On Wednesday the North Star Chapter and its supporters testified at a public hearing on the proposed Environmental Quality Board changes to rules regulating greenhouse gas emissions. The Environmental Quality Board is proposing an amendment to set the threshold for requiring an environmental assessment worksheet (EAW) at 100,000 metric tons of carbon dioxide, which is too high to capture the vast majority of new polluters in the state. By EQB’s own analysis, only 100 existing sources of greenhouse gases in Minnesota meet that threshold. If an amendment is not added, the existing threshold of 250 tons per year will be applied to greenhouse gas emissions.Background
Minnesota aims to reduce overall greenhouse gas (GHG) emissions that contribute to climate change by 80% below 2005 levels by 2050 to avoid dangerous climate change. To do this, we need new sources of emissions to complete an environmental assessment worksheet (EAW) to ensure they are reasonably mitigating their carbon footprint. The EAW is a six-page questionnaire about a project’s environmental setting, the potential for environmental harm and plans to reduce the harm. This worksheet is important to help project proponents think through how they can minimize their impact on the environment and provide an opportunity for citizens to know the impacts projects will have in their communities.
It would be reasonable to leave the rule unchanged, in recognition that carbon dioxide or equivalent greenhouse gases are “pollutants” under federal and state law. If a higher trigger than the current 250 tons per year were desired to focus public attention and resources on the very real task of reducing greenhouse gas emissions by the goals set in 2007, we suggest taking a cue from the Minnesota Pollution Control Agency’s GHG reporting requirements that require sources of 10,000 metric tons of CO2 equivalent to report as a workable solution.
More than 30 people showed up at the hearing before an administrative law judge to ask the Environmental Quality Board to set the threshold for greenhouse gases that would trigger an environmental assessment worksheet at a much lower level than the proposed 100,000 tons — some proposed maintaining the existing 250 ton limit, most argued for 10,000 tons, and MCEA suggested 25,000 tons may achieve the goal of reaching more than 90% of greenhouse gas emissions while limiting new projects asked to complete the review to a small handful. No one, except the Environmental Quality Board and Minnesota Pollution Control Agency staff, testified in support of the 100,000 ton threshold. In addition to the seemingly arbitrary and extreme increase to the threshold, several parties, including the Sierra Club, raised concerns about the lack of science and environmental impact that went into the rationale for this change in the rules.
- Paula Maccabee, former city council person and lawyer who has represented project developers, argued that EQB’s argument that it was following guidance from the EPA tailoring rule in establishing the 100,000 ton threshold failed to distinguish between permitting and environmental review. Environmental review is an opportunity for communities and developers to discuss a project before it is built and design it in a way that benefits all parties.
- Dick Ottman, a retired engineer who worked on pollution control technologies, testified in support of a threshold of 10,000 tons because it benefits the project by getting the engineers in the room talking to one another about how to design a better project.
- Boise Jones, representing environmental justice groups in the metro area, thought the Environmental Quality Board’s proposal threatens progress the state has made to reduce greenhouse gas emissions.
- Christopher Childs, an author and long time volunteer, asked “what is the difference between me and a climate skeptic? They hope I’m wrong and I hope they’re right. I don’t want to be right about the predictions science makes about global warming – more floods, more fires, displacement and death of hundreds of thousands of people. Climate change is a very real threat that we are facing and we cannot pass on our responsibilities to do something about it.” He supported maintaining the level of 250 tons.
- Amy Blumenshine, a Lutheran and mother, talked about rebuilding her house to Green Star standards and learning ways she could reduce her impact on the environment and the benefits she didn’t even know about before she started.
- Two youth who had been to Cancun, Mexico to participate in the international negotiations on climate talked about the real, immediate impact climate change was having around the world, and the role Minnesota has played as a leader and should continue to play, but cautioned: actions speak much louder than words. The state has a commitment to drastically reduce greenhouse gas emissions from 2005 levels, environmental review of new large sources of these emissions which move us in the wrong direction is an important opportunity for us to look at how to reduce pollution and give citizens a voice in the future of their community, state, and planet.
Despite the rhetoric of global warming skeptics, a majority of the public are concerned with climate change. Minnesota’s citizens play a critical role in helping the state meet its goals to drastically reduce its carbon footprint. The North Star Chapter sees the mandatory environmental assessment worksheet as an opportunity to engage projects before they are built in identifying ways they can achieve lower energy bills and a smaller carbon footprint – good for the bottom line, Minnesota’s greenhouse gas reduction goals and the planet.
Comments on the EQB’s proposal are due by Tuesday, March 29th at 4:30pm. You can email comments to firstname.lastname@example.org. In your comments, you need to note you are responding to “Proposed rule amendment regarding Minn. R. 4410.4300, subp. 15” To read the proposal, visit the EQB’s website. To get involved with the North Star Chapter and see how you can help push for better emissions standards contact Jessica Tatro at the North Star Chapter or sign up as a volunteer online!