DEQ DOW Community Meeting -  DEQ needs to make a decision Excerpts from 5/10/06 meeting transcript: Dow's intentionally fuzzy view of what constitutes a dioxin hotspot in the river. Link to the full meeting transcript It's incredible that five years into this contamination the state has not settled on what constitutes a hot spot. In the meantime, with every flooding event, the dioxin will be reshuffled and pushed down to the Saginaw River and out to Lake Huron. A letter was sent ( 6-14) raising the issue with both Dow and DEQ. DEQ needs to decide on a number (ppt) that would require sediment removal as the mapping begins this year on the Tittabawassee River and Dow needs to remove those levels when they find them. Will let you know what we hear back.
	About the National Academy of Science (NAS) Dioxin Review The release from the NAS is not the final word on dioxin. It is just one of 12 or 13 peer reviewed reports on the EPA's fifteen year Dioxin Reassessment. Dow has made rounds to the local media to put their spin on the NAS review.  Perhaps Dow has the inside scoop on these studies. Dioxin bill passes in House; effect uncertain Science Academy joining dioxin debate Rep. Moolenaar's abrupt amendment to his original legislation to  change the state's standard from 90 ppt to 1,000 ppt.  Perhaps Mr. Moolenaar  has the inside NAS scoop too. "The best available science, used on a national level, should be incorporated to guide our state-level public health policy," said Rep. John Moolenaar. Representative Moolenaar has consistently  ignored previous peer reviews at the national level which call for greater public health protection for dioxin exposure. If Representative Moolenaar really trusted the "national science"  he would  insist that the DEQ protect for cancers with a risk level of 1 in 10,000 like at the federal level. DEQ risk level is 1 in 100,000.
	Another gift from Dow Chemical

Behind Closed Doors Chemical Industry Initiatives to Discredit and Stall the Release of the EPA’s Dioxin Reassessment Conflict of Interest: How the Chemical Industry Stacks Scientific Peer Review Panels Public Participation: The Chemical Industry’s Attempt to Ram Through a Policy that Would Squash Freedom of Speech Bait and Switch: Science Advisory Board Report on November Meeting Lawsuits: A Way to Conceal Information from the Public Stall Tactics:  Delay is the Name of the Game Chemical Industry Efforts to Block Local Initiatives on Dioxin

A Big Problem with contaminated fish in the Saginaw River It is no surprise that MDCH found high concentrations of dioxin and PCB's in these fish. It is alarming that so many people are eating these fish and eating them regularly. One of the questions MDCH did not ask but agreed to pursue was if these fish were being fed to children and or families.  The question is important because children and women of childbearing age and their babies are more vulnerable to the effects of these of these chemicals. MDCH is to be commended for the great work they continue to do in support of public health, education and the well being of all of Michigan's residents. Click here for the MDCH Fish Consumption Press Release

ATSDR approves Petitioned Health Consultation The Lone Tree Council has successfully petitioned the ATSDR to perform a public health assessment for residents along the Saginaw River We asked the Agency for Toxic Substance and Disease Registry ( a division of CDC Center for Disease Control) to evaluate the exposures and implications  of resident living near and fishing from the Saginaw River due to the high levels of dioxins. Click here for  the ATSDR response

	1) LIABILITY FOR SAGINAW COUNTY RESIDENTS:
	2) FLOODED PROPERTIES
	3) LOST FARMLAND
	4) LOST WETLANDS
	5) CONTAMINATION OF GAME AREA
	6) IMPACTS ON DUCK HUNTING
	7) ODOR AND FUGITIVE DIOXIN PROBLEMS
	8) IMPACT ON LAKE HURON
	9) LACK OF WATER TREATMENT
	10) POTENTIAL GROUNDWATER CONTAMINATION
	11) PREEMPTING LOCAL CONTROL
	12) UNRESTRICTED USAGE
	13) NO CONSTRUCTION, MANAGEMENT OR OPERATION PLAN
	14) NO ENVIRONMENTAL IMPACT STATEMENT (EIS)
	15) FLAWED PROCESS
	16) MORE SUITABLE ALTERNATIVES
	Click here to view the entire update

	Dennis Paustenbach for hire, current and former affiliated companies (that we know of): ChemRisk, Dennis Paustenbach CEO and founder Dow Chemical is a client ChemRisk was once a division of McLaren/Hart Exponent, Inc., Paustenbach, former Corporate Vice President Dow Chemical is a client McLaren/Hart Environmental Engineering Corporation (defunct?) Pausenbach not mentioned, but this is the type of company that hired him: The Board of Ethics (the “Board”) pursuant to the authority contained in LSA-R.S. 42:1141, conducted a private investigation concerning information that William Kucharski, Secretary of the Louisiana Department of Environmental Quality, may have violated Section 1111C(2)(d) of the Louisiana Code of Governmental Ethics (LSA-R.S. 42:1101 et seq.) (the “Code”) by sharing in income received by his wife, Lynn Kucharski, as salary for services performed for McLaren/Hart Environmental Engineering Corporation (“McLaren/Hart”), at a time when that corporation had substantial economic interests which Mr. Kucharski could affect by the performance of his official responsibilities. Stauffer Chemical Syntex Pharmaceuticals
	Dow's 2002 bioavailability study for Mid-Michigan designed by Paustenbach would have raised the allowable level of dioxins to 831 ppt (from the current 90 ppt RDCC).  The proposal was part of Dow's failed 2002 attempt to manipulate the former corrupt Michigan DEQ administration to ram through an ILLEGAL Corrective Action Consent Order (CACO). EPA's objections to the CACO A few media excerpts from the past: AP,  MDN, WP
	The on-going, Dow funded "Oral Bioavailability of Dioxins/Furans in Midland and Tittabawassee River Flood Plain Soils" study is being prepared by Exponent.
	Originally proposed in the 2002 CACO, Paustenbachs proposed "Probabilistic Risk Assessment" methods resurfaces in Dow's 2005 RIA Scope of Work for the Tittabawassee River floodplain.  The EPA stated such methods are not allowed in it's 2006 letter of "Critical Deficiency comments".
	Paustenbach is a member of the EPA's Science Advisory Board and participates in the EPA's Dioxin Reassessment Review.  Much to the Chemical industries delight, his "contributions" have assisted in delaying the agencies final report by almost 15 years. Industry Influence in the Dioxin Reassessment, prepared by Boston University School of Public Health highlights Paustenbach's unethical involvement in the process.
	Interesting: Dr. David Garabrant, the U of M professor heading the Dow funded Human Dioxin Exposure Pathway study shares a seat with Paustenbach on the Mickey Leland National Urban Air Toxic Research Center Scientific Advisory Panel.    Any chance Paustenbach is influencing Garabrant?

	Failure to disclose who wrote the manuscript.
	Failure to disclose that the study was funded by PG&E.
	Falsely stating in the published paper that stomach cancer rates weren't available for the province.
	Basing analysis on the level of contamination detected in the wells in 1965, knowing that by the end of that year the picture of contamination in the wells had dramatically changed.
	Ignoring useful data that were readily available.
	Misrepresenting the study design in several ways to make it seem stronger.
	Failing to disclose key facts about the data presented.
	Simultaneous submission to two journals.

While Dow will be out conducting testing this spring, summer and fall, the sampling program is a preliminary one. Samples will be used for a bioavailability study Dow expects to complete in 2010. From 2009 to 2013, the company is proposing a human health risk assessment and from 2012 to 2014, another round of soil sampling. The work plans suggest that potential remedies would be explored and selected in 2015, with a two-year implementation ending in 2017.

In their bids to come up with the winning understatement of the year, Environmental Protection Agency and MDEQ  officials are quoted stating:
    "It's not quite yet where we want it to be,"  and  "It looks like there are opportunities to expedite some things,"

However, the following anonymous quote puts it all in perspective:

So that little child born in Midland in 2001 will be 16 by then, a goodly way through puberty and exposed to dioxins and furans during her whole life.  Her future is being gambled upon because Dow is too cheap to just acknowledge and clean up their mess sooner rather than later. 

It's time to end this nonsense.  We ask the EPA and MDEQ to correct the problems with Dows latest RIA , include an accelerated cleanup schedule, and TELL THEM THIS IS HOW IT WILL BE DONE.  No more delays.

 
05/09/06 Lone Tree/TRW Dioxin Update

	Bioavailability study to be done in 2010
	Human health risk assessment from 2009 to 2013
	More soil sampling again until 2014
	Potential remedies explored and selected in 2015
	Two-year implementation done by 2017

	Federal Judge denies restraining order to stop Zilwaukee/Frankenlust dioxin slurry pit
	Environment Michigan web site: www.environmentmichigan.org
	Dow Class Action Lawsuit update
	DEQ/Dow Meeting
	Click here to view the entire update

05/05/06  Floodplain wild bird food grossly contaminated

Another PR laden presentation by the DOW/MSU wildlife contamination study:

"It might look like the same trees and shrubs from a bird’s-eye view, but whether an eastern bluebird, tree swallow or house wren builds its nest upstream or downstream of The Dow Chemical Co. could mean the difference between everyday flies and earthworms and slightly more contaminated grub."

We are not sure if it was the Dow researcher or the reporter that used the phrase "slightly more contaminated", but whoever it was has a warped sense of statistics:

	Earthworms downstream of Dow have 339 times more dioxin than those upstream
	Moths downstream of Dow have 20 times more dioxin than those upstream
	Flies downstream of Dow have 32 times more dioxin than those upstream

Click here for details from the Midland Daily News.

Evidently the MSU student "researchers" have quite a few classes remaining in their education.  Have they ever heard of a "population sink" or where they instructed not to mention it.  Click here to read more about  MSU and it's link to corporate funded "research".

05/4/06 Groups go to Federal Court to ask dredge site review

	Lone Tree Council not opposed to dredging
	Floodplain may be unsuitable for spoils
	Environmental evaluation necessary
	The Lone Tree Council and co-plaintiff Environment Michigan filed papers yesterday in the Federal District Court for the Eastern District of Michigan citing the need to protect this region’s long term economic and environmental future.
	The proposed site, next to the Saginaw River, sits in the floodplain just a few hundred feet from a residential neighborhood and next to a wildlife game reserve. The site is not a licensed landfill, yet will accept highly toxic, dioxin-contaminated dredge spoils for a minimum of 20 years.
	Click here for all the details

04/29/06  Petition to stop the 1000 ppt cleanup level off to a great start

The kickoff of our petition drive got off to a great start with almost 100 signatures obtained from various locations around the area.

Click here for the latest Lone Tree / TRW Dioxin Update news letter.

Please oppose this  legislation by sending an e-mail with your name and city of residence to info@trwnews.net  and simply  state in your e-mail that you oppose 1,000ppt. We'll add your name to the petition OR you can  write to info@trwnews.net and ask for a copy of the petition which you can have your friends and family sign.  Remember, it doesn't matter where you live in Michigan because these natural resources belong to all of us. Please act today and send off that e-mail.  See related stories below for additional information.

04/28/06  Owls downstream of Dow have 100 times dioxin as those upstream

At a recent presentation by Michigan State University, a biologist revealed a snippet from their Dow funded study of area wildlife in the dioxin contaminated flood plain.  Click here for details from the Midland Daily News.

04/27/06  Sign our petition to stop the 1000 ppt cleanup level and keep Michigan safe

To sign our petition, stop by Saturday, 4/29/06 between 8 AM and 5 PM.  Click here for details.

You can help, send an email to info@trwnews.net and we will email you a blank form to use in your area.

04/23/06  Moolenaar out of control, the ATSDR 1000 ppt is not a cleanup level

Moolenaar's new un-sound science legislation is proposing 1,000 ppt dioxin cleanup levels for Michigan is a standout for all the WRONG reasons.

The ATSDR 1000 ppt was never intended to be a "cleanup" level:

1. Michigan’s 90 ppt RDCC soil criterion for dioxin is a level that is meant to be protective of public health in properties for unrestricted residential use.
2. The ATSDR 1,000 ppt was based on the detection limits of science available over 20 years ago in the 1980's.  Today, scientific instrumentation is much more sensitive and can measure 10 ppt or less.  The Michigan RDCC of 90 ppt was derived using current technology.
3. The ATSDR 1,000 ppt was calculated based on a 1984 assessment by the Centers for Disease Control that is NOT consistent with the current assessment of dioxin’s cancer hazard.
4. The 1,000 ppt level was NOT derived as a "safe" level. It was thought to be a level that could be associated with health effects. Cleanup levels are traditionally set at levels BELOW those thought to cause health effects. Therefore, it is not accurate to suggest that levels below 1,000 ppt pose no risk.
5. Referring to the ATSDR 1,000 ppt level as a cleanup level is not accurate. The 1,000 ppt level is NOT used by ATSDR for that purpose.
6. The 1,000 ppt level was NOT developed to serve as a standard for cleanup for residential areas
7. The 1,000 ppt level does NOT represent a line between safe and unsafe conditions, although it has been used in that way
8. The EPA has been reviewing dioxin’s toxicity for more than 10 years. Their review has been repeatedly peer-reviewed, but political wrangling and the power of the chemical industry have prevented its release. The draft document concludes that dioxin is more toxic than previously thought 
9. If the EPA reassessment were released, the state’s cleanup standard would be more stringent, not weaker, based on a new interpretation of studies on dioxin’s toxicity. The state standard would be between 12 and 53 ppt.
10. The 1,000 ppt level does NOT consider non-cancer health effects that may occur when people are exposed to dioxin at even lower levels than those associated with cancer. The most sensitive endpoint for dioxin’s toxicity is thought to be neurobehavioral impacts.
11. If the state were to use the 1,000 ppt standard, the issue of dioxin’s toxicity will continue to plague the state. When the Dioxin Reassessment is finalized, the EPA will again look at sites and reassess previous actions to determine if they are protective. So a cleanup to 1,000 ppt today will not guarantee that the issue will go away. It could just keep coming up unless contamination is cleaned up to a reasonable and legitimate standard.

Below are letters of support to NOT change Michigan's 90 ppt dioxin RDCC from the last time Dow's stooges tried to change it in June of 2004.

	Ted Schettler MD, MPH, Department of Internal Medicine Boston Medical Center and Science Director SEHN "...  State and Federal criteria restrict their focus to cancer as the outcome of concern, though we now know that other health effects occur at lower levels of exposure and may affect the entire population. In fact, due to the array of low-level effects, scientists today are uncertain about the threshold amount of dioxin that may begin to cause or contribute to illness in people. Moreover, dioxin-related health effects are often "hidden" in the general burden of disease and disability in the community. Trying to identify them as "caused by dioxin" is a fruitless task. ..." Click here to view entire letter
	Katherine R. Silberman, JD,  Associate Director Center for Environmental Health "... .  Dioxin is known to cause cancer in minute amounts.  As an elected official, you bear a deep responsibility to protecting the public’s health.  Please stand up to Dow and instead, stand with the people of Michigan in the pursuit of healthy bodies and a healthy environment for your beautiful state. ..." Click here to view entire letter
	Judith Robinson, Special Projects Director, Environmental Health Fund "...As an early advocate for veterans on this issue [of dioxin exposure] I found that one of the most tragic aspects of the entire struggle was the record of deceit and cover-up practiced by the government and the chemical companies responsible for the manufacture of dioxin, including the giants Dow and Monsanto...." Click here to view entire letter
	Joseph DiGangi, PhD, Director, International POPs Elimination Project EHF "... The events unfolding in Michigan are being observed internationally. I direct an international NGO project on persistent organic pollutants (such as dioxin) in partnership with two UN agencies with activities planned in 40 countries. International NGOs as well as intergovernmental agencies are paying close attention to issues involving dioxin and other persistent organic pollutants due to the legal entry into force of the Stockholm Convention. Dow Chemical’s legacy in many of our project countries makes public interest NGOs throughout the world especially focused on events in Michigan to see whether the legislature will support public health by maintaining the 90 ppt standard. ..." Click here to view entire letter
	James Clift,  Policy Director Michigan Environmental Council " ... The Michigan Environmental Council opposes HB 5963 and urges the committee to vote "no". The "action level" proposed as our new cleanup standard is inappropriate. As stated above, this level of exposure would cause an "urgent public health hazard" – not a level considered safe for prolonged public exposure. ..." Click here to view entire letter
	Paul Sutton, Chair Vietnam Veterans of America  Agent Orange/Dioxin Committee " ... Research has repeatedly shown that low levels of dioxin (30ppt – 100ppt) cause the greatest damage to humans and their offspring, from initial exposure out to 30 years and beyond the initial exposure.  Raising the floor at which human tolerance has already demonstrated adverse affect will only serve to expose far more citizens of the Wolverine State and consequently serve to drastically elevate health care costs in future years for those citizens least able to afford them. ..." Click here to view entire letter
	Kathy Henry, Tittabawassee River floodplain resident, Freeland MI "... Were you aware that Midland has the highest level of diabetes in the nation? There is a very strong link between dioxin exposure and diabetes. There has never even been a study done of just the affected residents in Midland and those who live on the highly contaminated Tittabawassee River. ..." Click here to view entire letter

04/22/06 Lone Tree/TRW Dioxin Update

The Saginaw River Dredge Materials Disposal Facility

	There is no disagreement on dredging the river. Where to place these sediments is what’s at issue.
	The DEQ has not  signed off on  the placement of dredged materials because an Operational Management Plan (OMP) on how the site will be built and how the contaminated sediment will be managed has yet to be submitted for DEQ review, input and approval. Until it is nothing can be placed in the site.
	Sampling data in the navigational channel is limited but concentrations exceed 10,000ppt. DEQ says the " dioxin furan concentrations in the Saginaw River are highly variable.”
	The proposed site in the floodplain of the river is the wrong site. Three or four previous attempts to site a disposal facility on the west side of the river have been rejected in the past because of flooding, westerly prevailing winds and proximity to the Crow Island Game Reserve. None of these dynamics has changed
	In a letter dated December 28th 2005, to Mr. Koski and the ACE, DEQ stated:  "Numerous sand lenses in the upper 13 feet at the site are saturated and have  the potential to discharge off-site, either to the wetlands to the west or the Saginaw River to the east…………….The geology of the site does not meet the criteria for the  natural clay base of composite liner”.
	A March 16th 2006 email, DEQ is estimating the cost of having to install a groundwater monitoring system. The one time cost estimates for monitoring wells  is $55,000 to $165,000 and the range for sampling which will be incurred annually until the permit is terminated are between $54,000 and $423,000. Where is that money coming from?
	Mr. Koski committed all the taxpayers of Saginaw County to perpetual liability for the site which will contain sediments highly contaminated with dioxin from Dow Chemical; a most compelling reason if none other to do the EIS. The counties long term obligations include; insurance, inspection and maintenance, deed restrictions, groundwater, storm water and effluent monitoring as well as corrective action planning in the event of environmental problems.
	DEQ further commented in  the March 2003 letter, “We remain concerned about the long term maintenance of a facility placed in the floodplain and the liability for any releases of the sediments resulting from placement of the dredged sediments in the floodplain”.
	Click here to view the entire update

04/14/06 Not a rumor: "HB4617 like" bills are being resubmitted by Dow's legislators

"Once vetoed as a poor protection of public health, the Homeowners Fairness Act is back at the state
Capitol with designs to restrict the state's ability to label any property as contaminated." See related
4/7/06 story below.

Click here for more from the Saginaw News or here from the Midland Daily News

         

"Moe" Moolenaar       "Larry" Stamas  "Curley" Goschka          

04/13/06 Dow files for another delay in lawsuit

Dow files motion to extend time to file brief to Appeals Court until May 8, 2006.  Original date was April 24.  Click here for more on the lawsuit.

04/12/06 Recent dioxin related science

	Increased levels of polychlorobiphenyls in Italian women with endometriosis.
	Body burden of dioxins and dioxin-like polychlorinated biphenyls in pregnant women residing in a contaminated area
	NOTE: SOME PCB'S ARE DIOXIN-LIKE IN THEIR TOXICITY

Click here for more about dioxin and it's effect on human health

04/10/06 Citizens petition Feds for Health Review of Saginaw River

Lone Tree Council Press Release: "Residents, fishermen, and environmentalists from the area are asking the federal government to look at contamination in the Saginaw River. The individuals and groups have petitioned the Agency for Toxic Substances and Disease Registry (ATSDR), a branch of the Centers for Disease Control. They are asking the agency to evaluate the health impacts coming from eating Saginaw River fish. Of most concern is the health effect on the children of both subsistence and recreational fishing families. " ...

Sediment samples taken in 2004-2005 by the Michigan Department of Environmental Quality (MDEQ), U.S. Army Corps of Engineers (USACOE), and U.S. Environmental Protection Agency (USEPA) show high concentrations of dioxin and furan compounds in the Saginaw River. ...

The need to evaluate and get advice on a specific public health issue related to human exposure to the contaminants in the river is what prompted the petition to ATSDR. “This God given source of protein (fish) should be accessible to everyone”, said Michelle Hurd Riddick of the Lone Tree Council. “Essentially this inexpensive food source has been contaminated. It’s a huge economic resource being denied the people of this watershed. There are documented subsistence fisherman and indigent people who rely on this fish to feed their families”.

Click here to read the entire Press Release

04/07/06 Rumor: "HB4617 like" bills are being resubmitted by Dow's legislators

	Goschka:  To change facility definition
	Moolenaar: To change the States RDCC from 90 ppt to 1000 ppt
	Stamas: To use the U of M study to determine cleanup levels

Click here to read all about similar efforts promoted by the three stooges last year.  Fortunately, Governor Granholm vetoed HB4617.  Men such as these lack the necessary morals, ethics, and concern for the health of Michigan's children to be in office.  So now they want to try again.  What's their motive?  Could it be re-election campaign finance?  To be continued.....

04/07/06 Lone Tree/TRW Dioxin Update

	Sediment Plume How long is long enough? The question needs to be asked over and over and over. This is Lake Huron at the end of this pipeline. Our Lake Huron Water levels are low making the sediment from the Saginaw River highly visible as it reaches far out into the bay
	1983 Document Revealing Recent Lone Tree research reveals a lot of dioxin sampling was done on the T.River back in the early 80's. In 1983 Dow evidently committed to a 3 million dollar health study to put people’s minds at ease about the toxicity of dioxin. It was also in 1983, after Congressional hearings, that a high ranking EPA official was fired for permitting Dow Chemical to edit the Great Lakes dioxin study being done by EPA. Dow objected to language about the toxicity of dioxin and to the company being identified as the source of dioxin. Sound familiar?   2006: Dioxin has been moving, migrating along the T-river, Saginaw River and out to Lake Huron while EPA, the State of Michigan and Dow Chemical continue to posture and spare in excess of 23 years.
	Natural Resource Damage Assessment (NRDA) The overall intent of the assessment regulations is to determine appropriate restoration and compensation for injuries to natural resources. Last month the “Trustees” in the NRDA signed a “Confidentiality Agreement” among themselves to permit open and transparent discussions within the group. It is understood that this is a typical activity within the NRDA process. However, given the long, long history associated with this contamination, including, lack of transparency, private negotiations and political intimidation we need to remain vigilant.
	High water event along the Tittabawassee River Once again, dioxin contaminated sediments are being moved and shifted around like chairs on the deck of the Titanic. Freeland Festival Park: "Here's Dow's Sound Science on where our children should play."  The wall is, in fact, a settling pond for dioxin………….  It catches and slows the river flow, enough to let the sediment drop out, all over the park.  The park caught LESS dioxin when they just let the river flow through it unimpeded. Click here for more pictures.
	Dow submits conceptual work plans for the Saginaw River Links  for the transmittal letter and the conceptual plan that was submitted by Dow for the Upper Saginaw River starting at the confluence with the Tittabawassee River to the 6th Street Bridge ( 5.5 miles)
	Saginaw River dredge plans Issuance of the Operational Management Plan is being delayed because of the inherent and significant environmental issues associated with placing contaminated dredge spoils  in the floodplain of the Saginaw River. Secondly the cost to implement even modest improvements is very high………….which is why all the agencies are NOW talking with Dow Chemical.

 Click here to view the entire update

04/05/06   Plaintiffs file brief in Michigan Appeals Court

April 4, 2006 Plaintiffs submit 58 page "Plaintiffs-Appellee's Brief Oral Argument Requested" document to the Michigan Appeals court.   We think the Appeals Court now has all the documents it needs to move forward.  See Court Activity page.

04/04/06   Saginaw Bay dioxin contamination: When will the EPA / MDEQ act?

To the left is a  satellite photo of the Saginaw Bay. Due to low water levels you can clearly visualize the Saginaw River sediment plume in the bay.

Commencing with a number of studies in the early 1980's Region V EPA and the State of Michigan have known about the presence of dioxin/furans in the Tittabawassee River and the presence of dioxin in fish and gull eggs in the Saginaw River and Bay. It's been 25 years and absolutely nothing has been done to obstruct the movement of these dioxin laden sediments into Saginaw Bay.

The existence of a responsible party ( Dow Chemical) and all the commensurate negotiating and posturing that comes with the corrective action process is doing nothing to address the build up of contaminated sediments in the Saginaw Bay. It has been said many times over that a comprehensive cleanup of the Bay is technically and financially not feasible. One DEQ officials commented "if it gets into the Bay it will stay there." The obvious question is why are you folks permitting these sediments to be deposited year after year. Is it because you're waiting for Dow? You don't have the expertise? Please help me understand.