David A. Domzal Member ddomzal@williamsacosta.com (Also admitted in Ohio and Colorado)

William sA costa A Professional Limited Liability Company

Attorneys and Counselors 535 Griswold Street, Suite 1000

Detroit, MI 48226-3692

October 30, 2014

Via Electronic Mail (Superfund Docket)

Docket Coordinator U.S. Environmental Protection Agency CERCLA Docket Office (Mail Code 5305T) 1200 Pennsylvania Avenue, NW Washington DC 20460

Phone: (313) 963-3873 Fax: (313) 961-6879

www. williamsacosta.com

Re: DSC McLouth Steel, Gibraltar Plant, Docket EPA-HQ-S Fund 2014-0625

Dear Sir or Madam:

These comments are being provided by Williams Acosta, PLLC on behalf of our clients, Detroit Steel Company ("DSC") and Gibraltar Land Company ("GLC"), the respective owners of the "DSC McLouth Steel Gibraltar Plant" and the "Countywide Landfill" parcels that are listed for potential inclusion on the National Priority List, in reference to the above docket matter. These comments are not technical in nature, but rather are submitted in order to supplement the record and provide needed background. My client wishes to explain how the current situation arose, and suggest an approach whereby needed funding for the maintenance of the two parcels can be secured minimizing the need for use of governmental cleanup funds.

I. Background

A. Site Acquisition and Execution of Consent Judgment

There is a significant amount of history related to this matter. The Countywide Landfill ("CWLF") represents only a portion of the properties previously owned by McLouth Steel Products Corporation ("McLouth") that were acquired by GLC and its affiliates. The following is a brief summary of the most relevant facts.

Beginning in 1973, McLouth owned and operated the CWLF, which is located at 15701 Vreeland Road, Gibraltar, Michigan. This was a Type III landfill, which is licensed to accept inert, non-hazardous waste, such as construction and demolition materials (brick, drywall, scrap lumber, etc.). A Type III Landfill is to be distinguished from a Type II Landfill, which is

-WilliamsAcosta Docket Coordinator October 30, 2014

Page 2

authorized to accept municipal solid waste. As such, the CWLF was never licensed to accept household waste or most industrial wastes.

As a result of McLouth's financial difficulties, the CWLF was not properly operated and maintained in accordance with applicable laws and regulations.

In 1997, as part of a financial arrangement whereby GLC and its affiliates acquired the McLouth properties, including the CWLF and the steel mill properties located both in Trenton and Gibraltar, Michigan, GLC and MDEQ entered into a Consent Judgment. While GLC and its affiliates were in the steel business, rather than the landfill business, they acquired the CWLF as part of an integrated asset acquisition, in order to have an assured place for disposal of the non­hazardous byproducts of the steel operations, which are allowed to be disposed of at a Type III Landfill.

Under the terms of the Consent Judgment, GLC agreed not to expand the CWLF into approximately 100 areas of the property located adjacent to the CWLF that had been previously designated to be developed for landfill purposes. Further, as set forth in technically detailed terms, GLC agreed to clean up existing environmental problems left by McLouth, including taking the following steps:

i) GLC was required to undertake hydrogeologic monitoring.

ii) GLC was required to engineer and construct a system to prevent the outbreaks of leachate at the CWLF.

iii) GLC was required to develop and implement an engineered plan to control erosion.

iv) GLC was required to remediate other environmental problems existing on the properties.

v) GLC was obligated to establish a Perpetual Care Fund, under which GLC initially deposited $220,000 into a trust fund, and in addition, provided financial assurance to the MDEQ in the form of a surety bond for $1 million. GLC provided Perpetual Care Fund deposits in the total amount of $1.2 million.

B. Ongoing Obligations of GLC

GLC assumed an enormous environmental liability at the time it acquired the McLouth properties. In an Affidavit MDEQ filed in the McLouth bankruptcy proceeding, MDEQ estimated that the costs of ongoing environmental obligations at the CWLF would be approximately $26,273,560.00 throughout the remaining life of the site. GLC had counted on the revenues generated by steel operations, as well as Landfill revenues, in order to cover these financial obligations. The revenue lost to GLC as a result of Wayne County's untimely action

-WilliamsAcosta Docket Coordinator October 30, 2014

Page 3

noted below is in excess of $100,000,000 When GLC's affiliates were forced to close the steel business, the only source of revenue available to fund these environmental obligations was revenue generated by CWLF operations. GLC now requires the additional disposal capacity represented by a vertical expansion of the Landfill in order to fund such on-going obligations.

C. Submittal ofVertical Expansion Application to Wayne County

In order to expand a landfill (either vertically or horizontally) within the State of Michigan, the Act mandates that two steps be followed. First, such expansion must be authorized under the applicable County Solid Waste Management Plan.1 Under the Act, each County is obligated to develop its own County Solid Waste Management Plan, which Plan must be updated from time to time. Second, the applicant must receive a construction permit?

In June 2002, GLC requested the County to approve the vertical expansion by submitting to the Wayne County Landfill Siting Committee an application under the process set forth in the 1990 Wayne County Solid Waste Management Plan ("1990 Plan"), and in accordance with the Host Community Agreement which had previously entered into between GLC and the City of Gibraltar. The Host Community Agreement provided, in relevant part that the City of Gibraltar agreed not to oppose any vertical expansion of the CWLF. This application was initially denied by the County Siting Committee, but on November 13, 2002, the then Wayne County Executive overruled the Siting Committee and ordered the expansion included in the Plan. However, through error or neglect, the County Executive failed to realize that he needed to issue such order prior to the time that the 1990 Plan was amended. While this error or neglect on the part of Wayne County initially seemed innocuous, it had dire consequences for GLC, and put CWLF on a downward spiral.

In December 2003, MDEQ denied GLC's application for a construction permit, on the basis that the County Executive did not have the authority to overrule the Siting Committee, since the 1990 Plan was amended seven days prior to the County Executive's overrule, and certain terms of the Amended 1990 Plan did not grant such authority to the County Executive.

Both the City of Gibraltar and Wayne County opposed MDEQ's actions, and recognized the dire consequences (see attached correspondence) of removing the sole funding source for site maintenance and cleanup.

As a result of such events, GLC filed suit against the State of Michigan in Ingham County Circuit Court. GLC prevailed in such action, but MDEQ appealed, and in October 2005, the Michigan Court of Appeals overruled the Ingham County Circuit Court's decision and ruled that MDEQ properly denied the construction permit request for the vertical expansion.

I MCL 324.11511 2 MCL 324.11509

-WilliamsAcosta Docket Coordinator October 30, 2014

Page4

Wayne County's error or omission in this process eliminated the principal funding source for the environmental liabilities at the Landfill and adjacent properties, liabilities that GLC had inherited from McLouth. GLC's 2002 application to Wayne County for allowance of the vertical expansion, entitled "Application for Fast Track Inclusion in Wayne County Solid Waste Management Plan", at page 5, stated the following:

"When cell construction costs, site engineering costs, taxes, HCA fees, PCF fees, insurance, labor, equipment, fuel, profit and other costs are considered, it is evident that we cannot achieve our goal of correcting the past problems at the site through the operation of a successful business given the current available disposal capacity. Expansion of the facility is necessary, therefore, for Countywide to have the revenue flow needed to continue to address concerns at the site." (Emphasis added).

GLC expended $2,000,000 in its initial investment for the Landfill, paid the City of Gibraltar $450,000 in Host Community fees, funded the Perpetual Care Fund in the amount of $1,280,000 and undertook capital improvements of $650,000. GLC needed the revenue from the vertical expansion to fund the remaining on-going environmental liabilities.

II. Current Status

At the present, GLC is again attempting to secure the required local approvals in order to construct the vertical expansion of the CWLF, and, by doing so, correct the injustice that took place in 2003. To that end, discussions continue with the City of Gibraltar, the host community, in order to finalize and execute a host community agreement. As part of the host community agreement, GLC would agree to set aside in trust certain monies from the landfill operations to fund maintenance and final closure activities at both the CWLF and the DSC McLouth Steel Gibraltar Plant. Should GLC and the City of Gibraltar finalize such an host agreement, GLC would then submit an application for inclusion of the expansion in the Wayne County Solid Waste Plan and, should such an application be approved, GLC would then be in a position to submit the application for a construction permit for the vertical expansion to the Michigan Department of Environmental Quality.

As noted above, such vertical expansion would provide a source of funding for the proper maintenance of the properties.

III. Summary

The designation of the properties on the National Priority List would make the financing of future landfill operations and/or the sale of the property to another landfill developer difficult. However, recognizing the continued areas of environmental concern, even if USEPA would elect to designate these sites on the NPL at this time, we would believe that USEP A could play a constructive role in attempting to mediate a resolution of this matter. Such a resolution

IIDwmiamsAcosta Docket Coordinator October 30, 2014

Page 5

would provide for the vertical expansion of the CWLF, which would in turn provide a source of revenue that would minimize the use of federal monies. There is a significant untapped value in the vertical air space at the CWLF that can be monetized and provide a much needed source of maintenance and clean-up funds.

Thank you for the opportunity to submit comments in this matter.

DAD/cal Enclosure

Sincerely,

WILLIAMS ACOSTA, PLLC

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David A. Domzal

cc: Mr. Mark Wilkinson (via electronic mail) Mr. James Logsdon (via electronic mail) Ms. Nuria Muniz, USEPA Region V (via electronic mail) Steven Kaiser, Esq., USEPA Region V (via electronic mail) Mr. Todd Quesada, USEP A Region V (via electronic mail)

JHN c0 2007 8:22 AM FR TO 813138616878 P.18 -,

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Mr. Steven E. Chester Director

December 19, 2003

Michiga:t Department of Environmental Quality P.O. Box 30241 Lansing, Ml 48909

RE: Construction Permit Application for Vertical Expansion of Countywide landtlJI, Gibraltar, Michigan

Dear Director Chester:

I am writing on behalf of my family's company, Gibraltar Land Company, to urge your approval of the pending construction permit app:ucation for the vertical expansion of Countywide Landfill in Gibraltar. This request comes toward the end of our 7-yea.r effort to work in partnership with the State to remedy the many environmental liabilities left by McLouth Steel when it abandoned the landfill in 1996 by creating a viable business entity that is fully protective of the public health and environment.

As you may know. Gibraltar Land Company and the MOEQ entered into a consent judgment in 1997, establishing a broad framework for the investigation, remediation and eventual reopening of the former Mclouth Type W landfill. Our company has invested over $3,000.000 relying upon the good faith of the MDEQ and the promises made in the consent judgment. To date, the MDEQ and Gibraltar Land Company have kept their promises to each other and I can state confidently that your staff, including Jim Sygo (who has worked with our company for many years). agree that the landfill's condition has been vastly improved since we acquired it as part of our family's companies· acquisition of the former Mclouth Steel assets in Trenton, Gibraltar and RiveNiew. This progress resulted in the consistent official support of the City of Gibraltar and the payment of substantial tipping fees to the City which have become a very important part of their municipal budget.

We have faced many political hurdles. many of which are carryovers from McLouth's storied past. Many people still refer to our property as the ''Mclouth property", a link we find leads to unjustified conclusions. Among those are the limted few who have very vocally opposed our efforts to reopen and operate the landfill, despite the indisputable. measurable, and substantial ·environmental

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Mr. Steven E. Chester December 'i 9, 2003 Page 2

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benefit we have made to the property with our considerabie financial investment and commitment.

We are at a crossroads. We understand mat you have ·been aske_d. by private parties to concwdel"Fiat former Wayne CountY- Executive\ McNamara-did "i"'I'rhave-attthu-ri~l'lloverF.ber 13, 2003 to agprove the inclusion of -the propose(] vertical expansion becaus~ the former MDEQ director, issued a re_tter

"Uateai\Jovemoer-'7;-2003approving t'le 2000 Wayne County Solid Waste Plqn Uldste. For many reasons, we believe that such a conclusion is not supported by law or in equity, and ask that you find that the pending construction permit application is consistent with the Wayne County Solid Waste Plan.

We ask for your favorable consideration not just because of the good we have done and wish to continue to do to protect the environment but because I am advised that we are entitled to that conclusion as a matter of Jaw. While our attorneys are aware of no reported case precedent controlling this issue, I have been advised by our legal counsel that Countywide's requested permit is consistent with the Plan, as supported by legal authority including:

i. The appeal that was pending before the County Executive was a vested right that cannot be eliminated· without offending the concept of due process of law. See Hurt v. MichaeFs Food Center, 249 Mich App 687 (2002) ('Pending causes of action that accrued while a statute was in force are considered vested rights and, thus, are not divested by repeal of a statute_ i

2. There is no indication that the Wayne Co~nty Commission intended to abrogate pendin a earswt'i'eilttacfo ted the 2000 Solid t. _ Update. lrtme a sence of any such indication, a pending appeal should not be nullified by aciapf1on of the update only days before a final decision is made.

3. The MDEQ's November 7, 2003 letter granting cond.itional approval of the 2000 Plan Update contained conditions that have not yet been properly incorporated into the Plan Update, some of which have ~igniticant legal effect. Regardless of the procedural or substantive significance of the conditions included in the conditional approval letter; the County Commission has not yet adopted a proper resolution or ordinance reflecting the chG\nges required for­approval of the 2000 Plan Update after rt had been filed with the MDEQ (on or §50UfMarch 8, 2002). UDtil such proper legislative action is taken~ the 1990 Plan remains in effect and thus, the County Executive would retain the power not just to decide pending appeals, but consider new appeals it filed prior to-the required revision of the proposed 2000 Plan Update. Section 11537 of Part 115 does not alicw the MDEQ to modify the plan at the time of approval (in contrast to other statutes, such as Part 303 [MCL 324.30307(2)]; that authorize the MDEQ to feqw:.:st modifications in a requested permit application). Therefore, th8 MDEQ's

JAN 23 2007 9:23 AM FR ZOOt-Jag·ZZ C9:37~m ~rom-r~u ~A Kl~~u~ U'r~

Mr. Steven E. Chester December 1 9, 2003 Page 3

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November 7, 2002 letter should be treated as an indication thabthe MDEQ will approve the 2000 Plan Update upon proper ratification of the proposed changes by the Wayne County Commission and 67% of the county's: municipalities. Burdensome as this may be. the Legislature did not grant the MDEQ authority tc act otherwise.

4. Finally. the MDEQ's .legal authority to aQQrove a pl~n update_after the expiration of the 6-mcnth approval requirementcontained in se~tion 1_1_5 _ f P'Sitfr5-;-rvrct.-s22f.T'f53T.1$i'lot clear. In the absence o -any language indicating that a pena1ng pian update is automatically approved or denied if action is not taken within the statutory 6 months (contrasted with default approval language applicable to construction permits and wetlands permits), it is reasonable to conclude that the Legislature only granted the MDEQ the authority to act within 6 months of submittal of the proposed plan update to the MDEQ, and after that a resubmittal is required. Although it.may not be necessary for you to resolve that issue to decide the pending permit application is consistent with the Wa.yne County Plan. we ask that you consider it. at least, in weighing the equities involved in exercising your judgment and making your decision.

In conclusion. we urge you to use your discretion to continue to honor the partner'sfi1p create a 1n 1 99 I between the MDEQ and Countywide by approvLng tfie pending construction perm1t apphcat~e we strongly believe that you h~ more than sufficient legal justification to support a consistency conclusion and the issuance of our permit. there is also the more practical rationale that upholds the permit issuance based on sustaining Countywide's ability to provide protection of the environment. Countywide Landfill has successfully taken what was an enormous liability to the State of Michigan, Wayne County, and the residents of Gibraltar, and transformed it into an asset with the potential to afford the highest level of environmental protection. Without the permit1 Countywide's ability to finance the current and future improvements desired by the MDEQ is severely jeopardized.

Should you decide that more time is required to consider tha legal or technical issues before you, we would of course be willing to withdraw and re-file the application, provided that the MDEQ and Wayne County agree to issue a letter of administrative completeness for the re-filed app!idc'ition prior to January 1, 2004 (due to a concern about the potential impact· of pending legislation).

Please contact me at any time should you have any questions or wish to discuss our request. If you prefer, you may contact our legal counsel, Richard Barr, at (248) 273-2161.

1-'.21

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, Mr. Steven E. Chester December 19, 2003 Page4

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Thank you for your coi1slderation of our request.

Sincerely yours,

GISRAL TAR LAND COMPANY·

"\ l "\ t . By: t f'.__y •. · """.\::' ~- ·-~ c .. J.J: : .. · (. -~· ....

Matthew Wilkinson, Presi~ent

cc; Richard A Barr. Esq. Robert Reicnel, Esq.

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December 10, 2003

MJ;. Stephen E.. Ch.arter Di.:reaor . ' 11ichiga.n Departw~mt ofEnviroDme:n.W Quality Waste and flazardoos MM.eriili Div~<m P.O. Box 30241 l..nnsing~ MI 48909 ·

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RE: Construction Pornn~ Awli cation fc:r.r 11 v ectic:n.l Ei.pWlBion ~f Cotm~dt: Landfill.; ltO. Existing 1'ypc ill Solid Waste Landfill .

Dr:xr Sir. .,.

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. 'This 1~ will serve as'botb my private eotnmetlt$ 'aia my om~ c~~ ~the . Mayor of the City of Gibt~lt.n:r.

·• '

· . The .City of ffibrnltar e~ into a host~~ with Countywide in the·~ Of· 2001. an ~ent that th(:y have livod u.p oo 100%. Durini 1iuu time: the~ have · . . contribuu::d over $230,000 to the Cicy ~era} f\lt:l.d. These a(~ roaneys ~ the City has sor~b. ':l.Clt:1derl and have boeri u.sed to .fUnd proj~ th4t ha.ve ~efitcd the enti.re . c~unity. I' rn mm:- you're awG.tr.: of the devtiSb:itiAA dfects. tho Sttlt~~ s b'aZ!g& shortfall bM hnd on lO<!ru govet':I'Xt!Wnt; lo&B of this reVentl£ wouid prove to be a. di~ to cru.r city. ·.,, .

. . ., . 6->untywide hrut li~ n.p tO alltbcir·oommitmt'!IlU tmd l~m :rw:e iJs.rhe n:~ating body· you a.re aware that compliro:ice ~lire being .met at un ~st' I(')()% ~vet · , · · ·

· On a pclitical5ick~· I mil.6t-~otc.that, I was ~iect.ed i.n'N~vem~ :ioo1 a.-: M.;\yor of · : · · ·: · · ·· Gibralw: My opponent,. who,is ·.also l~g. t.b.c opposition for ~nsion'.;~ this ve:ry. ,~ ,:;·:.::··- .. :·:·issuei:z:i'hL"Tcsu:apaigi:ulndwa.!·dt:feated· · .· .. ···. · : .· · :· :;; , .. ·.· · · · .· · ·.

• ;;·,:.;~,:~: .. ','•(,:',0;J,},;',:"",>: .. ,·'.::.-:·-'."~,)·•(,,~':';,";, '.,, .. ,':' ...... ' ' ;·,<,:> .. ~; ,_,' · ... ;• i, . ' .. ·: .... · ' I •• ,

i _: .<}::··~; ·'·"'· .: :; .. In.1 ruinary 20C13 ,'tbili 'same group used the Sa.me is.sue in· an effort 'to .recall\P:te ~s Mayor. i ii~ :r.c)·o;:X-> .: ~ -~'·!.- :· ; . .:,'1£ you.(,ppose.·me landfill, vof.b u)rCc...'1l.I the Mayor;·Th.i:t~ 1itw'"ili !Wind a strong · : ''"'1\."'f\';':!.~-·\o~~;,~ :' .. 1··~-~- ...... _. .i~ ... •.•.•• . ' >. ., -~ .... : . . ," .. > ·; •'· · ..... '• . . ' ., .. ~~,A~'._, ...... :.!~·.~.:·'· ... :.'···~- ... ~ge-to~ng ... . ~· ... l··~ .. .. . • . . •

: :}.'i:~~i-<;.:;,·.'/' :'~:::,:~:~;' '\ .:~ .. ' , ' . ' ~ .. ; ·.. . . ,, ' " . ' . ' 1 • ,,The :r~ effort w~ ~~y dc:feared. I ~ ~t~ly say th.at tlJ.tj people of Gibraltar ·

· · contin~ ro speak far thc:mselve.~ rather than having otbm do it for tb£m .

. It seems to~. a.n.d the ciry's· position i::-: the S1®f.· tha.t the~ solution toi~lring this problem ll1.l3 been to bring the landfill up standarcfs, f'ill it nnd cap it. That is exactly what County Wide is intrn.ding to do. To sr:op short of the d~ign elevation willjU3t invite

• 29450 J11unro Aut>:-·we. Gibm/Utr, Micbtgan 48173 <o- 734 676.3.900 • }'a.;(. 734 676.150!)

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JAN 23 2007 8:22 AM FR TO 813138616878 P. 16

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mofl'l problem:3 in~ future, Problems that tht s.tnte and :fcde.tnl goven;une"Dt will have to

step in and expend lil~Y to oolvt.

~<;tmcywide is a priva!e comp~y who has taktm.s ~blic nui~e. cle.ane~"ri! up~ht lt llit.O compliance I'Uld tum~ 1t J.nto ale lln.UltC! Dtlml.t".Ss:-I-believ~ type of

roject tbe st..o.te should !!upport,. using private sector co.mfum.i~ and monies·. to ht!ilp solve public ~ ~ etf issues.

I fumly believe that tn deny County-Wide their ex~ on.. while not O'llly ~i:n2 bm:m to the City of Gibmlntr. would also show the pri:vst.c sector that the Sf.at:J: wa$ not sincet:"O in encouraging their help in cleaning up sites ti.kr. thb. ·

Mayor

Cc: Jim Sygo, MDEQ George Bruchm.o.n. MDEQ :Ben Ok:wumabua, MDF.Q Robat .M~o. Wayoe County Executive Rolx:rt Rartz., WCOOE Kurt.Hei..-a~:;, WQ)QE / Boh Rcic:b.el, Attonll'JY Cteneral' s Office

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JAN 23 2007 8:20 AM FR + TO 813138616878 ~. 11

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2007-Jan-22 08:35pm From~FEO E~ !I!KO~ 0:74 \..oo ~....., ~aooc.,.lt.,.IL...o ...,.. ~ ,.,....,._. 0 'I ' I' 09/15/03' 11 ;46 B :03/03 N0:3

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Sl:~. 9. l!l03 l: 49PM iJ

WAVNE COUNTY 0. 0. E. 313-224-0045

llCJbA,~ A. Fie'4N Cn.tiii'V E;tm.'n..t

Mr. Stellll!tt'l c. CJ'leator Olre~tQr Mlc:::hlgllh Oep.Qrtment of Environ!Tlonl.al O.t.J.rialit~ PO~ox30473 Lanaing, Mlclilg~;m -4.SGOG-?~7a

Oear Mr. Cheat.~

NO. l330 P. 2

nu~l'lk YQU for ya\Jr OQrra.&I)QMden09 of Juno 1 e. 2003. in whieh ~ou "'"':::ti'C$r::l witn WliiYI"l& C~unty tho (!Q~I'no ef e~ numt>.r ()( o,;~tto laQh!114'",.,. t.-gllrc:ting the Ftf;.:,poaed o:.p•l"l•ial'l ot tho CQuntywida LGndflll, •s l!);~re:u~~d lr'l thelt =-ortcstspondor'lOO to yo~ of May 7, 2003.

Tha Wayna coun1Y Dep~rttTJent• ot Envitonmont 11nd Coroortdlan Co1.1nsel tt~ h81ti•WCfd the cln=urT1fllNnc:al aurrotmdiog formElr W:oJyna C101wnt)l Ex~c\A~ ~dw•n:t MCNamara's daclslon regarding CQUnt~ldo'a propofJed wxp/Jl'lfltCIIi So~ an.ch..:j April zo. 200J corraapond<inca rrom ~mE. Eldor, Wlilyna County Ccrpor•tion co~,.~n,.,f, to Sts!e Ropreflentriltilfe l<a\hleen L.ilw. Biaed upon that r•vlow, Wayne county ccnoiLJc:tad ma.t Mr. McNamara's dttel!fon. wnt!e not supported by the cummt administration, wa' atrlw-d ilt in a mW'In..,r cc.1nt1•t.r.t with ttus proeua& d~~;~~~oc-rib•d in U'J• tt1en-Qxlatlng Solu:l Wueta ManaliJerrlt~nt Pliin ('VIe Pltir\"). Although nun docl:alon c:Qme after lh8 3Q~roval ot the Plan Updat•. Ccunt~prodtada0d:._Rt:J.ct:::IO~tba_a~pr:g'1!it Qf thO n&w Plan. UPactte, under thf'l ~ppro'lfd.l ~od .-P-pesl pr'Qcesses ~voll~blc to It undttr UH!t then .,xitJtln; f!Sfan. For thflfJD reosorut,~~:~e Copn!y bsll~vea that it would be lmiP-_5;!rCP-riQte to dl.stllrb th(l pi'OCICUra!Jlllalltl dBCiBlon by the erevio~ «dministr:a.!i,on.

How•vtu•. as ygu pcint cui in yout c;C;lrre;pcmdaf'lco of J~o~ne 161 2otJ3, tha Michigan Cepartrrtttnl rlf EnvlrQtlmentat Q\J-'Iity ("MCEQ'') will make a final detorminil!tton regarding thO ~pproval of tha prelpo:ted County-N\de erpan..,;ion. Wayne County c;1efers 10 the authOI'ity of MDEQ. . .....,__

Kurt L. HGt&BI, OlrQd:Qf' CC1.1brtm6nt of Erwironment

CEO Rabel't A. Fic=ttno CQrporntt.iill'l Co\Jn~l AJ:um Elder

DEPARtMENT OF ENVlRONMENT • ADMINISfRA.TlON 415 CLIFFORD, 7tll FLOOR, DETROIT, MICHIGAN 48226 313-224-3620

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