MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY  
Public Hearing for the Administrative Rule Sewerage Systems  
Tuesday, April 8, 2025  
APPEARANCES:  
For the Michigan Department of Environment, Great Lakes, and Energy:  
Jim Ostrowski – Environmental Support Division (ESD)  
Phil Argiroff – Water Resources Division (WRD)  
Alyssa Sarver – WRD  
Charlie Hill –WRD  
TABLE OF CONTENTS  
Statement by Jim Ostrowski  
Statement by Alyssa Sarver  
Statement by Joel Roseberry  
Statement by Charles Hill  
Statement by Phil Argiroff  
Statement by Sally Duffy  
Statement by Jacob Mitchell  
Statement by Greg Tatara  
Statement by Mike Stephens  
Statement by Brad Johnson  
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In-Person and Zoom Public Meeting  
Tuesday, April 8, 2025 – 11:00 a.m.  
JIM OSTROWSKI: Thank you, Phil, Charlie and Alyssa again, my name is Jim  
Ostrowski, the Environmental Support Division here at EGLE. We are now going to start the  
public hearing portion of today's meeting and I'll be the hearings officer for the hearing and  
for the proposed Part 41 administrative rule revisions, specifically 2024-52 EQ, Sewer  
Systems. I'm going to have Alyssa go ahead and read the hearing, official hearing  
statement and it's kind of long, but I'll let you if you want to read it from there, you can go  
ahead.  
ALYSSA SARVER: Happy to. So, in order for the rules to be adopted, the Department  
must follow the procedure set forth in the Administrative Procedures Act, Act 306 of 1969,  
Michigan Department of Environment, Great Lakes, and Energy Public Hearing  
April 8, 2025  
as amended. The purpose of today's hearing is to give anyone interested an opportunity to  
provide information that the Department may use to make changes to the proposed rules.  
We are here today to receive public input on these proposed changes. The Notice of this  
public hearing was published in three newspapers of general circulation, the Lansing State  
Journal, the Mining Journal, and the Oakland Press on March 25th, 2025. The public hearing  
was also posted to EGLE’s Environmental Calendar on March 5th, 2025. Copies of the  
Notice of Public Hearing, Regulatory Impact Statement, and the proposed rules have been  
made available on the Michigan Office of Administrative Hearings and Rules, MOAHR  
website.  
Please understand the purpose of the hearing today is to provide an opportunity to  
receive and listen to your comments only. The hearings process does not allow for open  
discussion or questions about the proposed rules. EGLE staff will not be responding to  
questions or comments during the hearing. This hearing is being recorded, and your  
comments will become a part of the information the Department will consider when  
finalizing the proposed rules. The public comment period for the proposed rules ends on  
April 30th, 2025 at 5:00 PM. If you have written comments or materials that you would like  
to submit, please email them to [email protected] by 5:00 PM on April  
30th.  
Following the public hearing, we will review the written and verbal comments  
received during the comment period. Once this review is done, an Agency Report will be  
prepared. The Agency Report will explain any additional changes EGLE may make to the  
proposed rules as a result of comments received. It will also summarize who is in favor of  
the draft rules and who is opposed to them. The proposed rules and the Agency Report will  
be submitted to the MOAHR and the Joint Committee on Administrative Rules, JCAR.  
JCAR is a bipartisan legislative committee made-up of five House and five Senate members  
that provide legislative oversight of the rulemaking process. The Agency Report will be  
available on MOAHR's website or by contacting the WRD office. Once approved, the rules  
will be filed with the Secretary of State and will take effect immediately after filing. You can  
follow along the rulemaking process step-by-step by going to MOAHR's website.  
JIM OSTROWSKI: All right. Thanks, Alyssa. So just for the record, just want to make a  
note that here in attendance to get about 11 people here including EGLE staff. Also with me  
today is Joel Roseberry with our division. Joel, how many people online do we have?  
JOEL ROSEBERRY: 25  
JIM OSTROWSKI: 25 people online. Very good. All right, so to ensure today's hearing  
is conducted in a fair manner, we're going to follow these steps. I'm going, I've got  
everybody that wanted to make a comment here in person has filled out one of these  
comment cards and I'm going to go through those first. When I call your name up here, if  
you would, please come up to the desk and say your name and any organization that you  
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Michigan Department of Environment, Great Lakes, and Energy Public Hearing  
April 8, 2025  
might represent and then you can begin your comment. OK? Each person will have four  
minutes to make their comment today and I'll be tracking it on my phone. That's why I'm  
looking on my phone here. After we get through the people here in the audience that would  
like to make a comment, we are going to open it up to people online that would like to  
make a comment. And up on my screen here, I've got an indication how you do that. You  
can click the raise hand icon and you can make a comment, and Joel will let me know if  
your hand is raised and I will call on you and we will unmute your mic so you can make a  
comment. You can also submit your comment in the Q&A box if you don't want to voice  
your comment. If you do that though, make sure you type the word “comment” first, write  
the word “comment,” then enter your comment, and I'll have Joel read that off verbally on  
here. Also, if you're on the phone, do we have anybody on the telephone today?  
JOEL ROSEBERRY: One.  
JIM OSTROWSKI: One person on the phone. If you're on the phone and you'd like to  
make a comment, hit the pound two button on your phone, hit pound two and that'll  
indicate that you want to make a comment to us. OK. When all comments have been  
completed, we'll ask if anyone else would like to make a statement and anybody else  
hasn't made a statement and wants to, you can certainly do that then. Just a reminder,  
each person will have four minutes to make their comments, and we will indicate when you  
have one minute remaining. Please begin wrapping up your comments and end within the  
allotted time frame. If need be, we'll indicate when your time has ended.  
All right, so we'll get started then. And again, you know, probably should have you  
guys introduce yourselves because we didn't officially do that. So, I'm going to have you  
guys go each go through and introduce yourselves in your title.  
ALYSSA SARVER: Sure, that's a good idea. For the record, my name is Alyssa Sarver.  
I'm the Wastewater Certification and Exam Specialist for the Water Resources Division at  
EGLE.  
CHARLES HILL: Charles Hill, Wastewater Engineering Specialist for Water  
Resources Division at EGLE.  
PHIL ARGIROFF: Phil Argiroff, an Assistant Division Director in WRD.  
JIM OSTROWSKI: All right, thank you. And so just a reminder, they're just here to  
listen, take notes to your comments. So, they're not going to be answering any questions or  
anything like that. Yeah. All right. So, the first person that indicated they want to make a  
comment is Sally Duffy. Sally, you can come right up. And remember to state your name in  
any organization you represent, and you can get started when you're ready.  
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Michigan Department of Environment, Great Lakes, and Energy Public Hearing  
April 8, 2025  
SALLY DUFFY: OK. Thank you. Yeah. I'm Sally Duffy. Hubble, Roth, & Clark  
Consulting Engineers out of Bloomfield Hills, MI. I think I'll go ahead and just submit written  
comments that might be easier because we have until April 30th to do that. As my  
understanding to the email account, most of the comments are just suggestions on  
tweaking some language and definitions. So yeah, I think at this point, it might be better to  
follow up with an email. Thank you.  
JIM OSTROWSKI: OK, thanks, Sally. And we'll be showing up on the screen again  
how you make comments other ways too. Next up is Jacob Mitchell. So come on up, Jacob.  
JACOB MITCHELL: Hello, my name is Jacob Mitchell. I'm the Lead Collections  
Operator for MHOG out of Genoa Township. First, I want to thank Greg and everybody else  
who put their hard work in to get this off the ground. I'm very excited to talk about  
something that's going to make a big difference in our industry in the new collection  
system operator certification. It isn't just another requirement box to check, it's a real step  
forward. By setting clear standards for training and knowledge, we're bringing more  
consistency, accountability, and professionalism to the work that we do. Certified  
operators have always played a key role keeping our system safe and running smoothly.  
But now with the new certification, we're raising the bar even higher. And what's the biggest  
benefit? It makes our employees more valuable. It gives them more tools and training to do  
their jobs better, and safer, it turns a job into a career path. And for employers, it means a  
stronger, more skilled team that is ready to handle whatever comes next. So, let's not see  
this as just another requirement. Let's use an opportunity to grow and invest in our people  
and to build a better future for our industry and the communities that we serve. Thank you.  
JIM OSTROWSKI: All right. Thanks, Jacob. All right, next person here is Greg Tatara.  
Greg, come on up.  
GREG TATARA: Thank you. My name is Greg Tatara. I'm the utility director with the  
MHOG Sewer and Water Authority. I look back at my notes and the very first meeting we  
had on this was December 3rd of 2019, upstairs. I remember that well when we first  
brought this up. And just to kind of highlight based on what Jake said, this was born from  
our employees coming to us and saying, you know, we have a specific division that's just  
collection systems. They came to us, saying like, we want to be treated the same as the  
guys that get distribution licenses, and the guys that have wastewater operator licenses.  
And you know, in our group it was always seen that the, collection guys were kind of like  
the, you know, not the most deserved position. And people always want to get out of that  
because they could advance more in distribution and then go to a bigger system to work  
and things like that. So, really this was born out of that. That request I received from, from  
my employees.  
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Michigan Department of Environment, Great Lakes, and Energy Public Hearing  
April 8, 2025  
As an employer, I want to speak more from an employer standpoint here as to what  
it means for us. So, it gives us the ability to treat employees equally across the board. So, if  
I have collection operators, water distribution operators and operators, now each of them  
have a very similar collection path. So, I can base my, you know, rates of pay and things  
like that on advancing in, in those different categories. It increases the knowledge of our  
staff. Our staff now will be more knowledgeable, which will hopefully decrease our liability  
that we have.  
I view our collection systems as one of our biggest sources of liability from sewer  
backups to SSOs and it hopefully will reduce the liability we have with that. It provides  
standardization across the industry. So, if we do have to hire or do a recruitment for  
somebody, I know I'm getting somebody with a certain base level of knowledge if I hire that  
person in the future they come with a certain certification. It will improve the management  
of our assets, you know, the millions and millions of dollars our residents have paid to  
build the infrastructure we have and improves that management of that. That lifetime of  
that management.  
And then, it helps me with succession plan. As a director, I can look now for people  
who are advancing their career and look to them to become the leaders of the future and  
leave our system in a better place than I inherited it. So, I'm in favor of this, of course. And I  
just wanted to speak to you from an employer standpoint, what benefits I see. Thank you.  
JIM OSTROWSKI: Thanks, Greg. Can you repeat one more time? I didn't catch that.  
Which organization you're from?  
GREG TATARA: MHOG Sewer and Water Authority.  
JIM OSTROWSKI: OK, thank you. OK. Next person up is Mike Stephens. Mike, go  
ahead.  
MIKE STEPHENS: Hi, good morning. Mike Stephens with Guardian Wastewater here  
mostly representing probably the small guy in the room. So privately owned public  
wastewater facilities. I applaud your efforts on this. I know this probably include  
encompassed a great deal of time. I think one of the things that I wanted or noticed really  
quickly, I think we may have underestimated the impact or the small private facilities that  
might be affected by this regulation. So, I did read the impact statement, which estimated  
only 5% of 600 municipalities would be affected or were indicated as privately owned. That  
would be 30 systems estimated. I can tell you that our company operates 33 systems. So, I  
can tell you it's far greater than 30 systems that are privately owned public facilities. I think  
the operator training and certification, you know, we had to in the private industry, we had  
to step up when these privately owned facilities were reclassified as municipal facilities.  
So, the municipal wastewater operator certification programs are very much geared  
towards full time municipal operators, the 2,000 hours requirement to get to even exam for  
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Michigan Department of Environment, Great Lakes, and Energy Public Hearing  
April 8, 2025  
the system. So that was a great deterrent for private operations companies like ourselves  
to get municipal operator licenses to operate private, privately owned, public facilities. So,  
I'm glad to see that there aren't like those hour classifications in the in the collection  
system certifications that you're looking at. So that's good. But we had to step up and find a  
way to gather six years over multiple facilities to get the necessary 2,000 hours to test for  
those municipal examinations.  
I do want to comment. I think, I think you could better clarify the term “public.” And  
that's very important for privately owned public facilities. You talk about public as being  
one and more persons, but then you also talk about public sewer systems and may or  
being one or more individually owned properties or individually owned facilities. You define  
“public,” but you use the word public in the definition. So, I think there's, there needs to be  
better clarity on defining public or publicly owned facilities. This would be very important  
for the privately owned facilities.  
The collection systems. I, I did notice and many of the facilities that we operate  
would fall below that 50 connection limit, but there are some systems that would fall  
between 50 and 1,000. However, I noticed that you specifically exempted or omitted the  
language of low pressure sewer systems.  
JIM OSTROWSKI: One minute.  
MIKE STEPHENS: OK. And I'm curious as to why low pressure sewer systems was  
omitted and how those systems, low pressure sewer systems, would, would be classified  
between 50 and 1,000 connections. It appears that they don't, they're in a no man's land.  
And then I do think that, that plan review for Part 41 applications, since they're for  
public facilities, should be reviewed by professional engineers. If they're being submitted  
by professional engineers, plans are submitted by professional engineers. I think they  
should be. And that was the department's policy, I know quite a long time ago. I would like  
to see that again. And then I do think we did find out recently that the policy or guidance  
regarding responsible charge of the day-to-day operation and maintenance, the  
department doesn't have any guidelines on that. So that has been determined to be fairly  
subjective based on the EGLE staff compliance person. So, I would like to see more  
clarification into that. So, thank you so much.  
JIM OSTROWSKI: All right. Thanks, Mark. Mike. OK, I'm going to grab you, slide that  
mic down here. OK, so now does anybody else here want to make comment, in person?  
OK, going online, Joel, does anybody have their hand raised online? OK, just a reminder, I'll  
leave it open for just another few seconds here if anybody online will make a comment.  
You can click the raise hand icon on your Zoom toolbar. If you're on the phone, you can hit  
pound two or you can type your comment in the Q&A box and write the word “comment”  
on it. They always wait a minute because there is a little lag sometimes in Zoom so. Is there  
any hand raised?  
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Michigan Department of Environment, Great Lakes, and Energy Public Hearing  
April 8, 2025  
JOEL ROSEBERRY: Excuse me, I have one hand raised.  
JIM OSTROWSKI: OK, we do have a hand raised, name?  
JOEL ROSEBERRY: Brad Johnson.  
JIM OSTROWSKI: OK, Brad, we're going to unmute your mic and you can go ahead  
and make a comment. Just reminder to state your name, any affiliation and you got four  
minutes.  
BRAD JOHNSON: Hello, my name is Brad Johnson with Chocolay Township. I just  
wanted to thank the EGLE staff for putting this forward. This is going to be a great, a great  
thing. I, I don't know if I said where I'm from with Chocolay Township up in the Upper  
Peninsula. This is going to be great for us up this way. It's going to, give it, open up a lot  
more opportunity for training and stuff like this for our staff. I think it's going to be very  
beneficial, and I'd like to thank you guys a lot for doing this. Thank you.  
JIM OSTROWSKI: OK. Thank you, Brad for your comment today. Anyone else Joel?  
JOEL ROSEBERRY: We have a comment in the box and it just says please define  
operator.  
JIM OSTROWSKI: OK, so a comment came in and says please define operator.  
Thank you. And that'll go in our record as well. Anything else online?  
JOEL ROSEBERRY: No, I do not have anything else at this time.  
JIM OSTROWSKI: OK. With that then I will read our closing statement. Before I do  
that, I want to make sure I point out to those here and online the other ways to submit an  
official comment. You can do it via email, by sending an email to EGLE- WRD-OpCert,  
which is [email protected]. You can also submit comments by mail: Michigan  
Department of Environment, Great Lakes, and Energy, Water Resources Division,  
Attention: Alyssa Sarver, 525 W Allegan St. PO Box 3O458, Lansing, MI 489O9 and the  
comment period after this public hearing will be open until 5:00 PM on April 30th, 2025.  
Thank you for your comments and cooperation. We appreciate that you have shown  
interest in these proposed ruler revisions by taking the time to be here today, both in  
person and online. And as previously mentioned, the public comment period ends April  
30th, 2025 at 5:00 PM. Do you have any questions regarding the proposed rules, please let  
me know or you can come up here and visit our WRD staff once we're done. Also, on the  
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Michigan Department of Environment, Great Lakes, and Energy Public Hearing  
April 8, 2025  
screen for those that are online, I put Alyssa's contact information. I'll leave that up there  
for a minute. The hearing is now closed. And thank you again for being here. Thank you.  
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