Office of Administrative Hearings
P.O. Box 64620
Saint Paul, MN 55164-0620
RE: Docket 80-90030-34519
To whom it may concern:
In 1973, the MPCA enacted a wild rice sulfate standard based on research from the 1940s with the goal of protecting wild rice. Today, nearly 45 years later, new research using modern experimental and analytical techniques has shown that sulfate in and of itself is not harmful to wild rice. Instead, the MPCA suggests that sulfide may have an effect on wild rice. However, instead of using this knowledge to conduct further research to understand how and to what extent sulfide may impact wild rice growth, the MPCA has moved forward with a draft wild rice sulfate standard based on an inaccurate equation to derive a sulfate water quality standard. This rule could financially devastate my community and is not yet proven to protect wild rice.
I believe wild rice is an important crop, and I want to maintain its vitality. However, this proposed standard does not appear to accomplish that. At a March 2017 meeting in Northeast Minnesota, an MPCA official was asked if the new standard and the investments made to comply with the standard would result in more abundant rice and responded that based on the research there may be no benefit to the wild rice species. In fact, according to the Minnesota Cultivated Wild Rice Council, the crop is currently plentiful, and our state is one of the world's largest producers of cultivated wild rice, producing 5-10 million pounds annually. Nonetheless, the MPCA is moving forward with this unnecessary standard.
According to the MPCA, the only viable treatment option to meet the proposed standard is reverse osmosis. Reverse osmosis is costly to install and maintain. If the standard is implemented, many businesses, communities, and families will have to cover the cost. I understand it may increase household sewer and water bills in some communities by nearly five times the current cost. This cost is burdensome and unacceptable given that the proposed standard has not been scientifically proven to protect wild rice.
Our strongest industry in Northeast Minnesota is iron ore mining. For more than 130 years, this industry has worked in collaboration with many of our communities to build and grow the region. The proposed rule is predicted to cost over $1 billion in wastewater infrastructure. This is an investment that could alternatively be made to advance job growth and innovative new projects that will bring the industry to a brighter future. This cost could affect the mines' ability to stay open, and in turn, could affect my job and the health of my community.
The Minnesota State Legislature is aware of these costs and granted the MPCA an extension on publishing the standard in order to complete an economic impact analysis. Instead, the agency chose to publish the rule before completing the study that would inform regulated entities the true cost of implementing the rule.
For these reasons, I respectfully ask that the Administrative Law Judge reject the MPCA's proposed wild rice standard so Minnesotans can work together to find better wild rice conservation efforts.
The Iron Mining Association of Minnesota is asking you to voice your concerns regarding the MPCA's proposed wild rice sulfate standard in order to secure the future of Minnesota's iron mining industry and the communities of Northeast Minnesota.
The proposed standard has not been proven to protect or increase the health of wild rice. Moreover, the proposed standard predicts the wrong outcome up to one in five times. This is unacceptable when the costs of implementation are estimated to be hundreds of millions of dollars. In fact, the proposed rule would cost Minnesota’s iron mining facilities AND Northern Minnesota’s municipal wastewater facilities billions of dollars to comply. This is a cost that could shut the doors for Minnesota’s iron mines and increase municipal water bills exponentially.
Despite knowledge of these potential costs, the MPCA chose to publish their draft rule BEFORE completing an economic impact analysis to determine the true cost of compliance for Northeast Minnesota residents, workers, and businesses. We encourage you to share your concerns with the MPCA that the costs of the proposed wild rice standard are unsustainable for Northeast Minnesota and are not expected to provide a proportional benefit to wild rice.
How can you help? Take action by by speaking out against the MPCA's current proposed wild rice rule.
The comment period for the proposed changes is now open, and comments can be made online, via US mail, or at hearings to be held around the state between now and Nov. 22.
For more information on the background of this proposed standard, click here.
Click here to join the conversation online with the Office of Administrative Hearings by 4:30 p.m. Nov. 22.
Have additional questions about the proposed wild rice sulfate rule?