Site-Specific Sulfate Standard Framework - Policy Plan

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Comment From: Gail Rosenquist

8/29/23 @ 1:14 PM

Please see above MPCA comments.

Protecting wild and indigenous lands is crucial to survival of these precious ancestral natural resources.

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Comment From: Gio Cerise

8/29/23 @ 1:05 PM

Boozhoo, I am an elder from White Earth Nation, and MPCA must endorse 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.

Miigwech,

Giiwedini-binesikwe/Northern Thunderbirdwoman

(english name Gio Cerise)

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Comment From: Philip Rampi

8/29/23 @ 1:04 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: Gary Boelhower

8/29/23 @ 1:03 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...↓e "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. 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. It is clear that 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 state has a moral obligation to act for the common good of its children and to ensure the exercise of tribal Treaty-served rights. The wild rice sulfate standard is not advisory. Any discharger asking for MPCA even to consider a "site-specific" sulfate standard must prove that wild rice beneficial use will be protected long-term, yes long term. It is important to recognize that 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. Before a "site-specific standard" can be considered for wild rice waters that currently exceed the 10 ppm standard, the sulfate 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 for a new or expanded 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 nor assume a less stringent standard will at some point be approved.

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Comment From: Daniel McCarter

8/29/23 @ 12:59 PM

As a Michigander who loves Minnesota, I hope you will implement policy that properly stewards precious natural resources.

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Comment From: Michael Steffes

8/29/23 @ 12:55 PM

Safefguard our environment. For so many reasons that should be perfectly obvious to all state agencies.

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Comment From: Ardie Medina

8/29/23 @ 12:49 PM

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Comment From: Noreen Lassandrello

8/29/23 @ 12:48 PM

Wild rice has long been sacred to the native Americans. And it has been an ecological indicator for water.

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Comment From: frank florin

8/29/23 @ 12:40 PM

protection of our natural resources, water, and wild rice should be our highest priority.

thank you

frank florin

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Comment From: K. Feilmeyer

8/29/23 @ 12:31 PM

This is the 21st century and we know to use science and data to promote better stewardship of our land and water. Wild rice (manoomin) is sacred to the Anishinaabe and an ecological indicator for water quality. We must ensure the MPCA does not allow ...↓

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Comment From: Annah Gardner

8/29/23 @ 11:20 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. Both the Clean Water Act and ...↓

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Comment From: North American Water Office (Lea Foushee)

8/29/23 @ 9:48 AM

North American Water Office

Comments on Framework Site Specific Sulfate Standards for Wild Rice

August 29, 2023

The work of John B. Moyle on the harm caused to wild rice from sulfate discharged to wild rice lakes from mining companies, industrial facili...↓

As early as 1973 Moyle's 10 mg/liter sulfate standard was approved by the United States Environmental Protection Agency and adopted. However, this sulfate standard was seldom, if ever, enforced by the Minnesota Pollution Control Agency. Rather than enforce the existing standard, countless public taxpayer dollars and staff time were spent first studying the problem and then a grueling six to seven years were spent attempting to promulgate a wild rice rule that was defeated. The rule was defeated because it was so obviously biased against protecting sensitive resources.

NAWO mentions this historical evidence to call into question the MPCA framework for a site-specific sulfate standard (SSS) for regulation of sulfate discharges into wild rice waters. It is laughable to contemplate the non-existing army of paid agency staff members, boats and vehicles required to accomplish the testing and rules/limits for 2,400 wild rice lakes.

Enforcement has always been the weak link in the MPCA budget and NAWO questions the ability of the Agency to accomplish this framework. It is with interest that NAWO notes the number of wild rice lakes has increased by 1,2000 from the number cited by the Minnesota Department of Natural Resources website and 2008 study. The additional 1,200 lakes were brought to the Agency's attention by Tribal participants and others during the previous wild rice rule proceedings.

Each boat that enters a wild rice lake provides another opportunity for the introduction of invasive species such as starry stonewort, narrowleaf cattail, and Eurasian milfoil into wild rice waters. This must be guarded against with due diligence.

In terms of honor and respect for Indigenous Peoples, the Agency has frequently exhibited a callous disregard for the Traditional Ecological Knowledge of Minnesota Tribal Nations. Time immemorial knowledge is not comparable to the Western Science of the Agency that began with the creation of the Agency in 1967. NAWO noticed and appreciates that there is a language shift with this attitude in the SSS Framework. Whether language becomes action is another matter. We hope this shift in language leads to more appropriate behavior on the part of the Agency.

Former Governor Dayton called John Moyle's 10 mg/liter sulfate wild rice standard "outdated" and if it was left in place, it would hurt the mining interests in the state. By its actions, the Agency doesn't care about wild rice. The SSS framework demonstrates that the Agency doesn't care about wild rice. The SSS framework will simply enable more mining.

Wild rice for Indigenous Peoples is not just "beneficial use." Wild rice is the very identity of Anishinaabeg Peoples, the very soul of the Indigenous Nations. Additional sulfide in the soils and sediments mobilizes mercury and methylates mercury into fish tissue. Northern Minnesota Tribes traditional diets include fish particularly those fish that bio-concentrate methylmercury like walleye and northern pike. The Agency with this SSS framework is committing genocidal actions against the Northern Tribes. This will result in forced assimilation. Is this what you want?

Lea Foushee

Environmental Justice Director

North American Water Office

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Comment From: Patricia Nielsen

8/28/23 @ 6:19 AM

I have not lived in MN for many years but still feel very connected to MN with friends and family-Enforcement without further delay. Unless and until a "site-specific standard" has been formally approved as required under state law and the Clean Wate...↓

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Comment From: Linda Vukson

8/27/23 @ 8:25 AM

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.

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.

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: Don A. Zatroch

8/27/23 @ 12:39 AM

I am respectfully submitting the following 12 positions:

1) 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 dis...↓

2) 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.

3) 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.

4) 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.

5) 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.

6) 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.

7) 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.

8) 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.

9) 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.

10) 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.

11) 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, as well as a formal and public rule-making process.

12) 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, as well as implementation plans, to restore wild rice waters listed as impaired, due to excessive sulfate.

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Comment From: Peter Leschak

8/26/23 @ 4:00 PM

It seems to me the MPCA must enforce the 10ppm sulfate rule under the Clean Water Act, and water quality degradation is prohibited, regardless of the site. Also, the interaction of toxic mercury with sulfate must be taken into account, and on a relat...↓

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Comment From: Valerie Murphy

8/26/23 @ 9:47 AM

Dear MPCA,

Please do not allow changes to the 10 mg/L sulfate water quality standard designed to protect the use of the wild rice grain as a food source for humans and wildlife. (Minn. R. 7050.0224).

We need to protect the water for all. The steel comp...↓

Thank you,

Valerie Murphy

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Comment From: Terrie Christian

8/26/23 @ 8:15 AM

I support saving wild rice. I grew up on the Leech Lake reservation. I am not native. I took Indian Studies at the U of M from Ron Libertus. The history of government policies have harmed indigenous people from the federal government and the stat...↓

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Comment From: Thomas Sullivan

8/25/23 @ 12:10 PM

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 perm...↓

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Comment From: Joseph Wenzel

8/25/23 @ 12:09 PM

Thank you,

Joseph Wenzel

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Comment From: Kari Tomperi

8/25/23 @ 9:29 AM

Site exemptions are not needed and would be very difficult to enforce as well as mitigate any damage as a result of a failure or application of poor science. This approach sets a dangerous precedent for protecting and managing wild rice throughout th...↓

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Comment From: Mary Verrill

8/25/23 @ 8:47 AM

Dear MPCA:

Please do what you can to preserve and protect wild rice and wild rice habitat from pollution sources such as sulfate mining. Wild rice is an important food source for the region and the world.

Not only does my family purchase and eat wild r...↓

Of course, sulfate mining in MN will permanently destroy a large area in which wild rice is situated -- everyone knows that. Do the tight thing and halt mining efforts. The argument that sulfate is needed for e-cars is ridiculous when so many mass transportation and airplane options already exist.

I trust MPCA will argue on behalf of citizens of our state to stop sulfur mining and stop any debate about introducting it.

Sincerely,

Mary G. Verrill

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Comment From: Adam Wegren

8/25/23 @ 8:22 AM

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: Paul Moss

8/25/23 @ 5:20 AM

MPCA should strictly enforce the 10 parts per million sulfate wild rice sulfate standard and should not develop site specific standards. One of the problems with site specific standards is that these can allow mines and other industries to discharge ...↓

Wild rice (manoomin) is sacred to the Anishinaabe and is Minnesota's state grain. It is an important food for wildlife and humans and is an ecological indicator for water quality. The same sulfate pollution that kills wild rice also increases toxic mercury contamination of fish.

It is important that MPCA enforce strict adherence to the 10 parts per million sulfate wild rice rule with no site-specific exceptions.

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Comment From: Larry Risser

8/25/23 @ 4:06 AM

It is time for the MPCA to take its mission seriously. Repeatedly, MPCA compromises its protection of the environment in favor to industry.

Enforce the wild rice sulfate standards now. We have already seen unconsionable degradation in wild rice wate...↓

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Comment From: Robert Bullis

8/24/23 @ 7:16 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...↓

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

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Comment From: Connie Grundhofer

8/24/23 @ 7:06 PM

Please

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

Thank you so much for your commitment to protecting Minnesota's clean waters, health and environmental justice.

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Comment From: Grant Thrall

8/24/23 @ 6:53 PM

I am writing to urge the MPCA to enforce the existing maximum parts per million of sulfates for bodies of water producing wild rice. I understand there is no prescription for maintaining that standard, due to variability of circumstances, but I am es...↓

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Comment From: Dave Crawford

8/24/23 @ 6:23 PM

A line was drawn 50 years ago. MPCA has resisted enforcing it. 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 ...↓

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.

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.

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.

Pre-pollution baseline. 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.

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: Gabriela Santiago

8/24/23 @ 5:48 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. The 10 ppm sulfate standard is the "effects threshold" for wild rice impairment. MPCA must not all...↓

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Comment From: Michelle Gobely

8/24/23 @ 4:56 PM

Would appreciate it if MPCA would stop allowing the polluting of our precious waters, the place of wild rice, and the lands of our Indigenous tribes. None of this sulfate crap is safe. Why does the public need to tell you this!

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Comment From: Carl Sack

8/24/23 @ 4:01 PM

Instituting a "site-specific" sulfate permitting process is an unacceptable breach of MPCA's responsibility to protect our state's waters and wild rice, a treaty-protected cultural resource. Site-specific standards are simply a way to exempt mining o...↓

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Comment From: Dorie Reisenweber

8/24/23 @ 2:48 PM

It is disturbing to me that only written comment on changes to the wild rice standard will be received. Open public meetings help to inform people of the actions and possible harms our agencies plan to allow. The ten parts per million wild rice sulfa...↓

Please, MPCA, enforce the 10 ppm wild rice sulfate standard which is upheld by both the Clean Water Act and Minnesota laws and regulations. In my book it is criminal to let polluting industries harm the high quality, low-sulfate wild rice waters. Productive wild rice waters, including the Boundary Waters, Lake Superior's watershed and the waters near Big Sandy Lake have sulfate levels less than 10 ppm. I urge the MPCA not to grant any sulfate level increases in those lakes and waters.

For several years I have read reports on how sulfate pollution increases mercury toxicity in fish due to mercury methylation. Reducing enforcement of the 10mmp sulfate standard would harm fish and those who eat fish, harming fetuses, youngsters, the elderly, and actually all who subsist on fish, many of whom are indigenous. That violates their Treaty Rights, because they cannot without harm "hunt, fish and gather" in those waters with high mercury levels.

Please require any industry or entity wanting to put more sulfate in the water prove that their "site-specific sulfate standard" does not harm wild rice so that wild rice will be protected in the long run. A 2018 contested case hearing debunked the "site-specific" standards the MPCA was promoting. More wrongs don't make a right. The MPCA should not grant "site-specific" sulfate standards without tribal consultation and consent and without public rulemaking. It's time to nix the "site-specific" sulfate standards for the wishful and unscientific thinking it is.

Unless and until Minnesota's laws and the Clean Water Act formally approve a "site-specific sulfate standard," I urge the MPCA to apply and enforce the 10 ppm wild rice sulfate standards as you work to establish and enforce permit limits and as you develop TMDL studies and plans to restore any and all wild rice waters on the impaired list due to higher sulfates than the 10 ppm standard. Please do not put this off or apply weakened standards. Enforce the 10 ppm wild rice standards now.

We have no right to further degrade our environment. We must leave it in as good or better shape than we found it so future generations can enjoy and use it. Again please, enforce the 10 ppm wild rice standards now.

Thank you.

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Comment From: David M Amrod

8/24/23 @ 2:48 PM

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

Thank you so much for your commitment to protecting Minnesota's clean waters, health and environmental justice.

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Comment From: Candice Pierce

8/24/23 @ 1:54 PM

The same sulfate levels that harm wild rice also cause toxic mercury levels in fish. Please don't allow this.

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Comment From: Pamela Martin

8/24/23 @ 12:57 PM

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Comment From: Eric Morrison

8/24/23 @ 12:43 PM

Dear MPCA,

The following comments are submitted regarding the MPCA Site-Specific Sulfate Standard Framework - Policy Plan.

THE PROPOSED REQUIREMENT THAT WATERBODIES SHOULD HAVE AND ARE EXPECTED TO MAINTAIN A WILD RICE POPULATION THAT IS SELF-SUSTAINING...↓

A case of allowable destruction attributable to prior eradication of wild rice is the Saint Louis River, which is no longer protected for wild rice and therefore it is permissible for Northshore Mining to discharge sulfate without limit (NPDES-SDS Permit MN0042536 surface discharge site SD 033 Rail Culvert NE of Pit 5N Loadout Pocket – no limit on sulfate). For example, in the spring of 2022, Northshore Mining was dumping 11 tons of sulfate per day through Spring Mine Creek at SD 033. This wanton, willful dumping of sulfate is extremely destructive, not just to wild rice but to game fish and human health because of methyl mercury production by sulfate reducing bacteria and mercury bioaccumulation as discussed below.

Such a loophole is offensive to people of good conscience and it should be considered a sign of weakness, cynicism, and resignation (or outright corruption) to further loosen or further complicate regulations on sulfate discharges.

Another relevant case is PolyMet (now NewRange) NPDES-SDS Permit MN00701013. There are no restrictions on sulfate discharge within the 30 square miles of property owned or leased by PolyMet / NewRange, whether in consideration of mercury contamination of fish OR wild rice. This regulatory lapse is exacerbated by an outrageous limit on mercury. For the one site on property with a limit on mercury (SD001), the limit is 1000 nanograms per liter (calendar monthly average), which is 770 times the applicable water quality standard of 1.3 nanograms per liter. Mercury AND SULFATE are pollutants of great concern because they promote mercury bioaccumulation in game fish.

THE PROBLEM OF SULFATE PROMOTED BIOACCUMULATION OF MERCURY IN FISH SHOULD NOT SO EASILY DISREGARDED. In a 2017 report published by the USGS, there is a strong correlation between mercury in yearling yellow perch and sulfate concentration in lakes of the Voyageurs Park in Northern Minnesota [Christensen V, Larson J, Maki R, Sandheinrich M, Brigham M, Kissane C, LeDuc J (2017). Lake levels and water quality in comparison to fish mercury body burdens, Voyageurs National Park, Minnesota, 2013–15. Scientific Investigations Report. https://doi.org/10.3133/SIR20165175]. According to USGS data as plotted in Figure 1), when sulfate increased from 2 mg/L to 5 mg/L, mercury concentration in fish quadrupled. The strong correlation of mercury in yellow perch vs lake sulfate concentration is completely corroborated by the MPCA's own data for walleyes in the Fish Contaminant Monitoring Program (FCMP) database (Figure 2). The p-value for the correlation of FCMP walleye mercury levels vs sulfate is 0.006, indicating that this is not attributable to chance. The mercury levels in Crane Lake and Sand Point Lake walleyes are in excess of the maximum permissible level of 1 ppm of methylmercury for seafood set by the US Food and Drug Administration (FDA) and above the 0.95 ppm "NO CONSUMPTION" advisory limit recommended by the Great Lakes Fish Advisory Workgroup for raw fish filets [A Protocol for Mercury-based Fish Consumption Advice - An addendum to the 1993 "Protocol for a Uniform Great Lakes Sport Fish Consumption Advisory," May 2007. Available from the Minnesota Department of Health at https://www.health.state.mn.us/communities/environment/fish/docs/consortium/mercuryprot.pdf].

THERE ARE NO EXCUSES FOR ALLOWING SULFATE POLLUTION ABOVE THE 10 mg/L SULFATE WILD RICE WATER QUALITY STANDARD ANYWHERE. Membrane technology (reverse osmosis) is capable to economically remove sulfate to 10 mg/L. In public hearings, PolyMet promises that membrane treatment is tried and true technology that is capable to remove sulfate to 10 mg/L: "we're going to be collecting water at the tailings basin, water at the mine site, water coming off of the haul roads, anything that's going to be carrying sulfate or constituents of concern, all of that treated to below 1.3 nanograms per liter mercury to 10 milligrams per liter of sulfate before that is returned to the environment," "over the life of the project 27.6 billion [sic] kilograms of sulfate are going to be pulled out," and "sulfate loading will be reduced by 1 million, three hundred and eighty thousand kilograms per year" [source: testimony by Steve Donahue of Foth Engineering and Christie Kearney of PolyMet speaking on behalf of PolyMet at the U.S. Army Corps of Engineers St. Paul District PolyMet Public Hearing in response to an objection from Fond du Lac Band of Lake Superior Chippewa to the Corps of Engineers' Section 404 Clean Water Act permit for PolyMet Mine project, Day 2 Session 1. May 5, 2022 [video available at https://www.youtube.com/watch?v=x8BqknsJgjU].

SUMMARIZING: PLEASE DO NOT CONSIDER SITE-SPECIFIC SULFATE STANDARDS.

Sincerely,

Dr. Eric D. Morrison, PhD Chemistry

Volunteer, Northern Lakes Scientific Advisory Panel

(m) 651.334.8399 [email protected]

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Comment From: Nancy Conger

8/24/23 @ 10:20 AM

Your job is uphold the protections for our water, not find ways to degrade it.

The bounty of wild rice and all the other products of a healthy water and forest ecosystem are worth so much more than the temporary products of a mine. Allowing the pollut...↓

It won't buy it.

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Comment From: Anne Johnston Smith

8/24/23 @ 10:13 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: wendy Durrwachter

8/24/23 @ 9:31 AM

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Comment From: John and Betsy Flaten

8/24/23 @ 9:23 AM

You must enforce the wild rice standards in accordance with the views of Water Legacy!

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Comment From: Nicholas Eltgroth

8/24/23 @ 8:28 AM

Please clean up the water so the WILD RICE can increase.

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Comment From: Keith Monsaas

8/24/23 @ 7:01 AM

Please protect our environment!

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Comment From: Kevin LeVoir

8/24/23 @ 6:43 AM

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. 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: Cynthia Launer

8/24/23 @ 4:51 AM

I was angered to read in the Star Tribune ("Two Minnesota iron mines want exemption from state pollution rule designed to protect wild rice" 19 August 2023) that the MPCA is not enforcing the sulfate standard as urged by the EPA. Fifty years of ignor...↓

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Comment From: JL Charrier

8/24/23 @ 1:03 AM

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 co...↓

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

Thank you.

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Comment From: Brad Snyder

8/24/23 @ 12:39 AM

As a Science Teacher/Environmental Educator, Mechanical Engineer (Emphasis: Environmental Science/Eng.), Clean Water/Environmental Protection/Human Health Advocate, and an extremely concerned Minnesotan, I wholeheartedly insist the Minnesota Pollutio...↓

- 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!

- 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 MUST 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!

Thanks!

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Comment From: Zeb Noormohamed

8/24/23 @ 12:19 AM

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

Please our future generations depend on you to protect them against a polluted world.

Thank you.

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Comment From: Chris Nordstrom

8/24/23 @ 12:17 AM

Wild rice is a canary in the coal mine. We cannot allow industries to degrade our pristine lands for minimal public good. Minnesota needs clean water forever and cannot allow ticking time bombs to strewn across the landscape to be inherited by our ch...↓

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Comment From: Thomas Orne

8/23/23 @ 10:56 PM

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: Pamela Arnold

8/23/23 @ 10:41 PM

I write as a resident of Minnesota, a member of the Marine Carnelian St Croix Watershed District Citizen Advisory Council, and I live adjacent to the St Croix River, a National Wild and Scenic River whose waters contain PFAS/FOS chemicals. Something ...↓

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

Thank you so much for your commitment to protecting Minnesota's clean waters, health and environmental justice.

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Comment From: Laura Schauland

8/23/23 @ 10:10 PM

Water is our most precious resource and MPCA is supposed to be the agency that protects our environment from man made disasters and pollution. It seems that the agency does not focus on preventing pollution but actually promotes pollution.

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Comment From: Christine Popowski

8/23/23 @ 9:49 PM

The Health Threat of Sulfate and Mercury: 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 subsisten...↓

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Comment From: Dianne Hudson

8/23/23 @ 9:48 PM

ENFORCE THE WILD RICE SULFATE STANDARDS!!

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Comment From: Michael Degerstrom

8/23/23 @ 9:15 PM

I would like to advocate for the protection of our waters where wild rice grows. The wild rice is culturally important to our state and an important food source for people, waterfowl and other birds. And if the rice cannot grow then the lake habita...↓

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Comment From: Bob Jalonen

8/23/23 @ 9:03 PM

Sulphates are a dirty word when it comes to mixing with water. I suspect this is common knowledge. I am hopeful that the MPCA will be given the authority to review a thorough site specific sulphate standard application for waters on which wild rice...↓

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Comment From: Tania Malven

8/23/23 @ 8:14 PM

PROTECT HUMANS AND ANIMALS!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

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Comment From: Kent Simon

8/23/23 @ 7:57 PM

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: H Ande

8/23/23 @ 7:38 PM

Please do the right thing & protect the environment

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Comment From: Pat Becchetti

8/23/23 @ 7:17 PM

I am sharing only part of the information that was supplied by the Water Legacy because I assume that many copies of their "talking points" will be sent to you. I just want to express my strongly held conviction that Minnesota needs to protect our w...↓

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Comment From: Pat Kerlin

8/23/23 @ 7:07 PM

I have had a long term interest in wild rice for use and holiday meals. Also, I have had a continuing interest in the effects of the Enbridge pipeline on the land where wild rice grows and continuing disregard of treaty rights. Thank you.

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Comment From: Larry Bogolub

8/23/23 @ 7:05 PM

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: Dean Borgeson

8/23/23 @ 6:50 PM

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: John Margerum

8/23/23 @ 6:49 PM

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

Thank you so much for your commitment to protecting Minnesota's clean waters, health and environmental justice.

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Comment From: Gary Schwart

8/23/23 @ 6:34 PM

No exemptions to MN.sulfide standards for mines. Our lakes and rivers should be clean enough for wild rice.

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Comment From: Patricia M Shea

8/23/23 @ 6:34 PM

Any sulfate pollution is unacceptable. We are here to take care of our water environment. There have to be standards that are monitored and maintained.

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Comment From: Mary Arps Thompson

8/23/23 @ 6:22 PM

We must ensure the MPCA does not allow mines and other industries to discharge uncontrolled pollution for another half a century. Please, put CONTROL back in the MPCA.

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Comment From: Sally Downing

8/23/23 @ 5:21 PM

The MPCA has for 50 years not enforced the 1973 federally approved wild rice sulfate standards. Now it is proposing that 2 taconite companies be allowed to increase sulfate pollution. This sounds foolish and dangerous. Please think long about damage...↓

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Comment From: Stephanie Johnson

8/23/23 @ 5:20 PM

Wild rice is a tradition and instrumental in the Anishinaabe life style and it also will disclose the healthy status of the water itself. Please MPCA protect our water quality from copper/sulfate mining or any other type of mining that might pollute...↓

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Comment From: Al Gedicks

8/23/23 @ 5:14 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 of water quality. Sulfate becomes toxic to wild rice when it turns into sulfide in the mucky bott...↓

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Comment From: Karen Anderson

8/23/23 @ 5:05 PM

protect boundary waters!

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Comment From: Carla Albers

8/23/23 @ 4:44 PM

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: Nicole Everling

8/23/23 @ 4:43 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's lax enforcement of the wild rice sulfate standard and increased mercury contamination of fi...↓

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Comment From: Joel Barkley

8/23/23 @ 4:38 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...↓

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Comment From: Harriet McCleary

8/23/23 @ 4:29 PM

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Comment From: Tanya Hovi

8/23/23 @ 4:25 PM

Besides sulfates in waters, climate change is further damaging wild rice in Big Rice Lake in St. Louis County through drought, engendering lower water levels. Aquatic pickerelweed has been flourishing at the expense of wild rice beds, leading to a ye...↓

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Comment From: Lauren Kofsky

8/23/23 @ 4:22 PM

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Comment From: Christopher Loch

8/23/23 @ 4:16 PM

Mines and other pollution sources cannot be allowed to put sulfate into wild rice bearing waters or into ANY waters. No exceptions should ever be granted. Exceptions make a mockery of regulations and protections and are bad in the short and long run.

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Comment From: Miriam Gingold

8/23/23 @ 4:15 PM

We have environmental standards for precisely those times when companies or individuals or the government itself want to make exceptions ( such as via enactment of a site specific framework). Standards mean little if our watchdogs want to bend the ru...↓

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Comment From: Michael Overend

8/23/23 @ 4:12 PM

Dear MPCA Administration,

The iron mining industry is vital to Northern Minnesota's economy and the well being of the region's families and communities. At the same time the site-specific sulfate water pollution associated with this iron-ore extractio...↓

These tribal governments gave permission to our state government to make use of these mineral resources but they did not give permission to pollute their waters or destroy their wild rice resources. The 2018 Tribal Wild Rice Task Force Report has clearly defined the sources and impacts of sulfate pollution on the fresh waters and wild rice resources which are vital to the tribes:

https://mnchippewatribe.org/pdf/TWRTF.Report.2018.pdf

There is a cost-effective solution under development to address this problem through biological remediation of the sulfate impairment of fresh water. Please explore the clearwater BioLogic website for more information about this technology at this link:

https://clearwaterbiologic.com/

This technology offers a cost-effective and scalable solution that will allow the iron mining industry to address this sulfate pollution problem and meet the needs of the people of the native tribes for thriving wild rice and healthy waters to support their communities.

The MPCA should contact and work directly with clearwater BioLogic to help bring this technology to market as soon as possible and mandate the implementation of this technology to address the proven site-specific sulfate pollution of Minnesota's waters directly related to Minnesota iron mining.

The site-specific sulfate standard for our Minnesota waters must be enforced by the MPCA without exception and this is one of the most important roles and tasks of the MPCA as noted on your website:

"The Minnesota Pollution Control Agency is committed to ensuring that every Minnesotan has healthy air, sustainable lands, clean water, and a better climate.

Through the authority of state and federal statutes and guidelines, the state agency focuses on preventing and reducing the pollution of air, land, and water, and leads Minnesota's efforts to protect against the devastating effects of climate change. We work with regulated parties, businesses, governments, organizations, and Minnesota's 11 tribal nations to develop innovative, community-centered approaches that protect our natural resources, improve human health, and foster strong economic growth.

The MPCA addresses statewide inequities in pollution exposure through its work to ensure that Black, Indigenous, communities of color, and low-income residents enjoy a healthy environment and fair treatment with respect to the development, adoption, and enforcement of environmental laws, regulations, and policies. The agency advances meaningful engagement with communities most impacted by pollution and programs intended to protect against it. Read more about the agency's environmental justice work.

The MPCA is organized into seven divisions:...

Industrial handles permitting, compliance assistance and enforcement, and licensing and certification for industrial wastewater and stormwater facilities, sources of air emissions, underground fuel storage tank facilities, and hazardous waste generators."

https://www.pca.state.mn.us/about-mpca/about-us#:~:text=Industrial handles permitting, compliance assistance,facilities, and hazardous waste generators.

Please follow these guidelines that you have published on your website and that you have been tasked with by the authorities of the State of Minnesota.

Respectfully,

Michael Overend

1087 Isackson Road

Two Harbors, MN 55616

(218) 591-2514

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Comment From: Zoë Bird

8/23/23 @ 4:10 PM

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...↓

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

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Comment From: Michael Klug, PhD

8/23/23 @ 4:06 PM

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Comment From: Patrick Byron

8/23/23 @ 4:06 PM

Wild rice areas no matter where they are located in the state of Minnesota need to be protected to the greatest extent possible.

There should be NO changes implemented until the science has been proven that any modifications in any way, shape or form ...↓

Wild rice is a staple for many parties regarding their income.

Legislation that has been ignored over the decades to protect, enhance or develop this resource MUST

be implemented, immediately and consistently.

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Comment From: Marie Kube, PhD

8/23/23 @ 4:03 PM

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Comment From: Karl Hamann

8/23/23 @ 4:03 PM

Don't allow sulfate mining to kill off the manoomin(wild rice)!

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Comment From: r tippens

8/23/23 @ 4:01 PM

WHAT are you thinking about! The wild rice stands must be protected! End of Story. My nephew lives in the area and for that reason am personally concerned but even considering allowing sulfates to seep into the waters is reprehensible! MPCA must e...↓

Degradation prohibited. Both the Clean Water Act and Minnesota law prohibit degradation by the by. Furthermore: 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: Jean Ross

8/23/23 @ 4:01 PM

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Comment From: Eric Ristau

8/23/23 @ 3:57 PM

We cannot relax the sulfate standards for discharges into Minnesota waters but should rather be stiffening and enforcing them to protect our wild rice, fish & natural resources. It's our duty to protect these incredible treasures.

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Comment From: Bill Newman

8/23/23 @ 3:46 PM

I have over thirty eight years of experience as an Environmental Chemist working on surface water and ground water treatment. I am the owner and founder of RNAS Remediation Products a Minnesota Corporation that provides bioremediation products for g...↓

The complex, site-specific sulfate standard that was previously proposed by MPCA and ultimately rejected by the courts was to some degree based in science but not practical. It would be a huge task to properly evaluate every potential lake and stream environment to study and determine a site specific tolerance for sulfate inputs.

More importantly it ignores some common sense requirements for reactive iron to protect sediments from high sulfate inputs. The form of iron is very important. Zero valent iron with a high specific surface area will rapidly capture sulfide, while larger particles (with a low specific surface area) of oxidized iron are not effective in capturing sulfide. In review of "Sulphide Scavengers" in the attached article they discuss how treating sulfide contaminated drilling mud with magnetite is not effective at neutral or alkaline pH because reaction rates are very slow. Ferric iron has minimal water solubility and neutral pH water with more than 50 ppb of dissolve oxygen has little or no ferrous iron - there is little or no natural iron flux to replenish iron in sediments from water while soluble sulfate can be delivered at high concentrations. If the flux of reactive iron is not sufficient to react with the flux of unnaturally high sulfate inputs the end result is that what little reactive iron is present in the sediments will be depleted and toxic sulfide will poison wild rice.

Unnaturally high sulfate inputs are well known to cause other negative impacts to our streams, lakes and wetlands. The attached AGU Publication describes how not only do sulfate inputs create toxic sulfides but this alternative electron acceptor is used by microbes as an oxygen alternative, rapidly consuming natural organic matter in sediments which releases mercury, phosphates and TOC into our waters. The combination of sulfate reduction and releasing sequestered ionic mercury in sediments leads to greater production of methylated mercury which is of course the main toxic insult to humans and wildlife that consume fish.

The bottom line is that we must remove sulfate pollution at the source, before it reaches our natural waters and sediments. There are not that many high sulfate sources with the potential to impact wild rice waters. We now have low cost biological treatment methods that can take the sulfur out of the system in the mine pit lakes and at the power plant discharge locations before they harm our environment.

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Comment From: Heyward Nash

8/23/23 @ 3:44 PM

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: Jon Damon

8/23/23 @ 3:38 PM

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Comment From: William Thomas

8/23/23 @ 3:28 PM

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Comment From: Alan Olander

8/23/23 @ 3:28 PM

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Comment From: Amy Grace

8/23/23 @ 3:24 PM

Wild Rice is a precious resource and we are obligated to protect it.

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 cont...↓

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Comment From: Lori Erickson

8/23/23 @ 3:19 PM

Thank you for hearing my comments!

First and foremost, 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 ...↓

Further, 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. We need to keep our pristine or near pristine waters where we can!

Adding iron to the areas is not a fix. Peer-reviewed scientific evidence does not support allowing more sulfate when there is also a high level of iron in sediments. Adding sulfate to water bodies 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.

I firmly believe that 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.

Finally, 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 standard will at some point be approved.

Enforce the 10 ppm standard now!

Thank you,

Lori Erickson

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Comment From: Erin Enger

8/23/23 @ 3:18 PM

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Comment From: Sophia Langr

8/21/23 @ 3:01 PM

Please do not allow companies an exemption to the rules designed to protect wild rice! Exemptions like this could set a dangerous precedent for pollution. If requests like this are granted companies can avoid installing pollution control methods to r...↓

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Comment From: Brett Cease

8/21/23 @ 9:44 AM

Both U.S. Steel and Cleveland Cliffs are requesting site-specific exemption to the wild rice sulfate standard of 10 ppm (10 mg/L). In the article U.S. Steel claims that it would cost them between $9 and $27 million per year at their Minntac plant to ...↓

The Clearwater BioLogic sulfate reduction system (www.ClearwaterBioLogic.com) using biological reduction and DRI (Direct Reduced Iron) treatment is estimated to cost less than $3 million per year at the Minntac site to meet the wild rice standard downstream. And a big part of this solution uses the DRI pellets that the iron and steel companies themselves are or will be producing. The United Taconite site would cost much less. This technology is ready to begin implementation now. And furthermore, the biggest cost of sulfate remediation would be the providing of good paying jobs here in NE Minnesota. If we want jobs in NE Minnesota, we can provide jobs by solving the sulfate standoff.

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Comment From: Jean Ross

8/21/23 @ 7:50 AM

Do not allow U.S. Steel and Cleveland-Cliffs a pass on meeting the sulfate rules, Allowing U.S. Steel their request to discharge 8 times as much is bad enough, but to allow Cleveland Cliffs to discharge 40 times as much sulfate will be a death nell f...↓

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Comment From: Elizabeth Dailey

8/21/23 @ 1:56 AM

We have already had so much damage to our beautiful water ways in Northern Minnesota, caused by Line 3. We need to be very protective of all our water going forward. Please do not allow companies an exemption to the rules designed to protect wild ric...↓

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