August 28, 2015
Director Jon Allan
Office of the Great Lakes, DEQ
P.O. Box 30473-7973
Lansing, Michigan 48909
RE: Sustaining Michigan’s Water Heritage Draft for Public Review; WMEAC Comments
The Office of the Great Lakes and collaborating state partners at the DEQ, DNR, MDARD, and the MEDC are to be commended for this comprehensive draft. The Strategy is thoroughly researched, organized and well written. It reflects many perspectives, citizen and expert input, and was built upon a facilitated Community Water Dialogue. The breadth and scope of the issues covered are matched with 62 specific policy recommendations, and an early attempt has been made to identify lead actors and clear metrics.
WMEAC appreciates the strategy’s “ecosystems approach” and recognizes that the core values of our relationship with water — economic, environmental, social and cultural — are equally important. This means that in both times of economic growth and contraction we most hold up the environment as a foundationally important value. It means that sometimes citizen access might have to be curtailed to allow for the restoration of ecosystems. It means that sometimes brownfields will have to be ‘clean enough’ to clear the way for appropriate new developments. It also means that some areas should never by developed; ever. It means that we can’t cut environmental corners to create economic activity. It means that government, private and NGO environmental efforts will have to be expanded, not curtailed, to meet the ambitious recommendations herein. It means that Michiganders will have to pay more in taxes and fees to protect our natural resources, and it means that Michigan’s leaders, public and private, will have to stand up and unabashedly embrace new sources of funding as an investment in Michigan’s future.
Our water resources have to be protected, maintained, restored and Michigan people and businesses are going to have to pay more to accomplish that. There’s just no way around that basic fact. The Strategy’s Community Water Dialogue participants agreed citing “funding and participation” as the most common barriers to success. If we are serious about pursuing this Strategy, and if we are to have success in meeting some of the ambitious objectives and recommendations it outlines, this basic fact has to be embraced, owned, and recognized up front. It has to be communicated clearly, loudly, and without apology.
WMEAC supports the vast majority of the recommendations in this document. It would probably be easier to pick out those that we do not find terribly compelling than to list those we support. Therefore, neither list would be all that useful. What might helpful to identify are those recommendations that WMEAC is not only particularly supportive of, but those that we are ready and willing to invest resources into now, and into the future.
Strategy recommendations that WMEAC is excited to join local, regional, and statewide collaborations to see executed:
- Develop and implement a uniform statewide sanitary code, establish a long-term, sustainable funding source and inspection requirements for onsite wastewater.
- Establish a long-term Water Fund to achieve Water Strategy goals including water infrastructure m
- Promote green infrastructure, low impact development and green spaces to rebuild hydrologic integrity and address storm water.
- Evaluate and implement necessary changes to laws including state and local land-use statutes as well as the drain code to create a more integrated, watershed based system for managing water at the landscape level and achieving water quantity and quality outcomes.
- Water efficiency targets for all major water dependent sectors. Develop a water conservation and reuse strate
- Support groundwater and surface water monitoring.
- Integrate water literacy into state of Michigan curriculum standards.
- Develop and implement a water trails system.
*Attached you will find a memo identifying specific overlap between the City of Grand Rapids’ Downtown Development Plan GR Forward Grand River Restoration and the Draft Water Strategy. This is just one example of a local initiative WMEAC is engaged in that can be used as a vehicle to move forward priorities from the draft Strategy.
Draft Implementation Metrics
The implementation metrics represent a very interesting column in Table 2 Water Strategy Implementation Plan. In general the metrics are very good. They are clear and specific. However, many of them are associated with an implementation date that at times is aggressive, and that at other times seems to be more of a placeholder than a real timeline metric. For example, many of the metrics seem to have somewhat arbitrarily identified 2020 as their date for completion.
Many of the date metrics also post-date the Snyder Administration. Therefore, it is only useful to include such a timeline if a Strategy Implementation Process is established to survive the Snyder Administration. This is certainly possible, but a robust value-add process must be outlined in the strategy (more on this later) describing how this will be accomplished. The strategy certainly acknowledges this fact in Chapter 8, and it makes a recommendation for the creation of an interdepartmental implementation team. Perhaps this should not be a recommendation, and instead should be issued as a statement, and paired with an outline of the process. The “recommendation” status leaves Strategy readers unsure of whether or not such an initiative will occur, and calls into question the State’s internal buy-in and overall commitment to the strategy.
Laudably, Table 2 Implementation plan attempts to identify Lead Actors responsible for moving recommendations forward. This is an important component of any implementation plan, and one WMEAC would love to see included in the final document. More, this feature would be even more useful if the identified Lead Actor has been contacted, briefed, and has committed to their role as such. For example, the Legislature has been identified as the Lead Actor for the recommendation “Develop and implement a uniform statewide sanitary code that is flexible and provides standards for site suitability based on risk.” What is the appetite for legislative leadership to implement such an initiative? Indeed, if the Senate Majority Leader and Speaker of the House were willing to include this in their legislative platform, then identifying them as Lead Actor would be entirely appropriate. On the flip side if they have little knowledge of or interest in this priority, then it does the document a disservice to identify them as lead.
Careful thought should be given about how best to communicate in the Strategy likelihood of the Lead Actor actually owning responsibility for leading implementation of the recommendation for which they have been identified.
For many of the recommendations the Lead Actor is critically important. Community Water Dialogue participants reinforced this notion. They indicated their willingness to participate in many of the strategies initiatives, but they were very hesitant to lead. Therefore, a formal process for identifying, recruiting, and tagging Lead Actors might need to be established so that the final version of the Strategy will include a Lead Actor that has been briefed on the issue and that has some level of buy-in as a leader.
Strategy Implementation Process
Chapter 8 Page 54 expresses one of the most important ideas in the entire strategy. WMEAC agrees with the authors that this concept is fundamental to making the Strategy successful.
“In order to ensure the Water Strategy is durable over time and across administrations, the elements of the Strategy need to be fully integrated into decision processes, governance structures, and the culture of state and local governments, other organizations, and individuals.”
“If the critical elements of this Strategy are not adopted and deeply engrained into ongoing decision-making processes, then little will come of them over time.”
We are happy the authors recognize the challenge before them, and offer our support in any way we can be helpful. Perhaps there are a few ways, in addition to brute bureaucratic force, to make the Strategy durable over time. The first has already been identified as a recommendation: to unite agencies to ensure a cohesive common
- Create an Interdepartmental Water Team to unite agencies to ensure a cohesive common
strategy around implementation of the Water Strategy. The team will establish a process for stakeholder collaboration, criteria for setting implementation priorities, identifying cross agency joint projects, and an approach to assess and evaluate progress achieved against the metrics and outcomes.
The team should be formally established, well-organized, resourced, and directly connected to cabinet level decision makers and the Executive Office. As mentioned earlier, moving this from a Strategy recommendation to a confirmed fact – one that is announced with the finalized version of the Strategy would be highly valuable in building external confidence that State is committed to the Strategy.
- The Governor has to invest political capital in the Strategy. WMEAC understands that every important issue can’t be a priority for the Governor, but we also believe that for the Strategy to be effective the Governor will need to demonstrate privately and publicly that key pieces of the Strategy are very important to him. Public support from the Governor and top representatives will send signals across Michigan that the Strategy will be valued, resourced, and utilized. A high level of commitment will inspire reciprocity and commitment from external partners, funders, and the general public.
- The Strategy should produce new and signature initiatives.
One or several big, signature initiatives will inspire and motivate people to get behind the Strategy. A great example is recommendation 5 on page 65: “Fund a pilot project, through a competitive bid process, for the initiation and evaluation of a new model for wastewater management.” A host of recommendations from the Strategy would fit this bill: An aggressive push on statewide septics policy, the creation of a statewide water infrastructure fund and new revenue stream, etc…
In addition to a signature initiative, the creation of new programs, policies, and initiatives will breathe life into the Strategy. While existing DEQ, DNR, MEDC, and MDARD activities are certainly part and parcel to the Strategy, recounting, reorganizing, and rehashing a litany of existing DEQ/DNR activities will not inspire citizen, stakeholder and partner momentum.
- Don’t be shy about new funding, fees, and taxes
Strategy Community Water Dialogue participants identified funding as one of the top potential barriers to success. The majority of participants named external funding (state, federal, grants, foundations, etc.) as a potential source, but many participants also identified local sources, user fees, and even additional taxes. Dialogue participants were vocal and transparent about the need for new water funding. Strategy communicators and State representatives working with the Strategy should follow their lead. Strategy messaging should not be coy or defensive about the need for new funding. It is a fact that many in the Legislature are incredibly reluctant to create new revenue streams at the State or Local level. Many citizens are also reluctant, but the best way to confront that challenge is to be clear, open, and honest about the need.
Maintaining, expanding, and building new water infrastructure will be expensive. Protecting our incredible, world-class, fresh water resources will require serious expenditures; but Michigan is worth it, and we should be proud of it investing in its protection.
WMEAC Policy Director
From: Nicholas Occhipinti, West Michigan Environmental Action Council
To: Ann Armstrong Cusack, Office of Urban Initiatives
RE: Grand River Restoration Water Quality Recommendations; Opportunities for Integration with State of Michigan (Draft) Water Strategy
Background: Grand Rapids is currently undergoing a major planning initiative and visioning process (GR Forward) that will steer development of the downtown and Grand River corridor for the next decade and beyond. At the center of that process is the restoration of the Grand River. Citizen access, water quality, recreation, and downtown economic development improvements are central goals of this initiative.
The GR Forward River Restoration plan shares strategic and tactical approaches with the State of Michigan water strategy. Harnessed effectively, the projects will feed off and support each other. More, Grand River Restoration is ripe with specific project, policy, and programming opportunities that will fulfill recommendations and metrics detailed in the Governor’s Draft Water Strategy.
Many of the proposed issues are big, complicated, and difficult multi-year issues. That is precisely why it is so important to pursue them at a moment like this – when a unique opportunity has aligned many stakeholders behind two big visions. Grand River Recommendations (in no particular order):
|River Restoration Recommendation||Governor’s Water Strategy Recommendation|
|Improve septic programs and policies in the Grand River watershed area. Work with the Snyder Administration on a statewide septic code and with local health departments to adopt operational inspections and maintenance requirements in their septic regulations.||Develop and implement a uniform statewide
sanitary code that is flexible and provides standards for site suitability based on risk. Establish a long-term, sustainable funding source to support onsite wastewater programs at the state and local levels and to assist financially distressed owners of private on-site wastewater systems with repair and replacement costs. (P. 23)
|Address high impact point-source water quality infrastructure opportunities in the Grand River watershed area.||Establish sustainable funding mechanisms
to achieve the Water Strategy goals
including water infrastructure management. (P. 67)
|Maximize implementation of green infrastructure and low-impact development (LID) within the River Restoration Project Corridor area by encouraging local policies and incentives that favor LID.||Utilize pricing and funding strategies to support infrastructure improvements while allowing for water conservation.
By 2020, increase the number of communities that have pricing and funding strategies as part of their asset management plans to support infrastructure
Improvements (p. 44)
|The notion of improving the quality of the water in the Grand River should be imbedded in the messaging, branding and funding initiatives of the river restoration effort.||Implement a communication strategy
focused on messages that link the
relationship between investments in water
infrastructure and clean water and the
benefits infrastructure provides for drinking
water, recreation, and cultural and economic
opportunity. (P 66)
|Implement projects identified by the City of Grand Rapids Green Infrastructure Opportunity Assessment. Inspire a similar assessment and implementation process for managing stormwater runoff in upstream communities.||Provide technical and financial support to
communities to plan and implement green
infrastructure techniques and low-impact
development while preserving natural
spaces in the design of new developments,
redevelopments and road projects to ensure
storm water management and improve
hydrology. (P. 60)
Rec 17 Use existing authority to work with local
units of government with storm water
discharge or storm water-related hydrologic
impairments in their waterways to establish
Phase II storm water plans for impaired
water bodies. (P. 60)
|Address livestock and cropland pathogen pollutants in the Direct Drainage Subwatershed management unit of the Lower Grand River Watershed and in the Urban Waters Federal Partnership area. Plant buffer and filter strips along priority acreage adjacent to and encompassing the Direct Drainage Subwatershed and Urban Waters Partnership area.||Eliminate impairments in priority
watersheds that have degraded water
quality and/or aquatic ecosystems due to
nutrient runoff and soil erosion. Engage landowners through a collaborative and
adaptive community-based natural resource
management process to identify local
actions to change behaviors and solution to
achieve those outcomes. (PP. 60-61)
The chart serves as a side-by-side comparison of similarity in tactical and strategic approaches in the two plans. It is not a comprehensive list, but it does suggest the type and quality of synergies present. This list focuses on recommendations coming out of the water quality sub-group – additional water/river related synergies with the State Strategy can be found in the GR Forward Plan outside of the list focusing on the water itself. For example, dam removal, flood wall and riparian edge design, public access and recreational opportunities typify these other synergies
As with any visioning plan, each recommendation presented herein is at different stage of its conceptualization and implementation. Some have active government, private, and non-profit staff and resources behind them. Whereas others are new and exist mostly in the conceptual realm of literature and best practice. Finally, some of the recommendations have been previously forwarded through one initiative or another, but have hit significant political, economic, or social barriers.
A more sophisticated and formal analysis could be established to find the specific (existing and potential) ways in which synergy can be created between the two visions. Ideally, this could occur through a cooperative, formal, and resourced process in partnership with State of Michigan staff and River Restoration stakeholders. It is clear that several of the recommendations above will require this type of investment, coordination, and cooperation to move forward.