ELR Citation: ELR 20469
No(s). 204399, 210844 (Mich. Ct. App. Mar 21, 2000)

The court holds that the Michigan Department of Natural Resources exceeded its authority when it denied a power company's request for a Clean Water Act (CWA) §401 water quality certificate because the company failed to conduct a fish entrainment and mortality study. The court first holds that the a...