Mesaba Energy Project, PUC Docket No. E6472/GS-06-668
DOE Draft EIS for the Mesaba Energy Project (DOE/EIS-0382D)
Comments on Draft EIS
Submitted by: Citizens Against the Mesaba Project

QUESTIONS REGARDING THE MESABA ENERGY PROJECT DEIS

1. Carbon Capture and Sequestration (CCS) is arguably the main potential advantage of IGCC technology. Excelsior Energy only added their CCS "plan" when it became politically necessary to do so. MPUC Chair Koppendrayer has stated "You're in the wrong place." The DEIS states that "Excelsior has not established a detailed design for carbon capture and sequestration", and goes on to say that CCS is not feasible or economically viable for the Mesaba Energy Project.

Why allow this project to go forward if it has virtually no hope of realizing the main theoretical advantages of the technology? Given Minnesota's plan to reduce greenhouse gas emissions by 15% by the year 2015 and 80% by 2050, why would we allow a project to go forward that would be the state's 2nd largest polluter of CO2 and has no realistic hope of CCS?

2. Excelsior Energy's plan calls for the Canisteo Mine Pit to be closed to recreational use. The original Joint Permit Application outlined how this extraordinarily clear trout fishery would be ruined by concentrated discharge of cooling tower blowdown water. The appeal of the West Site for Excelsior is the availability of water that is not in the Lake Superior Watershed making it possible to discharge more mercury into our local waters. The DEIS does not reflect the importance of the CMP for local recreation. Excelsior continues to confuse the issue by discussing alternative water discharge plans based on theoretical future changes in water discharge permitting.

Why should we allow Excelsior Energy to take a rare lake trout fishery away from the public, and why should we allow them to pollute our local waters when technology exists to prevent this pollution completely?

Excelsior states that the Mesaba Project will not contribute additional mercury to the water discharge. Although they have repeatedly made this misleading statement, the reality is that the discharge water will carry highly concentrated levels of mercury, sulfates, and dissolved solids into Canisteo Mine Pit and/or Holman Lake and the Mississippi River.

Given the complex relationship of mercury in an aquatic environment, shouldn't the DEIS give accurate detail related to mercury discharge and subsequent impact? Why would the DEIS continue to repeat some of the same misleading statements given by Excelsior regarding mercury discharge? Why would the DEIS use an impact are of 3km when the mercury deposition will affect 720 lakes over 340 square km?

What is the health impact related to the 487,000 fish harvested from those lakes? Please address this health impact, especially as it relates to children and women of childbearing age. The DEIS should also address this impact relative to the information in Excelsior's JPA regarding the increased risk of cardiovascular disease in men even with low level chronic mercury exposure.

4. Adverse health consequences of the Mesaba Project are of significant local concern. Excelsior's early information to the MPUC in 2005 outlined significant negative health impacts related to air quality and plant emissions. These problems have been outlined during the Citizen's Advisory Task Force, in a letter to the MPUC signed by a majority of Itasca County physicians and nurse practitioners, and in citizen comments during the DEIS scoping. The DEIS discusses EMF health concerns, gives statistics related to the percentage of the population that is overweight, smokes, drinks, has hypertension, etc. However, the DOE/DOC ignores the real issue, which is the significant and expected increase in mortality and morbidity (death and illness) should this plant be built. The New England Journal of Medicine recently published a study outlining the 70-80% increase in heart attack and stroke for every 10 mcg/mm3 increase in PM 2.5 (See attached NJM article)

Why does the DEIS fail to address the negative health consequences directly related to the Mesaba Energy Project?

5. The DEIS lists "need" as a benefit of the Mesaba Project based on Excelsior's claim of regional baseload power need in the future. The Army Corps of Engineers and many citizens have challenged these claims, yet the DEIS then goes on to dismiss public comments refuting Excelsior's claims of "need".

Why would the DEIS ignore valid arguments contrary to Excelsior's unproven claim of need, yet list Excelsior's claim of need as a benefit of the Project?

6. The MPUC doesn't believe that the Power Purchase Agreement is in the public interest, as Excelsior's energy will be too expensive and the Project carries excessive risk.

Why does the DEIS indicate the MPUC will determine the public interest of this project, then disregard the MPUC findings/recommendations and instead reference Excelsior's press-release talking points in support of the Project?

7. The DEIS cites Excelsior's claims of economic benefit based on a single limited and poorly conducted study of economic impact that grossly overstates the Mesaba Project's economic impact. The DEIS then dismisses strong arguments against the claimed economic impact of this study stating that this will be evaluated by the MPUC. The MPUC has determined that a Power Purchase agreement with Excel Energy is not in the public interest due to the expense and risk to ratepayers. No cost benefit or total impact studies have been performed.

Why were citizen comments dismissed yet Excelsior's unfounded claims included? Why is the MPUC referenced as evaluating the economic merits of the project only to have that evaluation ignored?

8. The Minnesota DNR submitted numerous scoping comments related to water discharge and mercury deposition. The DNR has also maintained a strong interest in the Canisteo Mine Pit lake trout fishery, as well as in restoring water flow to Trout Lake (and thus improving Trout Lake water quality) from the CMP watershed.

Why does it appear that these comments have not been taken into consideration?

9. The DEIS outlines an ambitious emissions reduction program by Minnesota Power (MP), and states that these reductions would potentially offset visibility impacts related to the Mesaba Energy Project.

Why should we allow Excelsior Energy to "offset" Minnesota Power's emissions reductions and negate this improvement to our air quality?

10. The East Range site (Hoyt Lakes) carries less environmental impact than the West Range site. Although the air emissions, cost issues, and risk would be roughly the same, the West Site is more advantageous for Excelsior primarily because they can discharge higher mercury concentration water and might have greater ease obtaining land in the proposed footprint. There are many environmental disadvantages to the West Site.

Why does the DEIS appear to give preference to the more environmentally sensitive site just because of cost advantage for the developer?

11. Excelsior Energy did not perform a thorough investigation of the environmental permitting process as it relates to their original East Range site. Excelsior now says it would be too expensive to eliminate water discharge, so the West Site is preferred. This is because they apparently didn't realize the East Site is in the Lake Superior watershed and has a lower mercury standard. If this is the case, then they really don't have an "alternative" site, which is required. It may also mean that they don't even have a preferred site as their current plan won't allow permitting for water discharge. The current plan seems as poorly thought out as the first as they now need to rely on a "variance" or a possible future TMDL system which does not currently exist.

The DEIS could give scenarios on possible future options if regulations change, but the DEIS should first outline how Excelsior plans to meet permit requirements under current conditions.

12. Cumulative air quality effects are poorly outlined in this DEIS. For example, MSI already exceeds the Class I (BWCAW) limit for NOx and is supposed to buy NOx offsets to meet its permit requirement. It is unlikely these offsets will be able to be purchased. Since Mesaba is behind MSI in the permit line, Mesaba must have a NOX emission of zero, or purchase 100% of their NOx offset in addition to what MSI is supposed to buy. The DEIS makes no mention of this problem.

Why does the DEIS have such gross omissions with regard to cumulative effects? Why does the air quality modeling give no input assumptions/data? Why does the air quality information use modeling that gives low/conservative estimates?

13. The only way the Mesaba Project can meet environmental permitting criteria for water discharge (East or West site) is to totally eliminate water discharge. The DEIS gives a brief superficial description of this process.

The Final EIS should clearly indicate that total elimination of water discharge is necessary to comply with environmental regulations, and should give a detailed description of the Zero Liquid Discharge Process to be used. Only then can the actual environmental impact of the Mesaba Project be assessed as it relates to water quality.

1. Acknowledge that additional mercury, sulfates, phosphorus, dissolved solids, and suspended solids will be present in this discharge stream, leading to an overall increase of these constituents in the Swan River/Mississippi tributary system.

2. Accurately and completely describe the makeup and amounts of the constituents described above.

3. Quantify the current mass or concentration of mercury discharged to Panasa Lake from the HAMP under NPDES permit No.MN0030198.

4. Address increased concentrations of phosphorus to this discharge stream (JPA Appendix 6 Section 5) and how this relates to the Annondale-Maple Lake Court Decision (currently under appeal) which does not currently allow for any new source NPDES/SDS permits above Lake Pepin.

5. Address the ability to use NDPES permit No MN0030198 vs. the need for a new permit.

6. Address and completely describe the relationship and impact of mercury and sulfur with regard to increased methyl-mercury formation and discharge limits on methyl-mercury to the Swan River system.

7. Thoroughly address the discharge of mercury and sulfur to wetlands and the anaerobic conditions of this environment leading to formation of methyl mercury.

8. Address the potential for discharge limits for methyl mercury (including secondary formation in the above environments) in addition to a total mercury discharge limit.

9. Thoroughly address the above issues with regard to increasing levels of sulfur, mercury, TDS, etc in the source water over time due to operation of the plant at the west site.

10. Quantify the average and maximum amount of dissolved solids due to concentration of TDS in this discharge stream, and identify subsequent impact on Holman Lake, Swan River, and the Mississippi River.

11. Address how adjustments of water discharged directly to Holman Lake ("every 5 years, or as needed during Phase I and II operation, to limit the mass of mercury discharged") will further impact quality of the Canisteo waters.

1. How will this testing be performed, and how will the dry cake be stored prior to transport offsite?

2. How will storage containment measures and offsite transport be accomplished or change if the materials tested are found to be hazardous?

1. Quantify the maximum and average amounts of solids discharged to Holman Lake and Canisteo Lake in the absence of a ZLD system on the West Site.

2. Quantify the maximum and average amounts of solids requiring disposal with a ZLD system for cooling tower blowdown at the West Range Site.

3. Address appropriate disposal of these solids, and where this landfill would be located.

4. Address any potential environmental impact from this landfill.

1. Give citations of the DOE referenced studies.

2. Describe the performance upgrades that Wabash River required to meet discharge permit criteria for selenium, arsenic, and cyanide.

3. Submit data from Wabash River proving subsequent ability of that plant to meet these discharge permit limits.

1. Provide details on the acres and types of wetlands that will be affected.

2. Provide detail on how extensive these water table control measures would be, and how such measures would be accomplished.

3. Describe in detail how loss of wetlands will be mitigated.

1. The preferred route selection and alternatives do not list the amount of existing right of way vs. need for new property easements along each proposed route.

2. A list of affected landowners is not included, nor have landowners been notified.

3. HVTL routes should include information on landowners already affected by existing right of way, and separately identify landowners who will be affected by new right of way.

4. Identify the necessary upgrades required beyond Blackberry as well as the landowners affected by these upgrades.

1. The proposed routes do not detail or compare the number of properties on existing corridors vs. new corridors.

2. There is an existing NG pipeline (Northland?) from Virginia and Hibbing that currently goes to the MSI site, and is much closer to the proposed MEP West Range Site. This route would appear to have significantly less impact on landowners and would follow an existing corridor.Why is this route (with the required upgrade) not included as an alternative to the routes proposed?

1. Alternative 3 appears to have the least impact on undisturbed land, is the shortest route, and has more existing corridor than the preferred option. How many property owners are in the new corridor vs. existing corridor for this proposal?

2. Alternative 2 is the longest route, but has over 10 miles of existing corridor and 5 affected property owners. How many property owners are in the new vs. existing corridor for this route?

3. Explain why, in light of the above questions, Alternative 1 is preferred.

4. Please also see alternative route submitted in DEIS comments by Bob Norgard, Bovey

1. Excelsior Energy has claimed that carbon capture is viable option, yet how can this be if the system is yet to be engineered?

2. If, as Excelsior Energy states, CO2 caps/limits are inevitable, why not plan to capture CO2 now?

3. If a main advantage of IGCC technology is CO2 capture, why not plan to do this from the start?

4. How much CO2 capture is possible?

5. Given the geology of this region and inability to sequester CO2 in Minnesota, what are the details of a long term plan for CO2 sequestration?

6. What is the expected decrease in capacity and efficiency of the plant fitted for carbon capture? If carbon capture is not cost efficient IGCC may not be the right technology for this project. Alternatively, if carbon capture is cost efficient it should be put in place from the start.

1. If the Eastman process has been shown to remove 95% of mercury, why does this section state only 90%? The DEIS should hold Excelsior Energy to the higher standard.

1. The company needs to commit to detailed measures for handling these waters and thus prevent ground water and municipal water contamination.

2. The DEIS does not adequately describe the impact of fugitive particulates from incoming or exiting rail cars, especially with regard to impacts on nearby local communities including Taconite, Marble, Bovey, Coleraine, Grand Rapids, Cohasset, and Deer River.

1. How and when will this WWTF be updated?

2. This is a local issue in that there will be a direct financial impact on the local municipalities. What technology upgrades need to be evaluated if the local municipal WWTF is utilized for the MEP. What is the cost of this upgrade directly attributable to the MEP, and how does this compare to potential cost shifting to the public at the East Range Site?

1. The project plan as described will direct cooling tower blowdown(CTB) discharge water to the Canisteo Mine Pit which currently has clarity to depths of over 50 ft. The CTB discharge water will result in increasing levels of mercury, sulfates, TDS, etc. If the company's statement is to be accurate, they need to commit to ZLD on the CTB.

2. Flood control of the Canisteo water will be accomplished through a planned siphon independent of the MEP. This siphon will be built regardless of if the MEP is approved or not. Trout Lake water quality will benefit from the discharge of low phosphorous CMP water to Trout Lake. The Trout Lake Association is on record as being in support of receiving water from this siphon, and a recent survey cited by lake association members revealed Trout Lake residents to be in favor of siphoning CMP to Trout Lake by an 8:1 vote.

1. The wide range of influence is the 7 county area (Aitkin, Carlton, Cook, Itasca, Koochiching, Lake and St. Louis) the local range of influence is Census Tract 9810 (Iron Range Twp and Taconite) for the West Range Site and Census Tract 140 (Hoyt Lakes) for the East Range Site. The economic analysis is supposedly for the 7 county area the population and housing analysis is done from the Census Tracts.

2. The BBER, 2006 study does not do a cost/benefit analysis; it is strictly a benefit analysis. Even the BBER authors recognize this and caution against using their study as a complete view of the impacts of building Mesaba Phase I and II.

3. The BBER study is misleading in stating the economic value to Itasca County or the seven county wide range of influence. That is because much of the economic value supposedly coming to the area in the form of costs for coal, transportation, profits, interest, etc will actually be accrued where those services are provided or purchased. Most wages will be provided in Itasca County although 20% are estimated to be provided to residents of other counties.

4. The BBER study estimates the number of jobs that would be created in construction and during operation of Phase I and II as well as additional positions created as a result of having additional workers in the area. However, these predictions should be tempered as the job estimates are a combination of full time, part time and temporary positions.

5. Most of the construction and plant operation positions will be filled by people outside of Itasca County. That number will rise if this is a union construction job. This has direct negative impacts on housing in the area during the construction period.

6. The EIS assumes that there will be an available skilled labor force in the region due to, "...historically persistent higher unemployment rates..." and a decrease in the manufacturing and iron mining industries. It is not at all certain that jobs in iron mining and/or manufacturing are transferable to construction or operation jobs that Mesaba Phase I and II would provide. Continued investment in iron mining and the specter of Minnesota Steel would suggest that there will be a dramatic shortage of skilled labor for construction positions, requiring that more outside skilled labor be hired and housed in Itasca County.

7. The discussion of jobs, wages and employment is occurring in a vacuum. No mention is made of the impact that Minnesota Steel will have on the same population of workers that Mesaba will be trying to hire from. Job competition will be fierce if both are built at the same time. Although this is good news for a few people hired locally with an existing domicile the influx of workers and the shortage of housing will dramatically increase rental and housing costs to the detriment of imported workers through higher rentals, local homeowners through artificially increased property values and taxes and low-income non-skilled individuals and families through increased rental costs and wages that do not keep pace with the increased cost of housing.

8. Most if not all of the discussion in this section references dollars or employment that would be gained if Mesaba Phase I and II are built. Therefore the economic benefits are being overestimated given the scope of the proposed building. The permitting process is asking only for Phase I yet the economic analysis is offering figures for Phase I and II combined. We need to see an EIS that accurately compares all costs and benefits for Phase I, as well as for subsequent phases.

9. The proposed relocation of Itasca County Road 7, the Scenic Highway, is considered to be an act of Itasca County and not the Mesaba Project. Considering the fact that CR7 was recently (within the past 5 years) rerouted and resurfaced from 169 north along its original route at considerable expense it is obvious that an additional rerouting is being done to convenience the Mesaba Project at the expense of Itasca County taxpayers and should be at the very least considered an additional cost of the project.

10. The EIS estimates that, "Perhaps a dozen or more of the other residential properties along CR 7 and Diamond Lake Road closest to the plant site or rail alignment may experience reductions in values or at least slower rates of growth in values." (4.11-7)

11. The EIS states that, "...it is unlikely that residential properties along the proposed new HVTL corridors would experience substantial reduction in property values." Then proceeds to indicate that depending on the route chosen between 4 and 29 residences would be within 500 feet with some as close as 300 feet. I cannot imagine how these residences would not experience a negative impact to their property value. (4.11-7 and 8)

12. The EIS attempts to indicate that housing of temporary construction workers would be easier at the West Range vs. East Range site. This is not necessarily true, especially if Minnesota Steel is being constructed at the same time. (4.11-8)

13. The East Range site impacts fewer homeowners because the East Range site is a true brownfield site with existing infrastructure. This would reduce impacts on housing values due to construction. HVTL corridors would have to be widened and 49 residences are within 500 feet but the EIS states, "...it is unlikely that property values along these corridors would be affected by the additional HVTLs." in part because their values are already being impacted by existing HVTLs.

14. Consider that the economic impact is thought to be a 7 county region, or even throughout Minnesota, but areas that might be adversely affected are considered to be individual blocks within a Census Tract, or just along HVTL corridors and utility ROWs. This is inequitable.

15. Table 4.11.6 Summary of Impacts. This table claims, "Related realignment of CR7 by Itasca County may influence local housing development in vicinity" Here the EIS considers the realignment of CR7 'related' and a benefit yet does not include it as a cost. At the East Range site the lack of construction needed is considered a detriment where it should actually be a benefit.

16. The summary table 4.11.6 is not an accurate summary in that it represents the two sites (West and East Range) as being almost identical with the exception of the relocation of CR7 in the West Range plans and number of residences within rail alignments.

17. The text in section 4.11 points to numerous differences related to impacts to housing values as a result of construction and HVTL corridors, utility ROWs. The text does NOT point out that the East Range site is a brownfield site with existing utility and HVTL infrastructure and therefore more suitable for construction.

18. The socioeconomic analysis is incomplete. The Mesaba Project has to get its product to market and cannot do that without a HVTL that runs from northern Minnesota to the Twin Cities - St. Cloud area where the power is supposedly needed. This analysis does not cover the cost nor the impacts of creating an additional cross-state transmission line.

1. The region of influence for the environmental justice analysis is incredibly narrow and does not match the region of influence used for the socioeconomic analysis. Moreover, my guess is that neither would match the size of the region of influence for the true environmental impact of the Mesaba Project Phase I or Phase I and II combined. To wit, "The regions of influence for environmental justice are determined for each resource area by the potential for minority and low-income populations to bear a disproportionate share of high and adverse environmental impacts from activities within the project area." The EIS then goes on to define the project area as Census Tract 9810 for the West Range and Census Tract 140 for the East Range site. If the economic analysis can be extended to a seven county area why is the environmental justice analysis limited to a singe Census Tract for each site?

2. The environmental region of influence or environmental project area of the Mesaba Project is undoubtedly larger than a single Census Tract (here I am calling the environmental region of influence the geographic area that would receive atmospheric deposition). If this is true then the environmental justice analysis, which is charged with assessing the health effects, risk and rate of hazard exposure and potential cumulative adverse exposures, must take a larger geographic area into consideration.

3. Where is the health report that Excelsior Energy commissioned touting the 'health benefits' of the Mesaba Project. That information was not referenced in either the socioeconomic or environmental justice sections.

4. Northern Minnesota in general and Itasca County in particular is the center for the environmental region of influence. Residents of Itasca County will bear the burden of any increased health effects, any increased health risks or rates, or be affected by cumulative or multiple adverse exposures from environmental hazards. The electricity generated here, will be sent to the Twin Cities metro area where it is needed. Northern Minnesota does not need this electricity but is being asked ­ no required ­ to accept any health burden that its generation would impose. On that basis alone the environmental justice analysis should compare the environmental region of influence, which would include all of Itasca County, with the Twin Cities metro area being the control group. Then the environmental justice analysis can evaluate whether the Proposed Action or alternative would cause disproportionately high and adverse effects on minority or low-income populations in the region of influence.

5. The environmental justice analysis outside of construction sites, HVTL corridors and utility ROWs presented in this EIS is inadequate. The EIS looked at "...the potential for adverse health risks in a wider radius from respective project sites and corridors based on impact analyzed in Section 4.17, Safety and Health, and the assess the potential that an adverse health rise would affect a minority population, low-income population , or American Indian tribe at a higher rate than the general population." The term 'wider radius' was never defined and the only reference made was to effect that additional mercury deposition would have on subsistence fishing on Diamond Lake. There was no effort made to include any other health risks such as particulate matter, VOCs, NOx, SOx or other heavy metal contamination from airborne deposition, nor consider their impact either individually or as cumulative or multiple adverse exposures as required in the Method of Analysis.

6. Somewhere I heard a woman testify that the West Range site is within view of a proposed American Indian retirement home. If this can be substantiated, even if it has not been built but exists only as purchased property with a plan, it may trigger the low-income, minority or American Indian tribe provisions of the analysis.

7. On page 4.12-3 the EIS states that, "Mercury emission in Minnesota declined significantly (about 68 percent) from 1990 to 2000, and there is evidence that concentrations of mercury in Minnesota's fish have declined by about 10 percent, which is considered an encouraging response (MPCA, 2005)." Given this statement why would we want to go backwards towards higher levels of mercury emission? Especially since it appears that even significant declines in emissions have only relatively modest declines in the amount that is actually concentrated in fish. Clearly there is a long lag time between a decrease in mercury emissions and a decrease in mercury concentration in fish. This is consistent with the idea that mercury is a bioaccumulator that is not readily removed from the environment.

1. The above referenced study was prepared/modeled for the West Range Site. Provide similar modeling for the East Range Site.

2. The "health benefits" modeled are compared to a Super Critical Pulverized Coal Plant in Central Minnesota. Placing the modeled SCPC plant near a higher density population makes the expected health implications appear to have a substantially greater impact (and thus MEP would have a greater "benefit") than would otherwise be the case. The modeling should compare health risk of both plants in the same location in order to assess the actual differences in adverse air quality and health impact.

3. A SCPC plant would not be the only alternative to IGCC. If the air emission and health impact comparison between IGCC and SCPC is to be made, the company should also model other forms of power production including alternative energy sources, especially given that this project is labeled an innovative energy project and has received renewable energy funding.

4. REMSAD modeling uses PM2.5, not PM10 (emissions of approximately 440 tons/year) as is listed in the emissions data of the JPA. With regard to particulates, PM2.5 is thought to have the most significant adverse impact on human health. What are the average and maximum emissions of PM 2.5 from MEP I/II? Give data for both East and West Range Sites.

5. Chapter three of this study indicates that individuals with asthma, COPD (emphysema), chronic bronchitis, and heart disease are at greatest risk from particulates. "There will be a measurable effect on air quality up to 70-80 km from the plant,Š and a peak effect near the plant location with lesser impacts surrounding the plant in all directions." "Areas with higher proportions of older residents will have higher estimated risks owing to their higher Œbackground' mortality risks.


A. The company should describe the specific increase in health risk for people in nearby communities as well as individuals with co-morbidities and the elderly.

B. In addition, the company should address health impacts/risk for Native American elders with regard to the senior housing facility and interpretative center planned just off Hwy 169 near the Scenic Highway.

6. Compared to a hypothetical SCPC plant, the Mesaba Energy Project is expected to result in 1.5 fewer deaths per year in Minnesota for phase I, and 6.4 fewer deaths nationally. The report assumes doubling of this death rate in phase II. The information appears to indicate that MEP I/II would be responsible for 10.7 deaths nation wide, with 24% of those deaths occurring in Minnesota. Additionally, the report states that "It can be seen that mortality risks associated with the IGCC Power Station are both somewhat lower and more concentrated around the facility than the estimated risks associated with the Alternative SCPC plant". The company should quantify the "somewhat lower and more concentrated" risk in the area around the facility, and how this risk increases for nearby residences and municipalities.

7. The study is modeled on the original stack height. The current planned stack height has been lowered by about 100 ft for "aesthetic reasons" according to the Baxter testimony to the MPUC. Describe the aesthetic improvement for both the stack and the emissions plume, and contrast this with the increase in adverse local air quality and health impacts.

8. Morbidity (non-fatal health effects) related to particulate matter are described in the ICF Consulting study. Data is given for morbidity related to PM2.5 (cases per year in Minnesota) including:



Acute bronchitis	1.6
Non-fatal MI (heart attack)	1.9
Asthma exacerbation	100
ER visits for asthma	1.3
Lower respiratory illness	19
Minor restricted activity days	791
Work loss days	18,313



The company should:
A. Give the range expected for these morbidities in a given year, and adjust for seasonal variation.

B. Give the expected number and range of clinic or urgent care visits, and factor this in to projected costs both to the State, and to local health care facilities and health insurance plans such as Itasca Medical Care (IM Care).

C. Explain the apparent discrepancy between low numbers of minor respiratory illness, significant number of minor restricted activity days, and the seemingly out of proportion number of work loss days.

D. Describe the cost of these 18,000 work loss days to the average family affected, as well as the affect on employers needing to cover for sick workers.

9. Secondary formation of particulate matter can have a significant impact on human health.


A. The JPA should address air quality modeling and adverse health consequences, both local and regional, with regard to secondary particulates.

B. Provide similar analysis of secondary particulate matter health impacts for the general population, individuals with co-morbidities, and the elderly.

10. Ground level ozone health concerns and formation of smog need to be addressed by Excelsior Energy. Nitrous oxides contribute to formation of secondary particulate matter, and also play a major role in formation of ground level ozone. Volatile organic compounds (VOC) and nitrous oxides (NOx) combine in the presence of light and heat to form ozone. The Minnesota Department of Health indicates ozone exposure can lead to respiratory infections and inflammation and that one third of healthy adults are sensitive to the effects of ozone.

The Minnesota Department of Health also states that on hot sunny days, ozone concentrations can rise to unhealthy levels, and ozone transport can cause elevated levels in rural areas. MEP I/II will emit approximately 2700 tons of NOx/yr and 152 tons of VOC/yr. Because this will increase levels of ground level ozone, Excelsior Energy should address the following:


A. Estimate the increase in risk for developing childhood asthma

B. Estimate risk attributable to ozone exposure for people with co-morbidities, including children, individuals with lung disease, and the elderly. Provide details on average risk as well as risk on hot sunny days.

C. Estimate the health risk for healthy individuals and children exercising outdoors on hot sunny days.

11. The Excelsior commissioned study indicates that 7,780 women of child-bearing age reside in the mercury deposition impact zone of MEP I. The phase I mercury impact zone encompasses 720 lakes in which 487,000 fish are harvested. The company should:


A. Provide a clear detailed analysis of how lakes in this impact zone will be affected by additional mercury deposition.

B. Provide details and analysis of this plant's mercury speciation. Clearly chart/graph the local lake impact over time given emissions of elemental mercury, methyl-mercury, and secondary methylation of elemental mercury.

C. Provide information regarding which of these 720 lakes have been tested and how many have fish consumption advisories for mercury.

D. Provide details of health risk analysis for women of childbearing age who live in this mercury impact zone.

12. The Excelsior commissioned study states "Recent research has indicated that low-level chronic exposure to methyl-mercury via fish consumption may be linked with a higher risk of serious cardiovascular impacts in men, including MI, coronary artery disease, and other cardiovascular disease." Estimate the public's adverse health risk given increasing mercury concentrations over time with respect to the MEP.

1. The company should provide details of how such impacts will be prevented and at what reduction of water levels is it possible that this will occur. If this situation does occur, how will the company and municipalities be affected and deal with this situation?

2. In this situation, how such water level reductions or even lesser reductions of water levels affect Coleraine and Bovey water supplies as these wells are not nearly as deep, and may receive recharge from more superficial layers above the ore body?

Aesthetics - "the West Range HVTL is shorter" this is not true as additional transmission lines will be required at the West Site.

Public Services - the new infrastructure could be able to serve other businesses at the east site as well.

Tourism - any benefit from the lower levels in the lake may be offset by the deterioration in Water Quality over time. This table needs to reflect all aspects and impacts.

Air Quality - the table says that the West site will have less impact on the BWCA since it is further away, however due to prevailing winds being from the west and south west, the West site may have a much more significant impact on the BWCA since emissions may travel in this direction more of the time. The EIS needs to provide wind direction as a function of time for each site and also by season in order to be able to determine exactly what the level of emissions are for each site and to be able to make an accurate comparison.

Electric Transmission "the West Range HVTL is shorter" this is not true as additional transmission lines will be required at the West Site. The EIS needs to reflect the impact of all transmission lines required by this project.

Railroad/ Truck The table does not mention that the East Site has existing railroad right of way adjacent to the site. The West site will require a number of miles of railroad right of way including some crossings of residential property.

Energy Efficiency The table is not complete. The table does not mention the additional transmission line losses at the West Site that result from the POI to the users at Xcel Energy vs. the East Site.

The table also mentions the additional energy required to run the ZLD system at the East Site but does not address the energy required to pump water to the West Site. The Table should reflect all parasitic energy uses correctly.

1. The project plan as described will direct cooling tower blowdown (CTB) discharge water to the Canisteo Mine Pit which currently has clarity to depths of over 50 ft. The CTB discharge water will result in increasing levels of mercury, sulfates, TDS, etc. If the company's statement is to be accurate, they need to commit to ZLD on the CTB.

2. Flood control of the Canisteo water will be accomplished through a planned siphon independent of the MEP. This siphon will be built regardless of if the MEP is approved or not. Trout Lake water quality will benefit from the discharge of low phosphorous CMP water to Trout Lake. The Trout Lake Association is on record as being in support of receiving water from this siphon, and a recent survey cited by lake association members revealed Trout Lake residents to be in favor of siphoning CMP to Trout Lake by an 8:1 vote.

1. How and when will this WWTF be updated?

2. This is a local issue in that there will be a direct financial impact on the local municipalities. What technology upgrades need to be evaluated if the local municipal WWTF is utilized for the MEP. What is the cost of this upgrade directly attributable to the MEP, and how does this compare to potential cost shifting to the public at the East Range Site?

1. If the Eastman process has been shown to remove 95% of mercury, why does this section state only 90%?

1. The proposed routes do not detail or compare the number of properties on existing corridors vs. new corridors.

2. There is an existing NG pipeline (Northland?) from Virginia and Hibbing that currently goes to the MSI site, and is much closer to the proposed MEP West Range Site. This route would appear to have significantly less impact on landowners and would follow an existing corridor. Why is this route (with the required upgrade) not included as an alternative to the routes proposed?

Issues of local concern include:

1. Alternative 3 appears to have the least impact on undisturbed land, is the shortest route, and has more existing corridor than the preferred option. How many property owners are in the new corridor vs. existing corridor for this proposal?

2. Alternative 2 is the longest route, but has over 10 miles of existing corridor and 5 affected property owners. How many property owners are in the new vs. existing corridor for this route?

3. Explain why, in light of the above questions, Alternative 1 is preferred.

1. Acknowledge that additional mercury, sulfates, phosphorus, dissolved solids, and suspended solids will be present in this discharge stream, leading to an overall increase of these constituents in the Swan River/Mississippi tributary system.

2. Accurately and completely describe the makeup and amounts of the constituents described above.

3. Quantify the current mass or concentration of mercury discharged to Panasa Lake from the HAMP under NPDES permit No.MN0030198.

4. Address increased concentrations of phosphorus to this discharge stream (JPA Appendix 6 Section 5) and how this relates to the Annondale-Maple Lake Court Decision (currently under appeal) which does not currently allow for any new source NPDES/SDS permits above Lake Pepin.

5. Address the ability to use NDPES permit No MN0030198 vs. the need for a new permit.

6. Address and completely describe the relationship and impact of mercury and sulfur with regard to increased methyl-mercury formation and discharge limits on methyl-mercury to the Swan River system.

7. Thoroughly address the discharge of mercury and sulfur to wetlands and the anaerobic conditions of this environment leading to formation of methyl mercury.

8. Address the potential for discharge limits for methyl mercury (including secondary formation in the above environments) in addition to a total mercury discharge limit.

9. Thoroughly address the above issues with regard to increasing levels of sulfur, mercury, TDS, etc in the source water over time due to operation of the plant at the west site.

10. Quantify the average and maximum amount of dissolved solids due to concentration of TDS in this discharge stream, and identify subsequent impact on Holman Lake, Swan River, and the Mississippi River.

11. Address how adjustments of water discharged directly to Holman Lake ("every 5 years, or as needed during Phase I and II operation, to limit the mass of mercury discharged") will further impact quality of the Canisteo waters.

1. How will this testing be performed, and how will the dry cake be stored prior to transport offsite?

2. How will storage containment measures and offsite transport be accomplished or change if the materials tested are found to be hazardous?

1. Quantify the maximum and average amounts of solids discharged to Holman Lake and Canisteo Lake in the absence of a ZLD system on the West Site.

2. Quantify the maximum and average amounts of solids requiring disposal with a ZLD system for cooling tower blowdown at the West Range Site.

3. Address appropriate disposal of these solids, and where this landfill would be located.

4. Address any potential environmental impact from this landfill.

1. Give citations of the DOE referenced studies.

2. Describe the performance upgrades that Wabash River required to meet discharge permit criteria for selenium, arsenic, and cyanide.

3. Submit data from Wabash River proving subsequent ability of that plant to meet these discharge permit limits.

1. Provide details on the acres and types of wetlands that will be affected.

2. Provide detail on how extensive these water table control measures would be, and how such measures would be accomplished.

3. Describe in detail how loss of wetlands will be mitigated.

1. The preferred route selection and alternatives do not list the amount of existing right of way vs. need for new property easements along each proposed route.

2. A list of affected landowners is not included, nor have landowners been notified.

3. HVTL routes should include information on landowners already affected by existing right of way, and separately identify landowners who will be affected by new right of way.

4. Identify the necessary upgrades required beyond Blackberry as well as the landowners affected by these upgrades.

1. Acknowledge that additional mercury, sulfates, phosphorus, dissolved solids, and suspended solids will be present in this discharge stream, leading to an overall increase of these constituents in the Swan River/Mississippi tributary system.

2. Accurately and completely describe the makeup and amounts of the constituents described above.

3. Quantify the current mass or concentration of mercury discharged to Panasa Lake from the HAMP under NPDES permit No.MN0030198.

4. Address increased concentrations of phosphorus to this discharge stream (JPA Appendix 6 Section 5) and how this relates to the Annondale-Maple Lake Court Decision (currently under appeal) which does not currently allow for any new source NPDES/SDS permits above Lake Pepin.

5. Address the ability to use NDPES permit No MN0030198 vs. the need for a new permit.

6. Address and completely describe the relationship and impact of mercury and sulfur with regard to increased methyl-mercury formation and discharge limits on methyl-mercury to the Swan River system.

7. Thoroughly address the discharge of mercury and sulfur to wetlands and the anaerobic conditions of this environment leading to formation of methyl mercury.

8. Address the potential for discharge limits for methyl mercury (including secondary formation in the above environments) in addition to a total mercury discharge limit.

9. Thoroughly address the above issues with regard to increasing levels of sulfur, mercury, TDS, etc in the source water over time due to operation of the plant at the west site.

10. Quantify the average and maximum amount of dissolved solids due to concentration of TDS in this discharge stream, and identify subsequent impact on Holman Lake, Swan River, and the Mississippi River.

11. Address how adjustments of water discharged directly to Holman Lake ("every 5 years, or as needed during Phase I and II operation, to limit the mass of mercury discharged") will further impact quality of the Canisteo waters.

1. How will this testing be performed, and how will the dry cake be stored prior to transport offsite?

2. How will storage containment measures and offsite transport be accomplished or change if the materials tested are found to be hazardous?

1. Quantify the maximum and average amounts of solids discharged to Holman Lake and Canisteo Lake in the absence of a ZLD system on the West Site.

2. Quantify the maximum and average amounts of solids requiring disposal with a ZLD system for cooling tower blowdown at the West Range Site.

3. Address appropriate disposal of these solids, and where this landfill would be located.

4. Address any potential environmental impact from this landfill.

1. Give citations of the DOE referenced studies.

2. Describe the performance upgrades that Wabash River required to meet discharge permit criteria for selenium, arsenic, and cyanide.

3. Submit data from Wabash River proving subsequent ability of that plant to meet these discharge permit limits.

1. Provide details on the acres and types of wetlands that will be affected.

2. Provide detail on how extensive these water table control measures would be, and how such measures would be accomplished.

3. Describe in detail how loss of wetlands will be mitigated.

1. The preferred route selection and alternatives do not list the amount of existing right of way vs. need for new property easements along each proposed route.

2. A list of affected landowners is not included, nor have landowners been notified.

3. HVTL routes should include information on landowners already affected by existing right of way, and separately identify landowners who will be affected by new right of way.

4. Identify the necessary upgrades required beyond Blackberry as well as the landowners affected by these upgrades.

The above reference study should be prepared/modeled for the East Range Site.

The modeling should compare health risk of a Super Critical Pulverized Coal Plant in the same location as the IGCC facility in order to assess the actual differences in adverse air quality and health impacts.

The company should also model other forms of power production including alternative energy sources.

Emissions of PM2.5 should be evaluated. What are the average and maximum emissions of PM 2.5 from MEP I/II? Provide data for both the East and West Range sites.

The company should provide details of how such impacts will be prevented and at what reduction of water levels is it possible that this will occur. If this situation does occur, how will the company and municipalities be affected and deal with this situation?

In this situation, how do such water level reductions or even lesser reductions of water levels affect Coleraine and Bovey water supplies as these wells are not nearly as deep, and may receive recharge from more superficial layers above the ore body?

What impact might the potential need for permanent groundwater table control have upon the West Range Site?

-Mesaba shows an existing background of Sulphur Dioxide (SO2) at 10 ug/m3 in 1 hour, while MN Steel shows 90.

-Mesaba shows background Nitrogen Oxide (NOx) being 5 annually, while MN Steel shows it as being 12.
(MNSteel page 4-91, Mesaba page 4.3-11).

-Mesaba does not include Isle Royale.

-Mesaba does not include wet or dry deposition information for sulfur and nitrogen, or ozone concentrations info.

-MN Steel shows that the maximum allowed SO2 concentrations in 3 hr period in the BWCAW is 10.8, but Mesaba's DEIS indicates it's 1.5.
(MNSteel page 4-92, Mesaba 4.3-13).

• The generation of 1,212 MWe to help alleviate the need within Minnesota for 3,000 to 6,000 MWe of new baseload power generation over the next 15 years (Section 1.4.1.1).

• There will be an increased component of red, white and jack pine, cedar, tamarack, spruce and fir.
• The forest will have a range of species, patch sizes, and age classes that more closely resemble natural patterns and functions within this landscape.
• The amount of forestland and timberland will not decrease using FIA definitions for timberland and forestland. Large blocks of contiguous forest land that have minimal inclusion of conflicting land uses will be created and/or retained for natural resource and ecological benefits and to minimize land use conflicts

• The amount of forestland and timberland will not decrease using FIA definitions for timberland and forestland. Large blocks of contiguous forest land that have minimal inclusion of conflicting land uses will be created and/or retained for natural resource and ecological benefits and to minimize land use conflicts (hereafter referred to as "natural resource emphasis areas").

• In large blocks of contiguous forestland retain critical natural shoreline on lakes for scenic, wildlife, water quality and other natural resource values.