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This city WANTS a trump concentration camp:

The resolution below was passed by the City Council of Pine Island, Minnesota, on June 19, 2018.  The vote was 3-0, Mr. Hildebrand being absent.


What are we to make of this?  I’m sure these local government officials aren’t monsters.  Yet they seem to be operating without a moral compass.  I think they need to hear from LOTS of people, and contact information is below.


(I apologize for the poor formatting–Wordpress is tormenting us.)









WHEREAS:  The Mayor of the City of Pine Island and the Pine Island City Council have made a commitment to attracting needed employment opportunities for the City and County; and

WHEREAS:  The proposal by Management & Training Corporation and its partners is for a state-of-the-art detention facility with an aesthetically pleasing design that will integrate with and not adversely impact nearby properties; and


WHEREAS:  Construction of the project will contribute to the development of essential infrastructure within the Elk Run project area in the City of Pine Island and Olmsted County; and
WHEREAS:  The project will result in significant tax revenues in the City of Pine Island immediately and in the future; and
WHEREAS:  The project will result in several construction jobs in the near term and numerous permanent well-paying jobs upon completion;
NOW, THEREFORE , BE IT RESOLVED BY THE GOVERNING BODY OF THE CITY OF PINE ISLAND, MINNESOTA: That the Mayor and City Council support this project and its exclusive relationship with Management & Training Corporation, and directs the City staff to work with the developers on the planning and engineering issues to bring this project to fruition.


Adopted by the City Council of the City of Pine Island, MN this 19th day of  June 2018.
________________________       _____________________________
          Rod Steele, Mayor     David Todd, City Administrator


Motion by:


Second by:





Mayor and Council Members

Mayor (2-year term)
Rod Steele
1740 8th Street SE
Pine Island MN 55963
(up for election/re-election in 2018)

Council Members (4-year term)

Jerry Vettel
PO Box 436
Pine Island MN 55963
(up for election/re-election in 2018)
Jason Johnson
400 3rd Avenue SE
Pine Island MN 55963
(up for election/re-election in 2018)
Mike Hildenbrand
208 3rd St SW
Pine Island MN 55963
(up for election/re-election in 2020)
David Friese
406 N. Main Street Apt. 1
PO Box 371
Pine Island MN 55963
(up for election/re-election in 2020)


And here, thanks to Carol Overland, is info on the proposer, this “Management and Training Corporation.”

Comments { 7 }

City of Red Wing kisses Xcel Energy butt…..works to raise your electric bills

The City of Red Wing, Minnesota, contains various harmful facilities owned by Xcel Energy (Northern States Power Company of Minnesota).

These include two nuclear power reactors, two garbage burner units, and an nuclear waste cask parking lot.

Of course it’s no secret that utilities tend to accumulate great political, economic, and psychological power in the places they operate.  A place like Red Wing, where Xcel pays a lot of taxes and employs many residents, can become, and has become, a caricature of a self-governing community.  I’m not sure the Minnesota Legislature is a lot better.

Utilities are facing a world of change, of technological obsolesence, a world of existential threats, which are making them ever more aggressive and unscrupulous.  How, with electricity getting cheaper at the wholesale level, can they keep screwing their customers with rate increases? Continue Reading →

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Update on Xcel ripoff nuclear bills

This is a follow-up to the March 22. 2018 post entitled  “Xcel Energy–the most abusive special interest in Minnesota?” and subtitled “Action Alert:  Oppose Xcel Energy ripoff legislation.”

A hearing on Senate File 3504 , was rescheduled for March 27th at 1:00, in Room 1150 Minnesota Senate Bldg.  Energy and Utilities Finance and Policy Committee

If you would like to speak, contact Committee Administrator Darrin Lee at 651-293-2962 or darrin.lee@senate.mn.

There is a “delete all” amendment to the bill, meaning all the wording below the heading is replaced.  Here it is.  This will probably be presented as a “compromise” that addresses peoples’ concerns.  For orgs inclined to roll over after token opposition, the new version might be just the ticket.  But it really doesn’t change much–the changes are mostly cosmetic.  Mainly, the “Carbon Reduction Facilities” (note that this applies only to nuke plants, not other sources of low or zero-carbon electricity) business is partially tied into the existing “Resource Plan” procedures.  There is mention of “intervention” rights but these already exist anyway.

Nothing in this new wording should alter opposition to these bills.

Committee hearing

Our information is (it could change):

So far about 20 people have indicated they want to testify against1 SF3504.  2-3 want to testify in favor.  Thirty minutes will be allowed for each side.  That would mean that supporters of the ripoff would get ten to fifteen minutes each, while opponents would get around one and one-half minutes each.  Is this the way things commonly work in the Minnesota Legislature?  I don’t know, but it seems to me in general that opponents of proposed bad policies are often treated disrespectfully.

More fundamental problems with this bill is that it’s intended to authorize essentially unlimited future funding for the Monticello and Prairie Island nukes without prior considered discussion of whether keeping them going make sense.

Because alternative electricity sources are cleaner and cheaper, nukes are being closed, or are demanding huge public subsidies to stay open.  Such scams are being promoted in Connecticut, New Jersey, New York, Ohio, Pennsylvania, and Illinois.  They all lack merit as sound policy but have behind them the bloated political clout of electric utilities.  SF3504 is Minnesota’s version of such a scam.

According to opensecrets.org, Xcel spends about two millions dollars per year on lobbying and in 2017 had twenty-one registered lobbyists, far more than any other entity in Minnesota.  Is it any wonder, then that the Minnesota Legislature too often dances to Xcel’s tune?

Back to the nukes themselves and whether we really need them

Forbes magazine, in “Nuclear Subsidies Are Bad Energy Policy,” (read the whole article, Sept. 12, 2017) notes that:

Nuclear power has been doomed by cost escalation, while gas, efficiency, and renewables continue to get cheaper. And subsidizing nuclear plants isn’t popular in the states where ratepayers would have to foot the bill. Recent headlines tell the story:

  • “Subsidies for Nuclear Reactor Projects Waste Taxpayer Money,” U.S. News & World Report, August 17, 2017 (here)

  •  “Poll: Overwhelming majority of Pennsylvanians oppose nuclear bailout by Legislature,” The Beaver County Times,  August 16, 2017 (here)

  • “Nuclear Subsidies Distort Competition And Increase Power Prices,” Investors.com, May 31, 2017 (here)

  •  “Manufacturers oppose proposed $7 billion nuclear power subsidy,” Albany Business Review, August 1, 2016 (here)

Just yesterday, an article appeared in the Guardian:

“Wind, solar, and storage could meet 90–100% of America’s electricity needs”

The author is John P. Abraham, who teaches at the University of St. Thomas.

(The underlying paper is here but free access to the full text is lacking for many of us.)

Mark Jacobson at Stanford has been making similar arguments for several years, but the details need fleshing out, and that’s what Minnesota should be investing in:  Planning for the future not dancing to the tune of status-quo special interests.

What to do: 

Testify at the hearing if your schedule and the stability of your stomach allows.

Let the Senate Energy and Utilities Finance and Policy Committee know how you feel about Senate File 3504 .  You might email the Committee Administrator and ask him to share your views with the members:  Darrin Lee, Darrin.Lee@senate.mn, 651.296.2962.  And contact your own Senator and Representative.

Alan Muller


Comments { 1 }

Xcel Energy–the most abusive special interest in Minnesota?

Action Alert:  Oppose Xcel Energy ripoff legislation

Is Xcel really the worst?  It’s hard to say–there are so many candidates.  The Minnesota Chamber of Commerce?  3M?  The shadowy interests behind PolyMet and Twin Metals?

From where I write, in Red Wing, which is some sort of ultimate Xcel “company town,” there’s just no contest.  And for someone with a history of working on waste and energy issues, living in a community (nice as it is in many other ways) rendered so bereft of dignity and integrity by it’s servile relationship with Xcel can be painful.  (Of course, the locals don’t seen it that way–they are so used to being told what to do and what to think that they don’t notice.)

Info on Xcel’s latest foray is below, Senate File 3504 /House File 3708 (they are identical).

To see the abuses of Xcel on a larger playing field, one needs to visit the MN Public Utilities Commission and/or the state Legislature.  A puppet show on a different scale entirely.

A few things I’ve written here in the past might be useful or at least entertaining background:







So, Xcel Energy has three nuclear power units, the only ones in Minnesota.  They were all built in the 1960s/1970s and are old, rickety, dangerous, and expensive.  The are not much needed for the electricity they produce but are highly efficient and effective for separating Xcel’s ratepayers from their money.

Over the last decade or so hundreds of millions of dollars have been poured into these units, for “uprates” (running them at higher output than originally designed for, but cancelled in the case of the two Prairie Island reactors) and license extensions (running them 20 years longer than originally promised).  Xcel is allowed to charge ratepayers a high and guaranteed rate of return on these investments, often above ten percent, so has an incentive to spend as much as possible.

Now it’s time for another big reach into our pockets to feed the nukes.  Behold Senate File 3504/House File 3708 (they are identical) introduced on March 15th and 12th 2018.  These bills rename the nukes “carbon reduction facilities” and would create a whole new bill category called a “carbon reduction rider” to pay for them.  Ratepayers and their advocates would have very limited rights to effectively object.

These bills are such gross ripoffs that some Minnesota NGOs, often comfortably snuggled up with Xcel, are objecting.  These include “Fresh Energy,” AARP, “Citizens Utility Board” (CUB), Energy Cents Coalition, and Citizens Federation–Northeast.

The problem is that they, like the Star Tribune, seem to be accepting the basic argument that the nukes deserve a giant infusion of our cash to keep them going.  They are only complaining about the oppressive details.  For instance, Fresh Energy says:

“While Fresh Energy believes it is potentially economically and environmentally beneficial to keep Xcel Energy’s nuclear plants open until the end of their federal license, a blank check is not the way to do it. The bill provides no guardrails to ensure these investments are prudent. We support pursuing a comprehensive analysis at the Minnesota Public Utilities Commission of what it may take to keep these plants operating another 15 years.”

A joint letter from several orgs, likely written by CUB, raises various objections to the bills as they stand, but doesn’t object to the basically problematic concept of “special processes for cost recovery of nuclear facilities.”  This suggests that in advocating on this issue and these bills, people should be wary of dealmaking and sellouts.  It’s happened before.  For a disgraceful example, CUB rolled over on Xcel legislation allowing it to build a fossil-fuel plant in Becker without the usual regulatory review.  Likewise, “Fresh Energy” rep J. Drake Hamilton has been going around giving “how great they are” presentations about Xcel.  Can objections from “Fresh Energy” be taken seriously?

In spite of all this, the news on future energy sources is basically good.  Wind is cheapest and getting cheaper.  Cost of solar is dropping rapidly.  “Storage” of various kinds, such as giant batteries, can deal with the intermittency of wind and solar.  There is no reason why carbon emissions and electric bills can’t go down together.  But it obviously won’t happen if Xcel and other utilities are allowed to keep on driving the train.  From an industry source, January 8, 2018

  • An Xcel Energy resource solicitation received more than 400 individual proposals, the utility reported last month, including what may be record-low prices for renewable energy paired with energy storage. 
  • The median price bid for wind-plus-storage projects in Xcel’s all-source solicitation was $21/MWh, GTM Research’s Shayle Kann noted on Twitter, and the median bid for solar-plus storage was $36/MWh. Previously, the lowest known bid for similar solar resources was $45/MWh in Arizona.

This is much cheaper than even old-nuke power and illustrates the foolishness of dumping more money into them.  Note also that these are for “power purchase agreements” and do not involve any rate-base-inflating capital investment by Xcel.

(Aside, we can note that since around 2010, while the actual wholesale cost of fuels and electricity has dropped, Xcel has received multiple large, unjustified rate increases and Minnesota now has above-average electricity rates. Right-wing policy shops like the Center of the American Experiment blame this on investment in “renewable energy.”  This is not the case.  The cause is the chokehold that Xcel and other utilities have on regulators, legislators, and NGOs.  So far as I have seen, only Attorney General Lori Swanson has offered much opposition, and that has been rather low-key.)

So yes, these two bills are horrible.  They probably have some throwaway aspects Xcel is prepared to give up to encourage rollovers.

The bigger picture is that Minnesota needs to start regulating its utilities in the public interest, not allowing the utilities to twist and distort policies to the benefit of their management and stockholders but at high cost to the public.  We need a PUC and a Legislature with backbone and integrity.

SF 3504 was to be heard March 22nd, but many concerned citizens showed up and the hearing was postponed to March 27th (Tuesday), scheduled for 01:00 PM in Room 1150 Minnesota Senate Bldg.  Energy and Utilities Finance and Policy Committee

If you would like to speak, contact Committee Administrator Darrin Lee at 651-293-2962 or darrin.lee@senate.mn.

Three of the 10 committee members, including the Chair (Osmek)  are bill sponsors and one (Goggin) is an Xcel employee.  Don’t assume you will be treated respectfully or that the meeting time and place won’t be moved around to frustrate citizens.

HF3708 has been referred to the House Job Growth and Energy Affordability Policy and Finance committee but as far as I know no hearing has been scheduled.

“A kakistocracy (/ˌkækɪsˈtɒkrəsi, –ˈstɒk-/) is a system of government which is run by the worst, least qualified, or most unscrupulous citizens.”

Alan Muller





Comments { 3 }

Senators Klobuchar and Smith betray Minnesota air-breathers: Seek to protect “big ag” CAFO pollution

Action Alert: Senators Klobuchar and Smith betray Minnesota air-breathers: Seek to protect “big ag” CAFO pollution

Contact information below:

Klobuchar and Smith are cosponsors of a bill to exempt “farms” (including giant animal feeding operations, CAFOs) from reporting “releases of hazardous substances from animal waste” and releases from the “application, handling, and storage of “pesticide products.” A focus of attention has been two highly toxic and smelly compounds emitted in large amounts from CAFOs: ammonia and hydrogen sulfide.

Read the bill here: https://www.fischer.senate.gov/…/400ea859-eb96…/edw18106.pdf . S. 2421 Read a gloating press release about it here: https://www.fischer.senate.gov/public/index.cfm/news… .

S. 2421 has 29 co-sponsors, 12 “Democrats” and 17 “Republicans.”

The ever-malevolent Farm Bureau calls the bill “A breath of fresh air for ag.” (Time out for a laugh.)

Consider the context: Minnesotans are experiencing lots of problems from CAFOs: air pollution, water pollution, stinks, dust. Health problems and diminished quality of life are what oversized animal feeding facilities bring. One might think that Klobuchar and Smith would be introducing legislation to get these problems under control. But no, they are seeking to reduce the weak protections environmental laws now provide.

Why do Amy Klobuchar and Tina Smith seem to have no fear that betraying their constituents could cost them their seats on the Senate Gravy Train? Would it be different if we actually had a “two party” system in which both parties competed to show how much they could help the people. (Time out for laughing). I suppose they don’t fear the voters because they assume that no matter how often they betray us we’ll vote them back in anyway.

Neither Kkobuchar nor Smith seriously supports controlling drug prices or providing universal access to health care. They don’t support phasing out the hydrocarbon fuels that are cooking our planet. They don’t really oppose trump’s relentless attacks on democracy and governmental integrity. They will vote for increased war spending at every opportunity. “Corporate Democrats.”

ACTION steps you can take:

Make your calls and ask that Klobuchar and Smith WITHDRAW their support for S.2421.

Call Klobuchar: (202) 224-3244

Call Klobuchar’s State Director, Benjamin J Hill, 612-727-5220

Call Smith: (202) 224-5641

Call Smith’s State Director, Sara Jo Silbernail, (651) 221-1016 (This is Smith’s St. Paul office but has been going to voicemail.)

(Phone calls are generally more effective than emails because some staffer has to take time to deal with them.)

Alan Muller

Comments { 1 }

“10,000 Lakes” [Lori Swanson on 3M]

“The swamp that was referred to in the last election is not limited to Washington,” she said. “We have our own problems in Minnesota with regulatory agencies that are captive to the industries that they are supposed to regulate.”

— Minnesota Attorney General Lori Swanson



Date: Wed, 07 Feb 2018 13:06:16 -0600
To: alan Muller <amuller@dca.net>
From: Lori Swanson
Subject: 10,000 Lakes

Dear Alan:

My Office has been inundated with inquiries about the lawsuit against 3M Company regarding fluorochemicals. The purpose of this advisory is to provide background on the litigation.

The Manhattan Project.

The Manhattan Project was a top-secret project undertaken by the American military during World War II. Its mission was to create the nuclear bomb. A major hurdle in the Manhattan Project was the inability to separate the uranium needed to make the bomb. The scientists discovered that fluorine gas could be used to separate the uranium. Fluorine is a greenish-yellow gas that is buried deep in the rocks beneath the earth and is among the most dangerous elements that exists. It was called the “Wildest Hellcat” or the “Devil’s Poison.” It can burn water. It can burn steel. It can burn asbestos. Continue Reading →

Comments { 0 }

“Red Wing sorely lacking in representative government”

My letter published today (December 13, 2017), in the Red Wing Republican Eagle

By global standards, Red Wing is a comfortable and safe place.  It snows, and within hours the roads are plowed.  Potable water, electricity, and gas are almost always available by just turning it on.  Have a medical emergency, and a well-trained ambulance crew will show up promptly.  There is a well-trained fire service.  The streets are paved.  One can walk around day or night without much fear of getting mugged, partly due to an effective police department.  One could go on and on.  We have a lot to be thankful for, that we shouldn’t take for granted.

On the other side of the coin, there are problems with how Red Wing is governed, that are limiting the political, economic, and intellectual development of the community.  Examples: Continue Reading →

Comments { 0 }

The City of Red Wing is misbehaving again……

Robin Hensel, whose lawsuit eventually produced a pro-freedom-of-speech decision from the Minnesota Supreme Court, calls Little Falls (Morrison County) the “Intolerance Capitol of Central Minnesota.”  It seems that Red Wing (Goodhue County) is looking to be the “Intolerance Capitol of Southeastern Minnesota.”

Freedom of speech at City of Red Wing council meetings is under attack, with the Council advancing an ordinance intended to provide cover for police violence against residents, or, at the least to make it easier to prevent people from speaking.  This sort of thing has recently been seen in Little Falls and Mankato.  The good news is that a recent Minnesota Supreme Court decision is basically supportive of freedom of speech.

Here is a note sent the afternoon before the meeting.   I just happened to see this agenda item while checking out another objectionable item:

Dear Members of City Council (and members of the Red Wing Human Rights Commission): Continue Reading →

Comments { 0 }

Comments due Sept 15th: Support shut-down of polluting, resource-destroying incinerator in Benson, MN.

I rarely support actions by Xcel Energy, but this time Xcel is doing the right thing in five matters (for its own reasons, of course).  I’ll address these five in separate posts, as Xcel filed five separate matters before the Minnesota Public Utilities Commission.  First, this one about the incinerator in Benson, PUC Docket r-002/M-17-530 (when searching PUC’s eDockets or eFiling comments, it’s the 17-530 that’s important).

In one of the dumbest actions ever taken in Minnesota on an energy-related matter, a large “poultry litter” incinerator was built in Benson, Swift County.  This was supported by many “environmental” interests in MN, as part of a 1994 deal to keep the Prairie Island nuclear plant operating.  It was opposed mainly (only?) by David Morris — Institute for Local Self Reliance.   As one would expect, this facility has a horrendous record of pollution and environmental violations.   Its air emissions permit expired in 2008.  Xcel is proposing to buy the facility and shut it down.  This is good news.  Xcel generally gets what it wants, (regardless of whether it should).  The stated reason is to save Xcel’s customers money, and this the shutdown would likely do, as dirty biomass burner “Power Purchase Agreements” are inflated in cost.

Since the burner has not been able to get enough “litter,” about one-half of what is burned is wood chips, and many comments opposing the shut down have come from logging interests and, disgracefully, from the Minnesota Department of Natural Resources.

So far as I can tell, none of the enviro types, energy wonk types, regulators, or elected officials who supported this damaging incinerator scam have chosen to publicly admit their mistake and support the shutdown.

You can read all the filings in the docket and file your own comments in a couple of ways:

(1)  (less effective but easier) The PUC website has a “discussions” section but this has limitations including that dockets only appear here if they are officially open for public comment, and sometimes not even then.   For example, the Benson burner docket is not there, although it should be. Search for docket “17” (year) and “530 (docket number).

(2)  (more impactful) You can use the “edockets” system to read, download, or print the documents in any docket you are interested in.  You can use the “efiling” system to file your own comments in the Benson 17-530 docket — the next round of comments is due September 15.  To use efiling you need to sign up and get a password, but it’s not hard.  If you file comments after the official closing of public comment, they may or may not be considered.  For example, the Commissioner of the Department of Natural Resources recently filed out-of-time comments opposing the Benson shutdown–arguing on behalf of the DNR’s friends in the logging industry.

Here’s the notice with information on how to file comments in this Benson 17-530 docket:

Notice – 20178-134541-01

The “Public” Utilities Commission is not supposed to be just an industry playpen, though too often it seems that way!

Here are the previous comments I submitted in favor of the shutdown:

Alan Muller
Energy & Environmental Consulting
1110 West Avenue
Red Wing, MN, 55066

September 1, 2017

Daniel P. Wolf

Executive Secretary
Minnesota Public Utilities Commission
121 7th Place East, Suite 350
St. Paul, Minnesota 55101

Reply Comments: Petition of Xcel Energy to terminate a Power Purchase Agreement , etc. with Benson Power, LLC (Ex Fibrominn) E002/M-17-530

Dear Mr. Wolf:

I have been involved in controversies over poultry litter incineration projects instigated by Fibrominn and its successors for many year and in several states.

Such projects were rejected in various US states including Delaware, Maryland, Virginia, North Carolina, and Georgia. Thus, observers were puzzled that such a facility would be accepted in Minnesota. They especially were puzzled that “environmental” interests supported, or failed to oppose, the Benson proposal.

Opposition to poultry litter incineration projects has centered on high emissions, high costs, damage to public health and quality of life in host communities, and undesirable diversion of fiber and nutrients from field application to incineration. I note, for example, that so high are the Benson air emissions that a smokestack over 300 feet high was built to disperse these into the community. Only a fifty (or fifty-five) megawatt generator, The permit granted for their Fibrominn project allows them to be Minnesota’s largest single source of arsenic pollution, their largest source of sulfuric acid air emissions, their 2nd largest source of hydrochloric acid air emissions, and a significant new source of dioxin pollution.” 1

The history of the Benson project has been characterized, as would be expected, and as was predicted by opponents, by high emissions, serious and ongoing violations of air permit limits, deceptive practices, and complaints from Benson residents of damage to their health and quality of life. See, for example, this stipulation agreement with the Pollution Control Agency: http://www.bredl.org/pdf2/FibrominnExecutedSTIP12-16-09.pdf

The Benson project has been unable to secure adequate amounts of poultry litter and has become largely a wood burner. Poultry litter, in general, is about fifty percent wood chips and fifty percent bird emissions. Thus, the Benson facility, burning, as has been stated, about one-half poultry litter and one-half wood chips is in fact burning about 75 percent wood.

Wood is a very dirty and chemically complex fuel, and nominal wood burners typically cause the same sorts of environmental problems as the Benson “litter” burner, while producing excessively expensive energy.

Xcel, in its Petition, notes a “plant heat rate of 14,250 Btu/kWh per Benson Power’s 2016 budget.” This corresponds to a thermal efficiency of twenty-four percent. The most efficient coal units have heat rates of around 9,000 Btu/kWh, corresponding to a thermal efficiency of around 38 percent, and combined cycle gas units are over 60 percent efficient.

Thus, I support the proposals of Xcel Energy to terminate power purchase agreements with various “biomass” burning facilities and to purchase and shut down the Benson burner.

(However, one must note the hypocrisy of Xcel in continuing to operate company-owned garbage incinerators in Red Wing, Mankato and French Island (La Crosse) that are similarly dirty and expensive. If Xcel was truly concerned about the well-being of its customers and the public at large it would shut these down and get out of the dirty-burner business entirely.)

(Also parenthetically, large Confined Animal Feeding Operations, including turkey barns, produce large concentrations of nutrients which pose problems. Thus, it is understandable that promoters of “magic bullet” solutions such as incineration have an audience. However, it seems well established that best practices for management of turkey litter should be based on properly managed—not to excess!) land application.)

A review of the filings in this docket indicates—unless I have missed them—no mention at all of the environmental merits, or lack thereof, of the Benson facility. Similarly there is very little mention of the merits of the facility as a power plant. It seems that all the important issues are missed or disregarded.

Unfortunately the actual cost of the Power Purchase Agreement is concealed as proprietary, although it is difficult to imagine any justification for this.

The proposal to pay off the City of Benson out of the proceeds of the “Renewable Development Fund” are yet another abuse of this every-scandalous fund, essentially none of which has ever been used as intended to compensate Red Wing and Monticello for Xcel’s nuclear plant/waste presence.

I conclude that the most important matters in this docket are yet unaddressed, and the comment period should be extended. Especially, it is scandalous that “environmental” interests, which initially promoted the agreement leading to the Benson facility, have not chosen to comment.

I also contemplate petitioning to intervene in this docket.

Yours very truly,


Alan Muller

Comments { 2 }

Letter to MN officials about ADM Red Wing air permit

To:         jacobe.timler@state.mn.us

From:    Alan Muller <amuller@dca.net>

Subject: ADM air permit public notice

CC:         Kathleen.Winters@state.mn.us, “Carol A. Overland” <overland@legalectric.org>, Ruth.greenslade@co.goodhue.mn.us, john.stine@state.mn.us, ed.ehlinger@state.mn.us, Anne     Jacobson<ajacobson@republican-eagle.com>

May 10, 20717

Jacobe Timler
Industrial Division. Minnesota Pollution Control Agency
520 Lafayette Rd
St. Paul, MN 55155
Phone: 651-757-2410
Email: jacobe.timler@state.mn.us

Dear Mr. Timler:

I am a resident of Red Wing and am reviewing the:

“Public Notice of Intent to Modify Air Permit 04900001-101” dated May 4, 2017, for the subject ADM facility in Red Wing.

These are initial questions and comments:

Please provide a copy of the “Consent Decree” referenced in various places in the Technical Support Document.

The expiration date of the permit is February 28, 2011.  I question the appropriateness of modifications to a long-expired permit.  Can the MPCA provide assurances that the long-expired permit, as modified in the current action, would comply with all current State and Federal laws, regulations, rules, and agency guidance, and be adequately protective of the community?

The Technical Support Document (TSD), at page 1, states:

“The facility emits particulate matter (PM), particulate matter less than 10 microns in size (PM10), PM less than 2.5 microns in size (PM2.5), volatile organic compounds (VOC), sulfur dioxide (SO2), carbon monoxide (CO), nitrogen oxides (NOx) and hazardous air pollutants (HAPs). PM/PM10/PM2.5 emissions are emitted from the handling and processing of the seeds, the meal system, and the refinery. PM/PM10/PM2.5, SO2, CO, NOx, and VOC emissions are emitted from the boilers. Hexane emissions (which are both VOC and HAP emissions) are released from the hexane extraction and recovery systems. The facility is a major source under federal New Source Review (NSR), the federal Operating Permit Program (40 CFR pt. 70), and federal National Emission Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63).”

Has any ambient or fenceline monitoring been conducted to ensure compliance with air quality standards?

Have the cumulative impacts of this facility and others in the area been evaluated?

Has a Health Impact Analysis of this facility every been conducted?

Some of the emissions from this may be allergens, soybean particulate, etc.   Has this been evaluated for possible health and quality of life impacts?

The TSD also states at page one that:

“Due to the time-sensitive nature of this project, this amendment will be issued in stages. The first stage (Stage 1) of the issuance will include the NSR portion of the permit (construction authorization and Title I requirements) while the second and final stage (Stage 2) will include the Part 70 portion of the permit (operating and periodic monitoring requirements). This effectively allows the Permittee to complete the construction-portion of this project during EPA review. The second stage (facility operation) will be issued following EPA review.”

What makes this project “time sensitive” in the eyes of the MPCA?

I am concerned about the statement “allows the Permittee to complete the construction-portion of this project during EPA review.”  Construction should not be allowed to commence, let alone be completed, until the permitting process has gone to conclusion.  Does the MPCA consider the EPA review an insignificant formality?

Please provide the name and contact information for the Region 5 staff who will be/are reviewing this permit.

At page 88 of the TSD (as pages are counted by the PDF viewer) begins a long series of line items entitles “PTE [Potential to Emit] by subject item.”  The column headings are not aligned, but there seem to be entries for “Unrestricted Potential” and “Limited Potential.”  In a great many cases the “Limited Potential” is given as zero.  Just to pick one example, at page 95, emissions of “particulate matter” (undefined?) from “Bins/Harvestore” are given as 279 tons/year (“unrestricted”) and 0 (zero) “limited.”  Since few if any air pollution control measures or devices are 100 percent effective, all these zeros seem questionable to me, and need further explanation and/or correction.

Neither the Public Notice nor the Draft Permit nor the TDS contains any summary of the total emissions of the facility.  (The large emissions of Hexane, for example).  This fails, in my opinion, to give reasonable, good-faith notice to the public of why this permit action/this facility might be of interest from an air quality point of view.

In view of the issues raised by even my cursory review of the Public Notice, the Draft Permit, and the Technical Support Document, the public comment period may need to be extended, else a Public Information Meeting may be needed.

Yours very truly,

Alan Muller
1110 West Avenue
Red Wing, MN, 55066

Alan Muller
Energy & Environmental Consulting
Red Wing, MN
Port Penn, DE

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