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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 AprilAn 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

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Strange nonsense at the Minnesota Environmental Quality Board (and the MPCA)

Minnesota’s Environmental Quality Board (EQB), and it’s Climate Change Subcommittee, held a meeting on June 18, 2014.

“The mission of the Environmental Quality Board is to lead Minnesota environmental policy by responding to key issues, providing appropriate review and coordination, serving as a public forum and developing long-range strategies to enhance Minnesota’s environmental quality. The Environmental Quality Board consists of a Governor’s representative (by law the board chair), nine state agency heads and five citizen members. Minnesota Statutes, Chapters 103A, 103B, 116C, 116D and 116G (Statutes and Rules of the EQB)”
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City of Red Wing seeks garbage monopoly at expense of rural and small town residents

Recycling ignored

Minnesota law ignored

Recently, after years of campaigning by residents, Hennepin County abandoned it’s plan to burn more garbage in downtown Minneapolis and called upon the city to collect more materials for recycling.  The Minnesota Pollution Control Agency (MPCA), which had always opposed the residents’ campaign, reacted with displeasure, broadcastingan email saying: “The HERC incinerator will remain an important component of how the metro area manages garbage disposal.”

It should be no secret that a key cause of Minnesota’s failure for many years to make real progress on recycling is the MPCA itself.  The MPCA makes waste policy, issues permits for waste facilities, does environmental review of many of them,  and also makes grants for building/expanding these same facilities.  There are huge conflicts of interest in these multiple roles.  How can anybody believe the PCA is objective about a facility that it is funding?  Worse, the PCA’s waste policy people act as a branch of the garbage incineration industry.  Rather than focus on the top of the Minnesota “waste hierarchy”–source reduction and recycling–the PCA inverts the intent of the law and focuses on the bottom of the hierarchy–dumping and burning.

The Minnesota Legislative Auditor has said:

Minnesota law says that counties should manage municipal solid
waste according to a hierarchy that makes waste reduction, reuse, and
recycling the preferred methods and landfill disposal the least
preferred. In 1989, the Legislature adopted comprehensive waste
reduction and recycling legislation, commonly referred to as SCORE,
to support the waste management hierarchy. Among other things, the
legislation authorized state block grants to counties that could be used
for recycling and waste reduction activities, education, developing
markets for recycled material, and management of household
hazardous waste. The legislation also established goals for recycling
and waste reduction.

But the PCA puts constant pressure on counties and municipalities to burn more, at great expense and harm to air quality, while doing very little if anything to increase recycling.  Shameful examples of this can be found all over Minnesota, but here I will focus on Red Wing and Goodhue County.  The MPCA’s chief incineration agent is Sig Schurle, who prowls the state promoting the big burn.  (Schurle doesn’t return calls from this writer.  As a matter of fact, nobody at the MPCA seems to be returning my calls right now.)

The City of Red Wing has been into garbage incineration for a long time, with the usual toxic effects not only on the air but on policy.  For instance, Red Wing has lobbied the MPCA for years to get it to force more garbage from the Cities to be sent to Red Wing.  Why, because Red Wing’s burner has been losing the City lots of money for years and city officials’ idea of how to fix that is to get more garbage to burn.  Red Wing public works director Rick Moskwa said “since I took over that facility ten years ago, all I’ve done is look for waste [to burn].” The City has curtailed library hours, stopped distributing a newsletter, and curtailed other useful services while wasting hundreds of thousands of dollars per year keeping the burner going.

Now, Red Wing has shut down its municipal burner–old, dirty, obsolete, with a bad record of permit violations–and is working various alternative burner scams with Xcel Energy and the MPCA.  Why?  Xcel Energy also burns garbage in Red Wing in two converted 1940’s coal burners.  Xcel also wants to burn more garbage.  So the Red Wing legislative agenda for 2014 includes opposing a container deposit bill, more Cities garbage burned in Red Wing, and diversion of money from the Xcel “Renewable Development Fund” to buy Red Wing a garbage grinder–to increase burning at the Xcel incinerators.  Is all this shameful enough?  Read on:

For years Red Wing has also tried to force municipalities and waste haulers in and around Goodhue County to send their garbage for burning in Red Wing.  So far, these efforts have failed.  Now, Xcel, Red Wing, and the MPCA are trying again, beating on Goodhue County with carrots and sticks:

(1)     The MPCA is withholding approval of the Goodhue County solid waste plan;
(2)     he MPCA has withheld the last three “SCORE” payments–totaling about $70,000–to Goodhue County, and
(3)     is offering to transfer responsibility for an old closed landfill to the state.  This would require special legislation which Rep. Tim Kelly is reportedly prepared to introduce.

The conditions:  Goodhue County to pass a “flow control” ordinance forcing all county garbage to be taken to Red Wing for grinding up and burning.  Red Wing projects this monopoly would bring the city garbage operation an additional 8,000 tons/year of waste.  The motivation is financial:  it would bring the money-losing operation closer to break-even.

In effect:  Red Wing’s money-losing garbage operation, and the Xcel garbage burners, would be subsidized by rural Goodhue County residents.

At a March 3rd “workshop” on the scheme, attended by Red Wing city council members, Sig The Burner Man, and Greg Isakson, Goodhue County Public Works Director and County Engineer.  All said they liked the idea.  No public comment was allowed.  No mention was made of the health effects of more garbage incinerator pollution.   No mention was made of recycling except as a possible future issue.  (Red Wing’s Deputy Director of Solid Waste, Jeff Schneider, used to be “State Recycling Coordinator” at the MPCA.)

Data provided by Goodhue County indicates county recycling rates peaked at in 43% in 2007 but had dropped to 37 by 2012.

What are the implications of this scheme?

Higher disposal costs for everybody in Goodhue County, especially rural and small-town residents.
More health-damaging incinerator pollution.
Even less recycling.
Possible serious damage to private businesses such as the P.I.G. landfill in Hager City, Wisconsin (across the Mississippi River from Red Wing) that now takes a lot of waste from Goodhue County.

Benefits?

Well, some of the costs of Red Wing’s misguided waste operations could be shifted onto other County residents, and possible landfill cleanup costs could be shifted onto the entire state.  But are these real benefits?

Alternatives:

Communities all over the world are getting serious about source reduction and recycling (“zero waste.”)  There’s no reason the City of Red Wing, and Goodhue County, couldn’t do the same (Except for the perverted guidance they get from the “Pollution Control Agency .”)  With time and commitment, we could work up to a recycling rate of 80%, leaving a relatively small amount of stuff to be landfilled, and have solid waste management we could be proud of.

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The unending PolyMess ….

For about seven years various state and federal agencies have been doing “environmental review” of this project, the first of its kind to be proposed in Minnesota.   Mining industry people and their agents, including numerous Minnesota politicians of various parties, claim the proposed copper-nickel (sulfide) mining is the economic salvation of Northern Minnesota. The enviro side predicts disastrous pollution will result. Who is right?  Or does the truth lie somewhere in between? Officially the NorthMet Mining Project, the supposed plan is to dig up and process 240 million tons of this over a period of twenty years:

“The NorthMet Deposit is one of 10 known significant mineral deposits that have been identified within the 30-mile length of the Duluth Complex and just south of the eastern end of the Mesabi Iron Range. The complex is a well-known geological formation containing large quantities of copper, nickel, cobalt, platinum, palladium, and gold. The MDNR has estimated that the entire complex contains as many as 4.4 billion tons of mineral resources grading at 0.66 percent copper and 0.20 percent nickel. The NorthMet Deposit is believed to be the second largest deposit within the Duluth Complex and represents nearly 25 percent of the known mineral resources in the area.”

The Minnesota Department of Natural Resources (DNR), the US. Forest Service, and the US Army Corp of Engineers (the “lead agencies”) have produced the most recent environmental review report, a 2165 page “Supplemental Draft Environmental Impact Statement (SDEIS).”  In addition, the agencies have produce videos and “Fact Sheets” with generally cheerleading tones but factual errors.

The US Environmental Protection Agency had called a previous Environmental Impact Statement  “inadequate,” saying in a Feb 18, 2010 letter that the project may “may have substantial and unacceptable adverse impacts on aquatic resources of national importance.” In the runup to three recent public meetings, DNR Commissioner Tom Landwehr has done a frenzied road show, basically telling Minnesotans to see things through the same rose-tinted lens used by the DNR to evaluate mining projects.

The Duluth New Tribune lost its collective mind in one of the most insulting editorials I’ve ever seen in a mainstream newspaper.  Making copper mining happen seems central to the political agenda of Governor Mark Dayton.  Dayton has gone so far as to say he’d like to see the US Environmental Protection Agency abolished.  See Carol Overland’s Legalectric post on this. This is an issue on which many Minnesota NGO’s have been able to focus effectively.

Good information is available on the sites of Audubon, WaterLegacyMining Truth, and many others. Many people have studied the SDEIS in more detail than I have, and have identified many deficiencies.  I’ll just add a few thoughts.

The public hearings on this are inadequate and orchestrated.  Look at this about the last–presently scheduled–hearing in St. Paul on Jan 28th “Because of limited time, moderators will pick 60-80 names at random to deliver oral comments of up to 3 minutes in the large auditorium between 6:45 and 10:00 PM.”   This is a shameless attempt to limit public testimony.  Instead, the hearing should be continued on as many evenings as necessary until everyone has had a chance to talk.  In the previous cycle of public comments in 2009, the DNR got attention for refusing to let people testify in public at all.  I wrote this up at the time:”PolyMet, manipulation, and public meetings/hearings.”

According to the Minneapolis Star-Tribune, about 640 people signed up to speak on the 28th but only 59 were allowed to. State regulatory agencies like the DNR and MPCA can’t deal effectively with politically connected industries like mining in Minnesota.  (Or garbage-burning in Minnesota, or agriculture in Minnesota, or ….).  This is why the supervision of federal agencies is so important–they can be more insulated from state-level politics and help maintain the integrity of the process.  So how this current cycle of environmental review will depend a lot on whether the federal agencies, especially the EPA, again do their jobs, or whether they roll. In 2010 EPA called out “substantial and unacceptable adverse impacts on aquatic resources.”  Has anything changed to alter that conclusion?  I doubt it, because (1) the essential characteristics of the project haven’t changed, and (2) the “modeling” of water pollution impacts seems to be based on incorrect baseline data on how much water will flow through the site.   This casts doubt on the validity of all the predictions of how pollutants in nearby surface waters would change.  A good writeup of this here:  “Study may need major fix.”

The Native American tribes/bands/organizations  involved in the effort have identified 18 official “Major Differences of Opinion.”  They of course, “were here first,” and remain more closely connected to the lands and waters of the area.  They apparently have been pointing out the problems with the water flow baseline for some time.  Many of their “differences of opinion” seem like no-brainers.  Number 17 says:

“Fond du Lac and Grand Portage do not agree with statements in the document that indicate there is “no impact” when that assertion is based on not exceeding an evaluation criteria. They believe the SDEIS should acknowledge where there is a change, regardless if a criteria or standard is exceeded. With regard to the water quality effects analysis, Grand Portage and GLIFWC note that evaluation criteria are not equivalent to water quality standards. Grand Portage further notes that some evaluation criteria are high enough to cause human health impacts and evaluation criteria are not equal to or a substitute for water quality standards compliance. GLIFWC notes that in some areas, for example the cumulative effects section for the Partridge River, the text states all water evaluation criteria would be met, though water quality standards would be exceeded for several constituents.”

In other words, the “lead agencies” are simply cooking the books on water pollution.

Why, after about seven years of environmental review work, is the news so bad.  Simply because the news IS what it is.  There is no way such an operation, as the mining industry would run it, can avoid causing major problems.  The key reason:  the ore and some of the overburden contain sulfur.  When this is broken up, and exposed to atmospheric oxygen and moisture, sulfuric acid (H2SO4) is formed.  This dissolves other harmful constituents from the rock and directly adds sulfates (SO4) to the water.  Billions of tons of material are involved, so the “reactive” rock would cause mischief for hundreds or thousands of years.

So why are Governor Dayton, many members of the Minnesota Legislature, and others, pushing so hard for this?  Officially, “jobs.”  According to the SDEIS, Polymet claims the jobs created would be: Construction:  500 direct jobs plus 332 indirect jobs.  Total 832 Operation: 360 direct jobs plus 631 indirect jobs.    Total 991 Yet, these apparently are Polymet’s numbers and most likely exaggerated.  And they don’t mention the jobs that might be lost in other industries such as recreation and tourism.

The Current Population Survey of households showed 2,834,248 employed persons in Minnesota for December, 2013.  Minnesota added 9,500 jobs in December 2013 according to the CPS employment measure or 5,901 by the Current Employment Survey (The two surveys use different methods). To simplify, lets assume there are three million jobs in Minnesota and PolyMet generates a net of 500 more.  Then PolyMet would provide 0.017 percent of the jobs in Minnesota.  About equal to the number Target is laying off at its corporate headquarters.  Granted these jobs are very important to the people who need them, and 500 jobs on the Range are likely harder to come by than 500 jobs in the Cities.  But how much sense does it make to bring in a facility with a very high probability of crapping up a sizeable chunk of Minnesota, and perhaps increasing pollution of Lake Superior, to increase employment in Minnesota by 0.017 percent?

How reliable are the pollution numbers and other numbers in the SDEIS? The documents say the “Life of Mine” would be 20 years and the plant would process 32000 tons per day of ore.  But what is to ensure that the operation would shut down after 20 years?  Nothing, in my opinion.  This is not any more likely than that Minnesota’s nuke plants would shut down at the end of their 25 year licenses.  No reactor in the US has ever been denied a license extension.    As long as there is copper-nickel or to be dug up profitably, activities are likely to continue.

A more reliable source that the SDEIS and its predecessors may be a report on Polymet by Edison Investment Research Limited.  Edison claims to be “Europe’s leading independent investment research company …” and has an office in Toronto. Edison says “PolyMet Mining Corp. is a research client of Edison Investment Research Limited.” I think this means PolyMet pays Edison to promote Polymet to investors. It seems likely that the information in this report is what PolyMet want to pitch to investors.  The report says:

“We look for management to create additional value through expanding capacity or consolidating the Duluth Complex. In addition, we believe PolyMet might be able to optimise NorthMet’s ore processing rate while staying within the permitted emissions level.”

Our base case valuation is US$479m or US$1.49/share undiluted or US$1.32/share diluted. Our DCF valuation uses a 10% discount rate, a 20-year mine life and long-term price assumptions of US$2.96/lb for copper and US$10.14/lb for nickel. We assume a US$450m capital cost with US$100m financed with equity at US$0.85/share and US$350m funded with debt. No value is ascribed to the unused resource.

Our upside valuation, based on an expansion to 90,000 t/d [emphasis added] at an additional capital cost of US$400m, is US$1,254m or US$3.89/share undiluted or US$3.08/share diluted. Sensitivities: Permitting is key The important issues facing PolyMet are: permitting, geology, commodity pricing, access to capital and project execution. PolyMet is a junior development mining company… (“A junior mining company has no mining operations and is essentially a venture capital company.”)

PolyMet acquired the Erie Plant from Cliffs Natural Resources in transactions in 2005 and 2006 for US$32m. This materially reduces the capital cost to build NorthMet and shortens the required construction time.

NorthMet will start with a volume of 32,000 t/d (short tons), but historically the plant operated at 100,000 t/d and we believe an operating rate of at least 90,000t/d should be attainable [emphasis added].

PolyMet will be an open-pit mine. Run of mine rock will be delivered to a loading system, loaded onto rail cars and delivered to the Erie Plant six miles to the west. PolyMet will mine approximately 32,000 tons of ore per day in Phase I. It will have a life of mine stripping ratio of 1.4 to 1.0, but will start out with a very low stripping ratio the first several years.  [This means that for every ton of ore dug out, 2.4 tons of material will have to be moved, including the ore and the overburden.]

Waste rock with the lowest sulphur content will be placed in a stockpile with a ground water containment system. The remaining waste rock will be temporarily placed on foundations, liners and containment systems, then backfilled into the pit for underwater storage. Ore will be transferred from rail cars into crushers formerly used to crush iron ore. Once the ore is crushed to 0.5 inches it will be further ground in rod and ball mills, reducing it to 120 microns. The finely ground ore will be sent to new flotation cells that will separate the metal-bearing rock concentrate from non-metal-bearing rock (tailings). The flotation circuit will produce separate copper and nickel concentrates. Tailings will be collected from the flotation cells and sent to the existing tailings basin. Five years of testing have shown these tailings will not generate acid. The metals are separated into concentrate to be sold for further processing. … 

Initial annual production of Phase I is estimated at 72m pounds of copper, 15m pounds of nickel and 106,000 ounces of precious metals. Based on the economic  summary in the 2013 updated 43-101 Technical Report, NorthMet will have a cash cost of US$1.05 per pound of copper based on co-product economics and a negative cost of US$0.28 per pound of Copper based on byproduct economics. [copper now sells for around $3.25/pound but prices are highly volatile.)

The Erie Plant provides PolyMet with a competitive advantage. The Erie Plant is a large grinding and milling facility with a tailings pond. The plant includes two rail dump pockets, two primary 60″ gyratory crushers, eight secondary 36″ gyratory crushers, seven tertiary standard cone crushers, 14 seven-foot short-head crushers, 30 mill circuits each comprising one 12′ x 14′ rod mill, one 12′ x 14′ ball mill, three 12′ x 24′ regrind mills and maintenance facilities. It also has conveyors, feeders, bins, auxiliary facilities and a 225MVA high-voltage electrical substation, with a water supply, road, tailings basins and rail facilities. It owns a 120-rail car fleet, locomotive fuelling and maintenance facilities, and water rights. The Erie Plant operated from 1957 to 2001, processing taconite, and was shut down in the bankruptcy of its owner, LTV Steel Mining Company.

The existing Erie Plant has a historic capacity of 100,000 t/d, comprising four-stage crushing and 34 mill lines, each with a rod mill and ball mill. Cliffs operated the plant on behalf of the owners, processing 100,000 t/d of taconite ore. In the mid-1980s the consortium was consolidated into a single owner, LTV Steel.

The plant is in good physical condition and operated at or near full capacity prior to its closure. PolyMet has not operated the plant, but has examined it in detail and believes the mill is serviceable. PolyMet plans to use one of two primary crushers and one-third of its historic capacity (32,000 t/d) to treat the material mined from the NorthMet deposit in Phase I.

We believe management may optimise the potential of the plant in Phase I while staying within the permitted emissions level. [emphasis added]  We believe it could achieve a 20% to 30% increase in throughput while deploying minimal additional capital, which should enhance the project’s economics.

Phase II will further treat the milled nickel concentrate. The concentrate from the flotation cells will be put into a large pressure oxidation vessel called an autoclave. Oxygen will be added to create a chemical reaction with the nickel concentrate. Heat generated by the exothermic reaction and high pressure will drive the metals into solutions. Metals, including nickel, cobalt, platinum, palladium and gold, will be precipitated out of the solution and sold as semi-finished products: nickel-cobalt hydroxide and precious metal precipitate. Limestone will be added to the excess solution to neutralise acidity. This will create synthetic gypsum that will be stored in a lined facility. [Sounds like some serious potential for pollution here….]

The NorthMet resource

The NorthMet copper-nickel-PGM ore body is near a number of shut-down iron ore mines and the operational Peter Mitchell open-pit iron ore mine is approximately one mile north. The NorthMet ore body comprises 275 Mt of proven and probable reserves grading 0.79% copper equivalent with measured and indicated (M&I) mineral resources of 694 Mt grading 0.74% copper equivalent (Exhibit 2). We believe the size and scope of the ore body could support a much larger project, which would create meaningful additional value.  [Now we are getting to why the SDEIS does not capture the real impacts ….]

Potential resource expansion

We believe there is a good chance PolyMet will be able to expand the size of its resource by 50-100% based on what we learned on a site visit. [emphasis added]  The eastern end of the pit is cut off by the property boundary with the Teck-Mesaba project. However, down dip to the south and west the geology is open (Exhibit 3). Also, based on drill work to date there is a chance PolyMet will be able to identify economic mineralisation on the hanging wall and at depth. Expansion to 90,000 t/d Phase I is designed to operate at 32,000 t/d, which uses 32% of the Erie Plant capacity. Based on rule-of-thumb estimates, the capital cost of expanding to 90,000 t/d would be approximately US$400m. Expansion would require additional environmental review and permitting. We have assumed it would take two years to secure permits and one year to expand the mine to 90,000 t/d and update the mill. It operated at 100,000 t/d previously, so a 90,000t/d rate would leave a 10% cushion; the NorthMet deposit is large enough to support the larger capacity. We assume PolyMet would restructure its debt to fund the capital for the project and that it would begin working on permitting the expansion project within six months of receiving its permits for Phase I. On this basis it could complete its expansion by Q218. Third-party processing There are roughly 11 mineral properties within shipping distance of PolyMet’s mill.

We believe there is a good chance PolyMet will decide to toll process third-party ore or form some relationships with one or more the local projects. We believe government permitting agencies may encourage the developers of other mining properties in the area to work out an arrangement with PolyMet to use its pre-existing mill and tailings pond. This would limit the footprint of mining and processing in the area.

Like the expansion case, we believe it would take two years to permit the expansion of the mill and one year to complete the mill modernisation. But since we do not know the grade of the ore to be toll processed or its metal composition we cannot model the potential contribution a third party relationship may have. We believe eventually the copper-nickel-PMG properties in the Duluth Complex that are close to the Erie plant facility may consolidate under PolyMet.

Potential future permitting of throughput expansion up to 90,000 t/d

We assume PolyMet would begin working on permitting the expansion to 90,000 t/d within six months of receiving its permits for Phase I, permitting would take two years and construction would take one year. On this basis, it could complete its expansion by May 2018.

Ok, this is a bit long and tedious, but suggests that the scenarios laid out in the SDEIS are low-balls, not representing what will really happen in the genie is let of out the bottle.  Plainly, much more comprehensive studies are needed.
How much is this mine “needed?”  One of purposes of environmental review under both federal and Minnesota statutes is supposed to be consideration of alternative to the proposed project.  In practice this is rarely done in any meaningful way, and it has not been done in this matter.  But Paula Maccabbee of WaterLegacy has produced “RECYCLING OF NON-FERROUS METALS–AN ALTERNATIVE TO SULFIDE MINING IN MINNESOTA.” Take a look.
According to the DNR,  Comments will be accepted until 4:30 PM CT on Thursday, March 13, 2014.  NorthMetSDEIS.dnr@state.mn.us
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Martin King’s birthday

In  the 1980’s I was working as a consultant to the engineering department of a large chemical company.  Like many US corporations around that time, they had looked at the the changing demographics of the US population and figured out that their future workforce couldn’t be all white and all male.  White people were going to be a decreasing proportion of the population. and their just wouldn’t be enough of them.   So they needed to change their corporate culture enough that black and brown and yellow and female people would find it acceptable.  This, in corporate-speak, was called something like “celebrating diversity.”

In practice this meant hiring consultants to put on “diversity” programs and meetings.  The majority of people working there probably understood the point, and were supportive or at least accepting.  But some were not, and this is hardly surprising.  After all, the culture was not only “white,” but Southern, “conservative,” Republican, and upper-middle-class.  Many had grown up, as did I, seeing “Martin Luther King is a COMMUNIST” billboards.  Having been taught all their lives to dislike, if not to hate, King and what he stood for, it’s not surprising they felt betrayed by their managers’ change of tune.

What was the fundamental beef with King?  That he was uppity.  That he asked for too much.  That he was unreasonable.  That he wouldn’t take “no” for an answer.  Above all, that he was do damn charismatic and effective.

At my client’s offices, I had this to say:  Honoring the trouble maker King, 20 years safely dead, doesn’t take a lot of courage.  Deceased troublemakers mellow with time.  The real test of our sincerity in supporting the righting of   injustice is how we are treating the troublemakers who are active NOW.  Who are the annoying Black leaders active at the moment and how can we support THEM?

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Minnesota’s “Legislative Energy Commission” vs public participation

The Minnesota Legislature has a “Legislative Energy Commission” (LEC) made up of Senators and Representatives. The law establishing it says:  “The commission shall continuously evaluate the energy policies of this state and the degree to which they promote an environmentally and economically sustainable energy future.” Continue Reading →

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RIP Barbara Brenner (Breast Cancer Action)

Barbara Brenner , long time leader of Breast Cancer Action, was a hero of the fight against environmentally-related cancer–among many other matters–and a consistent challenger of the profit-oriented “cancer industry” symbolized by the “American Cancer Society” and “Susan G. Komen for the Cure.”

She passed on May 10 at the age of 61 from amyotrophic lateral sclerosis. Continue Reading →

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Welcome….

Subscribe to my Minnesota Energy and Environment (Etc.) mailing list.

Minnesota is rich in blogs, and alternative media such as The Uptake .  Is another blog really needed?  Good question!   My main reason for setting it up is to have a place to archive and link to various emails and posts. Continue Reading →

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Reminder: TODAY – Greenhouse gas hearing Thursday, August 30th, 2:00, at the MPCA

 

At least 43 people asked for this hearing; the requests, from around the state, make very clear that Minnesotans know what’s at stake and what needs to be done. One of my favorites is one of the shortest, from David Luce: “People, I add my voice to the request for a hearing. We are already way late on this and the longer we delay the worse it will surely get. Forget the difficulties, think of the kids. Thank you.”

An irony of all this is that many people in the Pollution Control Agency also know what needs to be done. The MPCA has a climate change page with a lot of information. Last year the PCA had a good global warming exhibit at the State Fair. (I heard that some Republican pols complained about it.) This year, I am told, “we didn’t back off at all” and the info is beefed up. (Haven’t yet been to the Fair myself this year.)

Minnesota has a Next Generation Energy Act, passed in 2007 with strong bipartisan support: “Effective Aug. 1, 2007, the law calls for cutting the state’s greenhouse gas emissions to 15 percent below 2005 base levels by 2015, 30 percent by 2025 and 80 percent by 2050. (Art. 5, Sec. 2)”

So if the people know what needs to be done, and the MPCA knows what needs to be done, and state law calls for it to be done, why is the MPCA proposing a regulation so weak as to throw out a key opportunity to regulate greenhouse gases?

For one thing, many of the activities officially promoted by the Legislature and the PCA as climate change solutions really accelerate climate change. These include garbage incineration, “biomass” burning, turkey poop burning, and corn ethanol distilling. These are high-carbon-emitting processes that can’t stand up to examination either in environmental review or permitting. (Wind power is probably the only politically-favored industry that does tend to reduce carbon emissions,but anyone following this industry in Minnesota knows it has plenty of issues of its own.)

The other approach that has proven politically possible involves various sorts of “offset” and emissions trading schemes. Some of these, such as the Regional Greenhouse Gas Initiative of some Northeastern states, may have a small beneficial effect. In general, though, years of experience clearly shows that these schemes mostly serve to enrich speculators and manipulators while creating a false illusion of progress.

The budgets of the MPCA and other regulatory agencies have been slashed, and they attempt to operate without sufficient staff or resources. Increasingly, MPCA staff are being expected to function less as regulators and more as skid-greasers for politically favored industries….

Minnesota politics, like US national politics, have largely descended into idiocy, with the likes of the Koch Brothers and the Minnesota Chamber of Commerce calling the tunes for both parties.

In any case, there is little hope of reducing climate changing emissions if we don’t use existing laws such as the Clean Air Act and related state laws and take action. These laws and programs are hard to understand in detail–the lingo is obscure, there are numerous interlinked Federal and Minnesota statutes, rules and regulations, policies and procedures….citizens are at a great disadvantage in disputing the fine details. But the bigger picture is clear enough, and that’s what we should focus on.

A little background:

The Clean Air Act wasn’t written with greenhouse emissions in mind, but rather to control the traditional, health-damaging pollutants such as sulfur dioxide and ozone. The common breakpoint for being considered a single “major source” of such pollutants, and requiring “permitting” of same, is 100 tons per year. (This, by the way, is why so many Minnesota air permits have limits of 95 tons or so!) The conventional argument goes that this number is too low for carbon dioxide, or carbon dioxide equivalent (CO2-e) which tries to factor in emissions of some other climate-changing gases such as methane. That CO2 is emitted in much larger amounts than other air pollutants (true enough) and a 100 ton limit would include heating systems for small commercial buildings, large homes, etc. The US EPA swallowed this argument whole and went for a limit one thousand times higher: 100,000 tons. Minnesota already adopted this number for environmental review, largely taking the Minnesota Environmental Policy out of play as a tool for controlling global warming. Now, the Dayton administration wants to adopt this same number for air permitting, taking the Clean Air Act out of play.

So the challenge for those of us wanting a future is to figure out what numbers we favor at this time, and how to advocate for them successfully.

EPA requires some reporting of greenhouse emissions. “Facilities that emit 25,000 metric tons or more per year of GHGs are required to submit annual reports to EPA.”

Data for Minnesota are here, but presented such that it is hard to analyze. It appears that 132 facilities reported 2010 data. Of those, 18 reported emissions below 25,000 tons, leaving a total of 114 facilities reporting emission above 25,000 tons. Of these, 46 reported emissions above 100,000 tons. (These, of course, include only large “stationary” sources. “Mobile” and “area” sources, such as cars and trucks, are a big part of the picture but not included here.)

“Permitting,” or “environmental review” for that matter, in no way ensures that CO2 emissions would have to be reduced. That depends on how the rules are written. In some cases, like an existing coal powered generating station, there are no practical ways to substantially reduce CO2 emissions other than to shut it down or run it less. It only implies that some consideration will be given to CO2-e emissions.

My own thinking, at the moment, is that the 100 ton limit ought to remain for CO2-e as for other pollutants, but permitting attention should be phased in, starting with the higher emitters. Facilities emitting 25,000 tons should receive immediate attention by means of reopening their air permits. Other existing permitted facilities could get attention as their permits come up for renewal, in a timely manner. (This is a crucial point because the MPCA air permitting program is generally ignoring expired permits.) New facilities likely to emit 100 tons per year would be next in line. Existing facilities emitting 100 tons per year, but not now permitted, would come after then. But these are only Muller’s thoughts and discussion is needed.

Additional resources would be needed to carry this out, but, again, as Mr. Luce said: “We are already way late on this and the longer we delay the worse it will surely get. Forget the difficulties, think of the kids. Thank you.”

The hearing this afternoon will not be an end point, but it could be a beginning. The Minnesota Administrative Rules for rulemaking hearings allow good opportunities for the public to participate, to ask questions, to get more information…. If the Administrative Law Judge follows these rules, if the PCA answers questions in good faith, if citizens show up and participate–these are all big IFs!–we may have a beginning of something very important.

Thanks again to Ken Pentel for his prodding about this.

Alan Muller

 

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Rep. John Kline blocking diesel/cancer report on behalf of mining interests

Note:  This originally published in the Twin Cities Daily Planet on Feb 6, 2012

Rep. John Kline represents the 2nd Minnesota congressional district.  Well, he’s supposed to, but he actually represents the interests of those exploiting the 650 thousand humans he’s supposed to be representing.  He believes, quite sincerely I suspect, that government should protect special interests, while human citizens should sink-or-swim.  To some this might seem like partisan political rhetoric.  I just ask you to withhold judgement for the few minutes needed to read what follows.

Most people already know diesel engine exhaust is highly dangerous to health.  Much of it is made up of tiny particles coated with heavy metals and organic toxins.  The particles carry these through the lungs into the bloodstream and into the brain.  Strokes, heart attacks, and cancer, among other health problems, result.

If it’s unhealthy to live hear a road or to operate a diesel truck, just imagine how unhealthy it must be to work in an underground mine alongside diesel-powered machinery.  In the confined spaces the pollutant concentrations are much higher.  The Center for Public Integrity reports:

“In arguing for a diesel exposure limit in 2001, the mine safety administration said that diesel particles spewed by front-end loaders, generators, air compressors, and other underground equipment could carry with them up to 1,800 other organic chemicals, including carcinogens. Median diesel concentrations in mines, it said, were up to 180 times higher than the average exposure in heavily polluted urban areas and eight times higher than in other workplaces.

‘When there is uncontrolled diesel equipment in an underground mine, it is like working in the tailpipe of a city bus,’ said Mike Wright, health and safety director for the United Steelworkers, which represents 15,000 miners.”

A regulation finally went into effect in 2008 but is only a partial solution.  New diesel engines are much cleaner than old ones but this only happened after years of foot-dragging and corrupt practices by engine makers.

Underground mining was very extensive in Minnesota up until 1961.  The Minnesota Department of Natural Resources–in a project incomplete for lack of funding–has mapped over 200 underground mines on the Iron Range.  Of course, not all of these would have used diesel engines, but on the other hand, many other digging/tunnelling operations all over the state have resulted in similar exposures.  Proposed sulfide mining projects could bring underground mining back to Minnesota.

So one might expect a Minnesota congressman like Mr. Kline to strongly favor full understanding of diesel health hazards so past and future miners can be protected and compensated.

But no, Kline is acting to block release of a report on diesel/mining health hazards in the making since 1992.  The scenario seems similar to actions by the chemical and incinerators industries, etc, to block an EPA report on dioxin.  Without the reports documenting the hazards, regulations won’t be tightened and people will continue to be harmed.  Again, from the Center for Public Integrity:

“The epidemiological study of workers at so-named metal and nonmetal mines was launched in 1995 by the National Cancer Institute and NIOSH to build on studies that suggested a link between diesel and lung cancer in truck drivers and other workers exposed to diesel particulate matter. The study’s results will offer a ‘state-of-the-art evaluation of diesel,’ said Kyle Steenland, a professor at Emory University’s Rollins School of Public Health and a former NIOSH epidemiologist. ‘It should provide a very important piece of information about whether diesel is a lung carcinogen. Unfortunately, it has been delayed and delayed for years. It’s high time that the public and the scientific community get to see the results of this study.'”

The tactics of the mining and diesel engine interests has been to use the highest-powered lobbyists and lawyers to obstruct at every point.  In this fight they’ve been repeatedly aided by the rulings of Bush-appointed U.S. District Court Judge Richard Haik of Lafayette, La. And Kline.

The mining interests demanded that the draft report and underlying data be given to THEM to review, and to the House Education and Labor Committee–now the Committee on Education and the Workforce, and chaired by Rep Kline–but withheld from the public.  Haik agreed and has found the US Department of Health and Human Services in contempt.

“‘We are troubled by the continued failure of NIOSH to produce the draft publications, data underlying the research reported in those draft publications, and other documents the Committee should be receiving based on instructions from the court,’ Kline and [Republican Rep. Tim] Walberg wrote on July 8.” (direct links not accessible)

Of course, when industrial interests and their legislative stooges like Kline are allowed to interfere in scientific publication this way, nothing good happens.  Nothing good for the public or for science, anyway.

“Rep. Miller, the Democrat, sent his own letter to Howard on Aug. 16. ‘The requirement for a pre-publication review by an interested party ­ and the insinuation of a congressional committee in such review ­ appears to deviate from the normal scientific process and threatens to undermine the integrity of these studies,’ Miller wrote.”

For more details see these stories:

Landmark diesel exhaust study stalled amid industry and congressional objections

Diesel dangers: Mining companies get first look at government cancer study

Diesel report’s publication delayed as industry demands to see documents first

Notes:

No one from Rep. Kline’s offices or the staff of the Committee on Education and the Workforce has so far returned my calls, so if there is an interpretation of these events less unfavorable to Kline, we weren’t given it.

The Center for Public Integrity does great work, but is hard to work with.  Many of the links in the two stories go to a document source not available to the public, and contact information for reporters is hard to come by.

ACTION:  Call Kline and tell him to stop fronting for mining interests with cancer-causing pollution to hide:

Washington, DC office:  202.225.2271

Burnsville , MN office: 952.808.1213

Alan Muller

alanmuller.com

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