Legalectric

Yesterday I saw notice that the Minnesota Pollution Control Agency is working on an amendment to the Archer Daniels Midland (ADM) plant in Red Wing. Here’s the notice:

It’s regarded as a “major source” under the federal rules. At that plant, they make oil from soybeans, however there’s also “new raw materials for processing,” and more:

Not only is the ADM plant regarded as a “major source,” the “permit action is a major amendment” so notice has been sent out to the public. There are three options for weighing in on this:

This is the chart of projected emissions in tons:

How many pounds per year of emissions does that mean? It doesn’t say, and it should. I’ve added tons per year, and left the blanks for TOTAL because they’ve not told us what the annual emissions are, just the increase!

Maybe that’s in the Draft Air Permit?

Or maybe it’s in the Technical Support Document?

This is not my area of expertise — Alan Muller, it’s all yours!! My take is that since most of us really don’t know what this means and can’t make meaningful comments, we should have an informational meeting so we know what we’re talking about. That’s #2 on the list of participation options:

If you’d like them to hold an information meeting, here’s what they expect to see in that request, in addition to points 1, 2, and 3 above:

Public meetings are possible, though don’t hold your breath on a contested case, I’ve been involved in some pretty intense matters before the MPCA, and I’ve yet to see a contested case request granted. Public hearings have happened, so that’s something else to request if you’re wanting to see/hear public involvement.

Send written comments on the draft permit, and FYI, comments should be specific, pointing out things on specific pages, specific tables, and what they mean, what’s not included that should be, etc., again, be sure to address points 1, 2, and 3:

Get to work!!!