Michelle Hurd Riddick, 09/26/07,
Letter to the editor, Midland Daily News
Comparison invalid
To the editor:
Regarding the Daily News' editorial "EPA should finish the work." Your apples
and oranges comparisons do little to educate your readers to anything but your
lack of understanding of Dow's corrective action requirements. I agree it is
long past due for the dioxin reassessment to go public, yet I fail to understand
what that has to do with EPA walking away from a process that is not
transparent. Suggesting EPA is walking away like a spoiled child while ignoring
the substantive issue of transparency and EPA's obligation to enforce the
requirements of the federal license is irresponsible on the part of the MDN.
RCRA corrective action requires the corrective action process be transparent. If
the MDN would read the latest Notice of Deficiency you find Dow's most recent
attempts to secret away information on the Saginaw River. If you would file an
occasional FOIA you would find some 440 documents on corrective action not
subject to public scrutiny under the ADR process which was set up while the
state was behind closed doors with Dow for eight months. MDN would also find
documents where EPA is making it clear they ... "are concerned that Dow is
attempting to use the ADR process to keep a document that would be required by
the operating license confidential" ( March 9, 2006).
I would like to think the MDN still considers community right to know and
transparency a cornerstone of critical importance especially over something as
magnificent as this state's water resources. When any public process isn't
transparent, I would like to think the MDN would use their soapbox to correct
such a democratic failing.
