Environmental Justice by Bunyan Bryant

Author:Bunyan Bryant [Bryant, Bunyan]
Language: eng
Format: epub
ISBN: 9781597269469
Publisher: Island Press
Published: 2013-03-21T16:00:00+00:00

We urge the MDNR to adopt this policy and encourage the environmental and civil rights communities and the people of Michigan to support this policy recommendation. The state may say that it has final authority in this matter and choose to ignore this recommendation. The state should remember, though, that it is simply the representative of the people of Michigan. We urge the state in this spirit to reopen the issue of fish consumption levels in Rule 1057, to renegotiate these levels in light of the data and findings of this report, and to weigh our recommendations with participation by all affected parties. It is our hope that out of this process the state of Michigan will adopt recommendation 3 (Option 4) and move to more adequately protect those (including the highest consuming subgroup—minorities) who consume above the average sport fish consumption levels.

It is also recommended that policies be established by EPA to sponsor fish consumption studies of subsistence consumption of on-reservation Native Americans in Michigan and elsewhere. Less is known about these groups because they do not require state fishing licenses and therefore have not been included in the mounting number of sport angler fish consumption studies (West, 1992b). This imbalance needs to be redressed so that point discharge policies sensitive to their consumption needs can be more fully established.

It is quite possible that the minimum recommendation of using average fish consumption (about 15 GPD) will be adopted by the state if for no other reason than that the EPA’s Great Lakes Initiative may impose this standard on Great Lakes states, including Michigan. Moving to 30 GPD, while less than we would wish, will be strongly resisted by the state of Michigan. It will take a concerted effort to gain this level of protection for minorities and others who consume over the mean toxic-contaminated fish—an effort involving civil rights and environmental groups exerting political pressure on the state. It will not be enough to simply make this policy recommendation based in part on the findings of this study. If we are to achieve fish consumption standards more protective of minorities, and on par with the states of Minnesota and New York, we’ll have to fight vigorously here in Michigan and in other states. Nothing comes easy in the realm of environmental justice. It never has and, alas, it never will.

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