Combining the departments of Environmental Quality and Natural Resources into a single agency will cause confusion and reduce efficiency. The organizational chart for the Department of Natural Resources and Environment embraces matrix management. Rather than clear lines of authority and responsibilities, the new agency instead utilizes an organizational structure that creates regional ecosystem managers (Lake Erie, Lake Huron, Lake Michigan, Upper Peninsula) who will compete with  resource managers (wildlife, fisheries, water, forest, recreation) for control and authority. Matrix management in the DNRE, which has considerable environmental permitting authority, will lead to bureaucratic infighting and power struggles resulting in additional time and cost for businesses to obtain required permits.

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To make matters worse the Natural Resource Commission, which oversees the DNRE, provides a new source of appeal for those opposed to agency permit decisions. Although the Natural Resource Commission has stated they do not intend to involve themselves in permit decisions, it is doubtful they will be able to maintain that position due to pressure from environmental groups or businesses who disagree with agency decisions. The Natural Resource Commission only meets once a month, leading to significant time delays when they involve themselves in permitting issues.

The timing could not be worse for reorganization of the state's environmental permitting functions. A perfect storm is brewing in the agency, fed by the forces of a lame duck administration, large budget overspending crises and union rules which require massive bump chains for employee reductions. None of this bodes well for businesses that must deal with DNRE to obtain permits in order to create much needed jobs in the state.

Environmental permitting in Michigan is badly in need of structural reform. Unfortunately, the organizational reform for the DNRE proposed by the Granholm administration will make matters worse rather than better.