Say NO! to Gov. Walz’s Green New permitting process
Governor Tim Walz and bureaucrats in St. Paul continue to create more red tape for job creators who want to do business in Minnesota.
The latest regulations, as outlined in these draft recommendations published by the Minnesota Environmental Quality Board (EQB), would force businesses to inventory the potential greenhouse gas emissions for new projects and potentially consider ways to reduce emissions as part of an Environmental Assessment Worksheet (EAW), or an Environmental Impact Statement (EIS), if they are required to complete these assessments.
We are encouraging all of our readers to say NO! to this Green New permitting process because the new regulations will be incredibly difficult to implement, and they are likely the first step to using greenhouse gas emissions as a reason to approve or deny a proposed project.
This is very bad because making it possible to deny a permit based on greenhouse gas emissions will require subjective judgments about whether the emissions are “worth” the cost. This will open the door for bureaucrats to make politicized decisions by approving projects they like, and denying projects they don’t like.
It may feel like we are asking a lot from our readers by asking them to send emails and sign petitions right now, but these new regulations are a much bigger deal than the California car mandates because they could impact a much larger portion of the economy.
Therefore, it is crucially important for us to make sure our voices are heard and make sure the EQB knows we oppose these new regulations. The price of freedom is eternal vigilance.
Make your voice heard by taking EQB’s survey and sending them an email
EDIT: The public comment period ended April 9, 2021 and the link to the survey is expired. However, you can still send EQB an email!
Take the Environmental Quality Board’s survey by clicking here, and say that you strongly disagree with the following statements:
Statement 1: “I believe adding climate information to the Environmental Assessment Worksheet form will benefit Minnesota.”
Statement 2: “A new category requiring preparation of an Environmental Impact Statement related to greenhouse gas emissions is important for Minnesota.”
Write them an email-
Flooding the EQB with emails will show them that many Minnesotans don’t agree with the proposed changes. You can copy and paste the email below and send it to this address: Env.Review@state.mn.us
To whom this may concern,
I am writing today to voice my strong opposition to the DRAFT Recommendations: Integrating Climate Information into MEPA Program Requirements because these recommended changes will impose significant costs on Minnesota job creators and responsible governmental units (RGUs) for zero measurable environmental benefits.
I am also worried that the proposed changes to environmental assessment worksheets (EAWs) and Environmental Impact Statements (EIS) will allow the permitting process to become more politicized, especially as it pertains to replacing future oil pipelines and the proposed copper-nickel mines in Northern Minnesota.
Requiring these projects to conduct greenhouse gas emission estimates will open the door to frivolous lawsuits from environmental special interest groups, especially if a standardized format is not provided. I am therefore asking the Environmental Quality Board (EQB) to withdraw this proposal from consideration.
Huge Costs, Immeasurably Small Benefits
The proposed changes to the current environmental review process are onerous. Requiring project proposers to quantify how their projects may be affected—and affect—Minnesota’s climate trends will likely require hiring an outside consultant. Projects emitting more than 25,000 tons of carbon dioxide equivalent will also be required to identify potential mitigation strategies.
These requirements will likely constitute an enormous cost for data that serves no practical function because completely eliminating all carbon dioxide emissions in the state of Minnesota would have zero measurable impact on future global temperatures.
Future Temperature Impacts Too Small to Measure
Using the same logic used by the Obama administration in developing the Clean Power Plan, which was widely considered to be the administration’s most sweeping climate change initiative, Center of the American Experiment has estimated the temperature impact of a net-zero Minnesota.
Had it not been stayed by the Supreme Court, the Clean Power Plan would have averted 730 million tons of carbon dioxide emissions from the electric power sector annually, which would have averted 0.019 degrees C by 2100, according to the Obama administration’s own climate models. This amount is too small to accurately measure with even the most sophisticated scientific equipment.
Completely eliminating greenhouse gas emissions from Minnesota (achieving net zero) would reduce carbon dioxide emissions by 161 million tons, or 146 million metric tons. This means completely eliminating emissions in Minnesota would yield a future temperature reduction of 0.003 degrees C by 2100.
If eliminating all greenhouse gas emissions in Minnesota will have zero measurable impact on climate trends, then there is zero credible basis for the EQB to argue that it is necessary or reasonable to force project proposers to quantify emissions from individual projects in the state.
Politicizing the Permitting Process
In a December 2020 meeting where some aspects of the draft recommendations were discussed, Minnesota Pollution Control Agency Commissioner Laura Bishop implied that the data collected by these new requirements could one day be used to approve or deny new projects if new laws or regulations are enacted.
Using greenhouse gas emissions as a reason to approve or deny a project is problematic because greenhouse gas emissions are a global phenomenon. This means the marginal increase from any project in Minnesota will be small within a global context. This means the ultimate decision as to whether a given project is “worth the emissions” will be highly subjective.
For example, would a new sports stadium potentially be denied due to its carbon footprint? Because many people in the general public enjoy professional sports, it is highly unlikely that a politician would deny the construction of a new stadium based on its potential greenhouse gas emissions. For more contentious projects though, like oil pipeline replacement projects or new iron or copper mines, regulators may decide the emissions are too high.
Allowing greenhouse gases to play a role in whether a proposed project is approved or not approved appears to be the long-term goal of Commissioner Bishop, but this new regulatory power is ripe for abuse and will undermine the public’s faith in the permitting process. It may also drive economic development out of state.
Regulations Affect Business Decisions
Enacting onerous regulations in Minnesota could drive economic activity and jobs out of state and result in increased emissions.
We recently saw how Minnesota’s arcane liquor laws hampered our economy by sending would-be job creators out of state, as Tattersall distillery has announced they will be building a large cocktail hall in River Falls, Wisconsin to avoid these onerous regulations.
Adding additional information that is very politicized to the already drawn-out EAW/EIS process will further delay new projects as opponents of those projects will challenge the accuracy of this subjective greenhouse gas information and write endless comments that would need to be answered by the project proposer.
Increasing the regulatory burden in Minnesota could have unintended consequences, such as incentivizing economic development in border towns. This would be a net negative for Minnesota’s economy and environment, as other states would gain jobs, and Minnesotans would travel further to access goods or services, increasing their carbon footprint.
Encouraging More Litigation
Minnesota has seen litigation over dairy farms that are seeking to expand their operations, and I believe this troubling trend will continue if the draft recommendations are adopted. Many local government officials are part-time public servants, not full-time experts.
Collecting data on greenhouse gas emissions and posting it publicly will provide ammunition to environmental groups who will encourage their members to barrage local government officials about the need to approve or deny a project based on greenhouse gas emissions. Or, they may use public pressure to increase the mitigation measures for projects over 25,000 tons per year.
These additional permit conditions will increase the cost of development in Minnesota and eat up valuable time at meetings that may be better spent addressing other local government issues.
The Costs Outweigh the Benefits
I believe Minnesotans should strive to reduce our emissions in the smartest ways possible. This means pursuing “no regrets” emissions reductions that result in fewer emissions and help save money. Requiring more red tape to the permitting process will harm our economy for zero measurable environmental benefits.
Because Minnesota’s share of global greenhouse gas emissions is so small, using these emissions as a criterion for approving or denying projects will be more subjective than scientific, paving the way for politicized permitting decisions.
For these reasons, I am asking the EQB to withdraw these changes to the EAW and EIS from consideration.