RIP RCRA
Lone Tree Council will be submitting comments on the major modification of Dow’s RCRA license as it is incorporated into the Administrative Order on Consent signed by EPA, MDNRE and Dow.
Dow’s RCRA license is being melded into the AOC as EPA takes over the lead on this cleanup. Make no mistake; MDEQ never had the political support to take on the recalcitrant chemical giant in Midland MI. It remains Lone Tree’s hope that many of Dow’s RCRA obligations will be met by work done under the AOC. No bets though.
That public comments are futile is an understatement. We commented on the Consent Order in 2002, RCRA 2003, Framework 2005, Public participation 2005, AOC 2010 and not one damn thing changed as result. Public comment periods are obligatory and perfunctory. Agencies go through the motion knowing damn well the deals, plans, changes, alterations, amendments were divined behind closed doors— far from public view. Political sausage making. This site was no different.
RCRA is regulatory program that by law is open and transparent and contemplated cleanup. REST IN PEACE.
MDNRE notice is herec.
Tags: accountability, aoc, cleanup, contamination, Delay, Dow, EPA, fraud, Health, Lone Tree, MDEQ, politics, pollution, RCRA, risk, scandal, toxic
Eye on the EPA, Press Release | mhr March 28, 2010