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Got a last minute notice of the Minnesota Environmental Quality Board’s Environmental Review Improvement Subcommittee meeting, so decided to attend. Here’s my take.


ERIS Members:

  • Sarah Strommen DNR (Chair today)
  • Laura Bishop MPCA
  • DOT (Arrived later) Margaret Anderson Kelliher
  • Alice Roberts-Davis Administration
  • Dan Huff MDH – for Malcolm
  • BOWSER Gerry Van Amberg (Not a Member; listening)
  • And… Citizen Members:
  • Alan Forsberg
  • Kristin Eide-Tollefson
  • Ben Yawakie
  • Bryan Murdoch

Katie Pratt – Still have OPEN CD4 & CD5 positions for Citizen Board membership.

Giuseppe Tumminello presented the ER Data Mgmt Plan & 2019 Performance Report with Thanks to the Tech Reps and MEQB staff.

His Questions: Framework and Metrics – are they meaningful info to make ER better? What would you like to see?

MN Rule 4410.0400 Subpart 1 says MEQB role is monitoring effectiveness  of parts 4410.0200 (definitions) to 4410.6500 (paying EIS costs) and taking appropriate measures to modify and improve their effectiveness.  (Water Quality is in pretty shit shape so… kinda failing.)

My ideas: Citizens have a BUNCH of usable information that your agencies are ignoring… systematic access to decision makers is not really a thing, nor is accountability… Delegating authority needs to be pulled back when RGUs demonstrate regulatory capture… There is no need to reduce delay if it means we will ignore the need to be thorough. And we need to start to reduce uncertainty with the use of REAL SCIENTISTS to review the projects!

My questions: What evaluation was made of WHAT IS WORKING?  HOW ARE YOU understanding the effectiveness? 

Guiseppe’s Data Management Plan Framework and Metrics were reviewed… looking at frequency checks (for ER types, processes by category and RGU, and completeness of citizen petitions), efficiency checks (cost and time for ER and EQB Staff performance) and Transparency (for usable info and citizen participation). [Makes one want to throat punch someone… this last point is just laughable.] But he went on to present some highlights:

  • ER in 2019 was WAY DOWN…far below the number done in any of the previous 4 years… and Almost NO EIS in the last 5 years… [what effect has that had? Did I mention shitty water quality yet?] In fact ALL 2019 environmental reviews were barely more than only the EAWs in 2015 and 2016 and their number was below the EAWs alone for both 2017 & 2018.
  • Reduce delay and uncertainty and duplication was covered with a review of citizen petition completeness and how many needed EAW (not many… never more than 3 in any year and often, only 1).
  • Efficiency over effectiveness seems the rule of the day. The ER Technical Assistance efficiency review showed: 175 calls in 2019.  [Almost NONE!! But we’re looking at how well we did on the calls!!!]  We’re GREAT! 84% of the public says EQB staff was responsive and punctual, 100% agreed that they were courteous and professional, but only 50% strongly agreed they were knowledgeable on the topic. So… nice, on time, but not really full of answers? [Maybe some scientists would help?]
  • Now to Transparency… first Giuseppe quotes MR4410.0300: “A first step in achieving a more harmonious relationship between human activity in the environment is understanding the impact which a proposed project will have on the environment” and he claims “The ER Process led to the public participation that would not have otherwise occurred…” ER Interactive Map shows locations of data received… but docs are Not readily available [uh… so much for transparency??? Seems they are saying, “Public Participation is important!!!  Speak Up!!!”  No promise they will listen though…]
  • New Map NOW in the works!!  Current map to be live in next week or so.

Data Mgmt Plan – adaptable each year!!  We’ll keep doing nothing… and making sure we talk about how we can keep doing nothing… [Yeah. Great.]

Questions: [I got what I could. You can listen to the whole presentation and such here.]

Bryan – what info is available in the map – project info?  G: Monitor info included.  B: Some include links, some don’t.  G: RGU prerogative to share that.  We share if provided. No link?  Pop-up will have responsible RGU name and contact for more info. B: RGUs should have capability to provide that.  Denise: Further explanation… Rule is current – would like more discussion on ERIS to see how we look at expanding how notification requirements are included.

Bryan: EAW world – citizen members want to understand…  Along with current, could there be an available cell with a running record of EAWs that can be sorted/searched based on categories – for reference.  [GOOD SUGGESTION!] G: Exploring ways to do that.

Alan Forsberg Q…   G: Accountability section performance report – pie chart on RGUs doing ER – maybe a majority – are from local govts.  MEQB staff should be reaching out to staff at local RGUs for their experience.

Alan: MEQB measures its performance – what about MPCA, DNR, etc?  Measuring effectiveness of their permits?  Denise: Don’t engage with other agencies on their effectiveness but some monitor their programs.  A: Drawing on many DNR – times when process is counter-productive to what environment is trying to achieve.  SS: ER vs. permitting – often related and intersecting.  Specific to Permitting? Not ER?  Alan: Unrelated question… I apologize.  They relate… overlap – info for ER and permits – there is a relationship.

Ben: Maps and access.  Getting info from EQB monitor – notice methodology between 2015 and 2020… evidence based to improve it? As much info to public as possible? G: Since 2015, a pilot process (CI) to improve data collected and shared.  DMP will be adaptive… will change as this is the first we’re proposing.  Frequency of ER… objective data – won’t change much.  Recommendation in current performance report not yet incorporated.  These are just proposed.  2022 data will be available to share on this…Denise: Data sets gathering… data from subcommittee… 

Kristin: Note the language – I appreciate the language – Public Members – ALL of us as practitioners.  Better framing of inclusive language.  Earlier Q on survey for RGUs … did ER make a difference for environmental quality?  Are we still asking this question?  G: Don’t recall where… one question we are proposing to ask is tied specifically to… going back to objectives – providing usable information.  Not covered today but ID’d in report.  Asking if the process gave usable info not otherwise being collected.  Is value provided?  K: Found it interesting we included it in previous surveys – applies to effectiveness of system.  Consideration I’d appreciate is keeping in mind integrity of the information.  Been in several ER that were delayed, created uncertainty, issues of transparency/accountability as the info was so inaccurate.  Getting accurate info to public is key.  Looking fwd to next steps. G: Consideration is noted.  Did the ER process make a difference for outcome for Env Quality? is the question to include.

My question: How is the data mgmt plan looking at the actual results in the field?  Like how poor our water quality is now in MN?  I’m seeing a check of how the system works as designed, but NOT how the system accurately determines effectiveness in the field. How are you determining how the ER is actually affecting the environment on the ground here in MN?  Denise: When ER doc is prepared, a lot of potential ER are ID’d and how to mitigate.  Fwd looking at projects as proposed and into permitting and other approvals.  Where do you see opportunities for field experience as most of where we touch a project is before construction or implementation?  ME: It really speaks to the question that Kristin was just asking. How are we evaluating how our ER process is working?  Your mission is to determine if the ER process is actually DOING SOMETHING, rather than just filling out paperwork and checking off boxes.  Specifically I look at – and she spoke to the inaccuracy of data –  and we can look at the Line 3 project – huge and very controversial.  We’ve asked over and over to be involved in agency meetings – we know that meetings are happening with Enbridge – we have scientists and retired MEQB (I meant MPCA)/DNR people, health professionals, and citizens like me, abutters to the line, who’d really like to have our voices heard.  I’d really like you to come up to the LaSalle Valley and look at where they want to install this pipeline.  Look at the land and the water levels on the ground.  Trying to understand how the MEQB is finding that THAT SYSTEM is actually working to protect the environment. Especially when we’re seeing many many people living with tainted water quality in MN now.  D: Thinking about opps I’m aware of to make connections.  Think about it further given that perspective.  Come back to the Guiding principles. What is the Purpose and objective and tying it back to the relationship to procedures in 4410 – meant to implement mandates from MEPA… I’d love to talk more on ideas for metrics and where you think that might provide us with meaningful information. 

ME: I’m very interested to hear how you plan to engage the public because I do think that has been a real fall down. We’ve tried going to the MEQB, speaking to the concerns we have about the fact that these decisions are being made potentially by RGUs who don’t have the scientific comprehension to understand the environmental review process and how it affects the environment outside of the project they want to implement and rather than what those real affects are to the environment.  I’d be very interested, esp as the OLA was looking at the MPCA for engagement this year. That project didn’t get selected but there’s definitely a breakdown between people feeling like they are being heard, who live here, and agencies who are making decisions about things they don’t seem to truly understand. That’s my biggest concern. We need some scientific accountability to what’s happening, rather than agencies just meeting ONLY with applicants, who are VERY gung ho about their projects and aren’t going to tell you anything about not wanting to implement them… versus listening to people in the field who are SEEING these changes happening in our state, seeing our water quality degrade, seeing this tremendous ignoring of citizens, including our Indigenous citizens who have spoken very loudly about this project and that gets into federal law.  It’s great that MN has these laws and rules and these ideas but if they are not effective, we need to look at why and how to make them effective.  And this isn’t truly doing that.  It’s looking at the projects we have and looking at the ER we have and it seems another kicking down the road of we’re going to look at how well we’re doing and see how well we’re doing…  instead of looking at WHAT ARE WE DOING, PEOPLE?  WHAT ARE WE TRULY DOING? I’d encourage you to start talking with health professionals and scientists in this state… retired agency officials who absolutely understand some of the problems that we’ve seen with regulatory capture, that create a system where applicants continue to get their projects, our water quality and environmental quality continue to degrade, and the people continue to be ignored.  D: Thank you for those observations, will take this back to the team.  SS: Thanks for the question!

Willis: Ecologist, retired MPCA.  Previous commenter made an excellent point by using Line 3 as an example. Not to get into the weeds with that project but let me point out how ER failed miserably. And MEQB can do significant things to change this.  EIS was 1000s of pages, revised several times… but… only when MPCA received a permit for 401 was it revealed – for the first time – that the company admitted they could not comply with MN Water Quality standards.  If that simple fact was not exposed in the ER documents, of 7000 pages, something was seriously wrong.  The public did not know… and (with No F/U in 401 cert process) still does not know, that this project will violate water quality standards all across this state! And now mitigation is being offered as permits are being approved by other agencies. The horse is out of the barn. Hard to correct now…  AFTER ER SHOULD HAVE EXPOSED THIS issue and then SERIOUS alternatives could have been considered. 

Now to the issue that Kristin raised… over years of participating on MEQB… I’ve consistently suggested that metrics are available that will answer her question.  IS ER MAKING A DIFFERENCE ON THE GROUND?  Curious and frustrated as no data points here drove to that question.  If you don’t, it allows Govt process to proceed bean counting – metaphor of bucket brigade putting out a fire.  Counting buckets, polishing them, storing them properly, but buckets are empty (of ER docs themselves)!  Let’s look at content and that this is Not measuring what proposers want to measure – reducing delay (serves the project proposer) and duplication (no one wants that). People want process to be effective! 

As an ecologist, I can tell you… we’re losing all our birds.  Have an avian apocalypse.  Losing insects.  Apocalyptic outcome – it’s measureable, it’s reportable, and someone is responsible.  We’re losing reptiles, amphibians, wild rice.  I could go on and on… listing on the ground, in the water criteria that tell us the story of how well humans are NOT LIVING in harmony with their environment as MEPA says.  I have offered and I will offer again to sit down with staff and look at meaningful metrics the DNR?MPCA/MDH/MDA accumulates. Metrics that in sum total tell us we have a miserable failure in ER due to no linkage to the ER and our Env losses (plants, insects, wild rice) and losses in human health.  5 connectors in how we: use land, extract resources, distribute invasive species, change the environment, & destroying habitat. If ER CANNOT measure these 5 parameters, why do it??? Those are repeatedly id’d as causes of our apocalyptic conditions in plants, wild life, insects, and human health. We have a Cognitive disconnect between causes of Env deterioration and what we examine in ER.  Please accept our offer of a year ago December – in our listening session with SS & LB attending – by group there. Many of these same points were made, OFFERS were MADE AND NONE have been ACCEPTED..  Not called in back to say WHY these methods work.  Please stop counting buckets you have in the fire brigade and assure that they are full of water and fire is being put out by some meaningful metric.  WILL YOU ACCEPT THE OFFER OF THOSE KINDS OF ASSISTANCE OFFERED by ME AND MY COLLEAGUES REPEATEDLY OVER LAST SEVERAL YEARS? If not, why not? [No REAL Answer… again.  Sorry, Willis.] SS: 2 other comments…  let’s go to that. WRT Last comment – we’ll respond to that…  Kristin have another comment… keep them succinct!  Who else do we have?

Lori Cox: Sustainable U-pick fruit farmer (Hubbard?) would love a confirm/deny – handoff for MEQB to allow agencies to monitor or agency’s role to decide?  Might bring foresight.  DW: Trying to better understand connection for ER doc and how info is used to inform other approval decisions… and the method for other approval decisions… LC: clarified… DW: MEQB role in the rule – responsibility and authority to pass rules and oversight. Delegate implementation to other govt agencies – who interpret how they are applied and how they affect the project decisions.  ER gives more look at what Env Impacts are and that informs permitting from other project agencies.  Rules require that those approval decisions consider ER docs.  No mechanism to give MEQB authority to vette the decisions made by other govt agencies.  [So no accountablity for regulatory capture?]

Tim Ahrens: In terms of metric to understand if process is working – rates of permit compliance and non-compliance available? DDW: Regulatory compliance done in framework of agency that oversees permits.  MEQB has no authority or oversight of those authorities. [That might be part of the problem…] T: Might be one part of the disconnect.  ER informs permit but if permit is not carried out with integrity…  SS: Monitoring is agency responsibility.

Kristin: Question on survey was asked retrospectively to parties that participated in ER.  Looking for their feeling of if it made a difference.  Wanted to clarify that is more process than outcome oriented – different mix.  Very valuable convo – wanted to clarify on that being procedural. DW: Asked for perception – data was qualitative and not aimed at whether project resulted in change in the ER but whether they were engaged in the process and the process was better than it would have been without ER.  [So they could just think it’s a PITA and respond accordingly…] K: And public input.  DW: And public input.

SS: Move to next agenda item… GHG Quantification and Assessment… presented by Denise Wilson. “No inclusion of recommendations today… want to discuss today how to overcome barriers.”

Team consists of Steve Roos (MDA), Louise Miltich [Yep, Anthony’s niece!] (Commerce), David Bell (MDH), Kate Fairman & Cynthia Novak-Krebs (DNR), Melissa Kuskie, Peter Ciborowski & Laura Millberg (PCA), Deb Moynihan, Peter Wasko, Jeff Meeks & Katherine Lind (DOT) and Eric Wojchik (Met Council).

Some of these agencies are project proposers… determine what info is needed and how it will be used. Before implementation of recommendations – we want input to help facilitate convos on this…  Not final – tech team will continue to refine. Nothing about adaptation or resiliency or category changes, etc. Much more to be done in the future… Elements we considered:

  • GHG Emissions (construction/operation)
  • GHG sources (& % from each)
  • Types of GHG
  • Alt Mitigation measures & justifications
  • Purchase of any renewable energy credits [Credits… push the problem to another part of the globe?]
  • Net lifetime GHG emissions (meeting state/local GHG reduction goals)
  • Contributions from other GHG emission sources

How Info will be used was reviewed: giving info to proposers/consultants to understand design decisions, RGUs to prepare GHG assessments for all, public can meaningfully participate in approval decisions – knowing climate effects! – and govt decision makers can use info for approval decisions. [Do they ever deny??? All this will only be possible if REAL data is provided…]

Barriers include: different calculations methods/references, broad range of project types, Not all RGUs have expertise, existing calculators/tools don’t meet ER Program needs, and financial and staff resources for GHG calculator tools. [#3 is my favorite!!!  What about BS checker from applicant?]

MEQB fix?  2 phases. Phase 1 involves a Qualitative discussion in the EAW form. They’ll even allow voluntary inclusion of QUANTITATIVE GHG emissions! [Voluntary inclusion???]

THEN… once tool is available, a GHG Calculator will expand assessment requirements in the EAW form for projects over 25,000 MT CO2e. [Over what timeframe?  Annual?] 

Alignment with regulatory requirements reviewed (from EPA website…)  [So why do we have to develop our own??? And wait until you see the cost data…]

OMG the cost data!!!  $3000 (Excel SS) to $500,000 (App development)!! And, hey, we don’t have 1-3 years for you you figure this thing out! [Noticing that there is no CHAT to all participants…  VERY CONTROLLED…] Then Denise asks everyone:

Made hummingbird food… sorry – missed some stuff here… came back to questions from Alan Forsberg.

Alan: reducing transport…  Around state different…. Metro – easy but Greater means things are far apart.  Commute 70 miles to Redwood Falls…  Moving freight…  DW: Asking folks to ID alternative mitigation methods considered and why…  Maybe those methods make sense in that location but another site would be different.  About info sharing.  A: Things getting to MN… ethanol plant… lot of moving required for our economy to function. 

Margaret Kelliher (DOT): Do believe starting with a calculator could be very beneficial.  MNDOT has been working with building up to use a GHG calculator for future projects.  Little concern… also have been a Comm very involved in council on technology…  when I hear about an App or program development.  SS is low risk.  Easy way to move fwd quick but benefit for a more complex set of anlysis going with it… 1) Worry about development costs and assuring having resources to do it.  2) are there opps to partner with other orgs across country?  Unique with MEQB but not in looking at climate issues  Strength in numbers working together or building off existing calculator. 3) Any tech – sustainability and updating going fwd – not only up front costs of scoping and such but also plans for truly utilizing a quanitization of GHG – also a legal element to consider – assure we are accounting for ongoing update and support. DW: Limit scope of what we’re asking folks to review, ID calculators that capture reliable data – Climate Registry… Enterprise has used.  How they track and report… Enterprise Sustainability just went through a process to develop a tool for that enterprise.  We did consider updating and maintenance – as science is developing quickly.  Once downloaded, how do we assure latest tool is in use?  Another barrier and challenge.  Not sure of answer.  Looking for your feedback on where to focus convo.  Maybe asses what elements we require at this point.  MAK: Happy to help as we look at expertise… to think through how we want to move forward and beyond.  Appreciate thought put into this.

Dan Huff: Thanks for comments MAK. Lot to look at and sustainability and funding are key.  Timing of Phase 1 & Phase 2.  1 immediately?  What is the timeline?  DW: Implementing this approach would bring a December subcommittee and Board January for Phase 1 implementation.  Challenge is once more detailed assessment is done is that RELIABLE info and good guidance is provided to implement correctly.  Phase 1 could be done early next year – Phase 2 longer – also resource dependent for 1-3 year development of tool.  DH: Need to move and begin to incorporate GHG ASAP.

Aditya Ranade from Commerce: Support Phase 1.  When tool launched, how long is Phase 1?  Potential assessment of operating expenses for calculator to individual projects.  DW: P1 continues for projects under 25mTCO2.  Phase 2 would start when we have a good tool…  (so years down the line… Not soon enough.  They’re still not getting it…)  Chair can amend – we can quicky add requirements and come to chair or board for implementation right away.  Ongoing support/maintenance – good question…  Depends on how we come up with our package for what needs might be – may need a budget item…

Bryan Murdock: Already regulate GHG on some mandatory categories… like phased approach.  Start with those requiring GHG first?  Threshold values – # of animal units? Under X size doesn’t require it?  Not all need to be burdened.  Thresholds would be a great thing.  Mega-emitters first, then roll to smaller makes sense.  LB: At MPCA working through GHG calcs as related to feedlot proposals – ruling with Daley farms – starting to put this in place in our EAW process to evaluate GHG… Start on some of this.  Can look at county… not all sources but some sources… and looks at mitigations applicants are making.  Tools to learn from… 5 different ones… since Daley where we’ve looked at GHG emissions wrt animal feedlot process.

Kristin: really excited about ability to start on Phase 1 – encouraging – can start shifting culture around how GHG fits in ER.  Concerned for Larger projects awaiting Phase 2. From data, how many projects might P2 apply to?  And, if not a large number, possible for tech team to begin working and support evaluation of these larger projects, if not too many.  Dula purpose of not letting things go too far or too long and getting concrete exp with these kinds of assessments.  [GREAT IDEA!] DW: GHG considered under EAW 100mtCO2 leads to ER…  Also for stationary sources that fall under air permitting requirements.  Data on projects including this info… since we don’t prepare docs, we don’t track how they are evaluated…  Don’t have that now.  K: How many MIGHT apply to 25KmTCO2?  DW: Haven’t gone through that – looking through mandatory catagories… will evaluate threshold.  [Dan’s right, they don’t have this answer…]  What gets you to mandatory reporting sector… TBD and how many that exceed that threshold…  Will probably do that.  KE: bears upon all cost issues.  You stated in beginning that you need broader stakeholder convos – who else are you planning to engage? [OOOHHHH!!!] DW: Going to be targeting specific groups – Ag community – many proposers going through.  League of MN Cities and Counties and local Muni govt acting as RGUs,  State RGUs framing and then, more broadly (framework TB developed) doing outreach with Community groups and perhaps focused groups.  [So mainly APPLICANT stakeholders, not AFFECTED PUBLIC… until MAYBE LATER???]  [Back to core values implies you’re not adhering to them now???]

Alan: splitting out… moving oil by rail, counting cost of constructing rail line?  Or eventually when oil will be burned?  DW: Some details ironed out in guidance.  Id’d important threshold and will develop questions for specific factors and guidance for how they are implemented.  RGU decides what info is needed and how it is assessed.  [WHERE IS MEQB OVERSIGHT?]  Alan: Many are complex – how do you not double-count?  DW: Understand. Thank you.

SS: Lots of energy to get moving on this project!  [Kinda late… 646 days since the IPCC report.]  Next time, with guidance – will want to devote adequate time to that discussion of these details.  Will assure we give that.  Like to do… 4 folks seeking public input.  Then F/U later.  3 minutes from scheduled adjourned time – “important to hear from public.”

Public Comments:

Amelia Vohs: Staff atty at MCEA – Allen Anderson – new Climate Program Director.  Thank DW and tech team for hard look and this presentation. Hard work, challenging questions.  Three reactions to presentation today. 1) From advocacy comm, want an QUANTITATIVE analysis ASAP in EAW – even if using existing calculators, even if not as robust as our own developed.  Clear about this analysis.  Since Daley Farms case- working to comment on EAWs to assure GHG analysis is done for projects with significant emissions even though not CURRENTLY ON EAW.  THAT analysis is HAPPENING!  MPCA did it for Daley and others.  Stillwater did a mixed use development GHG analysis.  RGUs are NOT considering GHG – waiting for analysis.  Many respects P1 requires less than what RGUs are ALREADY DOING.  Already seeing quantitative analysis – better than a qualitative – which would be moving backwards.  Guidance for RGUs need to be MORE ROBUST. 2) Recognize existing calculators cannot compute full scope of emissions MN deems relevant.  OK for now.  Emissions that can’t be included – scope 3 emissions – could be included in qualitative discussion while using existing tools.  3) Touch on question of RGUs being able to use these tools.  Stillwater JUST DID A GHG quantification even though no ER for a number of years. Used existing tools.  Even RGUs NOT using regularly are able.  IMPLEMENT NOW.  RGUs START with a quantitative analysis NOW to build knowledge about how to do a GHG analysis and allow community to suggest how analysis can be monitored or improved.  Collective process can help us get better and guide tech team on how to construct for and guidance.  LOVE the idea of our own tool that fits what we want to do in MN but cannot wait for this tool to exist before quantitative analysis starts.  TOO MUCH uncertainty in staffing, funding and time to develop  Cannot condition start on quantitative analysis on THIS uncertainty while other states are performing comparable analyses.  Understand variability of RGUs using different tools.  WE ARE EXPECTING THAT and it’s OK.  REALITY in Env Review variability exists!  By RGU and by modeling – ALL best estimates.  Public understands and accepts this.  Not expecting an objective truth.  May comment and disagree with assumptions made in model but that is true whether we have a specific of MN or existing tool use.  Two shorter points.  From public perspective – investment of resources, quantification is important but using staff tools on robust guidance is more effective.  Assembling reports – that is the type of public info the public needs, that doesn’t exist, and where we’d like to see staff resources devoted.  Support what Denise was mentioning about stakeholder process.  System for public to comment – requires a 2-way convo.  I’m talking AT you but had a productive convo earlier – asking and getting feedback.  Recommendations are better with 2-way with tech team – understanding their barriers – and creating better response based on why they recommend WHAT they recommend.  Monthly stakeholder team to discuss?  Tech and legal staff devoted to researching this – would like a back and forth convo.  SS: Thanks.

Lori Cox: Support of qualitative and quantitative program, particularly with land use and changing ag land uses.  If land were previously tilled but NOW wants to be a feed lot – want to see (Ag member of MDA WQ)  what is AS-IS state and what would GHG be after…  not only for land use – changes – but what else are you mitigating. If tilled 60 years prior – know that GHG – want to know change brought with a feed lot.  When project comes, not just changing GHG from Land/animals but also PRACTICES.  All affects water, soil, well quality.  Water Quality certified farm – always asking how we can do better.  Agri-business needs to ask themselves the same.  Agree with WIDER stakeholder view.  Would not be giving in to any lobby pressure that says “we have to”.  MN, Country and Globally – finding BEST PRACTICES that DO WORK, upheld by SCIENTIFIC DATA.  Recommend this rigorous process.

Willis: Support previous comments.  My primary concern is usable information…  UN climate panel said we had 12 years for siginicant change in course on GHG and carbon capture – now 2 years down range and calculator takes 3 years… 7 years for making a difference.  Focus on precision rather than moving immediately in a new direction to change trajectory on climate impacts.  Emphasis on WRONG PLACE.  Doing best we can with what we have and then making better choices.  Relevancy of Time and  Unless public can put these numbers in context, they are just numbers.  25K, millions over lifetime.  Want to reduce. HOW MUCH is ENOUGH? HOW much is enough SOON ENOUGH in a particular sector.  Need these frames of reference else public input is crippled.  Can’t know if project is begin held accountable for absorption needed.  Incorporate recognizable frames of reference to make them meaningful.  Is reduction fitting with pace of time scientists say we need.  We have statutes but all of us know that statute was best legislature could create but not consistent with science.  Need to know what panels of scientists say on pace and quality of reduction in each economic sector.  Suggest this is down the line… but if you don’t have these numbers in next 3 years, we will have wasted another 3 years!  5 years seems unacceptable to show public if we’re on track for each project.  TIME AND QUANTITY.  Feed lots… know world cannot sustain ag animal units around the world.  When a feedlot comes fwd – in MN, we have this many animals, increasing over time – consistent with number of animals the planet can support over time? If this is NOT in the frame of reference, we are deceiving the public.  They need this frame of reference to be able to effectively participate in the discussion.

Rob Bouta (bowtay): Env consultant – prepped ~100 EAWs over 30 years, City of ? sustainability commission.  Agree with MCEA.  Costs of developing tool – submit also costs of not developing the tool that are much greater over time as they affect the viability of life on earth.  In developing programs, anything the state can do to develop off-the-shelf implementation of mitigation measures would be really helpful to show project performance.  How they can do this, working with their projects – necessary.  Demo projects may be outside the scope of MEQB but Overland College – generates more energy than it uses.  Netherlands developing residential development.  Projects waiting for this… no time to wait.  Sooner the better in getting this done.  Carbon footprint – reference in some materials.  EPA calculator – looked at those as I had to respond… EAWs written by consultants, not RGUs generally.  I selected one by Conservation Int’l – thought it included all types of C generation (solid waste and air travel) not included in MPCA calculator.  MEQB staff can look at this to get in touch with ppl developing calculators to figure HOW to develop for MN.  Lots in CA… not readily adaptable to MN as CA uses energy different with their climate.

Chat discussion was also interesting… just me and the host… as it was for every participant?

[So much for engagement…]