Ms. Stephanie Aho Greenhouse Gas Data Analyst Environmental Quality Board 520 Lafayette Rd St. Paul, MN 55155 Dear Ms. Aho: On behalf of the Minnesota Chamber of Commerce (Chamber), a statewide organization representing 6,300 businesses and more than half a million employees throughout Minnesota, we appreciate the opportunity to provide feedback on the Environmental Quality Board (EQB)’s Draft Climate Calculator Tool (“Tool”). The tool is not required by statute and is billed as “an option, not a requirement” for filling out the climate questions on the Environmental Assessment Worksheet (EAW). The Chamber is concerned that implementing this updated calculation tool from a state board that facilitates the environmental review process will create a de facto expectation to use the tool, even if it’s not required. While the Chamber appreciates the disclaimer on the tool itself stating that it’s not required, project applicants may still be inclined to use the more aggressive assumptions created by the EQB’s tool, even if their own calculations say otherwise. EAW guidance requires GHG calculations be replicable. If the EQB uses this tool to replicate inputs from a different method, it may come to different conclusions. Therefore, applicants may be more apt to use the new EQB tool, with its arguably more aggressive accounting, to ensure replicable outcomes. Further, adoption of the tool continues to grow the EAW process to resemble a mini-Environmental Impact Statement (EIS). The EAW – a lower level of review – is intended to be a shorter review document. In addition, the tool attempts to increase the granularity of the GHG calculations beyond the level of detail that is typically available at the EAW stage of a proposed project. This large spreadsheet with broad assumptions, created by the administration who is overseeing environmental review of proposals, continues the EAW’s growth into just short of an EIS by a different name. The Chamber recommends abandoning implementation of the latest draft tool. However, below are recommendations from the Chamber to improve the draft tool if abandonment is not a possibility. The tool provides no way to account for emission mitigation practices. It does not allow for any accounting for innovative technologies and practices that may reduce emissions. It also does not account for potential emissions reductions should the project have a lower emissions profile than the existing facility it’s replacing. The Chamber recommends including a means to account for emissions mitigation. Aggressive accounting for indirect scope three emissions in the tool are nearly impossible to calculate. If the project has not yet even been approved, it is impossible to know how much and what materials may be required for construction, let alone the distance those materials may travel. The calculator also offers accounting for emissions related to “Employee Commuting”. This is well outside the scope of what an EAW is intended to illustrate. The Chamber recommends removing scope three emissions from the tool. Implementation of the draft climate calculator tool will create a de facto pressure on applicants to use it and goes well above and beyond what it takes to answer questions on an EAW, effectively becoming a mini-EIS. The Chamber recommends abandoning implementation, of the draft tool, or at the very least stepping back from its more aggressive accounting. Thank you for taking input on the draft tool. As always, the Chamber stands ready to offer feedback from the business community. Sincerely, Andrew Morley Director, Environmental Policy Minnesota Chamber of Commerce amorley@mnchamber.com 763-221-7523

Dear Environmental Quality Board Commissioners, Thank you for the opportunity to comment on the Environmental Quality Board’s Draft Greenhouse Gas Calculator tool. The Minnesota Center for Environmental Advocacy (MCEA) is optimistic about the tool and grateful for the thorough effort that has gone into it. The MCEA staff have experimented with analyzing a handful of potential project types using the calculator, and offer the following feedback: GENERAL - MCEA supports the inclusion of upstream and downstream emissions to make the calculator as informative as possible. ELECTRIC-GENERATING FACILITIES - The list of emissions sources should say “Emissions from coal combustion” rather than “Emissions from coal production,” because the latter is inaccurate, on both the Project Background and User Input tabs. - The list of emissions sources inappropriately excludes biomass and other non-fossil fuels for electric-generating facilities. Under the Project Background tab, the list of emissions sources categories does not include options for all potential fuels for electric-generating facilities. The tool displays options for “Emissions from coal production” and “Emissions from natural gas and oil products.” However, there is no option here or on the User Inputs tab to input non-fossil fuel sources such as municipal solid waste, agricultural byproducts, wood and wood residuals, or landfill gas, among others. This is surprising given the “Fuels” tab of the calculator includes emissions rates for these fuel sources. The calculator should allow for the calculation of emissions from these fuels in an electric-generating facility. - It is unclear how woody biomass electric-generating facilities can be evaluated. Selecting the combustion option for Treatment of Waste On-Site for an electric-generating facility automatically uses the municipal solid waste emissions factor, not one for wood or other biomass. The fuel-related options for this facility type also exclude biomass, as noted above. PIPELINE FACILITIES - The list of “Emissions from Natural Gas and Oil Products” under operational impacts for an oil pipeline does not include crude oil as a product type. This list should be expanded to include multiple grades of crude oil, since over 3 million barrels of various light, medium, and heavy crude is transported through Minnesota via pipeline each day. - It should be made explicit in the calculator where operational electricity use for pipeline pump stations should be input when analyzing a pipeline project. DAIRY FARM FACILITIES - Dairy farm facility emissions may be dramatically underestimated. MCEA staff tested the greenhouse gas calculator with an existing dairy farm project, which in the EQB calculator produced a baseline emissions estimate of 62,643 tons/year of CO2e. However, the same dairy farm project was recently evaluated by the COMET Farms model, which gave a much higher emissions estimate of 111,255 tons/year of CO2e. This could be because the COMET tool is able to take a lot of farm-specific information into account, such as feed type, manure handling, and how the cows are housed, whereas the EQB calculator holds all those variables constant based on region-wide estimates from the EPA’s national greenhouse gas inventory. However, this discrepancy deserves further investigation. Finally, MCEA acknowledges that this is a highly technical and complex tool. It is not possible to test every scenario, so it is important that the EQB incorporate iterative feedback and updates to the tool as real projects are evaluated.

Thank you for the opportunity to provide feedback on proposed changes to the greenhouse gas emissions calculator used for the environmental assessment worksheet. When initially created, the calculator was meant to provide an estimated emissions assessment for a proposed project. Unfortunately, the latest proposed version of the calculator has morphed into a highly complicated, detailed assessment of a proposed project that has minimal, if any, impact on the final decision of the responsible government unit(s) making the ultimate decisions on the project. The revised calculator to measure greenhouse gas emissions and climate adaptation has turned the environmental assessment worksheet into an environmental impact statement. The information required to assess a proposed project is massive, with little to no value when issuing permits for most projects. Detailing the emissions from construction equipment to the transportation of removing waste from the construction site does not impact the permits needed to construct a project. While recognizing that the proposed calculator placed measuring employee commuting habits during construction is a low priority, it is hard to imagine any project proposer being able to give a greenhouse gas emission estimate for construction contractors and subcontractor employees not yet hired for the project. Conversely, requiring some of this information in the environmental assessment worksheet creates unintended consequences for responsible government units with public expectations for setting new conditions on the location of sourced materials and labor for a project and the types of equipment used for a project during the issuing of a local or state permit. Lastly, the draft revised calculator does not account for mitigation and adaptation measures included in the proposed project. While the calculator references measures like cover crops, soil moisture sensors, rainwater harvesting tanks, carbon sequestration, digestors, and renewable energy for mitigating emissions, it does not include the benefits of the project’s calculations. Proposed projects should receive credit for mitigation and adaptation measures during the environmental review process. We encourage the EQB and its contractor to engage with stakeholders before finalizing a revised greenhouse emissions calculator.

Dear Environmental Quality Board Members, Thank you for the opportunity to provide comments on the Draft Climate Calculator Tool. We appreciate your efforts to create transparent and science-based methods for quantifying greenhouse gas (GHG) emissions in Minnesota. However, we have significant concerns about both the accuracy and the implications of the current tool as presented. At the outset, our most fundamental concern is that this tool is not truly a calculator in any meaningful sense. Rather, it functions more accurately as an adding machine—a tool designed to tabulate gross emissions based on fixed inputs without the flexibility to subtract or account for mitigation strategies. This distinction matters. By failing to recognize actual emissions reductions through on-farm practices, technologies, or process innovations, the current tool risks misleading stakeholders, customers and policy makers. Specifically: 1. No Accounting for Mitigation Practices: The tool makes no allowance for farms or facilities to subtract emissions that are mitigated through technology (e.g., methane digesters), management (e.g., rotational grazing, cover crops), or energy practices (e.g., solar, biogas reuse). This results in a one-sided portrayal of emissions, completely ignoring the growing number of operations that have invested significantly in sustainability practices. 2. Use of State Averages Based on National Averages: Relying on default emission factors derived from national data may be a starting point for large-scale statistical analysis, but it is a poor substitute for actual farm-level measurement and management. Minnesota’s farms are diverse, and using static averages in place of real data penalizes farms that perform better than the average and offers no incentive for continued improvement. 3. No Local Adaptation or Flexibility: Without the ability to input localized data or operational details, this tool undermines the very innovation it should be encouraging. For instance, a farm using precision nutrient application, renewable energy, or low-emission manure handling is treated the same as one that uses outdated systems, which not only is inaccurate but may encourage disinvestment in progress. 4. Duplicating Private Sector Efforts and Investments: It is worth noting that the dairy industry—and many other industries—have already invested in and developed credible, scientifically grounded approaches for identifying the GHG footprint of food production. Tools such as the FARM Environmental Stewardship module, processors’ carbon intensity scoring frameworks, and verified supply chain metrics are already in use. We hope that Minnesota taxpayers will be allowed to benefit from these private sector investments, rather than being burdened with the costs and confusion of developing standalone, potentially incompatible state resources. 5. Risk to Market Access and Credibility: The implications of using this tool for policy, permitting, or regulatory frameworks are alarming. Several processors—including at least two in Minnesota—are now assigning carbon intensity scores to align premiums and contractual incentives with sustainability performance. If the state uses a tool that generates different (and potentially less accurate) scores than private markets, we could unintentionally create a fragmented marketplace where farms are penalized for circumstances beyond their control. Worse, this could result in increased GHG emissions if processors shift sourcing to other states where emissions are higher but not captured in the Minnesota system. In conclusion, we strongly urge the Environmental Quality Board to reconsider the tool’s function and framing. If it is to be retained, it must: -Allow for subtraction of mitigated or avoided emissions, -Accept real data from farms and facilities rather than relying exclusively on broad averages, -Recognize technological and managerial advances, and -Align with existing and emerging market mechanisms for climate-smart agriculture. Alternatively, we suggest retiring the use of the term calculator entirely and labeling it a GHG Estimation Tool or Emissions Inventory Add-Up, which more accurately reflects its current operation. Thank you again for the opportunity to comment. We would welcome continued discussion and collaboration on improving this tool for the benefit of Minnesota’s farmers, food processors, and the environment.