SESC Procedures for Drain Commissioners
Michigan Association of County Drain Commissioners (MACDC)
Basin Program Funds:
In the state of Michigan, 32 County Drain Commissioners and the Michigan Department of Agriculture do not have an acceptable written Soil Erosion and Sedimentation Control (SESC) Procedures approved by the Michigan Department of Environmental Quality (MDEQ).
Earth changes routinely undertaken by Drain Commissioners are unique because they are actually working in the stream. This necessitates development of written soil erosion and sedimentation control procedures unique to Drain Commissioners.
Currently 32 County Drain Commissioners and the Michigan Department of Agriculture are not required to obtain SESC permits from the County Enforcing Agency because they are designated as authorized public agencies (APA) under Part 91, Soil Erosion and Sedimentation Control, of the Natural Resources and Environmental Protection Act, 1994, as amended (Part 91). Major revisions to Part 91 took effect on January 11, 2001. These revisions provided 3 years for APAs to adopt SESC procedures that are at least as restrictive as Part 91 and the administrative rules or lose their exemption.
To date, none of the Drain Commissioners have written SESC procedures to reflect the 2001 amendments. Other APAs, such as the County Road Commissions, have developed SESC procedures for their activities but they are of little value to Drain Commissioners that primarily undertake activities in streams instead of adjacent to streams.
A task force was established consisting of the following members: Janis Bobrin, MACDC First Vice President and Washtenaw County Drain Commissioner; Pat Lindemann, MACDC Second Vice President and Ingham County Drain; Dick Mikula, SESC Program Manager, MDEQ; and Hope Croskey, Project Manager and Larry Protasiewicz, Project Engineer, Spicer Group.
Specific task items included:
Implementation of MDEQ accepted SESC procedures by Drain Commissioners will provide a coordinated effort to reduce soil erosion and the resulting sedimentation requiring less drain maintenance and disturbance of the states drains.
- Review existing information and prepare a draft model SESC Procedures Manual template seeking input from the task force members, which included the MDEQ and MACDC Officers.
- Hold at least three one-day workshops with Drain Commissioners at different locations to review the draft manual and to solicit input for modifications within 6 months of the grant award date. All Drain Commissioners will be notified of workshop dates and locations.
- A re-draft will be distributed to all Drain Commissioners for review and comment.
- The draft will also be made available on the MACDCís website for Associate Membersí review.
- After incorporation of input from the Drain Commissioners the final draft will be submitted to the MDEQ for content approval.
- Technical support will be provided by Hope Croskey to individual Drain Commissions for preparation of county specific SESC Procedures. However, it will be the responsibility of each Drain Commissioner to submit their SESC Procedures to the MDEQ for approval.
The Soil Erosion and Sedimentation Control (SESC) Authorized Public Agency Procedures Manual template for the Michigan Association of County Drain Commissioners (MACDC) has been completed. Two workshops were held for Drain Commissioners, Michigan Department of Agriculture (MDA) representatives and MACDC Associate members. Comments received during and after these two workshops were incorporated into the manual and a copy was provided to the Michigan Department of Environmental Quality (MDEQ) in Mid November. Written and verbal comments received from the MDEQ in mid December, 2003, along with further discussions in January, 2004 were used in the preparation of this final document that has been submitted to the MDEQ by MACDC for content approval. This final document, in Adobe pdf format, has been posted on the Spicer Group, Inc. website at: www.spicergroup.com under "Project Info" and is available for use by MACDC, the MDA, and the Drain Commissioners in preparation of their APA specific procedures.
Contact: Ms. Hope M. Croskey, 989-224-2355