Today’s blog focuses on the feedback I gave recently to the MN Climate Subcabinet’s Climate Action Framework document on which they are seeking input through tomorrow. [No pressure! Though if you want to send an email, you can address it to: firstname.lastname@example.org – though if you look at their page asking for feedback, there’s no deadline listed… and… no date of issue! That’s how MN rolls! The 2/1/22 notice I saw on this work noted: The Climate Change Subcabinet will release a final Climate Action Framework in mid-2022. ] [NOTE: Email Address corrected 2/15/22.]
Before I could comment on the Framework documents, I needed to educate myself on their congratulatory notice of MN successes, so there is some coverage of the “ECO” Act of 2021 as well.
Good day, Climate Subcabinet. Thanks for requesting input from Minnesotans.
[Here’s to hoping they actually READ IT!!]
Just to begin, I’d ask the obvious question that is on the minds of thousands of Minnesotans:
HOW can MN say we’re making progress on Climate after allowing Enbridge to RUSH AND INSTALL its Line 3 Tar Sands Pipeline Relocation and Expansion project as the Fossil Fuel Industry faces tremendous controversy as it approaches its demise?
This recent experience, including the YEARS LONG Public Opposition, which was largely ignored by the Walz Administration, seems to show the blindness Minnesota has with regard to the urgency and direction we need to move in order to protect biodiversity and place for continued human existence here in the Land of 10,000 Lakes.
The only accomplishment Walz can seemingly claim for his work on improving climate change is still years down the road from realizing true benefits… and will also bring FURTHER DEVASTATION to MINNESOTA as the Clean Cars work seems reliant on MINING northern Minnesota to oblivion to become the reality some envision.
As I read this “Climate Action Framework”, SO MANY QUESTIONS come to mind.
Like… Why did the News Release on the ECO Act NOT include a LINK to the Act, for ready access to the details? Are you embarrassed at how MUCH this act provides to corporations that continue to eat away Minnesota’s rich – but quickly being decimated – Natural Resources? Instead, we’re given the narrative the administration wants us to hear… with no easy way to check this reporting for ourselves?
Governor Walz calls it “nation-leading energy conservation legislation” and even Lt. Governor Peggy Flanagan, a member of White Earth Reservation, says the act “expands our commitment to low-income consumers”… yet this “ECO” Act is only ECO in it’s acronym: Energy Conservation and Optimization Act of 2021. Its entire focus being, not on our NATURAL ENVIRONMENT, but on the financials and efficiencies of anthropocenic energy use.
The legislature finds that energy savings are an energy resource, and that cost-effective energy savings are preferred over all other energy resources. finds that optimizing the timing and method used by energy consumers to manage energy The legislature further finds that cost-effective energy savings should be procured systematically and aggressively in order to reduce utility costs for businesses and residents, improve the competitiveness and profitability of businesses, create more energy-related jobs, reduce the economic burden of fuel imports, and reduce pollution and emissions that cause climate change.”Energy Conservation and Optimization Act of 2021
WHERE does this address the effects on the natural world? It only seems to serve rule-making and ideologies around how humans manage their own extractive and anthropocene energy needs, not truly dealing with the climate impacts directly but, giving us a distraction to pretend we’re making progress… as we continue to assist large energy facility work. In other words, it seems only a bunch of busywork to be done as the spaceship on which we all depend for every aspect of our lives, continues its downward spiral of bad health… which leads eventually to the extinction of humanity.
Not serving the people, but facilities… the first point under the Large Customer Facility section is about creating opportunities for exemptions. [Who doesn’t love a loophole?!? FFS.]
The owner of a large customer facility may petition the commissioner to exempt both electric and gas utilities serving the large customer facility fromEnergy Conservation and Optimization Act of 2021
the investment and expenditure requirements of paragraph (a)made under an energy and conservation optimization plan filed under subdivision 2 or with respect to retail revenues attributable to the large customer facility. … Once an exemption is approved, the commissioner may request the owner of a large customer facility to submit, not more often than once every five years, a report demonstrating the large customer facility’s ongoing commitment to energy conservation and efficiency improvement after the exemption filing. The commissioner may request such reports for up to ten years after the effective date of the exemption, unless the majority ownership of the large customer facility changes, in which case the commissioner may request additional reports for up to ten years after the change in ownership occurs. The commissioner may, within 180 days of receiving a report submitted under this paragraph, rescind any exemption granted under this paragraph upon a determination that the large customer facility is not continuing to make reasonable efforts to identify, evaluate, and implement energy conservation improvements.”
It seems this basically implements authorization to charge rate-payers with the work the state is asking to be done, simply another way for the People to fund this mandated “ECO” work and thus improve the bottom lines for Utility providers.
Further, item (b) seems to provide even MORE LEEWAY to charge the public for these concerns:
A utility may file annually, or the Public Utilities Commission may require the utility to file, and the commission may approve, rate schedules containing provisions for the automatic adjustment of charges for utility service in direct relation to changes in the expenses of the utility for real and personal property taxes, fees, and permits, the amounts of which the utility cannot control. A public utility is eligible to file for adjustment for real and personal property taxes, fees, and permits under this subdivision only if, in the year previous to the year in which it files for adjustment, it has spent or invested at least 1.75 percent of its gross revenues from provision of electric service, excluding gross operating revenues from electric service provided in the state to large electric customer facilities for which the commissioner has issued an exemption…”Energy Conservation and Optimization Act of 2021
The Climate Action Framework’s “Working Together” section on page 17 pushes me to continue to wonder, HOW exactly Tribal Nations were involved with the writing of this framework. Here’s the statement on Tribal Nations role and leadership from the document:
However, based on the Walz Administration’s implementation of EO 19-24, it seems the State CLEARLY LACKS an ability to comprehend their TRUE obligation to Federal Trust Responsibilities. This sentence on page 19 perhaps gives insight to what we can expect… more of the same?
“The State of Minnesota must uphold treaty responsibilities in all State decisions, public processes, and policies by protecting the land, native foods, and the cultural heritage of Indigenous Minnesotans.”
Note this does not say “will” but “must”. Which has always been the case… throughout time immemorial, yet the respect for Tribal sovereignty has been an ongoing divisive issue here in Minnesotan when it comes to implementation of “law”.
The second paragraph notes the State “will work with Tribal Nations” but what we’ve seen to date has given NO INDICATION that the state will do what is required, which is to CONSULT with Tribes, not notify them, as we’ve witnessed over and over, including the most recent implementation of a permit issued locally for a new OSB plant for Huber Manufacturing adjacent to the Leech Lake Reservation… a project the Tribe learned about in a press release.
On page 20 of the Framework the topic of Water arises… which again returns my thoughts to the Line 3 project as it was installed with one segment just a stone’s throw from the St. Louis River itself, and with the project placed within St. Louis River’s recently (and expensively) restored Estuary. Unless this document is truly going to bring a CHANGE in the way MN interacts with the Tribes, I fail to see that it will be effective or even lawful.
Again, the only climate-related “success” of the Walz administration comes first – with Goal 1: Clean transportation focused on Clean Cars proposals and goals. But Minnesota must remember, while some of this work, especially that focused on more human-powered transport options, is good, the move to EVs will also be pushing for more intensive pressure for mining in Minnesota as humans have failed to implement Cradle-to-Grave systems where components and materials of products are re-used, recycled, or managed in a way to prevent continued heavy extraction of natural resources. I’d ask, what inputs from the Tribe were MOST HELPFUL in the implementation of the Clean Cars legislation? What suggestions of theirs can we call out in the Climate Action Framework verbiage?
The section on Goal 2: Climate-smart natural and working lands, on page 28, makes me consider the FAST PACE at which Minnesotans are slashing our population of trees across the state, recently notable with the work done to create a new corridor of destruction for the Enbridge Line 3 debacle. Large trees are better sequesters of carbon than small trees, yet MDNR appears geared to continue culling trees to support economic gains, without truly considering the importance of these Relatives. Even MNDOT is seemingly dismissive of trees suggesting now that along Highway 34 in Becker County, instead of say, reducing the speed limit for cars in the Smokey Hills Forest area, they want to cull trees on the south side of the road to enhance solar warming of the roadway to reduce traffic accidents. HOW ANTHROPOGENIC CAN WE BE? As we CULL the very beings that produce the oxygen we breathe?
I note on page 29 the sub-goal to “Prioritize groundwater and drinking water protection in vulnerable areas.” Yet we saw the Line 3 project given NO ONGOING POST-CONSTRUCTION MONITORING requirements in the MPCA permits. WHY NOT? Why is there no monitoring to assure the chemicals and muds pumped into our environment during horizontal directional drilling (HDD) – under many of our vital and important water bodies – is OK? No monitoring to ASSURE our groundwater and the water in our rivers that many depend on for drinking, like the Mississippi, which was affected in two places along the corridor, remain SAFE?
The various Initiatives noted on pages 31 to 34, while mentioning “emerging crops” give us NO MENTION OF “HEMP” – a vital and resilient friend that we long ago abandoned, for a variety of reasons, and demonized with a campaign on “Reefer Madness” among other tactics to instead promote extractive options. That this crop, specifically being promoted by a major Indigenous leader in our state, Winona LaDuke, is ignored, seems just another indicator of how LITTLE CREEDENCE was given to heeding Native Voices in this Climate Action Framework. While the section ends discussing “Equity”, it seems clear this is not something the Climate Cabinet understands.
While each section gives a focus on Equity, Goal 3: Resilient communities reminds me that, if we see continued actions as we have in Minnesota, without real change in adding voices of those most affected in vulnerable communities – perhaps even CONSULTING with them on projects that impact them, as is required by work in Tribal territories – might bring real change. But as long as the “systemic” changes continue, focused on a cultural understanding of white supremacy, I imagine most of the improvements we see will continue to disproportionately assist whiter and/or wealthier communities.
The section on Goal 4: Clean energy and efficient buildings could use a little proof-reading as the first sentence on page 47 reads: ” Minnesota’s electricity generation is getting cleaner: 55% came from carbon-free resources in 2020.” Yet the graph adjacent to this paragraph shows that the 55% was our CARBON-BASED Energy, not the carbon-free: 48% in Coal & 7% in Natural Gas = 55% of carbon-based energies. So, you can change the percentage to 45%… or you can modify to show that the majority of our energy is actually NOT from “carbon-free resources”. [This may explain why the Climate Cabinet continues to struggle? You have a mis-guided idea of where we are… let alone where we need to go?]
That said, this section captures where Minnesota is failing… noting: “The industrial and the building sector are both experiencing a rise in GHG emissions. Since 2005, GHG in the industrial sector have increased by 18%. In that same time period, GHG emissions in the commercial building sector have increased by 15% and emissions in the residential building sector have increased by 32%. This is partly driven by greater heating and cooling demands caused by our changing climate. ” [Can you see the vicious circle now, Climate Subcabinet members?]
While your Initiatives focus on a transition to 100% carbon-free energy by 2040, Minnesota just approved Enbridge to build a tar sands pipeline, committing us to decades more of fossil-fuel based pollution. How does this make sense? Especially as the project risks the clean waters on which we depend for life… and culled thousands of trees that provide not only oxygen but also store carbon? And, again, when it comes to Equity… these works seem to affect communities of color disproportionately historically. I’m finding it incredible that we might see Minnesota able to both amend past injustices and begin to work in ways that don’t create MORE injustice… as we just witnessed in 2021, concurrent to your work in developing this Climate Framework?
Perhaps the most hard to believe section is that on Goal 5: Healthy lives and communities. While there was a full court press for the pandemic, far more people die each year from pollution than died from Covid. Yet we see no real programs on pollution mitigation and improvement on the level we watched the Covid response unfold. Instead, we hear many reports in recent years on how ALL OUR WATER, in fact, all our BODIES, contain PFAS. The word-salad in this section seems especially condescending as it provides no real clarity on exactly how we will make the change, just lofty goals and vague ideas that give no secure feeling we will actually DO THIS WORK.
Nope, I was mistaken!! Section 6: Clean economy is the hardest to believe. After spending the last 7 years working to educate Minnesota’s Governor, Lt. Governor, Attorney General, Public Utility Commission, and various and sundry Agencies, most prolifically those of DNR, PCA and Health, I’ve seen little to encourage me that any of these parties are listening to the voices of MINNESOTANS. The goals of our economy seem largely based on “workers” and business (though, really, it’s just business, isn’t it?) as called out in the SHORT FORM challenges noted. Seems the biggest concern I’ve noted for Minnesota is not hearing Tribal voices, working to protect vulnerable communities, or even protecting land, air and water for Minnesotans… but instead it is to assure we “don’t leave workers or businesses behind.”
Let’s be honest. We’ve “been in transition” since 2007 when Governor Pawlenty gave us the Next Generation Energy Act. And, while we’ve seen some progress along the way, in recent years what we see is the desperation of a system that is on the verge of collapse as we find more and more severe weather events, less and less social justice, and growing global impacts as well, that show we’re far from assured to make the progress hoped for in this Climate Action Framework.
Though I know six of the contributors to this document, mainly from MPCA and DNR, I see no names of scientists I know, representatives from climate advocacy organizations, or even any Minnesota Native names… in fact, the only Native contributor I recognize (MPCA’s Tribal Liaison) is not from Minnesota’s Tribal Community.
Again, this document gives lofty goals, as do most of the frameworks and plans I’ve seen presented by Minnesota State Government. Yet I fail to see much hope that 1) these will be implemented in a good way (based on what I’ve watched to date in Minnesota government) or 2) they will be successful (as we seemingly fail to recognize the urgency with which action is needed or stress the focus on Indigenous knowledge and RECIPROCITY that will be required to move forward WITH Mother Earth).
Appendix 1 on State Action Steps is full of words like evaluate, prioritize, develop, deploy, collaborate, encourage… but the check boxes for Lead, Enact, and Encourage show far more hopes for Leading and Encouraging than actually Enacting.
Here’s one where Enact is checked but not the other two… which may be telling if it’s for what it brings to my mind, which is the Huber Manufacturing OSB plant just approved near Leech Lake Reservation.
2.5.2 Promote the use of forest products that store carbon and reduce GHG emissions: Enhance markets for long-lived wood products that increase carbon storage and substitute for more fossil-fuel intensive materials
Huber’s OSB plant may be justified by some climate-minimizing statistical calculations (you can prove ANYTHING with statistics if you try hard enough), though it certainly does NOT show Leadership for Climate Mitigation or Encouragement of Protection for Vulnerable Communities… as they plan to take many of the trees surrounding their plant and turn them into housing materials? [Again, with the Leech Lake Tribal government learning about this plant permit in a Press Release… HOW exactly are we ENACTING CONSULTATION?]
Telling of our desperation is this item:
3.3.1 Advance climate adaptation in residential & commercial development: Research ways to increase resiliency of buildings to extreme precipitation, flooding, extended heat waves, urban heat island effects, grid failure from extreme weather, and other climate change impacts [Uh, this recognition of the troubles coming our way (and for some already here) is not balanced by any urgency noted in this planning framework.] Or item 2 on this Sub-Initiative: Adopt resiliency provisions in codes, permits, and policies for new construction, rehabilitation and adaptive reuse, and create resilient design standards [Which gives no confidence that we actually have real plans for HOW TO DO THIS… let alone any certainly that we can do it quickly enough.] Or this third idea on the same bullet point: Encourage new construction and rehabilitation of housing to plan for resiliency/adaptation (e.g., waterproofing basements, raising mechanicals and coordinating with energy improvements, installing mold resistant and passive cooling building features), ensuring new developments build outside of higher risk flood areas that retain the natural benefits those areas often provide. [This is just an encouragement… when it could be more robust with rule-making or legislation.]
In the end, this seems a dreamy document, not based in the reality of our circumstance or the urgency of our situation at present. This is an ongoing concern I’ve been voicing to Minnesota officials and agencies for years now, that we are not taking the situation seriously enough and, perhaps especially as Minnesotans, not aggressively pursuing NEW WAYS to do the things more critical to our survival, but instead continuing to work within the white supremacy based systems we already have in place; systems which have offered little hope for the Native, Scientific and/or Youth advocates to be heard. These advocates, who worked diligently to prevent NEW fossil fuel infrastructure in 2021… as global calls for ending fossil-fuel infrastructure development continue to grow louder and more demanding, are instead facing prosecution as Minnesota continues to reveal its ever-present racist past rearing its ugly head.
If we look to the future and a green economy, Sub-Initiative 6.1.1 Grow green economy jobs through innovation gives little hope as again, we see ENCOURAGEMENT, not legislation or regulation to prevent damage or propose better solutions for this line item: Work with industry to advance process improvements that are better for our climate and for worker health
When it comes to policy, the actual work seems focused on things that FURTHER DETERIORATE Minnesota’s natural resources, as we watch friends continue opposition to Polymet and other mining initiatives still being considered by the State of Minnesota.
The things in these documents that make sense are largely well-known from the data and information we’ve had for decades, yet we have watched in this same time as Minnesota waters have become MORE impaired, State Agency work has culled MORE of our trees, and pollution has continued to worsen.
You all did a good job of assessing current short-comings but little to instill hope for a changed future. I hope you will take a look at my input and add detail and clarity on HOW this work will progress, not just the dreamy ideals on which it holds hope.
To close, I feel the most HONEST page in the Framework is the Vision page:
This at least seems to give insight to the lack of consideration you will give to Trees, as you fade them into the background, hiding their glorious color… and Children and perhaps even Minnesota herself, both shown as about as tiny as they could be on this graphic. Sad really. But, based on my experience, true.
Thank you for your consideration.
I’ll note, while I was disappointed to not be selected for this Climate Subcabinet, I can see now that it likely would have felt largely like a waste of time generating dreamy ideals not based in reality and largely leaving Minnesota beholden to corporate interests. So, for that, at least, I thank you.