This entry was posted on 9/24/2006 10:03 AM and is filed under Great Lakes Ecology.
The U.S. Coast Guard plans to begin live fire exercises in the Great Lakes. In the process, hundreds of pounds of toxic lead will be deposited into each of the Great Lakes. Most businesses would be prohibited from such release of toxic lead into the environment but the Coast Guard hopes to avoid this prohibition by framing the new program as the creation of safety zones for the exercises, not the creation of the exercises themselves.
The U.S. Coast Guard has announced an extension of the rulemaking comment period for the proposed safety zone carve out in the Great Lakes for live fire exercises.
This proposed rule is very misleading in that it frames the issue as the creation of safety zones rather than the creation of live fire exercises (which would naturally require safety zones).
By defining it this way there is obviously no environmental impact to consider from the firing of small arms and larger artillery in the Great Lakes. In other words, the proposed rule, creating safety zones, does not impact the Great Lakes ecosystem whereas the live fire exercise does have such an impact.
If the rule was framed as what it truly represents, the filling of the Great Lakes with lead containing ordinance, and possibly TNT and RDX containing artillery, then there would be an environmental impact to consider(and comment on).
This was a very tricky method for the Coast Guard to take on this issue. It does not put the impacted stakeholders on notice that the rule will affect them.
Our organization will be commenting on this misdirection and also the environmental requirements being ignored under NEPA, RCRA, CERCLA (future cleanup of current contamination), CWA, and the inconsistency with prior Great Lakes cleanup decisions such as the preliminary assessment and site investigation of artillery at Fort Sheridan under CERCLA, and the Chicago Gun Club Area of Concern near Chicago.
9/24/2006 6:02 PM
Anonymous wrote:
Why was this not in the news? This is the first I have heard of this issue. Reply to this
9/24/2006 6:08 PM
Steven Pollack wrote:
The Coast Guard appearantly tried to sneak this through without much fanfare. A Michigan congressman caught on to the propsed rule and put out a press release demanding the extension to the comment period.
I am researching the lead content of the types of bullets they are proposing to use and trying to come up with estimates of the amount of lead being proposed. One of the problems is that there is no description of the training exercises or any limitations being proposed. Because of this, the risk involved is not being properly conveyed to the public and the comments will therefore not be based on accurate assessments of the risks.
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Steven B. Pollack is a long time environmental advocate and recent law school graduate. He is awaiting the results of the Illinois Bar. In addition to environmental concerns, he posts opinions on issues affecting our civil rights and the Constitution.
, Sera.
