Comments on EQB Standards & Criteria
October 4th, 2013
On September 18th, the EQB sent staff back to the drawing board to rewrite model Standards and Criteria for silica sand mining… so NOW is the time to be filing comments on your ideas for EQB Standards and Criteria. New EQB Executive Director Will Seuffert has said that at the next meeting he will trot out a schedule for these festivities:
Here’s an example — the Comment drafted on behalf of Winona Co. CASM:
So, what to do? How do write your own comments? Here’s a format and form that may prove useful, see below for suggestions:
Send comments ASAP (the sooner the better) to:
Will.Seuffert@state.mn.us
jeff.smyser@state.mn.us
bob.patton@state.mn.us
kate.frantz@state.mn.us
The legislation passed last year, Minn. Session Laws Ch. 114, sets out categories for these Standards and Criteria (remember, this is NOT rulemaking, not any specific procedure for doing this). They’re needing your thoughts on Standards and Criteria, and there are so many categories that you’re bound to have some thoughts on this.
Many people have said this is just too complicated, and what I suggest is to take it in small pieces. For example, if you care about protecting the bluffs, just select that one row:
One way to do this is to work it backwards, do your research and work from right to left:
1) “Support for language” column, where you’d list the studies that support protection of the bluffs, i.e., “DNR Eco-Regions Subsections map” (with a copy to attach to your comment);
2) “Proposed Language” using that info as basis for language, from a map, studies, state statutes, local ordinances, figure out how bluffs could be protected, such as a prohibition of mining in bluffland areas as depicted by the dark green/grey of this map:
Your comment would look like this:
Or if you’re concerned about water, again, working backwards:
1) “Support for Language” column: Goodhue County map showing Sensitivity to Pollution of the Uppermost Bedrock Aquifers (with copy of map attached to Comment):
2) “Proposed Language” column: Prohibition of mining in areas with Very High or High sensitivity to pollution of the uppermost bedrock aquifer.
Your comment would look like this:
And another example:
The catch in all of this is that your comments have to specifically relate to the legislatively mandated development of Standards and Criteria — it’s not enough to give vague generalities and rah-rah no frac sand mining here statements. And working backwards seems to be the best way to develop this, to do some basic googling and find studies. Check the Save the Bluffs reference page for some ideas:
Again, here’s a format and form that may prove useful, see below for suggestions:
Send comments ASAP (the sooner the better) to:
Will.Seuffert@state.mn.us
jeff.smyser@state.mn.us
bob.patton@state.mn.us
kate.frantz@state.mn.us
| Standards & Criteria (from statute) | Proposed language | Support for language |
| (1) Setbacks or buffers | ||
| (iv) Bluffs |
Leave a Reply