Share your ideas for improving Minnesota's environmental review program
Consultation has concluded
The Environmental Quality Board (EQB) is gathering ideas for improving the state’s environmental review program, and we’d like to know what’s important to you. This is part of a wider effort to identify and prioritize program changes in a strategic, transparent, and efficient manner. Find more information on our continuous improvement webpage.
The ideas you share here will be considered by third-party consultants. Consultants will also conduct background research which includes analyzing past evaluations of the environmental review program. Consultants will prepare a report with program recommendations to the board this summer.
What is environmental review?
Public and private projectsContinue reading
The Environmental Quality Board (EQB) is gathering ideas for improving the state’s environmental review program, and we’d like to know what’s important to you. This is part of a wider effort to identify and prioritize program changes in a strategic, transparent, and efficient manner. Find more information on our continuous improvement webpage.
The ideas you share here will be considered by third-party consultants. Consultants will also conduct background research which includes analyzing past evaluations of the environmental review program. Consultants will prepare a report with program recommendations to the board this summer.
What is environmental review?
Public and private projects in Minnesota can have impacts on our air, land, and water resources. Since 1973, Minnesota has required that certain projects go through an environmental review process before getting governmental permits or approvals. The process provides an opportunity for public comment and produces a document that identifies potential environmental effects of a proposed project, as well as ways to reduce any negative environmental effects.
Environmental review is an information-gathering process that helps decision makers protect Minnesota’s environment. The review does not approve or deny a project.
What is the Environmental Quality Board's role in environmental review?
The state of Minnesota's environmental review program provides information about the potential environmental effects of certain proposed projects. The board oversees the program, including:
- Monitoring the effectiveness of the program
- Making program improvements
- Directing staff to implement rule-related administrative tasks
What improvements are we considering?
Help us improve environmental review now and into the future. Improvements that are in scope may include updates to forms, guidance, practices, standards, rules, statutes, data gathering practices, and more. Anything related solely to permitting or programs outside of the environmental review program are outside of the scope of this effort.
How will EQB use this information?
The EQB hosts this engagement platform, but third-party consultants will transparently evaluate your feedback. The consultants will also review background documents, including past environmental review program evaluations. For instance, in 2007, a report was requested by the board to evaluate the ideas that resulted from previous reports, studies and efforts related to improvement of the environmental review program. A 2011 evaluation report drafted by the Office of the Legislative Auditor examined the environmental review process as well. Your feedback, alongside previously cited recommendations, will be analyzed together by the consultants in a final report to EQB.
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How can we ensure that Minnesota's environmental review program meets your needs now and into the future?
about 1 year agoCLOSED: This ideas has concluded.Post any idea you have related to Minnesota's Environmental Review Program in the public forum, below. You may post more than once and respond to others' ideas as well. Not sure how to get started? Consider answering one of the following prompts:
- If you had a magic wand, what one thing would you do to improve the environmental review program?
- What is the environmental review program doing well or not well?
- What are the characteristics of an effective environmental review program?
Jo Gabout 1 year agoEssential: Include Lifecycle Greenhouse Gas Emissions in All Environmental Review
Without this metric any data will be incomplete and inaccurate.
0 comment1Katherine Dabout 1 year agoInclude Lifecycle Greenhouse Gas Emissions in All Environmental Review
I appreciate your recent improvements on the Environment Assessment Worksheet (EAW) to include calculation of greenhouse gas emissions for projects undergoing environmental review. However, the current agency guidance on the revised EAW only requires calculation of direct and indirect emissions, rather than full lifecycle accounting. More greenhouse gases are released from burning the fuel pushed through pipelines than what it takes to push through the line. Calculating lifecycle emissions is especially important for making sound decisions about fossil fuel infrastructure, because these types of projects will often enable the transportation/release of massive amounts of carbon. I ask that you update the agency guidance and/or the EAW to include a full lifecycle accounting of greenhouse gas emissions related to a project, in addition to the currently required calculation of direct and indirect emissions.
0 comment3JamesSabout 1 year agoIdea: Include Lifecycle Greenhouse Gas Emissions in All Environmental Review
Short description: I appreciate your recent improvements on the Environment Assessment Worksheet (EAW) to include calculation of greenhouse gas emissions for projects undergoing environmental review. However, the current agency guidance on the revised EAW only requires calculation of direct and indirect emissions, rather than full lifecycle accounting. Calculating lifecycle emissions is especially important for making sound decisions about fossil fuel infrastructure, because these types of projects will often enable the transportation/release of massive amounts of carbon. I ask that you update the agency guidance and/or the EAW to include a full lifecycle accounting of greenhouse gas emissions related to a project, in addition to the currently required calculation of direct and indirect emissions.
0 comment1Community Members for Environmental Justiceabout 1 year agoEnvironmental Justice issues
Thank you for this opportunity to comment. Community Members for Environmental Justice (CMEJ) is a community-based organization, committed to addressing the environmental injustices occurring disproportionately in pollution-burdened neighborhoods. Many of our concerned residents and families live or work in areas of the Twin Cities heavily impacted by the legacy of fossil fuel pollution in the state. CMEJ is located in North Minneapolis, an environmental justice (EJ) community - a low-income community of color with multiple sources of industrial pollution generating a legacy of environmental health issues. This disproportionate burden of air, soil, and water pollution in this area has been well documented across departments and jurisdictions including by the Minneapolis Health Department, Minnesota Pollution Control Agency, University of Minnesota, Minnesota Department of Health, and the federal Environmental Protection Agency. The area is an environmental justice neighborhood, as acknowledged by the City of Minneapolis’ Green Zones policy, comprehensive plan, and the MPCA’s environmental justice screening methodology. It is clear that climate change effects will not be experienced equally by communities, and that legacy pollution exacerbates impacts. Living near toxic waste dumps, freeways and other sources of exposures that are harmful to health is highly correlated with race as well as socioeconomic status. A 2014 University of Minnesota Study showed people of color are exposed to nearly 40 percent more polluted air than whites, and Minnesota is among the top 15 states in the nation with the largest exposure gaps between people of color and whites. 2 LP Clark, DB Millet, JD Marshall, "National patterns in environmental injustice and inequality: outdoor NO2 air pollution in the United States," PLOS One, 9(4), e94431, (2014). Furthermore, some of the most severe climate change-related weather disasters in the U.S. have had a disproportionate impact on low-income communities. Already vulnerable communities pose a unique challenge for mitigating climate change. For this reason, the federal government’s Council on Environmental Quality had established as one of its climate adaptation national goals to “(p)rioritize the most vulnerable: adaptation plans should prioritize helping people, places and infrastructure that are most vulnerable to climate impacts and be designed and implemented with meaningful involvement from all parts of society”. White House Council on Environmental Quality. 2010. Progress Report of the Interagency Climate Change Adaptation Task Force: Recommended Actions in Support of a National Climate Change Adaptation Strategy. Our recommendations for improving environmental review are as follows: 1. Establish a robust EJ Engagement Strategy for all Environmental Review processes and proposed rule changes. We are troubled by the loose language by the EQB around engagement of environmental justice communities. Environmental Review is a critical tool for community accountability and understanding of larger infrastructure and high impact projects. The EQB’s framing of “meaningful engagement” as something that “happens when all participants have the chance to feel heard and understand the basis for decisions, even if they would prefer a different outcome, (pg 5)” is inadequate. Feeling “heard” is not enough. To date, we have not seen a robust EJ community identification and engagement strategy laid out by the EQB in its Environmental Review processes. This is unacceptable given the extreme racial and economic disparities in the state of Minnesota across multiple metrics. Meaningful engagement first means a definition by the EQB of what an environmental justice community is, a tailored engagement approach to engagement of that impacted geography/population, and EJ communities being given the tools and resources to understand the technical aspects of a project to effectively provide comment and participate. Critically, any meaningful engagement must include outcome, not just process – namely the ability to affect the results positively to the benefit of impacted communities. Relying on broad surveys and individual spot interviews based on staff’s personal relationships, without a clear articulation of a coherent environmental justice engagement plan, is highly problematic. Bias informs what a “representative sample” of ER participants looks like. What measures are taken to make sure disparately impacted communities, historically marginalized peoples were/are equitably heard from and involved in this process to influence the outcome is important. How were individual interviewees chosen and what measures were taken to ensure fair representation of all Minnesotans, but most importantly representation of those that have been and will be most impacted by climate change? For example, how were transient and unsheltered populations taken into account and involved in the engagement process - how will they be taken into account in the EAW and EIS processes? 2. EQB must have a strong definition of Environmental Justice to inform its engagement processes and criteria for EAWs and EISs. Environmental Justice is the right to a clean, safe, and healthy quality of life for people of all races, incomes, and cultures, including Black, Native, and people of color. Environmental justice emphasizes accountability, democratic practices, remedying the historical impact of environmental racism, just and equitable treatment, and self-determination. How EJ areas are identified for the purpose of analysis should rely on the latest cumulative impacts data, as is emerging from the US EPA EJ Screen, MPCA MNRisk modeling, and MDH health disparities data. 3. Stricter criteria in the revised ER rule for assessing potential climate effects in EJ defined communities. It is clear that EJ communities are on the frontlines of climate change and will be disproportionately effected. Climate change will not be experienced evenly across Minnesota communities. That said, any assessment of climate effects must take into the account where the proposed project is being conducted and the population being impacted. The EQB should require projects to use tools such as EPA’s EJScreen, MPCA’s MNRisk cumulative pollution modeling, and MDH health data, along with localized community knowledge in assessing and getting a full picture of these impacts. 4. Any GHG mitigation plans for projects must have meaningful engagement, transparency, accountability and benefit to communities where projects are located. It is not enough for a project proposer to have a general plan to mitigate its GHG impacts. Communities where the proposed project is located must benefit from any proposed mitigation, and a project should be able to quantify and demonstrate that community benefit. Too often mitigation plans are negotiated between the state and project developers, with communities most impacted having no say or engagement in terms of what they see as a benefit. Emission reductions/benefit must occur where the pollution impacts are. Offsets and other mitigative measures in other locations are fundamentally unjust, as they inherently increase the pollution burden within an already impacted community. This is particularly the case for overburdened EJ communities, as GHG emissions are not emitted in isolation – they also include other toxic pollutant emissions, adding to the overall cumulative pollution burden. 5. True Cost Accounting of GHG lifetime emissions with estimations on a yearly basis. The inventory of emissions should project lifetime emissions with estimations on an annual basis. True Cost Accounting should be standard, including loss of traditional plant medicines and ecological/traditional value as well as the full environmental footprint as determined through life cycle analysis methods. This would include emissions from extraction, transportation, and raw materials used in project construction. For example, a facility constructed using concrete will account for the emissions from mining, processing, and transportation of concrete. This is important to account for even when it happens outside the State of Minnesota as the climate of the earth as a system will still impact us in Minnesota. 6. RGU conflict of interests should be resolved. The RGU or acting authority over the MEPA process for projects needs to not have a vested interest, or a real or perceived conflict of interest. For example, a City government should not be the RGU for its own City project. This is a conflict of interest and should be accounted for in the ER rules. 7. Anti-racism training by state employees and EQB board members working on Environmental Review should be required. State employees and others such as board members working on the environmental review process should be required to take annual and ongoing anti-racism development courses. This should be a preventative measure to ensure the full extent of impacts to and input from Black, Native, and people of color are considered when going through rule-making and ER. The full insidiousness of systemic racism will not be addressed if people don’t know where and how to look for it in both process and actions.
0 comment3Lane Ayresabout 1 year agoPlease add "lifecycle" emissions to the way emissions must be calculated.
Whenever I buy something I take into account all the indirect factors in determining whether the price for the item make it something I want to buy. We need to consider all the indirect and lifetime emissions for all our state projects too. Thanks!
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Who's Listening
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Email Karen.Gaides@state.mn.us