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Heartland pollution the worst known to mankind

Fri, Jan 21st, 2005
Posted in Commentary

Editor’s note: Loni Kemp of Canton served on the Minnesota Pollution Control Agency’s Citizens’ Board from 1990 to 1994. This is the comment letter she sent to the Citizens’ Board regarding the proposed Heartland Energy & Recycling tire-burning plant. The Citizen’s Board will meet on January 25 to decide if an impact study is needed.

Dear MPCA Board Members,As a former MPCA Board member, I know how easy it is to become mired in details of studies and models when considering the need for an Environmental Impact Statement. It is the Board’s role to look at the big picture – your authority is to interpret the law on Environmental Review. I recommend a very different analysis of the four criteria for determining the potential for significant environmental effects than the staff has recommended to you. I urge you to deny the recommended action, and request your attorneys to draft a new Supplemental Finding of Fact supporting an order for a full EIS, in light of the analysis below.A. Type, extent, and reversibility of environmental effects:The law requires you to consider whether the type of environmental effect is significant. In the case of Heartland, the type of pollution is the worst known to mankind – highly toxic, persistent, and bioaccumulative chemicals. The law requires you to consider the extent of pollution. In this case we are faced with widely dispersed pollution from a tall smoke stack, contributing to some of the most alarming global environmental problems facing the country today, including mercury and PCBs. At the same time, most of the pollution will impact an area encompassing a town including the K-8 public school, the nursing home, and numerous residences. If a project had pollution that could be confined to a small spill area, then you could say the extent of impact was small. But the extent of Heartland’s pollution is vast.The law requires you to consider the reversibility of environmental effects. The pollution predicted to come from Heartland can never be cleaned up or reversed. The persistent, bioaccumulative chemicals will be dispersed into the soils, the waters, and the bodies of people and wildlife. Again, if a project had pollution that could easily be dug up or pumped out, then you could say it is reversible. Heartland’s impacts are not reversible. B. Cumulative Impacts:I respectfully suggest that the AERA study that the staff conducted missed the point by only looking for potential overlapping, additive impacts of the same chemicals being emitted from both Heartland and the ethanol plant. In fact, the cumulative impact we are most worried about is the synergy that is sometimes found (yet little studied) between different chemicals on the same population. Children breathing what might be two sets of legal emissions from two factories all their lives have a cumulative effect that must be more closely evaluated. In addition to the neighboring Pro-Corn plant, fish which are already banned from consumption due to mercury buildup will have the Heartland mercury added to the other regional sources. At this very moment MPCA is trying to develop effective policy strategies for mercury, which has been at the critical point for fish consumption for some time, so why allow additional mercury emissions from a new tire burning plant without doing the full EIS on alternatives?C. Mitigation:The law requires you to consider whether environmental impacts can be mitigated, or made less harmful. Again, pollution from Heartland cannot be cleaned up once it has spread far and wide from the stack and been deposited on land, water or in people’s bodies. An air permit could be a tool to require tighter controls in the future, or could even lead to a shut-down of the plant, but that does not mitigate pollution that has already happened. An EIS might not be needed for cases where pollution could easily be cleaned up, but that is not the case with widely dispersed air pollution.D. Extent of other available studies:The law says an EIS might not be needed if there are other available studies that would give us the information we need. However there is no other fluidized bed burner using 100% tire-derived fuel in operation anywhere – it is a novel, experimental technology for which the scaling up from pilot tests needs additional study in an EIS.This is far from the first time that an EAW has grown from a simple worksheet to thousands of pages of information and comments. However, the EAW will never become the equivalent of an EIS because it does not do the main things an EIS does. An EIS is the only study that looks at alternatives, and an EIS is the only study that looks beyond environmental impacts to also consider economic, social, and other impacts. There are several alternatives that deserve serious evaluation. We need to look at alternative ways of dealing with tires, such as new closed-system burners with no emissions at all, or alternative locations closer to the urban sources of tires. We need to look at alternative ways of generating electricity, such as wind or biomass gasification using local crops. We need to look at alternative ways to create heat to sell to the ethanol plant, such as biomass digesters that produce methane. Only an EIS lets the public consider whether a proposer has fully explored and adopted alternatives for his business that are better for the environment.

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