Action Alert: Ask for public comment extension on Minnesota air monitoring plan

“Air monitoring” is really “air pollutant monitoring” and means measuring known-to-be-harmful substances in the air we breathe.  This sounds simple but is not.  Often enough we are not measuring what we really should be measuring, or are not given correct interpretations of the results.

In Minnesota, most air monitoring is done by the Minnesota Pollution Control Agency (MPCA).  The primary motivation of the MPCA is to show that air quality is OK.  The conflict of interest is obvious in that the MPCA issues the “permits to pollute” and is not motivated to admit that the resulting emissions cause problems.  That said, there is more monitoring of air pollutants in Minnesota than some other places and some monitoring goes beyond federal (Clean Air Act) requirements.  [Note:  I’m talking about the collective motivation of the MPCA under the political direction it gets.  This does not speak to the personal motivations of the staff, many of whom do care about “pollution control.”]

Monitoring is technically complicated and often the data can be interpreted in different ways.  For example, the MPCA may say that the “24 hour average” concentration of a pollutant is below the National Ambient Air Quality Standard.  This may be intended to give the impression that air quality is OK and people should stop worrying and complaining.  But within that 24 hour average could be “spikes” of intense pollution that are, in fact, making people sick.

In general, it is assumed that the air is OK to breathe unless measurements prove otherwise, even if you are under a giant industrial smokestack.  So, air polluters like less monitoring.  Some people could suspect the MPCA of putting monitors where the pollution ISN’T, and avoiding putting them where the pollution IS.  For example, some were surprised to learn that there were no ozone monitors in Minneapolis or St. Paul.  There are no monitors in Benson, MN, although the MPCA has issued permits there for an ethanol plant and a turkey litter incinerator, in spite of the fact that exceedances of air quality standards were predicted.  There are no monitors in Perham, where an unpermitted facility was predicted to cause exceedances of air quality standards, and where the MPCA has promoted, permitted, and partially paid for an expanded garbage incinerator.  Is anyone really protecting the health of people in Benson or Perham?

Evidence is piling up of health damage from air pollutants at far below the legal “standards.”  (It is very hard to lower standards because industrial and electric utility interests lobby against it, and these have far more money than health/environmental interests.)  For example, on March, 2014 the Guardian reported:

“Air pollution has become the world’s single biggest environmental health risk, linked to around 7 million � or nearly one in eight deaths in 2012 � according to the World Health Organisation (WHO).

The new figures are more than double previous estimates and suggest that outdoor pollution from traffic fumes and coal-burning, and indoor pollution from wood and coal stoves, kills more people than smoking, road deaths and diabetes combined.”

From a post last April:  “An MPCA report, based on EPA methodology used to estimate the cost-effectiveness of air regulatory programs, estimates that all man-made PM2.5 pollution is killing 3,800 people per year in Minnesota, those lost people being worth 34 billion dollars.  The Minnesota PM2.5 emissions alone are estimated to be killing 1,600 people per year, those lost people being worth $14 billion dollars.  Of course, many more people are made sick but survive.  For example, Minnesota PM 2.5 emissions alone are estimated to be causing 460 non fatal heart attacks per year, worth forty nine million dollars per year.” (Thanks to Rep. Jean Wagenius for asking for this report.)

The MPCA, along with industrial polluters, is funding a campaign to prevent the US EPA from finding Minnesota in “non-attainment” of the ozone air quality standard.  This, perhaps with intentional humor, is called the “Clean Air Dialog” or “Clean Air Minnesota,” and is run by an industrial front–“astroturf”–group calling itself “Environmental Initiative.”  The funders of this scheme are listed as 3M Company, Flint Hills Resources (the big Koch Brothers oil refinery) and the MPCA.  See the Role of Shame of participants.  Of course, “non-attainment” would be the best thing for air quality in Minnesota because it would force some serious planning and regulating for cleaner air.  For our purposes here we need to wonder whether an agency seeking to evade “non-attainment” can really be trusted to monitor ozone levels. [Note:  The current version of the “Clean Air Minnesota” scam is less blatant about the objective of evading non-attainment, but the real objectives haven’t changed.]

Every year the MPCA is required by the US Environmental Protection Agency to open a 30-day public comment period on an “Annual Air Monitoring Network Plan for Minnesota” for the upcoming year.  Few people comment on this; few people know about it.  It is not easy to understand what it really says.  (One regular commentor is Cliffs Natural Resources, operators of a taconite plant in Silver Bay, North of Duluth.  They don’t want monitoring for asbestos in the air)

But, interest in air monitoring is growing.  People in North Minneapolis want to know if their air is making them sick.  People want to how much frac sand dust is in their air, or could be.  People are tired of breathing wood smoke pollutants, “biomass” burner pollutants, coal plant pollutants, feedlot pollutants, traffic pollutants ….

It is reasonable to ask whether the proposed “monitoring plan” responds adequately to these concerns.  The 44 page draft plan was published on June 2nd with a public comment period extending to July 1.  We immediately responded with a Data Practices Act request for more information:

The PCA has just issued a public notice of opportunities to comment on the draft 2115 state Air Monitoring Plan.  I expect to do this as I have done in the past.

The plan document contains considerable technical information but little if anything about the budget for air quality monitoring.   However, it has been otherwise stated that funding limitations have had impacts on air monitoring in Minnesota.

Therefore, pursuant to the MN Data Practices Act, I request a summary of the funds allocated to air quality monitoring in Minnesota from 2004 to 2014, including total amounts and sources (state/federal, etc).  I also request all documents that speak to the adequacy, or otherwise, of this funding, and impacts of funding limitations on the extent of monitoring statewide.

This request also includes all grant applications, and/or grants received, for air monitoring and related activities.

This request also includes all requests for air quality monitoring in Minnesota received by the MPCA between 2004 and 2014, and the disposition of those requests.

This request also includes all correspondence between the MPCA and the Minnesota Department of Health, the Department of Public Safety, or other Minnesota entities, on or related to the subject of air quality monitoring.

This request also includes all correspondence between authorities in Wisconsin, Iowa, South Dakota, North Dakota, Manitoba, Ontario, the Canadian federal government, and the USEPA, and other US federal agencies, and regional/cooperative bodies including the International Joint Commission, regarding air quality monitoring in Minnesota, during the past five years.

This request also includes any presentations to or correspondence with the Legislature regarding air quality monitoring during the last five years, including budget requests.

My intent is to use this information to develop responsive comments are requested by the MPCA.  Given that:

“Public Comment Period Begins: June 2, 2014”
“Public Comment Period Ends: July 1, 2014”

Time is of the essence in receiving the requested materials.  Please contact me if any clarifications are called for.

Some but not all of this information has been provided.  The info on funding has not arrived.

At least four pages of the report make reference to monitoring being shut down or not started up due to funding limitations.

I sounded out the MPCA on extending the public comment period and was basically told “not if just you are asking for it.”

So, here’s the action part of this Action Alert:  Ask the MPCA to extend, or reopen, the public comment period on the air monitoring plan for at least 30 days, and provide all requested information (we will post it all):

Contact:

John Linc Stine, Commissioner, MPCA: John.Stine@state.mn.us , 651-757-2014
Susan Hedman, Regional Administrator, EPA Region 5 (Chicago): hedman.susan@epa.gov , 312.886.3000
Rick Strassman, MPCA:  Rick.Strassman@state.mn.us , 651.757.2760
your Minnesota Senator and Representative: Who Represents Me?

Alan Muller