PFAS in biosolids strategy

Comment From: Steve Robertson

12/12/24 @ 7:57 PM

See attached letter.

Attachments:

Download

Comment From: Mohammed Haque

12/12/24 @ 7:55 PM

See attached comments from Midwest Biosolids Association

Attachments:

Download

Comment From: Akilah Sanders-Reed

12/12/24 @ 5:59 PM

Please see the attached comments on behalf of Minnesota Center for Environmental Advocacy, CURE, W. J. McCabe Chapter of the Izaak Walton League of America, and Clean Water Action.

Attachments:

Download

Comment From: Marianne Bohren

12/12/24 @ 4:45 PM

Attachments:

Download

Comment From: Michael Happ

12/12/24 @ 4:14 PM

Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155

To whom it may concern,
Thank you for the opportunity to help shape Minnesota's biosolids strategy. We are thankful for the work you do, for gathering input from the community,...↓

Attachments:

Download

Comment From: Lois Norrgard

12/12/24 @ 4:09 PM

I am very concerned about this, toxic PFAS in biosolids are creating catastrophic impacts in other parts of our country. This contamination is a threat not only to our state waters, but also to farmers who rely on healthy soils for their livelihoods....↓

No attachments

Comment From: Steven Jahnke

12/12/24 @ 4:01 PM

Attachments:

Download

Comment From: Brooke Lund

12/12/24 @ 3:35 PM

Attachments:

Download

Comment From: John Paulson

12/12/24 @ 2:01 PM

Attachments:

Download

Comment From: Julie O'Leary

12/12/24 @ 1:57 PM

These comments are provided on behalf of the W.J. McCabe Chapter of the Izaak Walton League of America (IWLA) to provide our input on the Minnesota Pollution Control Agency's (MPCA) draft strategy for addressing PFAs in biosolids. The League is a "bi...↓g picture" organization, working to protect whole watersheds, including the air and water quality, the fish and wildlife habitat, and advocating for proper management of our soils, air, woods, waters, and wildlife. The McCabe Chapter is located in Duluth and the environmental quality of Lake Superior and the St. Louis River estuary have long been a high priority for us.

We applaud the MPCA for developing a strategy to address PFAs in biosolids and for getting ahead of the U.S EPA's risk assessment, expected by the end of the year. The strategy is an important step towards addressing the widespread pollution resulting from the use of PFAs in many products. We appreciate the emphasis on source reduction and pollution prevention, which are the only real solutions to this problem.

Our primary concern with the strategy is the proposed frequency of testing – once per year for all wastewater treatment plants (WWTPs). Wastewater plants vary greatly in size, nature of their influent and industrial contributors, pretreatment programs, and how much biosolids they land apply. A "one size fits all" approach is not appropriate and unlikely to produce an accurate picture of the problem. One annual sample might be adequate for a WWTP that does not have many industrial contributors and land applies infrequently, but a plant that has an ongoing land application program, such as the Western Lake Superior Sanitary District here in Duluth, should have to meet a higher standard. Sampling requirements based on the size of the plant and the frequency of land application are more appropriate. Some additional guidance for what constitutes a representative sample is also needed, as wastewater influent can vary considerably depending on the time of year and the seasonal activity of its industrial customers.

We also wonder how aware farmers considering land application are of the potential risk associated with PFAs in biosolids. We appreciate the requirement to notify farmers and landowners if testing indicates elevated levels of PFAs, but would suggest MPCA consider an educational piece could be made available to farmers as they are making the decision about use of biosolids.

No attachments

Comment From: Matthew Lemke

12/12/24 @ 11:52 AM

My name is Matthew Lemke and I am writing on behalf of the City of Fergus Falls to provide comments on the Minnesota Pollution Control Agency's ("MPCA") proposed PFAS in biosolids strategy. The City of Fergus Falls is an owner and operator of a waste...↓water treatment facility with authorization to land apply our biosolids. Our biosolids are heavily regulated by EPA and MPCA and the land application of those biosolids is safe and environmentally beneficial. The City of Fergus Falls supports efforts to identify, reduce, and eliminate sources of PFAS to POTWs, but we are concerned that MPCA's proposed strategy is moving faster than what is currently allowed for by law and supported by final risk assessment data. However, as a local government entity, we also recognize that PFAS presents an important problem that needs to be strategically addressed in manner that prioritizes public health without imposing undue burdens on municipal wastewater treatment facilities. As a result, we recommend the following key changes to the proposed biosolids strategy:

• Changing the sample period for PFOS and PFOA data. Fergus Falls WWTP has limited storage capacity and having to wait at least two to four weeks before land applying is too restrictive and does not work in our overall operation of the facility. The current proposal would make us have to find additional storage for at least six weeks before being able to pump over additional treated biosolids to our reservoir as to keep the current representative sample. The new PFOS / PFOA sample requirement of waiting on results will not work in the overall operation of our biosolids program.

• The levels of PFOA and PFOS for the four tiers should be adjusted as follows: Tier 1 (≤ 20 µg/kg), Tier 2 (21-50 µg/kg), Tier 3 (51-125 µg/kg), and Tier 4 (≥ 125 µg/kg). We believe this slight adjustment will provide some additional flexibility and certainty—especially for those facilities that find themselves in tiers 1 and 2.

• The ban on land application of biosolids in the tier 4 category should be adjusted to a ban on new application sites only--with the potential to include additional requirements such as reduced application rates, and/or other risk mitigation strategies. A land application ban in the tier 4 category is premature both legally and scientifically without risk assessment data demonstrating that such an approach is necessary to protect human health. Outright bans on the land application or other beneficial reuse of biosolids—like what was enacted in Maine—have proven to be disastrous. The only exception to this should be in the unlikely event that the MPCA identifies, on a case-by-case basis, PFOA or PFOS in such high levels that there is an immediate and substantial threat to public health.

• MPCA's proposal to require a reduced application rate of 1.5 dry tons/acre in the tier 3 category is too rigid and it is not tied to any data demonstrating that it is necessary to protect human health. This reduced application rate is used in both the Wisconsin and Michigan strategies, but it is arbitrary and not based on risk assessment data for protecting human health and the environment and could cause significant problems for POTWs and farmers. To address these concerns, we suggest using a stated range from 1.5 to 3.5 dry/tons per acre and keeping the existing "or an alternative risk mitigation strategy."
• The strategy should be voluntary, unless PFAS biosolids sampling indicates that there is immediate threat to public health on a case-by-case basis.

• To the extent available under law, MPCA should provide participants in the strategy liability assurances from future MPCA enforcement action related to the land application of biosolids.

No attachments

Comment From: Jill Wolf

12/12/24 @ 9:47 AM

Please see attached letter.

Attachments:

Download

Comment From: CHRIS EVANS

12/12/24 @ 8:09 AM

Attachments:

Download

Comment From: Carl Sonnenberg

12/11/24 @ 8:04 PM

My name is Carl Sonnenberg and I am writing on behalf of the City of Waseca to provide comments on the Minnesota Pollution Control Agency's ("MPCA") proposed PFAS in biosolids strategy. The City of Waseca is an owner and operator of a wastewater trea...↓tment facility with authorization to land apply our biosolids. Our biosolids are heavily regulated by EPA and MPCA and the land application of those biosolids is safe and environmentally beneficial. The City of Waseca supports efforts to identify, reduce, and eliminate sources of PFAS to POTWs, but we are concerned that MPCA's proposed strategy is moving faster than what is currently allowed for by law and supported by final risk assessment data. However, as a local government entity, we also recognize that PFAS presents an important problem that needs to be strategically addressed in manner that prioritizes public health without imposing undue burdens on municipal wastewater treatment facilities. As a result, we recommend the following key changes to the proposed biosolids strategy:

- The levels of PFOA and PFOS for the four tiers should be adjusted as follows: Tier 1 (≤ 20 µg/kg), Tier 2 (21-50 µg/kg), Tier 3 (51-125 µg/kg), and Tier 4 (≥ 125 µg/kg). We believe this slight adjustment will provide some additional flexibility and certainty—especially for those facilities that find themselves in tiers 1 and 2.

- The ban on land application of biosolids in the tier 4 category should be adjusted to a ban on new application sites only--with the potential to include additional requirements such as reduced application rates, and/or other risk mitigation strategies. A land application ban in the tier 4 category is premature both legally and scientifically without risk assessment data demonstrating that such an approach is necessary to protect human health. Outright bans on the land application or other beneficial reuse of biosolids—like what was enacted in Maine—have proven to be disastrous. The only exception to this should be in the unlikely event that the MPCA identifies, on a case-by-case basis, PFOA or PFOS in such high levels that there is an immediate and substantial threat to public health.

- MPCA's proposal to require a reduced application rate of 1.5 dry tons/acre in the tier 3 category is too rigid and it is not tied to any data demonstrating that it is necessary to protect human health. This reduced application rate is used in both the Wisconsin and Michigan strategies, but it is arbitrary and not based on risk assessment data for protecting human health and the environment and could cause significant problems for POTWs and farmers. To address these concerns, we suggest using a stated range from 1.5 to 3.5 dry/tons per acre and keeping the existing "or an alternative risk mitigation strategy."

- The strategy should be voluntary, unless PFAS biosolids sampling indicates that there is immediate threat to public health on a case-by-case basis.

- To the extent available under law, MPCA should provide participants in the strategy liability assurances from future MPCA enforcement action related to the land application of biosolids.

Thank you for your consideration to the above concerns and recommendations.

No attachments

Comment From: Robert Bredeson

12/11/24 @ 5:51 PM

See uploaded file

Attachments:

Download

Comment From: Daniel Marx

12/11/24 @ 5:21 PM

Please accept the attached comments of the Minnesota Environmental Science and Economic Review Board (MESERB).

Thank you for the opportunity to comment.

Attachments:

Download

Comment From: Aaron Luckstein

12/11/24 @ 4:57 PM

Attachments:

Download

Comment From: Elizabeth Wefel

12/11/24 @ 4:07 PM

Attached please find the joint comments of the Coalition of Greater Minnesota Cities and the League of Minnesota Cities.

Attachments:

Download

Comment From: Bruce MacLeod

12/11/24 @ 4:01 PM

Please see the comments in the attached file.

Attachments:

Download

Comment From: Shane Wohlman

12/11/24 @ 10:26 AM

Attachments:

Download

Comment From: Paula Trenda

12/11/24 @ 10:13 AM

My name is Paula Even Trenda and I am writing on behalf of the City of West Concord to provide comments on the Minnesota Pollution Control Agency's ("MPCA") proposed PFAS in biosolids strategy. The City of West Concord is an owner and operator of a w...↓astewater treatment facility with authorization to land apply our biosolids. Our biosolids are heavily regulated by EPA and MPCA and the land application of those biosolids is safe and environmentally beneficial. The City supports efforts to identify, reduce, and eliminate sources of PFAS to POTWs, but we are concerned that MPCA's proposed strategy is moving faster than what is currently allowed for by law and supported by final risk assessment data. However, as a local government entity, we also recognize that PFAS presents an important problem that needs to be strategically addressed in manner that prioritizes public health without imposing undue burdens on municipal wastewater treatment facilities. As a result, we recommend the following key changes to the proposed biosolids strategy:
• The levels of PFOA and PFOS for the four tiers should be adjusted as follows: Tier 1 (≤ 20 µg/kg), Tier 2 (21-50 µg/kg), Tier 3 (51-125 µg/kg), and Tier 4 (≥ 125 µg/kg). We believe this slight adjustment will provide some additional flexibility and certainty—especially for those facilities that find themselves in tiers 1 and 2.
• The ban on land application of biosolids in the tier 4 category should be adjusted to a ban on new application sites only--with the potential to include additional requirements such as reduced application rates, and/or other risk mitigation strategies. A land application ban in the tier 4 category is premature both legally and scientifically without risk assessment data demonstrating that such an approach is necessary to protect human health. Outright bans on the land application or other beneficial reuse of biosolids—like what was enacted in Maine—have proven to be disastrous. The only exception to this should be in the unlikely event that the MPCA identifies, on a case-by-case basis, PFOA or PFOS in such high levels that there is an immediate and substantial threat to public health.
• MPCA's proposal to require a reduced application rate of 1.5 dry tons/acre in the tier 3 category is too rigid and it is not tied to any data demonstrating that it is necessary to protect human health. This reduced application rate is used in both the Wisconsin and Michigan strategies, but it is arbitrary and not based on risk assessment data for protecting human health and the environment and could cause significant problems for POTWs and farmers. To address these concerns, we suggest using a stated range from 1.5 to 3.5 dry/tons per acre and keeping the existing "or an alternative risk mitigation strategy."
• The strategy should be voluntary, unless PFAS biosolids sampling indicates that there is immediate threat to public health on a case-by-case basis.
• To the extent available under law, MPCA should provide participants in the strategy liability assurances from future MPCA enforcement action related to the land application of biosolids.

No attachments

Comment From: Allan Fox

12/11/24 @ 10:06 AM

Comments uploaded.

Attachments:

Download

Comment From: Sara Sietsema

12/10/24 @ 10:11 PM

Attachments:

Download

Comment From: City of Windom

12/10/24 @ 4:55 PM

Attachments:

Download

Comment From: Matt Streit

12/10/24 @ 3:51 PM

Attachments:

Download

Comment From: Glenn Bauer

12/10/24 @ 3:25 PM

Attachments:

Download

Comment From: Emma Larson

12/10/24 @ 2:50 PM

The City of St. Cloud (City) appreciates Minnesota Pollution Control Agency's (MPCA) engagement with stakeholders prior to the release of the Draft Minnesota Biosolids PFAS Strategy for Land Application and through the review process prior to publica...↓tion. The City attended the informational meeting, held on November 21, 2024, and has reviewed the Strategy and fact sheet documents. The City recognizes that this draft strategy will be impactful to the successful land application program that has been in place for many decades and, as a result, has provided the following comments.
1. General Comments
The City acknowledges the need for addressing PFAS contamination in biosolids. The introduction of a tiered compliance structure allows for facilities with highly impacted product to make improvements and gain reduced application restrictions. The advancement of source identification and reduction work will likely lead to these gains. This City is supportive overall with the proposed tiered structure.
The Strategy requires alternative management of biosolids that are determined to be industrially impacted. With limited biosolids storage available, the inability to land apply product cannot be sustained for long periods without having an alternate destruction or disposal method. The City would encourage the MPCA to develop a list of alternative management strategies for facilities to utilize should the biosolids product be determined to be industrially impacted.
The Strategy indicates that detailed sample collection requirements will be provided to WWTFs. The City would appreciate the opportunity to review and provide comment on the detailed sampling plan once drafted.
2. Sampling Frequency
The Strategy details that any WWTF that land applies biosolids in Minnesota must collect at least one biosolids sample and analyze it for PFAS in each year that they intend to land apply, prior to land application.
The Strategy does not provide enough detail related to sampling frequency. As written, the Strategy could be interpreted that a single, representative sample is all that is required. The MPCA Land Application of Biosolids Manual establishes a minimum sampling frequency based on the annual biosolids production rate with a stipulation that an enhanced monitoring schedule is required if metals concentrations exceed 50% of the defined ceiling concentrations. The Strategy does not give clear indication if the required number of PFAS samples follows the same tiered structure that is defined for routine biosolids monitoring. The Strategy also does not define if an enhanced monitoring schedule would be required if a certain PFAS concentration was exceeded or perhaps if the results placed the facility in a specific tier. The City requests clarification on these points.
3. Data Management
The Strategy does not provide detail on how sampling data is going to be managed for compliance purposes. Using one sampling event to represent multiple storage cells, over two hauling seasons, could be problematic. Subsampling from individual cells and compositing into a single sample could result in the entire product being placed in a higher tier when only one cell may have elevated results. The City requests that the final Strategy details what compliance mechanism would be in place if a facility decides to analyze one sample from each cell. Please consider including if each cell's data set would be treated individually, which is consistent with the routine monitoring requirements in the MPCA Land Application of Biosolids Manual, or if an average could be calculated, using available results, and reported to determine compliance.

4. Results Notifications – Tiers 2 and 3
The Strategy outlines specific actions that are required in each Tier. Within Tier 4, the first action listed is that 'The WWTF must notify the MPCA and the landowner and farmer (if different than the landowner) within 24 hours of receiving the test results'. The Strategy has made it clear that land application cannot be completed without having received and reviewed the representative sampling results. The City questions why 24 hour notification would be required for product that would not have been land applied yet. This aggressive timeline would be hard to complete for several reasons. The first reason being that staff may not see the results come in, either by mail or email, within 24 hours of receipt. The second reason being that there are times, especially during the fall application season, that facilities may not have the field schedule completed that early as it is variable with crops being harvested. Contacting the landowners and farmers within 24 hours would not be feasible. The City would encourage updating the 24 hour notification requirement, as currently listed in Tier 3, to have notifications be completed within 10 days, as currently outlined in Tier 2.
Within Tier 2, the first action listed is that 'Prior to land application, the WWTF must provide the PFAS analytical results to the landowner and farmer (if different than the landowner) within 10 days.' It is unclear whether the 10 days is from the receipt of sample results or if it is 10 days before the anticipated start of land application. The City requests clarification.
5. Monitoring Timeline Feasibility
The Strategy details that sampling results must be received prior to land application. This requirement may prove to be challenging for facilities. The Spring hauling season is often fast paced, with farmers anxious to plant crops ahead of insurance deadlines. Suspending application while waiting for results could lead to farmers declining to wait for product and facilities with product that cannot be recycled. This would be especially challenging if the required number of samples follows the minimum number of sampling events as defined in the MPCA Land Application of Biosolids Manual.

Attachments:

Download

Comment From: Len Taylor

12/10/24 @ 11:55 AM

Attachments:

Download

Comment From: Lori Olinger

12/09/24 @ 8:49 PM

Comments are attached.

Attachments:

Download

Comment From: Andrew Fischer

12/09/24 @ 4:46 PM

My name is Andrew Fischer and I am writing on behalf of the City of Owatonna to provide comments on the Minnesota Pollution Control Agency's ("MPCA") proposed PFAS in biosolids strategy. The City of Owatonna is an owner and operator of a wastewater t...↓reatment facility with authorization to land apply our biosolids. Our biosolids are heavily regulated by EPA and MPCA and the land application of those biosolids is safe and environmentally beneficial. The City of Owatonna supports efforts to identify, reduce, and eliminate sources of PFAS to POTWs, but we are concerned that MPCA's proposed strategy is moving faster than what is currently allowed for by law and supported by final risk assessment data. However, as a local government entity, we also recognize that PFAS presents an important problem that needs to be strategically addressed in manner that prioritizes public health without imposing undue burdens on municipal wastewater treatment facilities. As a result, we recommend the following key changes to the proposed biosolids strategy:

The levels of PFOA and PFOS for the four tiers should be adjusted as follows: Tier 1 (≤ 20 µg/kg), Tier 2 (21-50 µg/kg), Tier 3 (51-125 µg/kg), and Tier 4 (≥ 125 µg/kg). We believe this slight adjustment will provide some additional flexibility and certainty—especially for those facilities that find themselves in tiers 1 and 2.

The ban on land application of biosolids in the tier 4 category should be adjusted to a ban on new application sites only--with the potential to include additional requirements such as reduced application rates, and/or other risk mitigation strategies. A land application ban in the tier 4 category is premature both legally and scientifically without risk assessment data demonstrating that such an approach is necessary to protect human health. Outright bans on the land application or other beneficial reuse of biosolids—like what was enacted in Maine—have proven to be disastrous. The only exception to this should be in the unlikely event that the MPCA identifies, on a case-by-case basis, PFOA or PFOS in such high levels that there is an immediate and substantial threat to public health.

MPCA's proposal to require a reduced application rate of 1.5 dry tons/acre in the tier 3 category is too rigid and it is not tied to any data demonstrating that it is necessary to protect human health. This reduced application rate is used in both the Wisconsin and Michigan strategies, but it is arbitrary and not based on risk assessment data for protecting human health and the environment and could cause significant problems for POTWs and farmers. To address these concerns, we suggest using a stated range from 1.5 to 3.5 dry/tons per acre and keeping the existing "or an alternative risk mitigation strategy."

The strategy should be voluntary, unless PFAS biosolids sampling indicates that there is immediate threat to public health on a case-by-case basis.

To the extent available under law, MPCA should provide participants in the strategy liability assurances from future MPCA enforcement action related to the land application of biosolids.

No attachments

Comment From: Jeremy Hutchens

12/09/24 @ 3:30 PM

Attachments:

Download

Comment From: Steve Bot

12/09/24 @ 3:14 PM

My name is Steve Bot and I am writing on behalf of the City of St. Michael to provide comments on the Minnesota Pollution Control Agency's ("MPCA") proposed PFAS in biosolids strategy. The City of St. Michael is an owner and operator of a wastewater ...↓treatment facility with authorization to land apply our biosolids. Our biosolids are heavily regulated by EPA and MPCA and the land application of those biosolids is safe and environmentally beneficial. The City of St. Michael supports efforts to identify, reduce, and eliminate sources of PFAS to POTWs, but we are concerned that MPCA's proposed strategy is moving faster than what is currently allowed for by law and supported by final risk assessment data. However, as a local government entity, we also recognize that PFAS presents an important problem that needs to be strategically addressed in manner that prioritizes public health without imposing undue burdens on municipal wastewater treatment facilities. As a result, we recommend the following key changes to the proposed biosolids strategy:

• The levels of PFOA and PFOS for the four tiers should be adjusted as follows: Tier 1 (≤ 20 µg/kg), Tier 2 (21-50 µg/kg), Tier 3 (51-125 µg/kg), and Tier 4 (≥ 125 µg/kg). We believe this slight adjustment will provide some additional flexibility and certainty—especially for those facilities that find themselves in tiers 1 and 2.

• The ban on land application of biosolids in the tier 4 category should be adjusted to a ban on new application sites only--with the potential to include additional requirements such as reduced application rates, and/or other risk mitigation strategies. A land application ban in the tier 4 category is premature both legally and scientifically without risk assessment data demonstrating that such an approach is necessary to protect human health. Outright bans on the land application or other beneficial reuse of biosolids—like what was enacted in Maine—have proven to be disastrous. The only exception to this should be in the unlikely event that the MPCA identifies, on a case-by-case basis, PFOA or PFOS in such high levels that there is an immediate and substantial threat to public health.

• MPCA's proposal to require a reduced application rate of 1.5 dry tons/acre in the tier 3 category is too rigid and it is not tied to any data demonstrating that it is necessary to protect human health. This reduced application rate is used in both the Wisconsin and Michigan strategies, but it is arbitrary and not based on risk assessment data for protecting human health and the environment and could cause significant problems for POTWs and farmers. To address these concerns, we suggest using a stated range from 1.5 to 3.5 dry/tons per acre and keeping the existing "or an alternative risk mitigation strategy."

• The strategy should be voluntary, unless PFAS biosolids sampling indicates that there is immediate threat to public health on a case-by-case basis.

• To the extent available under law, MPCA should provide participants in the strategy liability assurances from future MPCA enforcement action related to the land application of biosolids.

No attachments

Comment From: Foster Transburg

12/09/24 @ 2:38 PM

Attachments:

Download

Comment From: Valerie Neppl

12/09/24 @ 11:32 AM

Please see attached file with comments from Dakota County staff.

Attachments:

Download

Comment From: Kay Slarna

12/02/24 @ 8:23 AM

I mostly like what you propose, but I'm concerned that it doesn't go far enough. I would add that you limit untested industrial inputs to municipal waste. And if your lab tests only look for a couple PFAS, I think you should do frequent but cheaper ...↓

No attachments

Comment From: Kathryn Iverson

11/26/24 @ 12:59 PM

Thank you taking the time to read my comments. First, I never realized that biosolids from wastewater were being used as fertilizer for croplands. I applaud the MN legislature for addressing this critical issue. The strategy being developed for bios...↓

No attachments

Comment From: Carolina Fernandez Branson

11/26/24 @ 12:04 PM

Please require testing of biosolids for PFAS before using them for fertilizer. We are living in an increasingly polluted environment and young people, including children, are suffering the most. Please stop the pollution of our food supply and help u...↓

No attachments

Comment From: David Schiltz

11/22/24 @ 2:46 PM

1.Will the MPCA consider an extension of the implementation of the Interim Biosolids Strategy if a facility is found to have high levels of PFOS in the biosolids and is working on source identification and reduction?

2. After implementation of the B...↓

No attachments

Comment From: Kevin Shea

11/13/24 @ 10:55 AM

How does the sampling cycle effect larger land application programs that apply all the time? It appears the strategy was written with the idea of using a batch system that you would hold biosolids and wait for a sample result. Do we take a sample a...↓

No attachments

Comment From: Justin Femrite

11/13/24 @ 7:07 AM

We are also for protecting the environment and doing the right thing. The "right thing" in this case is to comply with Federal law relating to regulation. Extending beyond it just continues an approach that is ever more costly on all Minnesotans. ...↓

No attachments

Comment From: Jerry Vogt

11/12/24 @ 3:34 PM

I'm concerned about the cost and turnaround time for the test results. To sample for the application of biosolids for the next crop year, we need to sample after September 1. This year we started application on September 26. Right now the MPCA is hav...↓

No attachments