Environmental Week in Preview – Week of May 20, 2013

Published by Marney Hoefer on

May 20, 2013: The DNR will hold a public hearing on a proposed wastewater discharge permit for Ziegler Dairy Farms and GL Dairy Biogas LLC/ Middleton Digester. There are two linked projects, the proposed Dane County Manure Handling Facility (Middleton Digester) to be operated by GL Dairy Biogas, LLC and the expansion they have planned will make them a concentrated animal feeding operation requiring permit coverage.  GL Dairy has applied for a WPDES permit for the Middleton Digester because it is a new industrial processing facility.

May 21, 2013: The Division of Hearing and Appeals will hold a telephone prehearing conference in the matter of a conditional high capacity well approval for two potable wells to be located in the Town of New Chester, Adams Count issued to New Chester Dairy, Inc. and MilkSource Holdings, LLC.

May 21-22, 2013: The Natural Resources Board meeting agenda includes a recommendation to change the state mercury rule in response to the promulgation of federal rules regulating mercury.  The federal rules are the Mercury Air Toxics Standards which is applicable to EGUs larger than 25 MW and the Industrial, Commercial and Institutional (ICI) Boiler rule which is applicable to EGUSs smaller than 25 MW.  Both rules establish maximum achievable control technology (MACT) emission limitations for mercury as required under Section 112 of the Clean Air Act.  The agenda also includes a request for an approval of two scope statements to initiate rulemaking.  The first scope statement covers revisions to ch. NR 149, which establishes requirements for laboratories participating in the laboratory certification and registration program. The rule revisions are expected to minor, to bring it up to date with federal regulations, address technological changes and to clarify regulation.  The second scope statement covers revisions to the Wisconsin Administrative Code required by the new ferrous mining laws.

A Textbook Example of the Grey Market

Published by Jim Egle on

Out of the scores of disputes that arise with respect to “grey market” distribution channels, what are the odds that a case involving a Thai student doing business as “bluechristine99” on eBay would reach the U.S. Supreme Court?

“Grey market” refers to the sale of genuine branded products outside of established distribution channels established by a manufacturer. A manufacturer may provide different price structures to different markets and customers.  These price differentials create an opportunity for brokers and distributors to purchase products at discounted rates, but sell them in places where they can realize greater profits – in places not intended by the manufacturer. One example is the sale of on-line prescription drugs from Canadian distributors to individuals located in the U.S. The drug manufacturer sells the medications at a lower wholesale price in Canada; distributors take advantage of that lower price and resell over the internet and ship to U.S., thus undercutting retail prices charged in the U.S.

The “bluechristine99” case decided by the U.S. Supreme Court in March involved a textbook example of the grey market -- literally.  A student at Cornell University, Supap Kirtsaeng, had friends and family purchase English-language textbooks (which had been printed overseas) in Thailand and mail the textbooks to him in the U.S.  Using eBay as his distribution channel, Kirtsaeng re-sold the books at a profit.

The holder of the copyrights in the textbooks, publisher John A. Wiley & Sons, sued Kirtsaeng for copyright infringement, citing its exclusive right to distribute the copyrighted materials in the U.S.  Kirtsaeng asserted a defense based on the “first sale” doctrine of U.S. copyright law. Under that doctrine, the owner of a particular copy of copyright materials lawfully made under U.S. copyright law is entitled, without the authority of the copyright owner, to sell or otherwise dispose of the possession of that copy.

In the Kirtsaeng case, the issue was relatively narrow. The U.S. Supreme Court had previously held that goods manufactured in the U.S. and sold overseas were subject to the first sale doctrine, and thus the manufacturer could not bar subsequent sales of goods re-imported into the U.S. by asserting copyright infringement. In Kirtsaeng, the textbooks had been printed overseas, and not in the U.S.  The District Court and court of appeals found that distinction to be meaningful. But the U.S. Supreme Court did not. It overturned the district court’s finding of copyright infringement against Kirtsaeng, holding that the first sale doctrine defense applied to re-sales of copyrighted materials lawfully produced overseas.

The co-opting of distribution channels by brokers such as Kirtsaeng is only a part of the grey market problem in the distribution industry. Many grey market disputes involve parties who voluntarily have partnered to do business. Distributors and brokers may resort to buying or selling on the grey market for benign reasons (selling excess inventory at below-market prices, acquiring products on the grey market to meet customer demand when the manufacturer cannot deliver) or because they are engaging in more nefarious practices (falsely representing the identity of the end user to obtain additional discounts, exploiting pricing differentials between jurisdictions).

Whatever the reason for the practice, the grey market can damage a manufacturer.  There is the risk that items sold on the grey market are actually low-quality counterfeit goods that wind up disappointing the end user, hurting the goodwill of the legitimate brand and manufacturer.  If the goods aren’t purchased from an authorized dealer, there may be no warranty from the original equipment manufacturer.  Finally, those distributors who buy within established channels suffer financially while those bending the rules are rewarded, damaging the strength of the distribution system.

Addressing these issues can be difficult, especially for manufacturers without significant market power and who rely on large distributors to sell their products.  Contractual protections in distribution agreements are a critical starting point of any effort to curb grey market practices.

Environmental Week in Preview – Week of May 13, 2013

Published by Marney Hoefer on

May 14, 2013: The Department of Agriculture, Trade and Consumer Protection board meeting will include the request to approve the final draft rule related to the farmland preservation program.  The rule creates ch. ATCP 49 which specifies the application content and process for receiving certification of farmland preservation plans and ordinances, authorizes additional uses allowed in a farmland preservation zoning district and specifies when the DATCP may deny an application for a farmland preservation agreement. 

May 15, 2013: The DNR will hold a public hearing on an air pollution control permit application for the construction of the proposed University of Wisconsin – Oshkosh Foundation Rosendale Biodigester facility modification.  The application includes plans and specifications for construction and initial operation of two anaerobic biodigesters, including one 1,966 brake horsepower spark ignition engine generator and one backup flare. 

May 16, 2013: The DNR will hold a public hearing on an air pollution control construction and operation permit applications submitted by Generac Power Systems – Whitewater.  The application includes plans and specifications for construction and operation of new engine/generator test cells and a varnish line, and revision of Operation Permit for an engine/generator assembly and testing facility. 

May 16, 2013: The DNR will hold a public informational hearing on a proposed statewide general permit for wetland discharges that are a part of development for recreational purposes.  The proposed statewide general permit, once in place, is valid for 5 years and will allow applicants to apply for coverage under the permit for discharges of dredged or fill material into a wetland up to 10,000 square feet (0.23 acres) for purposes of recreational development if the impact meets all of the eligibility criteria and conditions of the general permits.  An environmental assessment has been prepared and is available for public review and comment.  The Department has made the determination the draft statewide general permit will not cause significant adverse environmental effects as proposed.  The Department has further made the preliminary decision that an environmental impact statement for the action to issue this statewide general permit is not necessary.

Facebook Postings Trashing Supervisor Are Protected By the NLRA

Published by Meg Vergeront on

The National Labor Relations Board (NLRB) recently decided that an employer violated the National Labor Relations Act (NLRA) when it terminated employees who complained about the conduct of their supervisor on Facebook.  The case is Design Tech. Grp. LLC d/b/a Bettie Page Clothing.  

The NLRA prohibits all employers, both union and non-union, from punishing employees who act together to complain about the terms and conditions of their employment (conduct referred to as “concerted activity.”)  In Design Tech., the NLRB determined that a Facebook “conversation” about workplace conditions is, in and of itself, concerted activity.  Based on this determination, the NLRB concluded that the law prohibited Design Tech from punishing its employees over the Facebook postings.  The Board ordered the employer to reinstate the employees and pay back wages, among other remedial relief.  This case is a reminder that employers must tread very carefully when taking any action based on the social media postings of its employees.  Consulting with legal counsel before doing so can help an employer stay on the right side of the law.

Undocumented Workers Can Bring Wage and Hour Claims

Published by Meg Vergeront on

According to a recent Eleventh Circuit Court of Appeals decision, undocumented workers are entitled to sue under federal law for minimum wage and overtime.  The Eleventh Circuit does not govern Wisconsin, but Wisconsin employers should nonetheless pay attention to the ruling.  Paying all employees at least minimum wage and all overtime due will help keep you out of court, no matter which employees are at issue.

Environmental Week in Preview – Week of May 6, 2013

Published by Marney Hoefer on

May 6, 2013: The DNR will hold a public hearing on an air pollution control permit application submitted by Motor Castings Company – Plant 1.   The application includes plans and specifications for modification and operation of a thermal sand reclamation unit. 

May 7, 2013: The DNR will hold a public meeting to present information regarding the master plan for the future for High Cliff State Park and to listen to comments from the public about the Plan. 

May 8, 2013: The Senate Committee on Government Operations, Public Works and Telecommunications will hold an executive session on Senate Bill 103 which restricts a municipals utility’s release of customer information which the bill defines as any information received from customers which serve to identify customers individually by usage or account status.  The bill prohibits a municipal utility from releasing customer information without the customer’s consent.  There are exceptions to the prohibition for releases to certain persons who perform services or functions for municipal utilities or to certain transmission and distribution utilities and operators or to those that are otherwise authorized by law to receive the customer information.

Environmental Week in Preview – Week of April 29, 2013

Published by Marney Hoefer on

April 29, 2013: The DNR will hold a public hearing on an air pollution control construction application submitted by Enbridge Energy regarding plans and specifications for construction and operation of increased incoming  and outgoing capacity, modify LDAR for new and existing operations (subject to BACT) and construction of two new tanks.

April 30, 2013: The Assembly Committee on Environment and Forestry will hold a committee meeting  for the “right the rules” initiative, reviewing Wisconsin Administrative Code Chapters NR 102, 105, 106, 217 and 220. No public testimony will be taken at the meeting.

April 30, 2013: The Senate Committee on Economic Development and Local Government will hold an executive session on Senate Bill 112 which would change the elements that are required to be included in a county development plan.  The bill would repeal the requirements that a city’s or village’s master plan must be included in a county development plan and also repeals the requirement that any official map be included without changes. 

May 2, 2013: The DNR will hold a public hearing on an air pollution control construction application submitted by Domtar Paper Company regarding plans and specifications for construction and operation of changes to stack parameters. 

May 2, 2013: The DNR will hold a public hearing on an air pollution control construction permit application submitted by WE Energies Biomass Fueled Cogeneration Facility regarding plans and specifications for a temporary boiler.

May 2, 2013: The DNR will hold a public hearing on an air pollution control construction and operation permit applications submitted by G.L. Dairy Biogas relating to plans and specifications for construction and operation of anaerobic digesters, manure storage, solids composting and two biogas fired engines to produce electricity.

Happy Earth Week!

Published by Marney Hoefer on

Environmental Week in Preview – Week of April 22, 2013

April 24th, 2013 – Natural Resources Board meeting.  The agenda, once again, includes no action items or scope statement requests on air, water or waste issues.  The Board will be taking comment on the public participation method and will review the new public input process for DNR guidance.

April 25th, 2013 – The DNR will hold a public hearing on the air pollution control construction permit application for the Waupun Correctional Institution for the construction of two new natural gas fired boilers with distillate fuel oil or biodiesel fuel oil as back-up fuel in the case of natural gas supply interruption.

April 25th, 2013 – The DNR will hold a public hearing on a proposed statewide general permit for waterway impacts and wetland discharges that are associated with utility projects.

Environmental Week In Preview – Week of April 15, 2013

Published by Marney Hoefer on

April 16, 2013: The DNR will hold a public hearing on an air pollution control permit application from Waupaca Foundry.  The permit application includes plans and specifications for modifications of an existing sand cooler process and the construction of a replacement shakeout process.

April 16, 2013: The DNR will hold a public hearing on an air pollution control permit application from FTS International Services, LLC.  The application includes plans and specifications for construction and operation of an industrial sand mine and processing plant. 

April 16, 17 & 18, 2013: The DNR will hold public hearings on proposed changes to Chapter NR 150 on April 16, 17 and 18, 2013.  The proposed rule changes include the replacement of the type list with criteria for identifying, prioritizing, analyzing and seeking public input on issues relating to DNR actions.  The new rule proposes to eliminate the use of Environmental Assessments as a means of Wisconsin Environmental Policy Act compliance (WEPA) for individual actions.  The proposed rule would add new process and procedures for “bigger picture strategic policy analyses.”  The changes in the rule may have significant impacts on the process for the analyses of environmental impacts as well as may act to preclude environmental review for individual projects where the DNR has performed a strategic analysis of the type of projects.

April 18, 2013:  Public comments are due on the DNR’s proposed guidance for implementing new EPA public notice requirements for substantial modifications to nutrient management plans. 

What to look for in coming weeks:
April 26, 2013: Public comments are due on the DNR’s proposed guidance for implementing water quality trading into WPDES permits and evaluating water quality trading as a permit compliance option and developing a water quality trading strategy.

Environmental Week In Preview – Week of April 8, 2013

Published by Marney Hoefer on

April 10, 2013: The Assembly Committee on Natural Resources and Sporting Heritage will hold a public hearing on a number of bills – Assembly Bills 8, 75 and 84.

Assembly Bill 8 relates to restrictions on hunting within a specified distance of hospitals, sanatoriums, or school grounds and restrictions imposed by local governmental units on hunting with a bow and arrow or crossbow and specifies that 1,700 feet restriction applies only to hunting with a firearm.  The Bill provides that a local government may not enact or adopt a resolution that prohibits hunting with a bow or crossbow within the jurisdiction of that local government unit.  An exception provides that a local governmental unit may prohibit hunting with a bow and arrow or crossbow within specified distance, not to exceed 100 yards of a building used for human occupancy that is located on another person’s land.

Assembly Bill 75 relates to the applicability of a county shoreland zoning ordinance in a shoreland area annexed by, or incorporated as, a city or village. The Bill eliminates the requirement that if a city or village annexes a county shoreland area after a specified date and that area, before annexation, was subject to a county shoreland ordinance, then the county shoreland ordinance continues to be in effect and enforced by the annexing City or Village. 

Assembly Bill 84 relates to exceptions for fishing licenses and aquatic plant management permits.  The Bill allows a person to use algaecide or herbicide in a self-contained pond that is located entirely on the person’s private property without obtaining a permit from DNR. 

What to look for in coming weeks:
April 16, 17 & 18th,2013: The Department will be holding public hearings on proposed changes to Chapter NR 150 on April 16th, 17th and 18th, 2013.  The proposed rule changes include the replacement of the type list with criteria for identifying, prioritizing, analyzing and seeking public input on issues relating to DNR actions.  The new rule proposes to eliminate the use of Environmental Assessments as a means of Wisconsin Environmental Policy Act compliance (WEPA) for individual actions.  The proposed rule would add new process and procedures for “bigger picture strategic policy analyses.”  The changes in the rule may have significant impacts on the process for the analyses of environmental impacts as well as may act to preclude environmental review for individual projects where the DNR has performed a strategic analysis of the type of projects.

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