Minnesota agency comments on EPA Region 5 climate change draft report…..??

The US Environmental Protection has laid out a  Draft Region 5 Climate Change Adaptation Implementation Plan (draft dated September 18, 2013)  and is accepting public comments through January 3, 2014.

For whatever reason, I just found about this yesterday.  Apparently, no effort has been made to alert the public, although NOTHING is more important to our future than climate change.  (Of course, we are having a cold winter, but that’s weather, not climate.)

The Minnesota Pollution Control Agency has been preparing comments.

I lack confidence in the PCA’s management to address this issue, mainly because of a disgraceful rulemaking in 2012, in which the breakpoint for regulating carbon dioxide was raised from 100 tons to 100 thousand tons.  More on that here.  More also from Carol Overland at Legalectric.org  Lots of people objected, but it seemed to be one of those “done deal” situations.  The Administrative Law Judge, Miguel Cervantes, seemed to be hearing the arguments, but–suspiciously, in my view–the order upholding the PCA’s indefensible position was signed by a different ALJ, Eric Lipman.  Neither the PCA or the Office of Administrative Hearings covered itself with glory….

Some rumors have circulated that MPCA staffers developed stronger, more substantial comments than the PCA’s management plans to submit.  There would be nothing surprising or unusual about this if true.  The PCA is a politically controlled bureaucracy and most politicians respond primarily to the short-term agendas of industrial interests.  Certainly Governor Dayton seems to.

But consider:  We are at a critical point in history and how we react, or if we react in advance, to climate change will have a big impact on our children and their children….  The only way to get real “value” from environmental regulatory staffers is to have technically and ethically competent, motived people and let them do real work, protected as much as possible from censorship and retribution.

With this in mind I sent in the following information requestto the head of the MPCA, and similar requests to MDH and DNR.

Dear Commissioner Stine:

It is my understanding that EPA Region 5 is accepting public comments on the Draft Region 5 Climate Change Adaptation Implementation Plan (draft dated September 18, 2013) through January 3, 2014.  It is also my understanding that the MPCA and perhaps other Minnesota agencies have been working on comments.

Pursuant to the MN Data Practices Act, I request copies of all comments and related correspondence, including all versions of all drafts of comments/proposed comments.

If this request raises any questions please contact me.

Yours very truly,

Alan Muller

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