Site-Specific Sulfate Standard Framework - Policy Plan

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Comment From: Lisa Ciorlieri

9/03/23 @ 10:27 AM

It's September 3 and the world its staggering through the hottest temperatures on record. Canada has had endless wildfires, fires of burning in Oregon and California. "Unprecedented" and "historic" everything; torrential rains, killer storms, drou...↓

Minnesota is a water rich environment. This is not just about wild rice. Sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. Increased mercury contamination of fish will damage the developing brains of fetuses, infants, children and people who rely on fish for subsistence. Instead of the never-ending pattern of contaminating and poisoning our waters (then spending endless sums of money for cleanup - which is not an option with mercury in the water), PLEASE PROTECT THE WATER AND DO NOT ALLOW the site specific standards to go forward. And PLEASE PROTECT THE WATER AND ENFORCE THE FEDERALLY-APPROVED WIILD RICE SULFATE STANDARD.

Thank you.

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Comment From: Julie Cox

9/03/23 @ 9:52 AM

I urge the Minnesota Pollution Control Agency (MPCA) not to permit the degradation of Minnesota's current low-sulfate waters with higher levels of sulfate. Allowing these higher sulfate levels will degrade wild rice crops, an essential food grown in ...↓

• 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 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 rule-making 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: Daniel Iverson

9/03/23 @ 8:19 AM

Clean water is the one vital and rapidly being depleted resource critical to all life. Wild rice is the "the canary" in the coal mines" our water quality .

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Comment From: Lydia DeGross

9/02/23 @ 10:44 PM

Wild rice is such a culturally significant food to the indigenous tribes of MN so it must be protected. We also must keep the waters pollution free.

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Comment From: Laurel Anderson

9/02/23 @ 10:43 PM

I am writing to appeal to MPCA's most basic responsibility, which is to act on behalf of Minnesota—its citizens, future generations and the precious environment upon which we all depend--rather than on behalf of industry.

MPCA has no discretion to con...↓

Valid science, rather than the debunked MPCA equation, must be utilized. Tribal consultation and tribal consent, as well as a formal and public rulemaking process, must be implemented.

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Comment From: Mark Good

9/02/23 @ 8:56 PM

Instead of conspiring with mining conglomerates and their shills to permit sulfide mining projects, it is incumbent upon the MPCA to enforce sulfide standards they have refused to observe for 50 years, specifically in the case of MinnTac. MPCA has th...↓

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Comment From: Rita Benak

9/02/23 @ 5:34 PM

Please work with the Indigenous population regarding this decision. It has huge implications for our future.

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Comment From: Howling For Wolves (Maureen Hackett)

9/02/23 @ 2:34 PM

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.

Please 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.

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.

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Comment From: Steven Timmer

9/02/23 @ 10:45 AM

I am Steve Timmer; I am a retired attorney and live in Edina, Minnesota. I write with questions about the proposed "site specific" standards for implementation of the Wild Rice Rule.

First, no "site specific" regime may be adopted without formal rulem...↓

Without a SONAR – including a proof of the science – and proposed rules, there no way for scientists, the tribes, environmentalists, or the public to judge what the MPCA proposes to do. Moreover, at the moment, it doesn't seem that the MPCA has the data to conceive or enforce a "site specific" regime.

Second, tribal nations must have a seat at the table in conceiving any proposed changes (in the SONAR) to the Wild Rice Rule. Recent Clean Water Act litigation in Minnesota has reminded both federal and state regulators of the need to include the tribes in a plenary way.

Third, the Clean Water Act's anti-degradation requirements must be strictly observed.

Fourth, it is obvious to any casual observer that, because of industry influence, the state and the MPCA have resisted enforcing the Wild Rice Rule for its entire existence. Now with pressure to enforce it, the MPCA wants to weaken it. This was entirely predictable. Lamentable, but predictable.

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Comment From: Scott Laderman

9/02/23 @ 10:14 AM

I am a wild rice harvester and I urge the MPCA to retain and enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts. The MPCA has no discretion to continue to delay...↓

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, where I often go ricing) 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. The MPCA must consider the effects of lax sulfate standard enforcement on mercury and methylmercury.

The MPCA's 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 the MPCA even to consider a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.

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.

Before a "site-specific standard" can be considered for wild rice waters that currently exceed the wild rice sulfate discharger, the proponent (discharger or the 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.

Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the proponent (discharger or the 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 the 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. The MPCA must neither delay nor assume a less stringent will at some point be approved.

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Comment From: Grand Portage Tribal Council (April McCormick)

9/02/23 @ 9:26 AM

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Comment From: Christa Ernst

9/02/23 @ 7:50 AM

Thank you for allowing my comments. I respectfully ask the MPCA to 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 de...↓

Please prohibit 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.

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.

Please recognize the significant health threats 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.

Please enforce 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: Manfred Justen

9/02/23 @ 6:59 AM

To Whom it may concern,

MPCA h...↓

Valid science, rather than the debunked MPCA equation, must be utilized. Tribal consultation and tribal consent, as well as a formal and public rulemaking process, must be implemented.

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Comment From: Eileen Levin

9/01/23 @ 10:23 PM

we cant allow pollution degradation of our low sulfate wild rice waters. Sulfate pollution increases toxic mercury contamination resulting in dead fish and can damage the health of people who eat them. The health of our waters, fish and humans must b...↓

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Comment From: Jordan Olsen

9/01/23 @ 6:05 PM

I am writing in concern about the MPCA's proposed changes to regulation of Minnesota waters used for the production of wild rice by adopting site specific standards (SSS) for acceptable levels of sulfate pollution to replace the statewide standard of...↓

The proposal appears sound in its reasoning that the requirements for maintaining ecological health may be dependent on specific location and a variety of environmental factors. Thus, a uniform standard for acceptable sulfate levels across the state may be inadequate for addressing the needs to maintain health and productivity of streams, lakes, and wetlands based on regional variations in ecology. While the proposal goes to some lengths to apply standards by which to evaluate the impacts of sulfate contamination on the health and productivity of wild rice, it is clear that the highly complex nature of sulfate interactions with wild rice-bearing ecologies is, at best, difficult to qualify and may be speculative with opportunity for error. An assessment of the predicted impacts of a newly adopted SSS that increases allowable sulfate levels is a gamble that, if lost, will result in irreparable harm to the environment and the people who rely on wild rice for their livelihoods. Why should we take such a risk? Furthermore, the applications for new SSS designations that expand allowable pollutant levels will undoubtedly be brought forth by parties who's vested interest is in polluting more, rather than those who seek primarily to preserve the environment and maintain ecological health and viability. This interest necessarily means that applications will be biased towards construing the impacts of sulfate contamination as less significant or harmful to the health and productivity of wild rice in the sites under consideration.

At a time when the Clean Water Act is under national attack and has suffered major erosion by the ideological, anti-science rulings of the Supreme Court of the United States, it is more important than ever that the state of Minnesota stands strong as an example of leadership in environmental policy and the protection of our waters. Moreover, wild rice is a fragile natural resource that must be protected and carefully stewarded to be maintained. This is critical to ensuring the health of Native populations who rely on it as a food source, preserving and respecting Native culture, and to fulfilling the state's moral and legal obligation to uphold tribal sovereignty and treaty rights.

Please reject this proposal for the door it opens to harming precious wild rice resources and the bad environmental policy precedent it sets. More robust policy should be aimed at reducing pollutants that already exceed allowable levels rather than giving polluters a way out of legal responsibility for the damage they may be inflicting. We should be focusing our efforts on better enforcement of current standards and holding those accountable who choose to ignore them. Thank you for your time and consideration of this important issue.

Regards,

Jordan Olsen (he/they)

Minneapolis, MN resident

651-343-4028

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Comment From: David Welch

9/01/23 @ 4:39 PM

Please promote the site-specific sulfate standard framework. In general, be site-specific. (pun intended)

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Comment From: Fond du Lac Band of Lake Super... (Nancy Schuldt)

9/01/23 @ 3:47 PM

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Comment From: Lynda Pauling

9/01/23 @ 1:01 PM

I urge you to enforce sulfate standards under the Clean Water Act. 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-...↓

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.

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Comment From: Zoë Bird

9/01/23 @ 12:01 PM

Minnesota's federally-approved wild rice sulfate standard of 10 parts per million must be enforced to protect the health of ecosystems and humans! We *are* our water, here in Minnesota.

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Comment From: Nell Wegmann

9/01/23 @ 11:16 AM

I do not support the site specific standards.

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Comment From: Julia Kloehn

9/01/23 @ 11:14 AM

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Comment From: Chel Anderson

9/01/23 @ 10:47 AM

My comments on the site-specific sulfate standard framework are as follows:

First, 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--the "effects...↓

MPCA permitting should not allow sulfate in wild rice waters to increase even if the degraded level of sulfate remains just below the standard. For instance, 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.

Sulfate pollution is known to increase toxic mercury contamination of fish via release of mercury from sediments and increased mercury methylation. MPCA should consider the effects of lax sulfate standard enforcement on mercury and methylmercury.

MPCA's 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". If a discharger is asking for MPCA to consider a "site-specific standard" they must be required to prove that wild rice beneficial use will be protected long-term.

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 has been shown to coat wild rice roots with iron sulfide and interfering 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.

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) 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.

Before a "site-specific standard" can be considered and valid 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 waters should be approved by MPCA without tribal consultation, 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.

Thank you for considering my comments.

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Comment From: Richard Staffon

9/01/23 @ 10:13 AM

I want to see a Pollution Control Agency with backbone that upholds its responsibiltiy to protect our state's water quality, wild rice reosurce and public health with fish that are safe to eat. Please stand up against the political and corporate pres...↓

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Comment From: U. S. Steel Corporation (Chrissy Bartovich)

9/01/23 @ 9:51 AM

Attached please find U. S. Steel's comments on MPCA's Proposed Site Specific Standard Framework. U. S. Steel appreciates the opportunity to provide this feedback. Please contact me if you have any questions.

Thank you,

Chrissy Bartovich

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Comment From: Tony Kwilas

9/01/23 @ 9:02 AM

Attached are the Minnesota Chamber of Commerce comments

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Comment From: Patience Caso

9/01/23 @ 8:54 AM

Support the site-specific sulfate standard! I want wild rice. I don't want more mercury in my fish. Don't let polluters continue to pollute our water.

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Comment From: Peter Pierce

9/01/23 @ 3:23 AM

Wild rice and fish could be harmed if sulfate standard is raised.

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Comment From: Rachel Youens

8/31/23 @ 11:58 PM

After half a century of failure to enforce Minnesota's federally-approved wild rice sulfate standard, the Minnesota Pollution Control Agency (MPCA) is proposing a plan for permitting and for "site-specific standards" that would allow more pollution t...↓

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

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 contamination of fish.

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Comment From: Michael Koppy

8/31/23 @ 9:20 PM

Standards must be enforce to 10 parts per million.

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Comment From: Larry Bogolub

8/31/23 @ 9:09 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.

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.

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: Paul Ryals

8/31/23 @ 8:05 PM

Enforce the already-existing standard. It's there for good reasons.

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Comment From: Jane Zimmerman

8/31/23 @ 7:18 PM

Please enforce the MN standard of 10 ppm. This is about protecting the health of people and the environment. And please involve the tribal communities about these things. we have ruined enough of their (and our) environment. I am a public health n...↓

Thank you.

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Comment From: Kathleen I Haskins

8/31/23 @ 6:34 PM

The health of wild rice is extremely important as it demonstrates water quality. Healthy wild rice means lakes are viable for fish and drinking and provide a meaningful source of income for Native Americans. Although I am not Native, I am one of th...↓

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Comment From: Menoukha Case

8/31/23 @ 6:13 PM

WILD RICE

Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. Many of Minnesota's most abundant wild rice stands in the Boundary Waters, the Lake Superior watershed, and north cen...↓

The 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. 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. The MPCA must not allow polluters to degrade high quality, low-sulfate wild rice waters. The MPCA has no discretion to continue to delay or deny enforcement.

Before debunked "site-specific standards" can even be re-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. Evidence should be based on at least 5 years of independent research using site-specific wild rice seeds and sediment to demonstrate 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.

In addition, 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.

FISH

PEOPLE

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. Any standards for discharge of sulfate in waters that support fish and wild rice should be approved by tribal consultation and tribal consent and a formal and public rulemaking process. Unless and until there is forma; tribal approval 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.

Wild rice harvested in Minnesota makes its way around the United States. The health of wild rice waters is of great importance, not only to tribal members in Minnesota, but to those dispersed who rely on that irreplaceable taste and heritage.

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Comment From: Samuel Engel

8/31/23 @ 6:07 PM

Hello,

The wild rice sulfate standards need to be upheld and enforced. This is not only good for the natural landscape of Minnesota, but also good for my kids. We fish, eat, and play in the waters that are in northern Minnesota. Please protect their q...↓

Thank you,

Sam

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Comment From: Benjamin Tsai

8/31/23 @ 5:57 PM

To whom it may concern,

As a long standing wild rice harvester in Minnesota, I urge the MPCA to enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm). Based off the Clean Water Act and decisions of the Minnesota courts, MPCA has...↓

We are blessed that 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. This is how the MPCA can protect Minnesota as it is meant to be, unsullied.

In addition to threatening wild rice, sulfate pollution increases toxic mercury contamination of fish due to release of mercury from sediments and increased mercury methylation. As an avid fisherman in Minnesota, I also urge the MPCA to consider the effects of lax sulfate standard enforcement on mercury and methylmercury, for the health of everyone that enjoys the outdoors.

Regards,

Benjamin Tsai

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Comment From: johnna Hyde

8/31/23 @ 5:53 PM

For more than 40 years my family and I have depended on wild rice that we harvest for a substantial component of our diet. It is nutritious, inexpensive, and harvesting also provides us with several lovely days of recreation in the fall. Although we ...↓

That is the reason for one family's personal desire to have the state of Minnesota ensure the health of rice crops for many generations to come, but there are much larger concerns at stake. First, like slaughtering the bison herds and spreading smallpox with contaminated blankets, allowing the wild rice crops to deteriorate would be a cruel and preventable disaster for native people who depend on rice for food and income. Sure, we can eventually compensate them with money they can use to buy potato chips, but where is the pride, sustainability, tradition and ritual in that?! Second, with climate change there is so much at risk in our native botanical heritage. Let's preserve what we can. Also, water is precious. Wild rice isn't the only thing that may be damaged by failure to uphold water quality. For Minnesota, water is an iconic resource and source of identity - Land of 10,000 Lakes and even our state name, Minnesota, refers to the abundance and purity of our water.

Enforcement is needed, unfortunately, to keep those whose short-term economic benefits favor contamination from destroying our legacy. Please ensure our future generations are able to enjoy Minnesota's water for wild rice harvest and thousands of other positive experiences. Just having clean water in abundance is becoming more and more rare, so don't allow what we have to deteriorate, and provide for waters already degraded to return to a healthy natural state. Please enforce our clean water laws, especially the sulfate standards.

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Comment From: Robert Walker

8/31/23 @ 5:52 PM

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Comment From: Michael Alexander

8/31/23 @ 4:59 PM

Stop chemical polluters from destroying our lands and waters. Also stop geoengineering and the chemicals they're spraying the skies with. What goes up..must come down.

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Comment From: Drew Hempel

8/31/23 @ 4:13 PM

wild rice is a sacred food to the indigenous peoples before the Europeans invaded. So protecting wild rice is a top priority for the state since Europeans have only been here a few hundred years in numbers while indigenous peoples have been here for ...↓

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Comment From: Lawrence Krantz

8/31/23 @ 4:05 PM

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.

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Comment From: Thrace Soryn

8/31/23 @ 1:19 PM

Protect wild ricing and the Tribe's well being.

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Comment From: U.S. Environmental Protection ... (Aaron Johnson)

8/31/23 @ 12:41 PM

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Comment From: Beth Tamminen

8/31/23 @ 9:45 AM

I support maintaining and enforcing the current legal standard of 10 ppm for all wild rice waters, including those that have been impaired by recent industrial activity to the point that they have lost much of their wild rice growth. Living in Duluth...↓

There appears to be no scientific basis for moving to a complex, cumbersome system of evaluating every body of water, and that method has been rejected in the past. Do what is best for our tribal nations and for the health of all of us in the St. Louis River watershed and the Lake Superior region and follow through on the standard that is in law. Thank you.

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Comment From: Steve Brandt

8/31/23 @ 2:47 AM

Wild rice is too uniquely a Minnesota resource and too important a part of the state's heritage to allow a relaxed standard for sulfates in wild rice waters. Minnesotans want a standard that allows no increase in sulfates, even if below 10 ppm.

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Comment From: Iris Borowsky

8/30/23 @ 8:59 PM

MPCA has no discretion to con...↓

Valid science, rather than the debunked MPCA equation, must be utilized. Tribal consultation and tribal consent, as well as a formal and public rulemaking process, must be implemented.

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Comment From: Karen Heegaard

8/30/23 @ 8:49 PM

We are seeing everywhere what happens if we do not care for our water, air, land and vegetation. It is our duty, obligation and great responsibility to do so. It is also a legal obligation to protect the conditions that allow wild rice to grow. Be...↓

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Comment From: Andrea Childs

8/30/23 @ 8:44 PM

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Comment From: Allan Frink

8/30/23 @ 6:55 PM

My Dad riced (now departed), I have riced. I would like to continue ricing.

1) 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 discreti...↓

2) 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.

3) 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.

4) 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.

5)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.

6) 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.

7) 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.

8) 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.

9) 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.

Note: Commercial wild rice (from CA) does not taste as good as the real thing!

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Comment From: Aron Rolnitzky

8/30/23 @ 4:27 PM

As a consumer of Minnesota Wild Rice, I am very concerned that if pollution standards are not upheld, Minnesota wild rice crops will be compromised and seriously affect the long standing industry.

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Comment From: Linda Herron

8/30/23 @ 4:09 PM

To the MPCA,

In the planning for any new standard for sulfate concentration in any Minnesota water, extensive research is required. Before a "site-specific standard" can be considered for a new or expanding discharge to wild rice waters, the MPCA-appr...↓

Additionally, this process should involve Tribal involvement and approval. 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.

Until such further research can prove a safer level than the current 10 PPM, I urge the MPCA to maintain the current previously determined safe level of sulfate at 10 PPM for all Minnesota waters.

Thank you for consulting the public, even if in a limited way.

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Comment From: Michael Murray

8/30/23 @ 2:36 PM

If implemented, these standards would allow more pollution to degrade the quality and quantity of wild rice for the benefit of industry. Please do your job and enforce the already established standard instead of proposing actions that would undermine...↓

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Comment From: Amelia kROEGER

8/30/23 @ 12:36 PM

For the life of me I can see no reason not to enforce our wild rice sulfate standard.

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Comment From: Anne Morrison

8/30/23 @ 11:52 AM

We, Americans, have dominated, stolen from, and controlled Native people across this continent for centuries. Little do most people know that such domination and theft are not historical, but are ongoing. The willingness of the Minnesota government...↓

Of course, there is also the issue of the environment. Floods, hurricanes, suffocating smoke, wildfires, the die-off of the organisms that sustain the world's ecology (and not incidentally, our food chain), the growing numbers of climate refugees... all indicate that we are entering into an era of self-created climate catastrophe. Yet our government and corporations CONTINUE to act as if we can continue to exploit and destroy the natural world with no ill effects, instead of figuring out how to sustain ourselves without wreaking yet more havoc... they continue on as if it is "business as usual.

Haha, the joke will be on us.

Needless to say, I am opposed to any changes in regulations which would allow mines and other industries to continue to discharge uncontrolled pollution the next 50 years.

Haha, we will soon be reaping the results of the environmental destruction we have sown for centuries.

Thank you for considering my opinion on this important issue.

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Comment From: Lyle Brandt

8/30/23 @ 11:47 AM

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: alek roslik

8/30/23 @ 11:31 AM

Once these waters are degraded, they can never be brought back to their original state. The wild rice waters in Minnesota are a unique ecosystem and cannot be replicated elsewhere.

If you are going to change the sulfate standards it should only be to ...↓

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Comment From: Inter-tribal natural resourse ... (john coleman)

8/30/23 @ 10:45 AM

Attached find a .pdf file of my comments.

Attachments:

Download

Comment From: Jeffrey Durfee

8/30/23 @ 10:41 AM

Please enforce the standards. Do not allow variances.

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Comment From: Georganne Krause

8/30/23 @ 10:13 AM

Hello,

Native and indigenous people's food supply, health, and well-being has long been a target, with little or no consideration by the polluting entity. The struggle has been a stain on Minnesota since out earliest days. The day has come to stop ...↓

The recent Court decisions regarding the MPCA, the Poly-Met Permits, and the Wild Rice issues of our Fond du Lac Band are clear enough. There are no barriers to moving forward into vigorous enforcement of the Wild Rice Standard of 10 part per million. I have included the following information from Water Legacy.

Must enforce standard.

Degradation prohibited.

Sulfate and mercury.

High iron does not protect wild rice.

MPCA's "equation" is not valid science.

Current discharge – historic proof.

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: Cary Anderson

8/30/23 @ 10:08 AM

Do your jobs NOW and quit being skeevy. Enforce 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 standa...↓

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Comment From: Paul Podemski

8/30/23 @ 9:48 AM

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 met...↓

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Comment From: Peder Otterson

8/30/23 @ 9:32 AM

I am a retired DNR hydrologist who began my work with the State of Minnesota on the Regional Copper Nickel Study back in the 70s. Through field studies and extensive review, I came to appreciate how waste rock from mining operations could form leach...↓

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Comment From: Louis Asher

8/30/23 @ 8:28 AM

Wild rice (manoomin) is sacred to the Anishinaabe and an ecological indicator for water quality.

Please ensure that MPCA does not allow mines and other industries to discharge uncontrolled pollution for another half a century.

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Comment From: Kevin Voir

8/30/23 @ 8:11 AM

Wild rice is sacred to the Anishinaabe and an ecological indicator of water quality. We must ensure the MPCA does not allow mines and other industries to discharge uncontrolled pollution for another half a century.

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Comment From: Mary Ellen Ryall

8/30/23 @ 8:10 AM

Please protect the wild rice of the Ojibwe Nation. I have lived in Wisconsin and gone ricing as a wild rice knocker with Lac Courte Oreilles Ojibwe University in Hayward, Wisconsin. I order wild rice from Native Harvest every year. Please protect the...↓

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Comment From: Janey Palmer

8/30/23 @ 8:06 AM

Just say no to this type of mining!

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Comment From: Andrea Sit

8/30/23 @ 8:02 AM

Dear MPCA,

Wild rice (manoomin) is sacred to the Anishinaabe people and an ecological indicator for water quality. Please do not allow mines and other industries to discharge uncontrolled pollution for another half a century.

Please enforce Minnesota's...↓

Degradation is 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.

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 methyl-mercury. 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 a "site-specific standard" sulfate standard must prove that wild rice beneficial use will be protected long-term.

New or expanded discharge research should be 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.

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.

Sincerely,

Andrea Sit

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Comment From: Heyward Nash

8/30/23 @ 5:31 AM

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: Sue Halligan

8/30/23 @ 2:49 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 p...↓

* 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 methyl-mercury.

* 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 dis-charger 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 dis-charger, the proponent (dis-charger 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 rule-making 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: Kira Vega

8/30/23 @ 1:22 AM

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, and the 10 ppm sulfate standa...↓

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Comment From: Steven Csorgo

8/29/23 @ 11:12 PM

No intentional contamination/pollution of any Minnesota waters should be allowed. Water is Minnesota's number one resource...clean water, which is necessary for the survival of all species on our planet. Clean water is scarce across the world. Does i...↓

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Comment From: Richard Fish

8/29/23 @ 9:16 PM

The current sulfate standard was enacted to protect wild rice habitat among other things. 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 ha...↓

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Comment From: Lynn Anderson

8/29/23 @ 8:07 PM

The MPCA must enforce Minnesota's current wild rice sulfate standard of 1o parts per million. Degradation of low sulfate waters should be prohibited so that wild rice that the Native people depend on continues to grow. Low sulfate waters should be pr...↓

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Comment From: Kathryn A. McKenzie

8/29/23 @ 7:24 PM

As a person who loves both fresh water fish and wild rice I want to be able to eat them both without fear of mercury contamination. For more than twenty years I helped with the clean up of the St. Louis River Watershed. This included getting the me...↓

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Comment From: Nan Stevenson

8/29/23 @ 7:07 PM

This land is sacred to Native Americans...stop corporate pollution on this land. ENOUGH!!!!!

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Comment From: Betsy Blume

8/29/23 @ 6:56 PM

Please consider this feedback for the process of assessing sulfate effects on the health and well being of the water, wildlife, wild rice and people.

Protect low-sulfate waters. Many of Minnesota's most abundant wild rice stands in the Boundary Waters...↓

Further,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.

Sincerely,

Betsy Blume

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Comment From: Kate Dougherty

8/29/23 @ 5:55 PM

As someone who eats wild rice on a consistent basis, I understand that degradation is prohibited. Both the Clean Water Act and Minnesota law prohibit degradation of water quality in Minnesota lakes, streams, and wetlands. MPCA must not allow pollute...↓

Also, there is a 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.

Talking about science, who came up with the high iron does 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.

Thank you.

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Comment From: Candice Pierce

8/29/23 @ 5:46 PM

Sulfate pollution adversely affects wild rice & also causes mercury poisoning of fish. Please stop this.

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Comment From: Larry Bogolub

8/29/23 @ 4:15 PM

Wild rice (manoomin) is sacred to the Anishinaabe and an ecological indicator for water quality. We must ensure the MPCA does not allow mines and other industries to discharge uncontrolled pollution for another half a century.

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Comment From: Sheila Packa

8/29/23 @ 3:55 PM

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Comment From: Nancy Giguere

8/29/23 @ 3:27 PM

MPCA must enforce Minnesota's wild ric...↓

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: Gwen Myers

8/29/23 @ 3:22 PM

It is hard to believe that MN's wild rice standard of 10 ppm is once again under discussion. MPCA has failed to enforce this standard since the 1970s when it was first promulgated. MPCA's effort to develop "site specific" standards was rejected in co...↓

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Comment From: Norm Herron

8/29/23 @ 3:04 PM

Enforce the sulphate standard

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Comment From: Kathryn Mosher

8/29/23 @ 3:01 PM

Standards are made for a reason and agencies are assigned to enforce these standards. Please follow the guidelines you are assigned to enforce and protect.

Wild rice (manoomin) is sacred to the Anishinaabe and an ecological indicator for water qualit...↓

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Comment From: Christopher Loch

8/29/23 @ 2:54 PM

You 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...↓

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Comment From: Jean Heberle

8/29/23 @ 2:54 PM

Wile rice is sacred to Native Americans as well as a delicacy for we who live in Minnesota. It would be a sacrilege to foul the sacred waters where it grows!

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Comment From: Lorrie Ogren

8/29/23 @ 2:38 PM

We MUST 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.

Here. are the 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.

WE 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 – we require 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 – much more research is 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

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: Alex Comb

8/29/23 @ 2:15 PM

Wild rice grows and flourishes in a fairly small growing area. I don't think it's well known exactly why it grows in one area and not another. It is known that water levels affect growth within its natural growing area and that sulfate levels are als...↓

Why doesn't it grow in New England, which seems to have a similar environment to northern Minnesota? I've no idea. There has to be reasons. What we all know is that it does grow and historically has grown in a broad area of northern Minnesota. It is an important food source for people and I suspect wild life and has a sacred role to play for native people who have depended on it for thousands of years.

The mandated level of sulfate pollution at 10 parts per million was determined by scientific study. No studies have been shown to suggest this is too low a threshold. That waterways which have been allowed to exceed this level have been known to have impaired growth of wild rice. To suggest that area not now growing wild rice or growing it sun-standardly, should no longer be protected by that level of sulfate pollution seems irresponsible. If levels are too high now in places, they should be identified and measures taken to reduce those levels, not abandon the protection.

We need to protect our waters for wild rice and also for other forms of life and preserve the quality of our drinking water. We live in a special place - let's keep it that way.

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Comment From: Dean Borgeson

8/29/23 @ 2:13 PM

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.

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: Jean Ross

8/29/23 @ 2:13 PM

MPCA should 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...↓

As you may know exposure to sulfate and mercury has negative health impacts. MPCA's 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: Elizabeth Dailey

8/29/23 @ 2:13 PM

Now, before it's too late!

I urge you to not only support sulphate restrictions in our state, but increase them. We need to protect our water, our fish, our rice, and our people. This is your job. Call me if you need help. Thank you for your good work...↓

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Comment From: Mary Androff

8/29/23 @ 1:57 PM

MPCA has no discretion to con...↓

Valid science, rather than the debunked MPCA equation, must be utilized. Tribal consultation and tribal consent, as well as a formal and public rulemaking process, must be implemented.

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Comment From: John Harrington

8/29/23 @ 1:51 PM

How will MPCA enforce Minnesota's wild rice sulfate standard of 10 parts per million (ppm) under the Clean Water Act and decisions of the Minnesota courts under the proposed changes?

How will the proposed changes align with the Clean Water Act and Min...↓

Protect low-sulfate waters.

Will any increase in allowed sulfate levels increase the mercury content of fish and result in additional consumption advisories?

What will constitute appropriate scientific, peer reviewed evidence proof that wild rice beneficial use will be protected long-term?

How will any site specific standard be determined to be in compliance with tribal water quality standards?

What plans does the Agency have to incorporate consultation with indigenous nations and tribal consent and a formal and public rulemaking process as part of the proposed modifications?

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Comment From: Richard Mammel

8/29/23 @ 1:35 PM

Pure safe water is the most important ingredient to sustaining health and life.

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Comment From: Leah Rogne

8/29/23 @ 1:32 PM

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Comment From: CAROLYN JONES

8/29/23 @ 1:31 PM

We need to increase regulations not ease up on them. Our planet needs protection and that is literally in your name

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Comment From: Harriet McCleary

8/29/23 @ 1:29 PM

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Comment From: Janet Draper

8/29/23 @ 1:22 PM

I am writing to urge you to enforce the wild rice sulfate standard rather than weaken it. What is bad for wild rice and fish is bad for us all. I hope you will act to control the pollution of Minnesota's waters rather than encouraging it.

You will n...↓

Sincerely,

Janet Draper

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Comment From: Linville Doan

8/29/23 @ 1:21 PM

Once contaminates degrade water quality it requires years to rectify, if ever. I cite the example of the St. Louis River. Admittedly a different form of pollution but the results are the same. Incremental increases in contaminates culminate in un...↓

Because of recent negative findings concerning actions by the MPCA it would seem the agency would seek to establish a more reputable course of actions.

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Comment From: Dodd Cosgrove

8/29/23 @ 1:15 PM

Clean water is the state's most valuable resource. It is clean water that creates the environment for the state's renowned wild rice. Copper mining and wild rice do not mix. Changing the sulfate standards is a bad idea. The state needs strict sul...↓

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