Site-Specific Sulfate Standard Framework - Policy Plan

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Comment From: Jean Skinaway-Lawrence

9/04/23 @ 11:57 PM
MPCA must enforce Minnesotas wild rice sulfate standard of 10 parts per million under the Clean Water Ace and decisions of hte Minnesota Courts. MPCA has no discretion to continue to delay or deny enforcement.. the 10pm sulfate standard is the "effec...↓
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Comment From: WaterLegacy (Paula Maccabee)

9/04/23 @ 10:50 PM
WaterLegacy submits the uploaded September 4, 2023 Comments, along with Attachments E through U. These Comments supplement WaterLegacy's prior July 31, 2023 Comments, with which Attachments A through D were uploaded.

Sincerely yours,
Paula G. Maccabee,...↓
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Comment From: Chris Baldwin

9/04/23 @ 10:41 PM
My name is Chris Baldwin, a native Minnesotan, a long-term and current resident of Hibbing and descendent of an Iron Range railroad pioneer grandfather. My father was executive VP and Director of Research for Cargill for 30 years. I am a retired hard...↓
My alarm signals are really going off as I research more into the long term BIO-ACCUMULATION affects of the sulfide minerals that I personally witnessed and collected in the taconite ore the I helped mine for 23 years. As a professional engineer responsible to 'do no harm to the public and my fellow miners', I bear some responsibility to warn of an upcoming Bio Accumulation 'Bridge Collapse' I compare to the 35 W bridge collapse. Not only is the Methyl Mercury in the sport fish celebrated as Minnesota's best feature from the Land of Sky Blue Waters becoming so high that 3 game fish meals a week will give you a state recored for high levels of Mercury Toxicity. The sulfides in the taconite ores are partly responsible for these elevated mercury levels seen as especially acute from Minntac's tailings basin flowing into Lake Vermillion, and the abandoned Dunka River Taconite mine sulfide overburden stockpile leaching into Birch Lake and into the BWCA, and Eire's tailings basin leaching into St Louis River.
The sulfides in the taconite ores are responsible for mobilizing the methyl mercury and poisoning the food chain that we humans rely on for sport fishing and subsistence fishing. And the threat to wild rice is increasing and is a direct threat to another Iconic feature of Minnesota Northland and subsistence food source for Native Americans.
Tailings dams are 50 years old and are too high for long term safety.
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Comment From: Barbara Veit

9/04/23 @ 10:37 PM
Please enforce site-specific standards for a healthy, plentiful wild rice crop in impaired waters.
It's such an important food.
Thank you.
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Comment From: Jennifer McEwen

9/04/23 @ 10:25 PM
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Comment From: Linda Jensen

9/04/23 @ 10:22 PM
I am not a scientist or engineer but a regular person who eats, drink, breathes the essential resources within Minnesota. The fact that we are asking questions and commenting on this topic is a tragedy of our time because it means that at some point,...↓
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Comment From: Jennifer Hengelfelt

9/04/23 @ 10:13 PM
I am writing to ask the MPCA to uphold strong standards to protect our wild rice ecosystem from sulfate harm.

I'm especially concerned that our low-sulfate waters not be degraded, with consequent harm to wild rice viability, especially when allowing s...↓

The degradation of water quality in lakes, streams, and wetlands in Minnesota is prohibited by both the Clean Water Act and state law. It is imperative that the MPCA takes stringent measures to prevent any deterioration of high-quality, low-sulfate wild rice waters.

The MPCA must adhere to the 10 ppm wild rice sulfate standard when establishing and enforcing permit limits, as well as when conducting TMDL studies and developing implementation plans to facilitate the restoration of wild rice waters categorized as impaired due to excessive sulfate. It is important for the MPCA to not delay or presume that a less stringent standard will eventually be approved, until a "site-specific standard" is officially sanctioned in compliance with solid science, state law and the Clean Water Act.

MPCA and potential polluters must prove that allowed sulfate standards will not cause harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

In addition to harming our sacred wild rice, higher sulfate standards will continue to create a rise in mercury contamination in fish, which will have severe consequences on the brain development of Minnesotans dependent on fish for subsistence.

This negligence will also obstruct the exercise of treaty-reserved rights held by tribal communities. The MPCA should not approve any "site-specific standard" for sulfate discharge in wild rice waters without engaging in tribal consultation and obtaining tribal consent, while also following a formal and transparent rulemaking process.
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Comment From: Anne Brataas

9/04/23 @ 9:55 PM
Dear MPCA,
Did you get my postcard I sent you opposing a site-specific sulfate standard, and instead asking you to enforce existing wild rice sulfate standards? To recap: I urge you to enforce the existing 10ppm sulfate standard to protect Minnesota's...↓
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Comment From: Michael Maleska

9/04/23 @ 9:11 PM
I oppose the site-specific standard proposal from MPCA.
Water carries its dissolved burdens wherever it contacts other water through marshes, hard & soft soils & subsoils, even concrete.
Evaporation and rain (natural distillation) leaves most of those ...↓
It took us 50 years to understand that sulfates were the cause of mercury methylation. There is too much yet to learn about why some water bodies with sulfate levels from 0 - 5 ppm become polluted by mercury at an exponentially higher rate than those water bodies with sulfate levels above 30 ppm. MPCA has even proposed allowing more sulfate pollution in water bodies with HIGHER iron concentrations, contradicting their own rulemaking of 2018.
In no scenario does it make sense, scientifically, morally, or otherwise - to abandon the current wild rice standard in exchange for an unproven site-specific sulfate standard. This would open the door for unenforceable variables, confusion, and deliberate mischief.
All organizations and individuals professing to seek the best scientific solution to proposed changes in water quality standards need to be of the same understanding.
Current testing of waters in NE MN reveal one simple certainty: sulfates exist at exceedingly low levels in water bodies within the BWCA and other places where there are no intrusions from upstream mining operations. Sulfate levels there remain predictably steady and low.
Site-specific standard is a crapshoot.
There is never an acceptable time or reason to poison the public's natural environment.
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Comment From: Tara Widner

9/04/23 @ 9:03 PM
The manoomin (wild rice) & fish of Minnesota are protected by Treaties. They must be honored.

Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the ...↓
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
Thank you,
Tara Widner
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Comment From: Bryan Wyberg

9/04/23 @ 7:30 PM
I am dissatisfied with MPCA's actions over the past decades which demonstrate a confirmed bias in favor of industry and a continued pattern of ignoring the law to avoid protecting wild rice waters from sulfate pollution. This is a clear case of the m...↓

Following are my comments and concerns about this situation. I hope that the agency will give these comments a serious review and that it takes the recommendations for the protection of our wild rice waters seriously this time.

Legally, the MPCA must enforce the established standards. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is the "effects threshold" for wild rice impairment.

Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.

Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north-central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.

Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to the release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.

Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence and will impair the exercise of tribal Treaty-reserved rights.

Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.

High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.

MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.

Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay nor assume a less stringent standard will at some point be approved.

Please ensure you address all these issues prior to the release of your final decision. It is time to follow the law and enforce our state's water quality standards.

Thank you.
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Comment From: Gerri L. Williams

9/04/23 @ 7:20 PM
The quality of water is of utmost importance to our state of Minnesota, our country and the world. The MPCA should not advocate for different standards of sulfide pollution for different sites-- there needs to be one standard that can be fairly and c...↓
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Comment From: W.J. McCabe Chapter, Izaak Wal... (Julie O'Leary)

9/04/23 @ 6:07 PM
Re: Proposed MPCA proposed framework for site-specific sulfate standards for the protection of wild rice

Dear Commissioner Kessler,

Thank you for the opportunity to comment on Minnesota Pollution Control Agency's
(MPCA) proposed site-specific sulfate st...↓

The Duluth chapter, representing approximately 125 members in northeastern Minnesota. has been engaged in a wide range of issues concerning public policy and natural resources in northeastern Minnesota dating back to the 1950s, including the policy discussions and proposals surrounding the sulfate water quality standard and wild rice. Please accept these comments regarding our concerns about the proposed framework.

As proposed, the framework for site specific standards (SSS) for wild rice waters would offer a deviation from the Minnesota standard for sulfate, provide a way to allow sulfate standards and associated pollution higher than the current 10 parts per million (10ppm), and provide a way to avoid limiting sulfate discharge for individual sites using just about any approach as justification. The proposed framework will not protect wild rice.

While the introductory section describes beneficial use in broad terms (production, biomass) and recognizes tribal interests and uses, and while apparently MN statutes allow for setting SSS, the proposed implementation of setting SSS is open-ended and seems not to recognize these principles of beneficial use. Determining the sulfate "effects threshold" is particularly concerning, as extensive research has shown that the current 10ppm standard is, in fact, the effects threshold.

MPCA's concept that sulfate discharge limits will not consider degradation but rather capacity to absorb pollution, will mean that a permit would allow sulfate discharge much higher than the sulfate standard if the wild rice waters downstream have a low sulfate concentration. An example is Big Sandy Lake, with an average sulfate concentration of 1.2mg/l, which would ostensibly allow loading from the proposed Talon Metals to degrade the lake for wild rice and cause a huge increase in mercury in fish tissue and risk to human health.

The approaches in the framework suggest either setting the current sulfate standard or taking "novel approaches" which are not defined. All the suggested "novel" approaches seem to open the door to justify sulfate loading into wild rice waters far above the current standard, in ways that are not supported by scientific evidence or knowledge. The section on demonstration of wild rice health using "experimental endeavors" completely ignores the research and demonstrations by Minnesota scientists (Paster, Johnson, Myrbo and others, which are cited in the literature section). The two examples of historical data (Mississippi River and Perch Lake) are puzzling as they show, in the first case, that wild rice stands in backwaters likely have not been measured for sulfate, but nearby river channels have high amounts of sulfate. In the second case, sulfate caused a decline in wild rice. These examples offer nothing in terms of examples for this framework.

The last section on documenting ambient sulfate in regional waters seems irrelevant to the topic of SSS in wild rice waters. Figures show that sulfate is higher in samples from various waterbodies in SW Minnesota without connecting those data to any wild rice waters that may have been sampled. An examination of the MPCA map of wild rice waters shows that only a small handful of wild rice waters are located on the boundary between high and low sulfate waters in the state - the vast majority of wild rice waters in Minnesota are located where sulfate levels are generally far less than 10mg/l (see attached map). There was no attempt to demonstrate how regional waters could effectively be used to predict wild rice beneficial use in an SSS.

The framework begins by setting a goal of protecting wild rice but offers only a jumble of unjustified and open-ended approaches.

The McCabe Chapter of the Izaak Walton League makes the following recommendations for this framework:

• MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. 10ppm sulfate is the "effects threshold" for wild rice degradation.

• Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters. MPCA must not allow pollution discharge into known and listed degraded waters.

• Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than10 parts per million of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase at all, even to just below the standard.

• Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production and sustainability of this important annual plant.

• MPCA's "equation" method to determine if wild rice production would be protected without the 10 parts per million standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.

• The wild rice sulfate standard is not advisory. Any discharger asking for MPCA to consider a "site-specific standard" for sulfate must prove that wild rice beneficial use will be protected long-term.

• Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharge, the proponent (discharger or MPCA) must prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to density, productivity, genetic diversity, and nutritional quality.

• Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) must prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to density, productivity, genetic diversity, and nutritional quality.

• Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury, and the resultant increase in mercury contamination of fish - damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence; and impairment of the exercise of tribal Treaty-reserved rights.

• No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent, and a formal and public rulemaking process.

• Unless and until a more stringent "site-specific standard" is formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 parts per million wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. This includes all waters that have historically supported wild rice.

The McCabe Chapter of the Izaak Walton League urges the MPCA to remember its purpose and mission to protect our waters, especially including our wild rice waters and wild rice heritage, and protect human health and wellbeing from sulfate and other pollution by enforcing the current 10ppm wild rice sulfate standard. We especially encourage the MPCA to listen to our Tribal leaders and experts, as they depend on wild rice for community heath, culture and other benefits.

Attached in the uploaded document are two illustrations supporting our recommendations. I have also attached the IWLA's past comments on this issue for history.




Julie O'Leary
President, W.J. McCabe Chapter
Izaak Walton League of America
PO Box 3063
Duluth, MN 55812
 
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Comment From: Wesley Sisson

9/04/23 @ 5:57 PM
The MPCA must enforce the sulfate standard.
The MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny...↓
Degradation prohibited.
Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters.
Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury.
Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury.
MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard."
The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice.
Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof.
Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required.
Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay.
Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
Historic and heritage considerations.
For over a century, critical bodies of water in Northern Minnesota have been heavily degridated by mining discharge. Billions of dollars have gone into the mitigation of the impacts of this pollution caused by the mining process which has continuously been ignored by the MPCA. This pollution heavily impacts the sovereign treaty rights of indigenous nations and deprives them of an essential resource that is guaranteed to be protected by state and federal laws. Wild rice is a significant spiritual and cultural crop which is central to indigenous groups in Minnesota and must be protected from sulfide pollution that exceeds the recognized state and band limits of 10 PPM.
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Comment From: Croitiene ganMoryn

9/04/23 @ 5:57 PM
The Minnesota Pollution Control Agency (MPCA) has resisted enforcement of Minnesota's 1973 federally-approved wild rice sulfate standard for 50 years. However, due to advocacy by WaterLegacy and tribes, state courts have recently upheld Minnesota's 1...↓

The MPCA:

Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is the "effects threshold" for wild rice impairment.
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.

Abstract: "We exposed a model annual wetland plant, Zizania palustris [wild rice], to elevated sulfate concentrations (3.1 mM) and quantified the development of iron oxide and iron sulfide precipitates on root surfaces throughout the plant life cycle. During the onset of seed production, root surfaces amended with sulfate transitioned within 1 week from iron (hydr)oxide plaques to iron sulfide plaques . . . Sulfate-amended plants produced fewer and lighter seeds with less nitrogen than unamended plants.
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Comment From: Maureen Johnson

9/04/23 @ 5:57 PM
Wild Rice Standard Framework Comments

Maureen Johnson
Stacy, Minnesota

As a biologist with a B.A. in Biology, Winona State College, I contracted with US Environmental Protection Agency (EPA) as research biologist to collect underwater samples for Shagaw...↓
My review is based on 26 years of experience in environmental research and cleanup of Superfund hazardous waste sites in Minnesota, and another 10 years research and commenting on mining.

This set of comments is submitted in addition to my previous comments submitted 7/31/23. My previous comments addressed a number of concerns. I am trying not to repeat them here but these comments and those should probably be read together.

A Site-specific sulfate standard is absolutely not appropriate.

I am a biologist by training, MPCA proposes Site specific standard (SSS) as an alternative to the current standard of 10 ppm sulfate for wild rice. MPCA proposes to allow local sulfate concentrations at their existing level if some wild rice has survived it locally.

"Populations exposed to 300 mg L�1 sulfate concentrations produced fewer and smaller seeds and declined to extinction in 6 years or less." Result from Abstract.
From Sulfur Geochemistry Destabilizes Population Oscillations of Wild Rice (Zizania palustris)
Sophia LaFond-Hudson, Nathan W. Johnson, John Pastor, Brad Dewey
First published: 18 July 2022
https://doi.org/10.1029/2022JG006809

The above statement indicates that the endurance of wild rice populations cannot be assumed if wild rice is simply present at the time of a SSS. The populations local to a discharger may be in flux in response to anthropogenic stressors as opposed to normal ecological stressors that also cause changes in population dynamics. MPCA does not have the capability to determine the viability of a population in the minimum of likely ten years it would take to differentiate between natural vs anthropogenic stressors. The above example was for "300 mg L-1 sulfate concentration". It would be logical that a population could take much longer than six years to decline at concentrations lower than 300, but it is reasonable to assume they would decline, based on the original reason for the 10 ppm standard that has been upheld in court.

Ground water studies would also be required to see whether the "surviving populations" are actually receiving dilution waters from ground water upwelling or natural connectivity to water table inputs, and not really surviving the upstream discharge concentrations of sulfate. If that is the case, the wild rice standard would still apply because the discharge is likely limiting wild rice growth where the additional water input is not available.

The 10 ppm standard should be enforced because allowing only the surviving wild rice to repopulate areas will also limit genetic variability, making the system less durable when only the wild rice that tolerates somewhat higher sulfate is able to survive. There are so many places that would want the MPCA's site-specific standard across the northern part of the state that the overall health of the wild rice as a species could be affected as it has in mid-Minnesota (Typo Lake overlying the Isanti-Anoka County border was a wild rice lake, and now has a TMDL with no real solution). Downstream waters will also be receptors of lower quality waters. Money spent on this multi-year SS standard study effort would be better spent in installing expensive technology, solving a problem instead of avoiding a solution.

MPCA needs to understand that genetic variability in sulfate tolerance may or may not be tied to other survival traits needed to deal with other crises. Until you have sufficiently studied the genetic connections in wild rice you do not have license to limit wild rice to only those strains that have survived higher sulfate concentrations. It is possible that these surviving populations are stressed enough and may not be able to tolerate other stresses, including those caused by coming climate change or other unregulated or uncontrolled pollutants, for example, like the now uncontrolled specific conductance that EPA recommended 300-320 uS/cm as protective for invertebrates in Ecoregion 50. It does not matter whether there is a standard or not in the rules, in NE MN the Minnesota Rule requiring 95% survival rate of invertebrates will be violated many times when the EPA recommendation for specific conductance is allowed by MPCA to be violated in their NPDES permits. A decreasing number of invertebrates mean the base of the food web is weakening and every living animal population that depends on the base will weaken also, and on up the ladder. When sulfate is allowed as a SSS, the resultant effects and the more-difficult-to-predict effects on water quality must also be considered. Increased specific conductance is one of those effects.

The wild rice is much more likely to have healthy populations with normal genetic variability when the current standard requires compliance. MPCA should not be proposing alternative compliance techniques without sound study to back up their proposals. Native Indian tribes have a right to biologically sound wild rice beds capable to respond to stresses in their normal growth patterns. The treaties did not say it is ok to pollute "some" of the rice beds. Sulfate is a symptom of worsening underlying pollution that may also be causing unidentified problems, as documented by the growing impaired water list.

MPCA, time to do your job and control the sulfate and the pollution that rides the sulfate train. Businesses and people need to foot their bills to solve this problem, but we as a state will be healthier for it.


Sulfate removal technologies warrant a variance, not a SSS

Among many possible search results, I found the following sites about sulfate removal.

https://www.wateronline.com/doc/sulfate-removal-technologies-a-review-0001#:~:text=Physical processes for removing sulfate include: 1 Ion,GYP-CIX and Sulf-IX™ 2 Nanofiltration 3 Reverse osmosis

This 2015 website lists a number of ways to remove sulfate. The problems include that the removal processes leave other undesirable and polluting chemicals in the discharge, that the waste disposal is costly; and and/or that finding a disposal site to accept the removed waste may be difficult.

https://www.wateronline.com/doc/a-new-process-for-sulfate-removal-from-indust-0001
This is a newer APEX article on their work.

https://www.predest-ec.com/post/treatment-systems-for-sulfate-removal-in-water-and-wastewater

Other new ways to remove sulfate found on-line will likely each have their pros and cons; so dischargers should show that they have reviewed all of them and explain why each of them will not work and/or show their finances before they get a 5-year variance. At the variance fifth year, the assertions must again be reviewed and dischargers must again show why none of the newest and old alternatives will not work for them. MPCA must evaluate each as to whether the discharger is fully compliant with the variance requirements.

The waste from the reverse osmosis process is reject water or backflush, can be 40% of the discharge so it is voluminous, but also at least toxic and may be hazardous waste. Either way it may be expensive to properly dispose. We understand that the cost of reverse osmosis is the reason that Mesabi Nugget (near PolyMet's taconite processing plant) went down. Some of this is the cost of doing business.

It may be that industry and cities will have to install chloride- and sulfate-capable technologies to be responsible to downstream water users, or the state will be sued again in court to get that done, like Wisconsin did, that required the Metro treatment plant discharge to be fixed at big cost. Treaters' costs are legitimately reflected in higher prices that the public must pay if we want their services or products and if we want clean water.

The more appropriate approach is to give a variance, not a new SSS. The problem first must be solved in the discharge treatment by both public and private dischargers as part of their obligation to maintain clean water for future generations, and the public will wind up paying for it because we participated in the dirtying of the water in the first place by buying the products of dischargers and by discharging our own wastes to the land, water, sewer systems, and public sewer systems. The more costly it becomes, eventually dischargers may find other ways to provide for our needs and wants, but those are just ideas, and for now we are all responsible and must clean up our messes with our dollars.

The way that is fair to all businesses and all people is that everyone in wild rice territory has the same standard, that cannot be massaged by dischargers with manipulation talent and capabilities. Then it becomes political: those who can pull the most strings in management or the most wool over staff eyes are the ones who get the best SSS.

The MPCA equation

MPCA makes the following assertions:

The MPCA sponsored studies on how sulfate affects wild rice. Research projects � including a field survey, laboratory experiments, and mesocosm (pot) experiments � began in 2012 and were completed by December 2013, and produced several research papers. Based on these studies MPCA found:

Sulfate in water combined with bacteria creates sulfide, which is toxic to wild rice. High levels of organic carbon in sediment feed bacteria, which increases sulfide. However, high iron levels will neutralize the sulfide instead.
Iron in sediment binds to sulfide and neutralizes it, making it nontoxic to wild rice. Organic carbon in sediment is food for the bacteria, causing more sulfide to be produced. Sulfide is toxic to wild rice.
In the sediment in which wild rice is rooted, sulfate from the water above is converted to sulfide by bacteria.
Higher levels of sulfide in the sediment create an environment that is less hospitable to wild rice.
However, certain factors change the rate at which sulfate is converted to sulfide. Most significantly, it was stated higher levels of iron can lead to less sulfide, and higher levels of organic carbon can lead to more sulfide.

To take these variables into account, the MPCA developed an equation that can determine a sulfate level that will protect wild rice for a specific water body. The agency proposed to amend the 1973 water quality standard to include this new equation, and to specifically identify waters to which the standard should apply, based on information compiled into a database.

I recall this equation was much doubted by the scientific community. To use the equation for any purpose, ALL of the adverse comments must be refuted in writing in public to show the legitimacy of use of the equation.
MPCA must provide the per cent level of confidence in the accuracy of the equation, and the percent probability of error which will be most illustrative. The derivation of the equation must be clear and based on data with QAQC provided. If the data is questionable, the equation is also questionable.
MPCA must show that the above assertions are true, citing the sources used and refuting any applicable asserted contrary statements in other sources.

We are digging a hole, and every year it gets deeper. We should be solving the sulfate problem with our dollars, not delaying with studies and alternate standards.
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Comment From: Roberta Haskin

9/04/23 @ 5:41 PM
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit l...↓
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Comment From: Jackie Holmbeck

9/04/23 @ 5:35 PM
The MPCA should not continue to drag its feet concerning sulfate pollution in Minnesota's waterways. Polluters should not be able to further degrade our waters and negatively affect wild rice in areas that are currently showing low levels of sulfate...↓
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Comment From: Joan Beaver

9/04/23 @ 5:33 PM
MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Tr...↓
It is appalling that the MPCA has allowed this health threat by not enforcing the law and may consider even more pollution.
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Comment From: chris olson

9/04/23 @ 5:22 PM
MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is th...↓
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Timothy Frantzich

9/04/23 @ 4:56 PM
We must enforce wild rice standards! I teach history to 8th graders. The long trail of broken promises to native peoples must stop. Please. Please.
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Comment From: Bruce Johnson

9/04/23 @ 4:29 PM
I am a retired environmental scientist with over 30 years of water quality and regulatory expertise, much of which is in Northeast Minnesota. I have determined this proposed rule to be nothing more than a permanent permit to pollute replacing the wil...↓

1. It would allow industry, municipal and other dischargers to routinely discharge sulfates above the numerical limits into wild rice waters during the detailed scientific and economic studies currently associated with the site-specific individual justifications, since a complete study would take six to ten years to complete (Hudson, 2022).
2. It would allow Grandfathering in areas that have had numeric violations of sulfate concentrations after the mid- 1970's Clean Water Act initial allowance of existing pollution, thus ignoring the fact that many of these waters after the CWA may have had healthy wild rice populations.
3. It would sidestep NPDES permitting that uses reasonable potential calculations for permit holders.
4. Once approved it would allow dischargers to avoid best management technologies that are developed.

The proposed rule is ecologically excessively narrow; it addresses a single numeric parameter, sulfate. This approach fails to assess other cumulative pollutant stresses that act synergistically with sulfate to impact not only wild rice but the aquatic food web in a receiving water. Mercury is a known human neurotoxin for many years. One main route humans acquire mercury is through the consumption fish. Mercury levels in fish in Minnesota are increasing in many areas. The Minnesota Department of Health has numerous fish consumption advisories. These advisories have recommended limits to the amounts of fish humans should consume from specific waters. Fish from the St. Louis River watershed are some of the least recommended to be consumed. Overall, the advisories in the State are becoming more stringent. Mercury is sequestered in wetlands. NE Minnesota has abundant wetlands, especially the St. Louis River watershed. Addition of sulfate to wetlands convert mercury to methyl mercury the form that is biologically available to the food web. Ambient levels of sulfate in non-anthropogenically impaired waters in NE Minnesota average median concentrations of less than 7.4 mg/l (Thingvold, 1979). Research has demonstrated that increasing sulfate concentrations in wetlands converts sequestered mercury into methyl mercury and is readily taken up in the food chain (Groetsch 2003, Mitchell 2007, Wasik 2015). The current mercury TMDL study appears to be avoiding chemical involvement of sulfate in its mercury study. The proposed rule for site-specific standards ignores the relationship between mercury and sulfate. The parsing of ecological synergy is neither scientifically defensible nor is it protective of public health or the environment.

Native American tribes are disproportionally affected by methyl mercury, no SSS for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

Although the SSS formally approved in state rules, the SSS in the case of sulfate is not scientifically defensible. MPCA must apply the 10 mg/l wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay nor assume a less stringent number will at some point be approved.

References:
Groetsch 2003, Investigations into Walleye Mercury Concentrations related to Long-Standing Reservoirs' Water Quality, Wetlands and Federal Energy Regulatory Licensed Dam Operation. Kory Groetsch, Larry Brooke, Great Lakes Indian Fish & Wildlife Commission Biological Services Division P.O. Box 9 Odanah,WI 54861, Lake Superior Research Institute University of Wisconsin - Superior Belnap and Catlin Superior, WI 54880, Project Report 03-02, March 2003.

Hudson 2022, Sulfur Geochemistry Destabilizes Population Oscillations of Wild Rice (Zizania palustris), Lafond-Hudson Sophia, Johnson Nathan W, Pastor John, Dewey, Brad
IGR Biogeosciences, July 2022, https://doi.org/10.1029/2022JG006809

Mitchel 2007, Spatial Characteristics of Net Methylmercury Production Hot Spots in Peatlands
Carl P.J. Mitchell, Brian A. Branfireun, Randall K. Kolka, Environmental Science & Technology / Vol. 42, No. 4, 2008

Thingvold 1979, Water quality characterization of the Copper Nickel Water Quality Research Area, Thingvold Daryl, Nancy Sather, Peter Ashbrook, Regional Copper-Nickel Study Minnesota Environmental Quality Board, December 1979, Table 20, http://www.leg.state.mn.us/lrl/lrl.asp CN 153.

USEPA 2022 a, Memorandum: Assessment of effects of increased ion concentrations in the St. Louis River Watershed with special attention to potential mining influence and the jurisdiction of the Fond du Lac Band of Lake Superior Chippewa, Cormier, Senior Scientist, Office of Research and Development, Center for Environmental Measurement and Modeling, Watershed and Ecosystem Characterization Division, March 15, 2022.

USEPA 2022 b, Memorandum: Request for Scientific Support Regarding Potential Downstream Impacts of the NorthMet Mine, , Joel C. Hoffman, Supervisory Biologist Office of Research and Development, Center for Computational Toxicology and Exposure, Great Lakes Toxicology and Ecology Division Christopher D. Knightes, Research Environmental Engineer, Office of Research and Development, Center for Environmental Measurement and Modeling, Atlantic Coastal Environmental Sciences Division, January 25, 2022.

Wasik 2015, The effects of hydrologic fluctuation and sulfate regeneration on mercury cycling in an experimental peatland, J. K. Coleman Wasik, D. R. Engstrom, C. P. J. Mitchell, E. B. Swain, B. A. Monson, S. J. Balogh, J. D. Jeremiason, B. A. Branfireun, R. K. Kolka, and J. E. Almendinger, Journal of Geophysical Research: Biogeosciences , Research Article 10.1002/2015JG002993, 2015.
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Comment From: Tom Dimond

9/04/23 @ 4:28 PM
Minnesota's pollution prevention standard for sulfate and other pollutants including PFAS should be clear. Our pollutant standard should ensure cleanup of existing pollutant and prevention of new pollutant releases into the underground and surface w...↓

Degradation of existing water quality and inaction on cleanup of polluted waters are not actions we and nature can live with.

Discharge of pollutant has a disproportionate negative impact on the less fortunate and people of color.

Endangered people, plants and wildlife are most vulnerable to impacts of pollutant.

The framework should be revised to ensure no degradation of existing waters and provide a clear path for removal of existing pollutant from our aquifers and waterways.

Inaction takes a high toll on the economics and livability of our State.

Thank you for your consideration. Our future depends on it.

Tom Dimond
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Comment From: Rebecca and Jim Myerly

9/04/23 @ 3:55 PM
The Minnesota Pollution Control Agency's enforcement of Minnesota's 1973 federally-approved wild rice sulfate standard is long overdue. We urge MPCA to enforce Minnesota's 10 parts per million wild rice sulfate standard without diminishment or compro...↓
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Comment From: Richard Mammel

9/04/23 @ 3:24 PM
Only people inoculated from reality, truth, intelligence, and integrity will knowingly allow the poisoning of water, land, and/or air.
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Comment From: Robert Hale

9/04/23 @ 3:21 PM
Listed here are my comments:
Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or ...↓

Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.

Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.

Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.

Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Coalition of Greater Minnesota... (Elizabeth Wefel )

9/04/23 @ 3:16 PM
Attached please find the comments of the Coalition of Greater Minnesota Cities.
Attachments:

Comment From: Jo Ann Morse

9/04/23 @ 3:15 PM
I am concerned about the MPCA's proposed plan for permitting that would allow low-sulfate waters to be degraded.

Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota have f...↓

Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.

No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

Unlike many states, Minnesota still has abundant, high quality water. The MPCA should do everything in its power to maintain that precious gift.
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Comment From: Wendy Ward

9/04/23 @ 2:48 PM
Minnesota has nearly 2,400 waters that produce wild rice and 35 of those waters are currently impaired, or polluted, by sulfate. Wild rice plant biology and sulfur biogeochemistry are complex. Significant natural variability in hydrology and other fe...↓


The MPCA framework provides more clarity for the public, facilities, and tribal nations regarding the protection of wild rice. It defines what constitutes protection of the wild rice beneficial use, establishes expectations for facilities requesting and agency staff reviewing a site-specific standard application, and identifies consistent data collection and informational needs used to review a thorough site-specific sulfate standard application. The ultimate expectation is that the MPCA will require a demonstration that the waterbody has and will maintain a wild rice population that is self-sustaining and productive.
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Comment From: Anne Uehling

9/04/23 @ 2:47 PM
As someone who wrote an article almost ten years ago, published in MINPost, about the relationship between mercury, sulfate and wild rice, I find it incomprehensible that MPCA is still trying to get around the 10ppm standard. Politicians and indust...↓

At that time, too, a survey of babies born along the north shore showed a worrisome percentage of infants with unacceptable levels of mercury in their bodies, a condition threatening normal brain development.

The newly MPCA proposed "Site-Specific Standards" offers one more back door to sulfate pollution.

The proposed permitting plan does not provide a credible definition of criteria. How large a body of water with rice growing in it would be automatically excluded from a site specific permit being issued? What would be the criteria for which rice areas could be sacrificed?

What would be the standard for run off or connecting link to another body of water or stream?

The claim iron is a sufficient ameliorator has been disproven. (See research, S. LaFond-Hudson, Iron sulfide formation on root surfaces controlled by the life cycle of wild rice, Biogeochem. (2018))

I urge the MPCA to act in accordance with the words "pollution control" that are part of the agency name rather than act to expand the perimeters of allowable pollution.
Anne Stewart Uehling
Ely, MN
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Comment From: Bob Jalonen

9/04/23 @ 2:43 PM
I support all positions Water Legacy has presented relative to the site specific sulphate standard framework for wild rice in Minnesota.
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Comment From: Mark Fitzpatrick

9/04/23 @ 2:40 PM
Please do not undermine Minnesota's federally approved wild rice sulfate standard. Do not allow site-specific standards for proposed copper-nickel mines.

Please enforce Minnesota's current federally approved wild rice sulfate standard. Thank you.
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Comment From: Christina Lincoln

9/04/23 @ 2:35 PM
Strong and consistent enforcement of Minnesota's federally-approved wild rice sulfate standard of 10 parts per million is essential to protect ecosystems and human health.
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Comment From: Suzanne Owens-Pike

9/04/23 @ 2:34 PM
Many waters in Minnesota are already polluted from sulfate. We should do everything in our power to protect the clean water we still have. Climate change will continue to put great pressure on our water supply. We should not put Minnesota at risk for...↓
In addition, we have caused so much harm to indigenous communities. We should respect and support the needs of their communities and protect all places where wild rice still grows.
Keep to the highest standards to protect our waters from possible sulfate pollution!
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Comment From: Janet Keough

9/04/23 @ 2:14 PM
See attached file with my comments
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Comment From: Denise Tennen

9/04/23 @ 2:03 PM
Please safeguard our precious wild rice in the state of Minnesota. The lower the PPM of sulfate in our wild rice beds, the healthier our wild rice will be. For ourselves and future generations, this protection is a must! As an individual who harvests...↓

MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is the "effects threshold" for wild rice impairment.

Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. Critically, MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.

Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard. Protect these at their existing low levels, do not allow any increased sulfate levels!

Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury. These effects are importantly interconnected and are a detriment to public health.

MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights. Do not renege on treaty rights and do not put health at risk for those that rely on fish to feed themselves!

The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term. Considering exceptions is not acceptable.

High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.

MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory. We have the scientific information to support the 10 ppm limit, do not revisit this issue.

Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process. All existing research shows clear degradation of wild rice with increased sulfate exposure.


Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.

Protect our heritage. Wild rice is a special resource of our state. It is our duty to protect it. Do not put it at risk!

thank you for your consideration,
Denise Tennen
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Comment From: Ashley Deitering

9/04/23 @ 1:51 PM
I am deeply troubled by the MPCAs incompetence in the protection of our lands and waters. It seems as though the agencies concerned more with accommodating for big polluters by bending the laws in their favor putting corporate interest ahead of the w...↓
A Threat to the wild rice is a direct assualt on the communities that depend on it physically,spirtiually,mentally,economically. Wild rice is a sacred food of the annishanabe-the first peoples of these lands. Allowing sulfate to contaminate wild rice waters is a violation of Treaty rights which is then a violation of our constitution(article 6) which states that treaties are the supreme law of the land. The lack of protections for wild rice not only threatens the present but will continue to impact future generations. No "Site specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal CONCENT. We must change the course of history doing away with genocidal policies such as the ones that allow for more pollution to harm our water ways. What we do to the water we do to ourselves. All living beings are dependant on clean water to thrive. As an enviromental protection agency is your responsibility to protect us from pollution not to give the green light on more pollution. We must stop sacrificing our well being and our future generations for the sake of corporate polluters that exploit the land,the waters and all those dependant. We should be working towards stronger legal protections for wild rice not creating loop holes for the pollution to enter our water ways.
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Comment From: Randolph Pflueger

9/04/23 @ 1:29 PM
You are a government agency representing a link that signed a treaty with native Americans reguarding their well being and provisions for living life for perpetuity. I can not comprehend how you can possibly try to set standards that destroy a vital ...↓
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Comment From: Katy Tharaldson

9/04/23 @ 1:15 PM
force Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is the "effects t...↓
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Patricia Schmieder

9/04/23 @ 1:05 PM
The current 10 ppm wild rice sulfate standard must be enforced as is, to uphold MN law and the Clean Water Act prohibiting degradation of our water quality the state.

The 10 ppm on the book since 1974 has been proven to be scientifically sound, and th...↓

The validity and effectiveness of site-specific standards would need much more scientific basis and ground-proofing to demonstrate that beneficial uses will be protected. The "site-specific standards" loophole should not be used to resurrect the unsupported MPCA theory that wild rice could be protected without enforcement of the 10 ppm standard in the 2018 contested case hearing. Research has also shown high iron does not protect wild rice, with formation of iron sulfides on roots interfering with the sustainability of wild rice populations.

Don't take us backward by ignoring the facts on the ground. And, no "site-specific standard" for discharge of sulfate should be approved by MPCA in the future without tribal consultation and tribal consent and a formal and public rulemaking process.

Enforce the current 10ppm standard in all our Minnesota waters now.
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Comment From: Allen Richardson

9/04/23 @ 12:56 PM
None of the proposed changes towards a "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.Before a "site-specific standar...↓

MPCA should not allow sulfate in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area or other areas that have far less than 10 ppm of sulfate even if the degraded level of sulfate remains just below the standard.

Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation.MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.

Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Johnny Barber

9/04/23 @ 12:52 PM
I do not believe a site specific plan will increase protections for our fresh water lakes rivers and streams. By changing to a site specific plan we will effectively limit accountability to those who pollute our waterways. We need regulations that wi...↓
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Comment From: Demetrius Peet

9/04/23 @ 12:49 PM
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting ...↓
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Comment From: Amanda Sanchez

9/04/23 @ 12:47 PM
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
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Comment From: Kathryn A. McKenzie

9/04/23 @ 12:46 PM
Why would the work on the St. Louis River watershed be jeopradized by adding the potential for more pollutants upstream? Wild rice growth is specific to a small sulfate window. With all of the millions spent on the St. Louis River clean-up it seems...↓
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Comment From: Joseph Knaeble

9/04/23 @ 12:45 PM
I am writing to you today to strongly encourage the MPCA to follow the current Federal and State laws regarding sulfate pollution from mining and to protect Minnesota waters. Below are just a few of the reasons I support the current Federal and State...↓

The MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is the "effects threshold" for wild rice impairment.

Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.

New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality

Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

In closing I once again strongly urge the MPCA to follow the existing laws and prevent pollution of Minnesota waters and life.

Sincerely,

Joe Knaeble
2533 Colfax Ave S
Mpls, MN 55405
612 644 9412
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Comment From: Alan Knaeble

9/04/23 @ 12:36 PM
Please enforce the present sulfate standards and if possible make these standard more strict in order to protect wild rice from sulfate pollution.

thank you,
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Comment From: Frederick Campbell

9/04/23 @ 12:23 PM
The historical and observable effects of excess sulfate on wild rice and the lakes that support wild rice are much more widespread than the cited 35 wild rice lakes that are impaired by sulfate. The tribes have already noted and documented historical...↓
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Comment From: Karen Johnson

9/04/23 @ 12:13 PM
Besides all the known scientific testing completed. the MPCA should use those proven facts and its powers to protect and control all natural wild rice growing areas to keep them as clean and natural as possible. They should not allow the currently ...↓

Thank you, Karen Johnson
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Comment From: Jane Reyer

9/04/23 @ 11:58 AM
Dear Minnesota Pollution Control Agency Officers and Staff,

Although I have followed the debate about sulfate levels in Minnesota's waters for many years and am quite familiar with the science regarding sulfate and sulfide influence on both wild rice ...↓

It is difficult not to notice, however, that you now propose to allow site-specific standards to increase the allowable level of sulfate, but this time apparently without a corresponding requirement for a stricter standard where needed. With permittees doing the studies, and with any proposal for a site specific standard coming from a permittee, you can be sure that a site-specific standard of less than 10 mg/L will never be considered even when one is needed to protect wild rice. The environmental community fought your attempts to pass a standard that did both, primarily because: 1. the science you relied on does not account for the impact of iron in sediment on plant roots and population viability over time; 2. we had concerns with enforceability; and 3. we objected to your refusal to consider the impacts of mercury on fish tissue. Perhaps in your view, this new proposal is what environmentalists get for not supporting the earlier one. Unfortunately for everyone, the outcome will be more polluted water, less wild rice, and more mercury in fish. I guess in a society where the environment has become a "special interest" you can count that as a loss for a special interest group that has gotten your goat rather than as a regulatory failure.

I understand that our current standard for sulfate is intended only to protect wild rice, but it is unconscionable that you do not use your authorities to limit sulfate pollution to address mercury in fish tissue. The thing that just kills me is that I do not need to go through all of data and reports (regarding both humans and wildlife) on that subject because you already know them. You already know them, and yet you use you power to support the continuation of and the addition of new pollution that can only make the situation worse. You can (and probably will) say that because the legal standard is intended only to protect wild rice, you cannot use it to protect the edibility of fish. Perhaps that would be true if you were proposing to tighten the wild rice standard. But you are under no legal obligation to even consider site-specific standards for wild rice, and there is no legal requirement that you ignore the fish tissue mercury problem when deciding whether to make such a proposal. If that is what you are pretending to yourselves, each of you involved in this, individually, needs to take a good look at yourself in the mirror and ask yourself how you got to this point of callousness. Fish-eating wildlife species are in decline and we put our infants at risk if we eat the fish that we catch, and you are proposing a rule change that will contribute to the problem. And you are under no obligation to do so.

On another legal note, the Clean Water Act provision for site-specific standards is intended to allow such standards only when higher levels of a constituent are naturally-occurring or otherwise would not be addressed by limiting the pollution from a permittee. To my knowledge, there is no allowance in the Clean Water Act or any of its regulations that allows for increasing a numeric standard whenever a permittee can make the case that the standard is not needed in a particular location. Think about what a nightmare it would be for you if that was the law!

If anyone who actually works for MPCA reads this, thank you for doing so. If comments are being read by a contractor who is submitting a summary to agency staff, I request that this comment be forwarded to someone at the agency who will read it.

Sincerely,
Jane Reyer
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Comment From: ML Wilm

9/04/23 @ 11:54 AM
Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm...↓
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Comment From: Martin Kurcias

9/04/23 @ 11:48 AM
Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm...↓
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Lynn Levine

9/04/23 @ 11:45 AM
I'm writing to urge you to provide the most stringent possible restrictions on site specific sulfate standards for wild rice.
I am terribly upset by the continuing erosion of protections for air, water, crops and everything else. I am in my late 80s a...↓
A common phrase we used to say is if you're going in the wrong direction slowing down is not the answer but rather turning around.
Please turn around.
Thank you!
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Comment From: Richard McGehee

9/04/23 @ 11:39 AM
As someone who values a clean and healthy environment, I urge you to enforce the sulfate standards you already have. Please do not weaken them.
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Comment From: Mary Dosch

9/04/23 @ 11:25 AM
I respectfully urge you to enforce the wild rice sulfate standard. There are numerous reasons why enforcing the wild rice sulfate standard is needed and one basic one is that degradation of water quality in the lakes, streams and wetlands of Minneso...↓
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Comment From: Robert Tammen

9/04/23 @ 11:24 AM
I request that the MPCA honor the State of Minnesota's non-degradation policies as expressed in statute and no longer issue permits that are little more than obituaries for wetlands.
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Comment From: Elizabeth McCambridge

9/04/23 @ 11:20 AM
My husband and I love to eat wild rice. Not store bought but the real stuff! So for personal reasons I want the MPCA to enforce the wild rice sulfate standard. As a former social studies teacher for 30 years, I also recognize the need to protect and ...↓
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Comment From: Anita Anderson

9/04/23 @ 11:01 AM
Hello-

I am not in support of the site-specific sulfate standard framework. MPCA must enforce Minnesota's current wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no dis...↓

Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.

Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.

These wild rice stands are important to all Minnesota citizens, especially Native Americans. Wild rice is one our state's prized possessions and we need to put the highest priority on protecting it, especially as a food source for those who truly depend on it.

Sulfate pollution also increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.

MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.

Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.

Thank you,
Anita Anderson
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Comment From: Minnesota Center for Environme... (Melissa Lorentz)

9/04/23 @ 10:50 AM
Attachments:

Comment From: Ann Beane

9/04/23 @ 10:46 AM
Here are some additional points to protect areas where wild rice grows.

Wild rice (manoomin) is sacred to the Anishinaabe and is also an ecological indicator for water quality. The same sulfate pollution that kills wild rice also increases toxic mercu...↓

Strong and consistent enforcement of Minnesota's federally-approved wild rice sulfate standard of 10 parts per million is essential to protect ecosystems and human health.
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Comment From: Arrowhead Indivisible (Denny FitzPatrick)

9/04/23 @ 10:23 AM
Don't allow degradation of out water. Protect wild rice and fish. Thank you, ~Dennis.
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Comment From: Karla Anderson

9/04/23 @ 10:13 AM
I oppose site specific standards that would allow more sulfate pollution.
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Comment From: Jon Damon

9/04/23 @ 10:06 AM
Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm...↓
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Nancy Schmidt

9/04/23 @ 10:01 AM
Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm...↓

It's pretty clear that the Minnesota POLUTION CONTROL Agency must do the job of protecting sensitive resources that if damaged, cannot be replaced. It is your job to prevent potential contamination of wild rice plants and the water they need to grow and thrive. It is our states heritage and must be protected from commercial enterprises.
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Comment From: Juliann Rule

9/04/23 @ 9:53 AM
MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is th...↓

Degradation must not be permitted. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.

Low-sulfate waters must be protected. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.

Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.

MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.

Proof should be required to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.

High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.

MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.

Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

Research must be required for new or expanded discharge. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

Tribes and the public must be involved in the process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

Enforcement must happen without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Nancy Beaulieu

9/04/23 @ 9:30 AM
Honoring treaties well overdue;free,prior, and informed consent is critical. Manoomin must be protected from pollution and climate change. Climate change already reeking havoc. We (humans) are nature and must protect the environment for our own healt...↓
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Comment From: LSP (Richard Meierotto)

9/04/23 @ 9:30 AM
MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is th...↓
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
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Comment From: Angela Anderson

9/04/23 @ 9:23 AM
MPCA currently fails to enforce sulfate standards for wild rice and has failed to protect the waters
of wild rice for 50 years. The Minnesota Pollution Control agency is supposed to protect the public from environmental pollution not to dismiss it
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Comment From: Karen Graham

9/04/23 @ 9:04 AM
MPCA currently fails to enforce sulfate standards for wild rice and has failed to protect the waters of wild rice for 50 years.
With the MPCA's new proposal of site specific sulfate discharge, the polluters are gifted freer hands to pollute. A most d...↓
Let me reiterate, this agency's proposed plan allows raising sulfate pollution to degrade wild rice and interfere with the exercise of Treaty-reserved rights.
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Comment From: Diane Stuart

9/04/23 @ 9:01 AM
The MPCA's plan to permit the requests of two taconite mining companies to increase sulfate pollution in northern Minnesota streams and rivers, the BWCA, and the Lake Superior watershed is ironic given its stated reason for existence: MN "Pollution ...↓
1. Harm to wild rice (sulfate added to water and sediment high in iron form iron sulfide plaques on wild rice roots and impair seed production - decreasing the availability of rice for food) 2. Increased mercury contamination of fish - also affecting the food chain 3. Adverse consequences in the future that we are not even aware of now
This appears to be a treacherous policy to pursue in light of the world-wide environmental calamities the world is facing: global warming; drought and famine; air pollution; and decreasing freshwater supply in aquifers and lakes, to name but a few. We need to maintain our clean water in MN and promote and protect diverse food production sources. Sound environmental policy needs to be based on human needs and not for the bottom line of commercial mining concerns.
Additionally, wild rice is not only a food source for the Anishinaabe; it is of central cultural significance to them as well. The State of Minnesota needs to honor prior agreements with Native Americans and be respectful of their history, culture, and beliefs.
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Comment From: Chris Heeter

9/04/23 @ 8:56 AM
Sometimes we are our own worst enemy. This site-specific sulfate standard for wild rice is one such example. As a (caucasian) wild rice harvester for 30 years, I can attest to the degradation over the years. Climate change hits wild rice hard, im...↓
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Comment From: Mary M Hartnett

9/04/23 @ 8:55 AM
Please deny the permit requests from the taconite companies and enforce the wild rice sulfate standards. Our water is precious and we can't go back once it's soiled. Please do not let this degradation happen. Don't proceed without the tribes consent...↓

The MPCA:

Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is the "effects threshold" for wild rice impairment.

Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.

Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.

Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.

Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.

High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.

MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.

Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality

Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Rachel Youens

9/04/23 @ 8:49 AM
Dear MPCA,

Your agency must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts immediately and without delay. The 10 ppm sulfate standard is the "effects thresho...↓

Degradation is prohibited. Both the Clean Water Act and Minnesota law protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.

MPCA must also consider the effects of lax sulfate standard enforcement on mercury and methylmercury. The health threat of sulfate and mercury. and its contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.

High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.

MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.

New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm
to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

Importantly, no "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

Sincerely,
Rachel Youens
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Comment From: Tracy Sides

9/04/23 @ 8:48 AM
MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is th...↓

Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.

Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.

MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.

High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
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Comment From: Catherine Chayka

9/04/23 @ 8:44 AM
The MPCA is tasked with protecting Minnesota waters from pollution, as mandated by the Clean Water Act as well as Minnesota's own laws. There is currently no independent scientific study that suggest increasing sulfate levels from anthropogenic disch...↓

Thank you for your consideration.
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Comment From: Robert Kosuth

9/04/23 @ 8:43 AM
I'm not a scientist and I don't think this is mostly a science question. It's largely an issue of being on the safe side or taking chances with the future. Having very specific standards seems reasonable but I can speak from my 40 years of living an...↓
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Comment From: Kevin Lanigan

9/04/23 @ 8:29 AM
Please enforce the wild rice sulphate standards!
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Comment From: William Newman

9/04/23 @ 8:25 AM
I previously submitted comments but did not see a confirmation that they had been received. I have over 38 years of experience with both surface water and groundwater remediation and I am the President and founder of RNAS Remediation products a comp...↓

The site specific evaluation to determine how sensitive wild rice waters are to sulfate was never practical. The state does not have the resources to carefully evaluate thousands of sites.

The concept of iron protecting wild rice from sulfide is also flawed. Some forms of iron like small particles of zero valent iron ste very reactive but oxidized iron with a minimal specific surface area are very slow to react with sulfides especially at neutral or alkaline pH.

Without a flux of reactive iron that matches sulfate inputs the reactive iron present in sediments will be consumed. Mine pitlakes often have over 1000 mg/l sulfate but little or no soluble iron. This is not surprising as even 50 ppb of dissolved oxygen at neutral pH will result in almost no soluble iron being present.

Sulfate inputs also release TOC, phosphate and mercury from sediments and sulfate reduction stimulates methyl mercury production.

Removing sulfur at the source before it impacts wild rice eaters is the only way to protect them.
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Comment From: Dennis Kaleta

9/04/23 @ 8:21 AM
Thank you for this opportunity to comment on this important issue. I believe the MPCA should enforce the 10ppm wild rice sulfate standard without exception, as that has been found to be the threshold for wild rice impairment. The Clean Water Act shou...↓
Finally, no site-specific standards for discharge of sulfates in wild rice waters should be approved without tribal consultation and consent, and formal and public rulemaking process.

Thank you.
Dennis Kaleta
Grand Marais, MN
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Comment From: Kevin Hoeschen

9/04/23 @ 8:08 AM
I am writing to ask you to not weaken the MPCA standards that are currently in place to protect wild rice.
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Comment From: gerry fuller

9/04/23 @ 8:02 AM
MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm sulfate standard is th...↓
Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Susa Wiste

9/04/23 @ 7:53 AM
I do not understand why enforcement of Minnesota's 1973 federally-approved wild rice sulfate standard has never been done. WHY? The wild rice is a barometer of the health of our waters and we need to do all we can to facilitate its growth. Enforcemen...↓
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Comment From: Robin Nicholson

9/04/23 @ 7:50 AM
I believe that for the protection of our environment it is critical that tge sulfate standards be enforced in all water vital to wild rice harvesting.
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Comment From: Melissa Polster

9/04/23 @ 7:49 AM
Wild rice (manoomin) is sacred to the Anishinaabe and is also an ecological indicator for water quality. The same sulfate pollution that kills wild rice also increases toxic mercury contamination of fish.

Strong and consistent enforcement of Minnesota...↓
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Comment From: Julie Allen

9/04/23 @ 7:40 AM
We harvest wild rice rice every year in northeast Minnesota. This is a family ritual that we do for food, income, and fun.
We expect and require that MPCA is doing everything possible to not only maintain healthy bodies of water, but to enhance them a...↓
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Comment From: Donna Karnuth

9/04/23 @ 7:30 AM
We are loosing plants and animals at an alarming rate. Once gone, they are gone. They need a place to live, breathe and eat that is safe. We all want safety and they, the plants and animals, have no voice.
Please do NOT loosen any standards. Being m...↓
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Comment From: Beth Carpenter

9/04/23 @ 7:29 AM
Growing up next to the St Louis River, less than a mile from USS Steel plant, the water was toxic. It is still polluted 45 years after the plant closed. Why risk the world's most precious commodity? Water! Water equals life. Peace
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Comment From: Maxine Hughes

9/04/23 @ 7:26 AM
Please continue to enforce Minnesota's current wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. We must protect our waters for future generations. There is no alternative.
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Comment From: Arthur Baldwin

9/04/23 @ 12:49 AM
My name is Chris Baldwin, a native Minnesotan, a long-term and current resident of Hibbing and descendent of an Iron Range railroad pioneer grandfather. My father was executive VP and Director of Research for Cargill for 30 years. I am a retired hard...↓
My alarm signals are really going off as I research more into the long term BIO-ACCUMULATION affects of the sulfide minerals that I personally witnessed and collected in the taconite ore the I helped mine for 23 years. As a professional engineer responsible to 'do no harm to the public and my fellow miners', I bear some responsibility to warn of an upcoming Bio Accumulation 'Bridge Collapse' I compare to the 35 W bridge collapse. Not only is the Methyl Mercury in the sport fish celebrated as Minnesota's best feature from the Land of Sky Blue Waters becoming so high that 3 game fish meals a week will give you a state recored for high levels of Mercury Toxicity. The sulfides in the taconite ores are partly responsible for these elevated mercury levels seen as especially acute from Minntac's tailings basin flowing into Lake Vermillion, and the abandoned Dunka River Taconite mine sulfide overburden stockpile leaching into Birch Lake and into the BWCA, and Eire's tailings basin leaching into St Louis River.
The sulfides in the taconite ores are responsible for mobilizing the methyl mercury and poisoning the food chain that we humans rely on for sport fishing and subsistence fishing. And the threat to wild rice is increasing and is a direct threat to another Iconic feature of Minnesota Northland and subsistence food source for Native Americans.
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Comment From: Arthur Baldwin

9/04/23 @ 12:40 AM
I've worked in taconite mines for 23 years, and I have most recently worked on permitting and starting up a sulfide gold mine in South Carolina as the technical services superintendent. As a retired mining engineer, I am increasingly alarmed by iron ...↓

In my retirement, I am inspired to make hand drums as a tool for meditation and community building via drum circles. And I am dedicating each one of the drums I make to one of Minnesota's 10,000 lakes in an effort to raise awareness of the impaired water quality from legacy mine pollution. The threat of poisoning by methyl mercury to the fish we love to catch and eat, and the threat to wild rice from sulfate pollution is real, and permanent. Trading our beloved outdoor water recreation and livelihoods is not worth permitting a predatory mining company's resource piracy.

Further, the threat isn't looming on the horizon. It's already here in the form of sulfide minerals associated with taconite ore. The tailings containing sulfides end up dissolved in the discharge waters from all of the taconite plants. These sulfide minerals left untreated, are oxidized, and mobilize the heavy metals in the sediments in the lakes and rivers downstream from the tailings dams. This 50 years of legacy mine pollution, reaching from Swan Lake to Silver Bay, needs to be cleaned up now, and water quality restored to the impaired downstream lakes and rivers.
Attachments:
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Comment From: Arthur Baldwin

9/04/23 @ 12:32 AM
Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm...↓

>Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.

>Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.

>Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.

>Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.

>Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.

>High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.

>MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.

>Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.

>New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality

>Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.

>Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.

Clean up the legacy pollution from taconite mining before the taxpayer gets sacked for the bill!
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Comment From: Lurinda DeFoe

9/03/23 @ 11:25 PM
Lower sulfate standard to save our eco system and water.
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Comment From: Scott Doblar

9/03/23 @ 9:30 PM
We must protect our wild rice from sulfide contamination!
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Comment From: Duane Gustafson

9/03/23 @ 8:45 PM
Wild rice (manoomin) is sacred to the Anishinaabe and is Minnesota's state grain, an important food for wildlife and humans, and an ecological indicator for water quality. The same sulfate pollution that kills wild rice also increases toxic mercury c...↓

We must ensure the MPCA does not allow mines and other industries to discharge uncontrolled pollution for another half a century.

Please begin enforcing existing laws on this issue-it is long overdue!
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Comment From: Grant Berg

9/03/23 @ 6:32 PM
Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm...↓
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Diane Tessari

9/03/23 @ 4:35 PM
Must enforce standard. MPCA must enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. MPCA has no discretion to continue to delay or deny enforcement. The 10 ppm...↓
Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters.
Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north central Minnesota (including the Big Sandy Lake area) have far less than 10 ppm of sulfate. MPCA permitting should not allow sulfate in these wild rice waters to increase even if the degraded level of sulfate remains just below the standard.
Sulfate and mercury. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.
Health threat of sulfate and mercury. MPCA lax enforcement of the wild rice sulfate standard and increased mercury contamination of fish will damage the developing brains of fetuses, infants, children, and people who rely on fish for subsistence, and will impair the exercise of tribal Treaty-reserved rights.
Need proof to consider "site-specific standard." The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider of a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.
High iron does not protect wild rice. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to waterbodies with high levels of iron coats wild rice roots with iron sulfide and interferes with wild rice seed quality, production, and sustainability.
MPCA's "equation" is not valid science. MPCA's "equation" method to determine if wild rice production would be protected without the 10 ppm standard was debunked in contested case proceedings in 2018. The "site-specific standards" loophole should not be used to resurrect this scientifically unsupported theory.
Current discharge – historic proof. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or MPCA) should have to prove based on independent research––from the time historic sulfate discharge began to the present––the absence of harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality.
New or expanded discharge – research required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or MPCA) should have to prove based on at least 5 years of independent research using site-specific wild rice seeds and sediment that the proposed sulfate levels would not cause harm to wild rice beneficial use, including harm to wild rice abundance, seed productivity, genetic diversity, and nutritional quality
Tribal and public process. No "site-specific standard" for discharge of sulfate to wild rice should be approved by MPCA without tribal consultation and tribal consent and a formal and public rulemaking process.
Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Water Act, the MPCA must apply the 10 ppm wild rice sulfate standard in setting and enforcing permit limits and in preparing TMDL studies and implementation plans to restore wild rice waters listed as impaired due to excessive sulfate. MPCA must neither delay or assume a less stringent will at some point be approved.
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Comment From: Scott Mills

9/03/23 @ 3:14 PM
The MPCA must enforce the 10 ppm sulfate standard. Site specific standards should not be used to endanger wild rice, as there is no methodology based on sound science that shows the 10 ppm threshold can be exceeded. The proposed rule should be open...↓
Site specific standards should not be allowed without that input.
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Comment From: Scott Mead

9/03/23 @ 2:39 PM
We, as a state, should be protective of our sacred natural resources and not adding to the problems by loosening our regulations. We are now at a point where enforcing the existing standards should be the priority. We have too much at stake to allow ...↓
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Comment From: Judy Grant

9/03/23 @ 1:50 PM
I have a lake home on Big Sandy Lake near McGregor MN. This is a very wet area and I am very concerned that the MPCA may allow Copper Nickel mining in the Tamarack area, which would due to the fact that the sulfur content of this ore is high contami...↓
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Comment From: Thomas Leaf

9/03/23 @ 11:35 AM
Dear MPCA,
I am writing to ask that you please enforce current Minnesota wild rice sulfate standards of 10 ppm. There is good quality historic scientific backing for this standard. We must not allow polluters to degrade high-quality low-sulfate wild...↓
Please protect our low-sulfate waters. No "site-specific standards" without good long term quality scientific data and consultation, input and consent from our native tribal citizens.
Sincerely,
Tom Leaf
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