Mr. Russell Harding
Director
Michigan Department of Environmental Quality
P.O. Box 30473
Lansing, MI 48909-7973

Dear Director Harding,

The Michigan Land Use Institute urges the Michigan Department of Environmental Quality to reject Environmental Disposal Systems’ application to construct and operate a deep well injection facility in the City of Romulus. The Institute has grave concerns about the proposal's effects on land use, transportation, and public safety. Approval of the proposal also runs counter to the environmental management goals enacted by the legislature last year.

After careful consideration of the following concerns, we concur with the Site Review Board’s recommendation that the Michigan Department of Environmental Quality reject the application.

Affects on Existing Patterns of Land Use
The Romulus area is a delicate balance between residential neighborhoods and a regional airport along I-94, one of the state’s most important transportation corridors. Romulus already is an area of intensive land use. It also has the elements necessary to be a major economic hub in the future. While Romulus wrestles with deciding its future land use plans, a state decision to approve EDS’s development proposal despite local opposition will take away the community’s decision to choose its own future. Once a hazardous waste facility is sited, it will be a disincentive to future development in the area. And the inevitable nuisances, health risks, and stigma associated with the facility will limit the community’s economic future.

Transportation System
The proposed facility will be located near I-94 and the Detroit Metropolitan Airport. Both of these transportation centers are essential to the economic health of southeast Michigan. They are also currently overused. Any interruptions in service caused by accidents at the facility would cause a dramatic decline in transportation service and economic loss.
Moreover, heavily traveled I-94 is one of the most congested road segments in Michigan, and a poor choice for a route to carry hazardous waste generated across the Great Lakes and the nation.

Safety of Technology
Class 1 UIC wells are unsafe for the disposal of hazardous waste. In Florida, similar wells are the nation’s largest source of underground contamination of drinking water. These wells also are contaminating groundwater supplies in Texas, Ohio and Oklahoma. Alabama, Georgia and Wisconsin have already banned this well technology. The Institute urges the Site Review Board to learn from the mistakes of other states, and oppose use of this failed technology in Romulus.

A Move Away from a Sustainable Economy
Approval of the EDS proposal will provide an additional 96 million gallons per year of disposal capacity. According to the U.S. EPA, Michigan imported 817,230 tons of hazardous waste in 1997, second in the country behind New Jersey. Clearly, there is no need for additional disposal capacity to meet the needs of our state’s industrial community. Siting excess capacity likely will increase Michigan’s roll as a repository for the nation’s hazardous waste, and also lower the cost of hazardous waste disposal.

Increased capacity and lower costs will lessen incentives to prevent pollution, allowing businesses to continue practices that have long-term costs and consequences for Michigan’s environment and economy. This also runs counter to the legally binding goals established as a part of the last year’s amendments to P.A. 451 of 1994.
For these reasons, the Institute urges you to reject EDS’s application.

Sincerely,

Arlin S. Wasserman
Policy Director

Cc: Steve Sliver, Permit Writer, Financial Assurance