facilities, it will be very unusual for them to result in zero discharge or emissions.

• Ask existing sources for a zero discharge plan.  The governments should ask all known sources how they plan to reach zero discharge by 2020. The request could also include a question about what help they will need from the governments to meet the goals and what the barriers are.

• The goal is Zero Discharge.  The governments and sources need to begin planning now to get to zero by 2020.  The LaMP talks about "reductions" rather than elimination.  If companies are encouraged to put money into technology that will reduce but will not eliminate discharges and emissions now, they may be less willing to make additional changes necessary for zero discharge later.  Governments and sources need to think about the ultimate goal when they make decisions about permitting and capital expenditures.

• Good news.  Let Minnesota and the EPA know that by planning to help industry develop mercury control technology they will move the plan towards eliminating U.S. mercury emissions from the source with the single largest increase from 1990 to 1999 (coal combustion - 60% increase).  By developing such technology and encouraging renewable energy production, Lake Superior will have fewer mercury emissions.

• Wisconsin is AWOL.  Wisconsin makes no commitments on PCB phaseouts, solid waste management, product stewardship, purchasing policies, demolition, electric production, and more.

• Murphy Oil.  Wisconsin also is completely silent on Murphy Oil.  There are some figures on mercury emissions, but they may be based only on refining, and not on burning #6 oil.  There may also be dioxin, HCB and OCS emissions from refining.  These should be investigated and a plan developed for elimination by the respective deadlines.

• Ontario-lite.  Ontario seems to have the belief that nothing should be asked of Lake Superior industries that is not asked of all industries in Ontario. This is supposed to be a demonstration area--we are supposed to be leading the way, not waiting until stricter regulations are passed that affect the whole continent.

• No new or increased discharges.  It's crazy to allow new sources of toxic substances to start up when you're planning to eliminate those substances within twenty years.  At the very least, before a source is given a permit for new or increased discharges or emissions, they should be required to submit a plan detailing how they will eliminate PBTs from their discharges and emissions by 2020.