Administrative Procedure for Setting Policy in a Timely Manner
Bringing Forward an Issue
Issues may reach the McNALMS Board in one of two ways: 1) as an advocated issue where an individual McNALMS member proposes an action or 2) as general information with no advocate or a request from a party who is not a member of McNALMS.
For advocated issues any McNALMS member may bring an issue, legislative action or policy matter to the Board. In asking the Board to make a policy decision the member will provide the Board with an analysis of the issue such as an “issue paper” or legislative analysis, which identifies the pros and cons. An example issue paper used in the Michigan Inland Lakes Partnership is attached. The issue paper is presented to the Board for action.
For issues with no advocate or outside request the President or Executive Director will raise the issue via letter or email with the Board and ask if any Board member or other member would be willing to serve as the issue advocate and produce the necessary issue paper. If a Board member accepts they are only committing to writing the issue paper. They are not committing to any work beyond writing the issue paper, such as lobbying the legislature or supervising the implementation of a new project or program. If no Board member or other member is willing to be the issue advocate, then no action will be taken on the issue. If an advocate is identified, then the issue moves forward as in the case of the advocated issue.
It is not the responsibility of the Executive Director to produce the issue paper or legislative analysis. Once the policy is set by the Board the Executive Director will assist with implementing the policy but he/she does not have to be the advocate for the issue.
Policy is set by the Board at a meeting. A telephone conference call into a meeting is allowed by bylaws. The bylaws do not address email voting or email “meetings”, therefore emails may be used to develop a draft position or policy, but the vote on the issue must be in a meeting.
Members of the Board must be provided notice which is marked urgent (email is not mentioned in the bylaws, but would probably apply) of a meeting at least five days in advance.
Using this procedure it is possible a response to an issue could be acted upon by the Board in about 10 to 20 days.
1 – 3 days to disseminate the issue to the Board and identify an advocate.
3 – 10 days for the advocate to prepare an issue paper (much longer for a more complicated issue.
5 days for meeting notification.
1 day for the meeting and development of the policy regarding the issue
Since in most situations it will not be possible for the Board to take input from the entire membership when developing a policy, it is desirable for all major interest groups in the membership to be represented on the Board to insure input when setting policy. Example interest groups would include: educators, consultants, resource managers from local and state government, lake improvement boards, riparian property owners, and service providers such as commercial applicators.
The Board may react to the issue paper or analysis in three ways: 1) by adopting a policy, 2) asking for additional clarification of issues or 3) by not setting policy or reacting to the issue.
Policy should not be set and then placed in a “Policy Book” never to be seen by those that establish policy at the local, state or federal governmental level. There should be some action to implement or make known the policy position of McNALMS.
If the issue initially had an internal or external advocate, the Board must decide how the advocate will use McNALMS input to promote the policy.
If the issue initially had no advocate the Board must establish a priority for the issue.
Low Priority – Executive Director will send notification letters to the appropriate policy makers regarding McNALMS position.
Example Issue Briefing Statement
Example Issue Statement
Proposed General Permit: Bioengineering Practices for Stabilization of Inland Lake Shorelines
Prepared by: Howard Wandell
Type of Action: Send letter (email) of support to the Michigan Department of Environment, Great Lakes and Energy (EGLE) regarding the proposed general permit for bioengineering practices for stabilization of inland lake shorelines.
Issue: EGLE is recommending a general permit for projects that use bioengineering practices on lake shorelines to prevent or stabilization shoreline erosion. This will allow EGLE to issue a permit without public notice.
At this time there is a general permit to allow shoreline homeowners to install small seawalls and hard armoring to prevent shoreline erosion. However, there is no general permit to allow shoreline homeowners to install bioengineering practices to prevent shoreline erosion. Without a general permit category all permit applications must be public noticed, which can significantly increase the cost and time to get a permit. Consequently, it is easier to get a permit to put in a seawall, than it is to install bioengineering practices. This policy discourages the installation of bioengineering practices and encourages the installation of seawalls. To eliminate this policy bias EGLE’s proposal will create a general permit for bioengineering practices and give homeowners an equal advantage to use bioengineering practices with seawalls.
Ms Jane Smith (alias McNALMS member) has been involved with the development of the general permit. Her only suggestion regarding the general permit is that the Floristic Quality Assessment identified in the third bullet under Limitations and Conditions is not user friendly.
A copy of the Public Notice for the Proposed General Permit Category is attached.
Option 1: Do nothing and hope the new general permit is approved.
Option 2: Send letter of support to EGLE with any suggestions or comments if any.
Decision: (this would be voted upon by the Board).