Met Council Wastewater Treatment Plant (St. Paul) - Environmental Assessment Worksheet

My comments come from the perspective of a community member who has lived near the Metro plant my whole life. I am concerned about all the sources of pollution and contamination that are competing with our healthy air, soil and water and I'm afraid t...↓hey will dominate if projects like this are not described and impacts on them accurately measured. While the construction of the fourth incinerator at the Metro Plant has merits which are described in the EAW, it is not complete

I've lived in the area and been exposed to the human progress and folly in this are most of my life. The early years in my parent's home and in my elementary school were spent 5.25 miles southwest of the Metro Plant, as the crow flies. Now, for more than 30 years, I have lived 2.5 west of it. However, some of my neighbors live less than a mile from it, less than 5,000 feet due west, just west of Southport industrial area.

The EAW has not fully considered the residents who live close by, in the West Side neighborhood, and the impact the current and future development at the Metro Plant will have on them and their quality of life. There is a significant amount of St. Paulites who live between 4,700 feet and a mile west of the plant. Yet in multiple parts of the EAW, these residential areas are not described or considered. South St Paul neighbors live less than a mile from the plan, but they are not considered either.

Sacred Sites

Well known sites sacred to the indigenous Dakota people are not mentioned, including the burial mounds at Indian Mounds Regional Park and Wakan Tipi (aka Carver's) cave in Bruce Vento Nature Sanctuary. The historic village of the Kaposia Dakota was just north of the Metro Plant. After they were removed west of the Mississippi, the Kaposia village was within a mile of the plant. Riverview Cemetery is on the hill overlooking the river valley just over a mile from the plant, but it is not mentioned.

Land Use

The most this worksheet mentions these residents is in the following statement, "On the western bank of the Mississippi River, the land use is a combination of industrial uses, parkland, residential, and the Saint Paul Airport approximately one mile away." That is not enough and I ask that people living on the West Side be seriously considered.

Air quality

Another example is air quality. The general statement, "Based on the air dispersion modeling and cumulative impact analysis for the Project, the Metro Plant will comply with the applicable air quality standards and is not expected to contribute to an adverse cumulative potential air quality effect" is just not enough.

Noise

Without further study about noise impact this EAW is not complete. Despite what I've described above the worksheet states, "the Metro Plant is in a zone designated for industrial use and is not near residential properties." I disagree.

Comment Regarding: Metropolitan Wastewater Treatment Plant Solids Management Improvements Project Environmental Assessment (EA)

I am concerned about the proposal to expand the Metropolitan Wastewater Treatment Plant Solids Management Improvements Proj...↓ect (MWTP) which is in an incredibly wrong location to begin with. This plant is mere feet from Pigs Eye Lake, the Mississippi River, Mississippi National River and Recreation Area, and many other public parklands, as well as being adjacent to multiple environmental justice communities of Saint Paul, including multiple neighborhoods with a majority BIPOC, low-income, and renter populations.

Permit decisions and the siting of polluting facilities was not considering equity or justice when this plant was originally constructed in 1938. Even in 2005, when the solids management building (SMB) was constructed, and the facility was expanded, important science and statistics regarding the health and well-being of local communities was not taken into consideration. Today we must do better.

What are the reasons that increasing capacity at this site is the best course of action? Were alternative facilities within the metropolitan area considered for modernization and why or why not?

When multiple sources of pollution and other destabilizing factors are in the same place, the added pollution of each facility leads to more negative impacts on the health and environment of the community. Polluters have treated certain communities as "sacrifice zones" for decades, purposefully polluting those communities instead of others. This has created and contributed to a number of disparities in health, environment, quality of life, and economic stability.

Cumulative Impacts

Minnesota should ensure that the cumulative effects of pollution are incorporated into environmental permitting. This will ensure that Minnesota's regulatory process cannot continue forcing pollution on overburdened communities. The Minnesota Pollution Control Agency (MPCA) should deny permits for facilities that are causing or contributing to a substantial adverse impact to the health or environment of an environmental justice area unless a community benefit agreement is developed.

The Cumulative Impact Assessment provided with this EAW indicated that pollutants of concern were below the National Ambient Air Quality Standards threshold, but this is not a complete story – it is well known that for human health no amount of toxins are ok. Any increase in a community that is already being impacted by existing pollutants should not be allowed.

I am requesting that the responsible agencies hold a public meeting on the cumulative impact analysis. This is to promote the informed participation of impacted communities and to ensure that the cumulative impact analysis can be effectively enforced. This should be done in conjunction with the EIS analysis.

PFAS

There is not adequate research available about the transmission of PFAS into the air during the incineration of waste or wastewater containing PFAS. The MWTP is listed as a likely source of PFAS and is on the MPCA list of PFAS monitoring sites. The EAW does not describe in detail the MPCA's plan for monitoring PFAS either in water discharge or air emissions. This fact alone requires a hard look and further analysis before any permitting can move forward. I am requesting that an EIS is done for this project.

Minnesota's Environment

I am also concerned about the local natural public lands within this location, the endangered Rusty Patched Bumble Bee and other species of special concern that are found in close proximity to this project. I am concerned with additional pollution affecting the waters of the Mississippi River, Pig's Eye Lake and the many creeks and wetlands in this location.

It appears that a Rusty Patched Bumble Bee ground survey has not been done in this area for close to 10 years. It is imperative that up-to-date wildlife and plant life species of concern surveys be done – for which an EIS would allow the opportunity to do.

In conclusion, thank you for the opportunity to comment on this EA, and I appreciate consideration for my concerns. I request that the Minnesota Pollution Control Agency require an EIS as the next step in this process – with comprehensive analysis of the impacts to communities and the environment using the best available science. This must include community meetings and a transparent public involvement process.

Thank you,

Lois Norrgard

The facility is adjacent to multiple environmental justice communities of Saint Paul, including multiple neighborhoods with a majority BIPOC, low-income, and renter populations. The Cumulative Impact Assessment provided within the EAW showed that pol...↓lutants of concern were below National Ambient Air Quality Standards threshold, however this does not mean they are incapable from causing harm. According to any toxicologist there is no "healthy" or truly 'neutral' amount of toxins that can be processed through the body, so any addition of pollutants is accumulating effects regardless of those standards. More simply, if you asked any individual, which would you prefer in your neighborhood: Zero additions of pollutants; or pollutants below the National Ambient Air Quality Standard threshold, most would most certainly choose the former because these two options are not the same. I hope efforts are made to hold a public meeting with the potentially impacted communities to explain more thoroughly the cumulative impacts analysis, reason for location vs non ej communities, and clearer analysis of the potential to spread PFAS, and why development would move forward if there is still no clear answers around this issue or ways to mitigate from PFAS harm.

Tom Dimond

2119 Skyway Drive

Saint Paul, MN 55119

As a neighbor of the Pig's Eye Waste Treatment Plant. I have served in numerous roles including Saint Paul City Council, Planning Commission, and MNRRA Commissioner. The Met Council has a responsibilit...↓y to address negative impacts to our BIPOC majority neighborhoods. MCES's past and proposed waste burning along with pollutant discharges into wetlands and aquifer have negative consequences that affect people, wildlife, the water we drink and air we breathe.

Saint Paul and Ramsey County have called for the Met Council to transfer 80 acres east of the Waste Treatment Plant to the Regional Park System. The Met Council has expressed their support of managing the 80 acres as Regional Park. The MWCC told Saint Paul they were willing to transfer 80 acres to Saint Paul's Pig's Eye Lake Regional Park. The Met Council assured the public the ash ponds would be cleaned up. The public was led to believe the polluted ash pits and 80 acres would be cleaned up and managed as the valued habitat and recreational opportunities the Pig's Eye Lake Park Plans envision.

The Metropolitan Council should transfer the land outside the berm for use as Regional Parkland. The highest and best use. The Regional Park System and residents of BIPOC majority neighborhoods would benefit from management of the flood plain forest as part of the Regional Park. This flood plain forest should be managed as part of Pig's Eye Lake Regional Park. The flood plain is of Regional Significance and part of St. Paul's Great River Passage plan. The area is a National Park, State Critical Area and State Scientific and Natural Area.

Pig's Eye Lake was created by glaciers prior to the existence of the Mississippi River in Saint Paul. It is a significant geological, wildlife habitat, and recreational treasure. Pig's Eye Park Planning began before any of us was born. The Met Council approved the 1975 Regional Recreation and Open Space Plan for Saint Paul. The Plan is a Regional Park complex including Indian Mounds Park, Battle Creek Park, and Pig's Eye Lake Park. In 1975, the Metropolitan Council received a Pig's Eye Park Reserve Master Plan from Ramsey County. The plan called for picnicking along the river shore, boating in the lake, access to the river, and protection of the heron rookery. The Met Council approved the plans. Pig's Eye Lake Park Plan implementation is overdue. Our neighborhood, the region, and State deserve better. We deserve better opportunities to enjoy what the Park has to offer when access is enhanced, pollution removed, and habitat restored.

In the 1980 Critical Area Plan review the Met Council approved removal of 278 acres from the park plan. Saint Paul called for the 80 acres east of the levee to be included in the park and ash pit area restored. After decades of waiting, it is time to act and include the land outside the berm in the park.

The State Critical Area designation calls for parkland next to treatment plants. The area is classified as parkland.

The BIPOC majority neighborhoods around Pig's Eye Lake Park have waited 43 years for the Met Council to implement an agreement with the City or County so recreational use and natural resource restoration can move forward on 80 acres of public land outside of the berm. An agreement should be in place prior to any discussion about possible expansion with adding another burner.

The Met Council should support removal of the ash pit berms built with pollutant, removal of the pollutant that soaked into the ground, and restoration of wetland. The public has waited too long to enjoy the amazing potential of this park as illustrated in the Great River Passage Plan.

PFAS is only one of the toxic pollutants that should be a focus of the cleanup at Pig's Eye. The waste treatment plant was supposed to protect us from pollutant. Instead it operated for years with pipes that dumped toxic pollutant into our aquifer. We can get angry or we can do something to correct the mistakes of the past.

I appreciate and support comments submitted by Saint Paul Councilmember Jane Prince, and Ramsey County Commissioners Rafael Ortega and Mia Chong Xiong.

The Metropolitan Council should address the negative impacts to our BIPOC majority neighborhoods impacted by MCES waste burning and wetland pollutant discharge.

Forty three years ago, Saint Paul and Ramsey County called for transfer of 80 acres east o...↓f the Waste Treatment Plant to the Regional Park System. The Metropolitan Council called for an agreement that would manage the area as parkland. The Metropolitan Council assured surrounding neighborhoods the ash ponds would be taken care of. How can the public trust new Met Council assurances with a record of 43 years of inaction regarding cleanup of polluted ash pits and 80 acres of public open space?

The Metropolitan Council should transfer 80 acres east of the Waste Treatment Plant to the Regional Park System. The Regional Park System and residents of BIPOC majority neighborhoods would benefit from management of the flood plain forest as part of the Regional Park. This flood plain forest was jointly owned by St. Paul and Minneapolis and should be managed as part of Pig's Eye Lake Regional Park. The flood plain is of Regional Significance and part of Saint Paul's Great River Passage plan. The area is a National Park, State Critical Area and State Scientific and Natural Area.

Planning for Pig's Eye Lake Park started over a century ago. The Metropolitan Council approved the 1975 Regional Recreation and Open Space Plan for Saint Paul. The Plan is a Regional Park complex including Indian Mounds Park, Battle Creek Park, and Pig's Eye Lake Park. The plan called for picnicking on the river shore, boating on the lake, access to the river, and protection of the heron rookery. The Met Council approved the plans.

In the 1980 Critical Area Plan review, the Met Council approved removal of 278 acres from the park plan. Saint Paul called for the 80 acres east of the levee be included in the park and ash pit area restored. The 80 acres serve as partial compensation for parkland loss.

The Metropolitan Council supported an agreement with the City and County for the interim recreational use and landscaping of the 80 acres east of the treatment plant. State Critical Area designation regulations call for parkland next to treatment plants.

The BIPOC majority neighborhoods that surround Pig's Eye have been waiting 43 years for a Met Council agreement with the City or County so recreational use and natural resource restoration can move forward on 80 acres of public land. An agreement should be a priority in any discussion about possible expansion tied to adding another burner.

The Met Council should support City or County efforts to remove the ash pit berms, built with pollutant, and wetland restoration. The public should not wait another 43 years.

Jane Prince

Saint Paul City Councilmember, Ward 7

I am a resident of the Indian Mounds area. My primary concerns are odors and air emissions. Over the years, I and my neighbors have been participants in meetings, giving testimonies, phoning, and writing complaints. I request that you be vigilant ...↓in preventing any odors and air emission problems. Thank you.

SUMMARY: The Metro Wastewater Treatment Plant wastewater sludge incinerators should be modified to capture and "recycle" their anthropogenic AND BIOGENIC CARBON DIOXIDE (CO2), using existing technologies such as those described in my attached public ...↓comments.

I have been working with my state representative, Amanda Hemmingsen-Jaeger, to propose legislation that would fund a front-end engineering and design (FEED) study to evaluate a project that would add CO2 capture and recycling to the St. Paul Metropolitan Waste Treatment Plant incinerators (and/or other waste-to-energy facilities).

Considering the current record global heat wave, air quality alerts from Canadian wildfires, prolonged drought in the Southwest, record flooding in Vermont, etc., Minnesota needs to quickly demonstrate its commitment to significantly reducing the state's CO2 greenhouse gas emissions!

Best regards,

Dale R. Lutz, Ph.D.