At the Seabrook Civic Association Monday October 15

Thank you to the Seabrook Civic Association, who invited me to be the guest speaker at their last meeting of the season on Monday evening. We discussed beach safety issues that had been the subject of discussion at the Board of Selectmen meeting earlier in the day, as well as the beach work, including the placement of storm fencing and the beach management movement of sand by our DPW. Thank you and congratulations to newly elected Civic Association President Vicki Sawyer.

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Seabrook Regional Household Hazardous Waste Day Saturday October 20, 2018

Seabrook will participate in a regional hazardous waste day on Saturday October 20, 2018 at the Exeter Public Works Garage, Newfields Road (Route 85) between 8:00 a.m. and 1:00 p.m. The below flyer has the details. For more information please call the Department of Public Works at 603-474-9771.

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Beach Safety Issues Memorandum Board Meeting October 15 2018

The Seabrook Board of Selectmen have instructed me to deliver a preliminary report on the options available to the Board relative to increasing safety measures at Seabrook Beach. That report, attached below, will be delivered at today’s meeting, along with the draft of a potential warrant article.

Board Memo Beach Safety Issues

Lifeguard Warrant Article Draft 2018

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Seabrook Harbor Dredge Project Receives Important Federal Funding

The Seabrook-Hampton Dredge project, which has had some preliminary engineering work done by the U.S. Army Corps, has received great news from Senators Shaheen and Hassan. The bipartisan America’s Water Infrastructure Act of 2018 has passed both houses of Congress, and will now await the signature of the President. Terrific news for the region, and for the fishing industry on the seacoast. Thank you to the N.H. Legislative delegation, and to Senator Jeanne Shaheen and Senator Maggie Hassan for their tireless work in support of this project. Below is the joint statement from Senators Shaheen and Hassan.

Shaheen & Hassan Provisions to Address Mitigation Efforts at Hampton-Seabrook & Portsmouth Harbors Head to President’s Desk as Part of Water Infrastructure Bill

(Washington, DC) – U.S. Senators Jeanne Shaheen (D-NH) and Maggie Hassan (D-NH) issued the following statements after the bipartisan America’s Water Infrastructure Act of 2018 passed the Senate 99-1. The biennial legislation authorizes water infrastructure projects around the country, and Shaheen and Hassan helped secure approval of mitigation efforts at Hampton-Seabrook and Portsmouth Harbors. The legislation will now head to the President’s desk to be signed into law, having passed both chambers.

“The shoaling of Hampton-Seabrook Harbor is so extreme that it has started to threaten the welfare of our fishermen and the sustainability of our Seacoast economy. As it has become increasingly more difficult for vessels to navigate the harbor, public safety and accessibility to and from the open water have become serious concerns – that’s why I’ve repeatedly fought to push forward on emergency dredging,” said Shaheen. “I’m glad to share that this legislation prioritizes emergency dredging for Hampton-Seabrook Harbor, as well as widening the uppermost turning basin on the Piscataqua River to address similar navigation safety issues. I urge the President to act quickly and sign this bill into law so efforts can move forward to deliver much-needed relief to New Hampshire’s coastal community.”

“Funding for mitigation efforts at Hampton-Seabrook and Portsmouth Harbors will help ensure the safety and vitality of our Seacoast,” said Hassan. “If fisherman cannot get their boats out to the open water, our coastal communities and small businesses will suffer, which could create a ripple effect throughout our state. I am pleased that the measures Senator Shaheen and I pushed for were included in the passage of this bipartisan bill and I am eager to see it become law.”

Addressing the Senate Committee on Environment and Public Works (EPW) leadership earlier this year, Shaheen and Hassan requested the Committee support emergency dredging at Hampton-Seabrook Harbor and the Portsmouth Harbor & Piscataqua River Navigation Improvement Project. Shaheen and Hassan’s letter can be read here.

The final America’s Water Infrastructure Act includes the language secured by Shaheen and Hassan that would permit emergency dredging for Hampton-Seabrook Harbor. Significant shoaling at Hampton-Seabrook has caused sand to pile high enough to prevent boats from exiting and entering the harbor at low tides. For Portsmouth Harbor, the current 800-foot width of the turning basin on the Piscataqua River is a safety concern for large cargo ships. Their provision will permit the basin to be widened by 400 feet, which will allow for broader use of area ports, improve navigational safety and provide an economic boost for New Hampshire and the region. In addition to Congressional approval, these mitigation efforts would need to be included in the Army Corps of Engineers’ (the Corps) work plan.

Additionally, Senator Shaheen successfully added language to the final bill to require the Corps to adhere to existing law requiring the regular release of a project report detailing all authorized Corps projects around the nation. Shaheen’s reporting requirement compels the Corps to issue the annual Harbor Maintenance Trust Fund Report to improve transparency so that Congress and the public are aware of all ongoing projects, including the status, funding levels and other relevant information on all Corps infrastructure priorities.

Senators Shaheen and Hassan have been fierce advocates on behalf of New Hampshire fishermen and coastal communities in Hampton and Portsmouth. In September, the New Hampshire delegation called on the White House Office of Management and Budget (OMB) Director Mick Mulvaney and Assistant Secretary of the Army for Civil Works R.D. James to include emergency dredging for Hampton-Seabrook Harbor in the OMB and the Corps’ fiscal year 2019 work plan. The New Hampshire delegation has repeatedly called for the Corps to dredge Hampton-Seabrook Harbor. Shaheen toured Hampton-Seabrook Harbor in the spring and released an exclusive video showing how badly the shoaling is occurring in the harbor, underscoring the need for federal assistance to perform emergency dredging.

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Mayor Dennis DiZoglio Authors New Book “The Value of Political Capital”

Former Methuen Mayor Dennis DiZoglio has authored a new book “The Value of Political Capital” which is now for sale at Amazon and bookstores everywhere. Mayor DiZoglio had a book signing event at the Nevins Library, where I got my signed copy and listened to his overview of lessons learned, and important concepts in local government that we can all glean from Mayor DiZoglio’s many years of service in local government. While I have not read it yet it is next in the reading line, and yes I will write a review that you can read here. Congratulations to Mayor DiZoglio for this work. (He told me to look in Chapter Two!)

The book can be found here.

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A look at Bob Woodward’s “Fear: Trump in the White House”

Fear: Trump in the White HouseFear: Trump in the White House by Bob Woodward
My rating: 4 of 5 stars

I am a veteran of the many Woodward books on Washington politics, and generally I have enjoyed them all. I enjoyed this one as well, but from my perspective it was not a flowing narrative of the Trump candidacy and Presidency, but rather a book that moves from subject to subject, depending on where Woodward’s primary sources took him. It is not hard to figure out who those sources are, with Cohn, Priebus, Bannon, Porter, et al being prominently placed in the book.

My view of the book is that it is a good read, fascinating in its own way, telling us some things that many likely understood to be the case before the book. Trump is shown to be a policy ignoramus, with the staff (sources) holding him back from his most reckless instincts, especially on foreign policy. Many of those episodes have been covered in the press, with Trump tweeting about many of them himself. Having said all that I did not take the book to be as negative to Trump as the publicity would have you believe. Whether Trump’s position on Afghanistan is cited (wants to get out) or on Iran (wanted to exit the nuclear agreement) the discussion does not show Trump to be off the rails as much as it shows an enthusiastic willingness to tell huge lies in support of his policy objectives. On Iran you can, and likely should, criticize Trump for his insistence that Iran was in “violation” of the agreement in spite of the evidence that showed otherwise, but that misses the larger point. Trump could care less whether Iran was in “compliance” with the terms of the agreement, with the truth of the matter not even remotely important. He wanted out of the agreement for political, as well as substantive reasons, and that desire simply put him into propaganda mode, which does not even consider what the truth is.

“One day Tillerson came to the dining room next to the Oval Office to see Trump and Priebus and explain to the president again that there was no violation. “They are in violation,” Trump insisted, “and you should make the case that this agreement is done and finished.” He suggested they might consider reopening the terms of the deal. “And that maybe we’d be willing to renegotiate.” “Mr. President,” Tillerson said in exasperation, “you have the authority. You’re the president. You just tell me what you want me to do. You call the shots. I’ll do what you say.” He was getting dangerously close to violating the protocols of dealing with a president.”

Woodward, Bob. Fear: Trump in the White House (pp. 131-132). Simon & Schuster. Kindle Edition.

On Afghanistan Trump’s lazy approach is criticized implicitly, but his view remains the view that he ran for President espousing, despite his unwillingness as President to follow through. Trump makes you pay a steep price, as a staff member, for forcing him to deviate from his gut instinct. I would have to say that Trump himself would not likely object to the below characterization.

“McMaster spent the initial part of the meeting identifying objectives and framing issues for discussion. Trump looked bored and seemed disengaged. After about five minutes, he interrupted. “I’ve been hearing about this nonsense about Afghanistan for 17 years with no success,” he said before McMaster had finished laying out the issues. We’ve got a bunch of inconsistent, short-term strategies. We can’t continue with the same old strategy. He brought up his meeting with the troops the previous day. The best information I’ve gotten was from a couple of those line soldiers, not the generals, he said. “I don’t care about you guys,” he told Mattis, Dunford and McMaster. We’re losing big in Afghanistan. It’s a disaster. Our allies aren’t helping. Ghost soldiers—those paid but not serving—are ripping us off.
NATO is a disaster and a waste, he said. The soldiers had told him that NATO staff were totally dysfunctional. “Pakistan isn’t helping us. They’re not really a friend,” despite the $1.3 billion a year in aid the U.S. gave them. He said he refused to send any additional aid. The Afghan leaders were corrupt and making money off of the United States, he insisted. The poppy fields, largely in Taliban territory, are out of control. “The soldiers on the ground could run things much better than you,” the president told his generals and advisers. “They could do a much better job. I don’t know what the hell we’re doing.” It was a 25-minute dressing-down of the generals and senior officials.”

Woodward, Bob. Fear: Trump in the White House (pp. 124-125). Simon & Schuster. Kindle Edition.

Trump’s views on trade, and his stated desire to promote trade policies that would “bring back manufacturing” to the United States are covered in some detail, with Woodward highlighting Gary Cohn’s fruitless attempts to explain the textbook economics of trade to Trump. The book shows Trump’s refusal to contemplate change in his trade beliefs despite a constant drumbeat from Cohn:

“Several times Cohn just asked the president, “Why do you have these views?” “I just do,” Trump replied. “I’ve had these views for 30 years.” “That doesn’t mean they’re right,” Cohn said. “I had the view for 15 years I could play professional football. It doesn’t mean I was right.”

Woodward, Bob. Fear: Trump in the White House (p. 138). Simon & Schuster. Kindle Edition.

But again I think the effort to show Trump as either ignorant of, or unwilling to learn, on trade misses the larger point. He does not care about the truth on trade because he perceives the politics of his position as bearing fruit in critical areas of the country, such as Michigan and Pennsylvania. That is all he cares about, so he will deny (and infuriate academics) obvious economic truths because those truths are not important to him, and acknowledgement could be politically damaging to him. (See global warming)

Trump’s dysfunctional method of managing staff is highlighted, but we did not need the book to show us that. It has been covered extensively in the media and frankly has not even been a blip on the political radar. But it is very entertaining.

The book is, as always with Woodward, well researched and well sourced. No question in my mind that the episodes represented are accurate. Woodward always gives you a readable and entertaining book, and this is no exception. Trump has dominated the media coverage of his candidacy and presidency, and even though this book highlights some of his glaring deficiencies it simply is part of that domination, and not likely to change any views on the Trump presidency. The first answers on how the public views that Presidency are right around the corner with the mid-term elections. Read the book, but more importantly get out and vote in those mid-terms. The future of the country depends on it.

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A Look at “Servants of the People: The Inside Story of New Labour” by Andrew Rawnsley

Servants of the People: The Inside Story of New LabourServants of the People: The Inside Story of New Labour by Andrew Rawnsley
My rating: 5 of 5 stars

Andrew Rawnsley does a superb job of covering the first term of Prime Minister Tony Blair’s “New Labour,” starting with Blair’s landslide victory in 1997 (179 seat majority) and how a group of governmental neophytes got around to the job of forming a new government after years in the political wilderness. We get right to the love/hate relationship of Blair and Gordon Brown, the new Chancellor of the Exchequer, his rival and ally. The Blair/Brown relationship dominates the book, as it should. That fabled relationship would likely be able to fill a book all by itself.

Rawnsley gives us some “inside baseball”(gossip) but does not neglect substance. He is not at all reluctant to criticize both Blair and “New Labour” for what he considers to be their shortcomings, but sticks in praise when he feels it warranted. Rawnsley was a skeptic on the so called “third way” politics espoused by Blair, not buying into Blair’s contention that centrist problem solving could produce government that delivers for people. What was Blair’s idea of the “third way?”

“My vision for the twenty-first century is of a popular politics reconciling themes which in the past have wrongly been regarded as antagonistic – patriotism and internationalism; rights and responsibilities; the promotion of enterprise and the attack on poverty and discrimination…”

Rawnsley, Andrew. Servants of the People: The Inside Story of New Labour (pp. 311-312). Penguin Books Ltd. Kindle Edition.

We see today how Blair’s prescription has gone off the rails, with “patriotism” seen by so many as irreconcilable with “internationalism,” or globalism. We have heard that directly from Donald Trump at the United Nations in the last week. Rawnsley highlighted prominent critics of the Blair philosophy:

“The attempt at a united field theory of politics pretended that there were never any choices to be made between competing interests and contradictory values. But to govern is always to choose. The interests of business and the requirements of social justice were sometimes reconcilable, but they could also be mutually incompatible. It was a useless compass when confronted with a decision which did not permit of compromise. One of the most acute of liberal critics, the philosopher Ralf Dahrendorf, identified the Third Way as a politics that speaks of the need for hard choices but avoids them by trying to please everyone.”

Rawnsley, Andrew. Servants of the People: The Inside Story of New Labour (p. 312). Penguin Books Ltd. Kindle Edition.

Blair’s heavy borrowing from Bill Clinton is highlighted. Blair was always considered a Clinton acolyte, and there is no doubt that New Labour took much of its political philosophy from the Clinton playbook.

“The apparent similarities with Bill Clinton, from whom New Labour had certainly looted much of its rhetoric, many of its techniques and some of its policies, also struck another American. Maureen Dowd accused Blair of ‘cloning himself from a clone’.”

Rawnsley, Andrew. Servants of the People: The Inside Story of New Labour (pp. 5-6). Penguin Books Ltd. Kindle Edition.

Rawnsley was not only skeptical on the “third way” philosophy, but manages to weave into the narrative the constant charge that Blair, and New Labour, were more interested in media puffery and spin than on substance. His reference to the very skillful spinmeisters serving New Labour, and the frequent war between the media operations of Blair and Gordon Brown, are interesting and have a ring of truth. Without question Blair got caught up rather early in some party financial chicanery that did not reflect well on him (Ecclestone affair) as well as making a hash out of the Millennium Dome project, and those failures are highlighted prominently. Rawnsley is fair, and covers the achievements as well, including the Good Friday Agreement, the reform ceding interest rate power to the Bank of England, Blair’s determined and principled stand on Kosovo, and some of the progress made, through difficulty, on major domestic issues, like the National Health Service. As a precursor to the Brexit debate raging in Britain today the New Labour government faced the issue of whether to join the single European currency. That controversy, which Blair straddled on, lent some credence to the idea of spin over substance. But Blair was, like Theresa May today, faced with some pretty difficult cross currents to navigate. Blair’s heart was in Europe, but he could never muster the political strength to integrate into the Euro.

I do not agree with Rawnsley entirely on the issue of New Labour being all spin and no substance. Gordon Brown is recognized as having been a person of major substance as Chancellor, and Blair is without question brilliant and articulate. I had the opportunity to watch many segments of Prime Minister’s Questions with Blair fending off William Hague with relative ease. There were major achievements, and principled stands that may have cut against the political grain, (Kosovo) showing that Blair was not “substance free.” The book weaves together the full first term, and is an easy read, especially for those that enjoy government, and British politics.

Blair remains an interesting figure, both brilliant, and at times not so much. His idea that centrist politics would be predominant, that technocrats would find the “best” solutions to governmental issues of the day, has clearly collapsed, along with the political center. Might Blair himself be responsible for some of the wreckage of the “Third Way?” His decisions on British participation in the invasion of Iraq certainly played a role in his decline in popularity in future years, but that did not occur in his first term. He managed to win another landslide victory and become the first Labour Prime Minister to serve two full terms. What happened after the first term? I guess we will have to read Rawnsley’s “The End of the Party: The Rise and Fall of New Labour” to find out. I highly recommend this first installment.

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Seabrook Meeting on Harbor Dredge Tuesday September 25, 2018 at 6:00 p.m.

The Seabrook Board of Selectmen will hold an informational meeting on the Seabrook Harbor Dredge Project at Seabrook Town Hall tonight, Tuesday September 25, 2018 at 6:00 p.m. The U.S. Army Corps of Engineers will be on hand, as well as a representative from New Hampshire Fish and Game. The discussion will be focused on the placement location for the sand that is dredged from Seabrook Harbor.

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Public Information Meeting Hampton Harbor Bridge Project

A public information meeting on the New Hampshire DOT Hampton Harbor Route 1A Bridge project will be held this Wednesday September 26, 2018 at the Marston Elementary School in Hampton starting at 7:00 p.m.

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The EPA Report on Flint Water

The story of the Flint water system, and how governmental action (and later inaction) created infrastructure that poisoned the residents of Flint by the supply of tainted water, has not only impacted the residents but has left a wide trail of recrimination, finger pointing, and now indictments. The Michigan “Emergency Manager” law is under siege as a consequence of key decisions being made by Emergency Managers in Flint appointed by the Governor. The history and the effectiveness of that law requires another post. For today we have the release of the EPA report on the Flint water situation. While the EPA report does deal with some technical data it is instructive in how the relationship between the State and the EPA worked, and is working today, and the failures of management at the EPA level that allowed state and local malfeasance to continue until it was too late for the residents of Flint.

Before you can even get to “what happened,” determining who was in charge, and who had the statutory authority to act, is vital. Although ultimately governed by federal law the EPA has granted most states “primacy” in enforcement, meaning that the State handles enforcement of the (Safe Drinking Water Act) federal law after a finding by the EPA that the state is equipped to do so. Michigan was operating under “primacy” in this instance. From the report:

The SDWA, 42 U.S.C. § 300f et seq., is the federal law that protects public drinking water supplies throughout the nation. The law assigns the EPA Administrator the ultimate authority to protect public health by setting and enforcing drinking water quality standards. However, the SDWA allows the EPA to grant states the authority to implement and enforce SDWA regulations in an arrangement referred to as “primacy.” To receive EPA approval for primacy, states must demonstrate that they have adopted regulations that are at least as stringent as national requirements, are implementing adequate procedures for the enforcement of these regulations, and will keep records and make reports as the EPA may require. The EPA has granted nearly all states—including Michigan—primacy to implement the SDWA. When states are granted primacy, the EPA retains the responsibility for overseeing state implementation and federal enforcement authority. In 1978, the EPA determined that Michigan met all SDWA requirements to be granted primacy, including adopting and implementing enforcement procedures.

The “primacy” of Michigan did not take away ultimate oversight authority from the EPA, but it certainly put Michigan in the position of initial oversight of the transactions that created the problem in Flint. When Flint determined that they were going to change their source of water from the Detroit water system to the Flint River the MDEQ (Michigan Department of Environmental Quality, the primacy agency) did not require Flint to add anti-corrosion chemicals, a fatal error. But beyond being an error was it also a violation under the LCR component (Lead & Copper Rule) of the SDWA that Michigan, under primacy, was charged with enforcing? This EPA report claims that it was, but seems to acknowledge some degree of gray in the “interpretation” of the LCR by the MDEQ.

Under the MDEQ’s supervision, the Flint water system did not adhere to two Lead and Copper Rule requirements: (1) develop and maintain an inventory of lead service lines needed for sampling, and (2) maintain corrosion control treatment after the water source switch in April 2014. The rule requires utilities to minimize consumers’ exposure to lead in drinking water. As the primacy agency, the MDEQ is responsible for enforcing this rule for Michigan water systems. The MDEQ did not issue a notice of violation or take other formal enforcement action regarding either requirement until August 2015. Instead, the MDEQ advised Flint public water system staff to conduct additional tests and to delay corrosion control treatment installation. The decision to delay corrosion control treatment prolonged residents’ exposure to lead.

Once the decision was made to “test” rather than ordering the anti-corrosion treatments after the switch in water supply the Flint water infrastructure was permanently damaged. As the extent of the problem began apparent the reaction of the MDEQ, the EPA, and of the Flint local authorities was slow and ineffective. Flint made a determination to switch back to the Detroit water system (renamed the Great Lakes Water Authority) which had anti-corrosion treatment in the system. They additionally added anti-corrosion treatment of their own, but the damage to the system was done, and lead levels in the water did not drop below federally acceptable levels.

In October 2015, instead of installing corrosion control treatment, Flint’s water system returned to purchasing drinking water from the Great Lakes Water Authority (formerly called the Detroit Water and Sewerage Department), which already included corrosion control treatment. At the time of this change, almost a year-and-a-half of exposure to improperly treated water had damaged the city’s drinking water infrastructure, and lead concentrations continued to rise. In December 2015, the MDEQ reported that Flint began supplementing Detroit water with additional corrosion control treatment. However, due to the damage done to the Flint distribution system, the lead levels in drinking water did not fall below the federal action level until late 2016.

The EPA report deals with the interaction between the State of Michigan and the EPA, and is without question vitally important in understanding the management and systemic failures that brought catastrophe to the residents of Flint. There is a lot more to the story, including the interaction between the local government and the MDEQ, and the role of the Emergency Managers who were running the City of Flint under the authority granted by the Michigan State Legislature (Public Act 436 passed in 2012.) Two of those Emergency Managers were indicted, as well as two local officials connected to the delivery of water to the residents of Flint. Public Act 436 has had much written about it, but for the purposes of this post I will leave that discussion for another day. The Anna Clark book “The Poisoned City: Flint’s Water and the American Urban Tragedy” will be reviewed here soon, with Public Act 436 left to that post.

The below report highlights the management failures on the part of the EPA. It is evident to me that the MDEQ “primacy” in enforcing the SDWA led to laxity on the part of the EPA in looking at the critical early actions of the MDEQ when Flint made the water system change over. The communication between the EPA and the MDEQ was lax, as the EPA acknowledged in the report overview. From my perspective the lack of clarity in the language of the LCR led the MDEQ to make the wrong call on the legal requirement that the new source of drinking water for Flint contain anti-corrosion treatment. While the EPA cited that error, and stated clearly that the MDEQ should have ordered that treatment under the LCR, the damage was done. Where was the initial EPA review of that fateful decision? Why did the language of the LCR leave any doubt as to the correct course of action for the MDEQ, and the City of Flint, as to whether the switch in water systems required the addition of anti-corrosion treatment? The report highlights the dispute between the EPA Office and the MDEQ on the legal requirements of the LCR on this question, which highlights to me the obvious language difficulties in the LCR. Spending time seeking legal clarity on the intent of the language in a situation where the requirement should be clear points to the need for some adjustment to the LCR language.

Region 5 stated that the length of time that it took to obtain a legal interpretation delayed formal intervention. In a July 2015 meeting, the EPA and the MDEQ disagreed over interpretations of LCR corrosion control treatment requirements in Flint. The MDEQ requested, and Region 5 program staff agreed to obtain, a legal opinion from EPA headquarters. In August 2015, Region 5 and EPA headquarters began discussing Flint compliance with the requirements and the MDEQ’s interpretation of those requirements.
However, headquarters personnel stated that Region 5’s characterization of the situation lacked a sense of urgency. Region 5 did not make an official request for a headquarters’ opinion until September 30, 2015. Region 5 did not receive a legal opinion, but the region’s request ultimately resulted in a November 2015 Office of Water memo clarifying the LCR corrosion control treatment requirements for all large water systems.

The failure of communication, mentioned above, is highlighted by the below excerpt, again centered on the disagreement on whether the LCR required the addition of corrosion control after the system change by Flint. From my perspective it is a failure of both the EPA and the MDEQ, but if the MDEQ was making the wrong call it was incumbent on the EPA to order the MDEQ to add the corrosion control. It is amazing to me, from a management perspective, that such an issue was not vetted as Flint looked to make the water system change.It should have been on a punch list that was evaluated by the MDEQ, and reviewed by the EPA, with the final determination made before any change was approved. The weakness of the EPA field office is shown clearly by the below.

Region 5 told us that communication with the MDEQ was frequent, consistent and clear, but the MDEQ failed to take appropriate actions when Region 5 consistently identified problems. According to EPA Region 5 managers, in April 2015, the EPA voiced concerns about the lack of corrosion control treatment to the MDEQ’s Water Director. Region 5 managers said that in June 2015 they advised the MDEQ that the LCR required Flint to maintain consistent corrosion control treatment. However, an MDEQ manager stated that Region 5 did not advise them to initiate corrosion control at that point.

The report does not attempt to hide the federal deficiencies.The EPA Inspector General brought forward the summary of management failures exhibited by EPA Region 5, and discussed each one in detail.

The EPA retains oversight and enforcement authorities to provide assurance that primacy states comply with the SDWA. However, timely oversight interventions rely on effective management systems that govern how and when the agency should intervene. EPA Region 5 did not manage its drinking water oversight program in a way that facilitated effective oversight and timely intervention in Flint. EPA Region 5 did not:
• Establish clear roles and responsibilities with the MDEQ.
• Communicate clearly and effectively.
• Use effective risk assessment protocols.
• Proactively use available SDWA authorities and oversight tools to intervene in Michigan’s drinking water program.
These weaknesses limited Region 5’s ability to monitor, adapt and respond to changing situations in Michigan and the city of Flint.

The failures of the EPA in this case need to be remedied so that future calamities are avoided. There is no substitute for strong management, even where areas of responsibility may not be clearly delineated.Sometimes that strong management requires the placing of inter-agency collegiality on a lesser scale of importance. Although not covered in this report the question of whether Michigan should have “primacy” revoked so that the “roles and responsibilities” issue is resolved in favor of full EPA regulatory authority was not mentioned, although it probably should have been. The human costs of these mistakes have been severe. Hopefully the lessons learned will help avoid these costly management mistakes in the future.

EPA IG Flint Report July 2018

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