Category Archives: Environmental Review

DOE says it is holding HEARINGS, not meetings, on GNTL

Hot off the press, the DOE is holding DEIS HEARINGS for the Great Northern Transmission Line:

FINAL DOE Response Letter to Overland_June 23_2015_GNTL inquiry to DOE and MN DOC-1 (oops, didn’t post this one previously — and it’s the important one!!)

DOC with DOE_Letter – 20156-111735-01

The Minnesota Department of Commerce has taken to holding public “meetings” when there’s an opportunity to comment on a DEIS, but that’s NOT sufficient, and I’ve been raising that issue for years now, particularly in our rulemaking docket, Minn. R. Ch. 7850.  Here we have a joint EIS with the Minnesota Dept. of Commerce and the DOE’s Office of Electricity Delivery and Energy Reliability.

Here’s their joint initial filed notice, and notice the title:

Notice of DEIS Meetings FINAL DOC-DOE Approved (V-2)

With DOE involvement, I’d expected public hearings, and so filed a letter requesting public hearings.

Cover_DOE-Commerce_June 23, 2015

Seems the DOE is sensitive to the distinction between public MEETINGS and public HEARINGS!  Beyond that, I’m not real clear on what all this letter means, but I trust we’ll find out.

Thanks, DOE!

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Filed under DOE (Dept of Energy), Environmental Review

PUC CoN & Siting/Routing FINAL Rulemaking meeting

DraftIt’s final… that is, the FINAL meeting notice was just issued, one more go round on these draft rules for Certificate of Need (Minn. R. Ch. 7849) and Power Plant Siting Act (siting and routing of utility infrastructure) (Minn. R. Ch. 7850).

We’ve been at this for about a year and a half, maybe more, and to some extent we’re going round and round and round.

Here are the September 2014 drafts, hot off the press:

September Draft 7849

September Draft 7850

Send your comments, meaning SPECIFIC comments, not “THIS SUCKS” but comments on the order of “because of _______, proposed language for 7950.xxxx should be amended to say_______.”  It’s a bit of work, but it’s important, for instance, the Advisory Task Force parts are important because we were just before the PUC on this last week, trying to reinforce that Task Force’s are necessary, despite Commerce efforts to eliminate and/or neuter them.  That despite ALJ orders otherwise, the Final EIS should be in the record BEFORE the Public Hearings and Evidentiary Hearings (just lost a Motion to require this last month).

How can you comment?  The best way is to fire off an email to the Commission’s staff person leading this group:

kate.kahlert@state.mn.us

If you’re up to it, sign up on the PUC’s eDockets, and file your Comment in Docket 12-1246.  If you’d like your comment filed there, and can’t figure it out, please send it to me and I’ll file it for you.  It’s important that these comments be made in a way that the Commission will SEE, in a way that they cannot ignore, when this comes up before them.

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Filed under 7850, Certificate of Need, Environmental Review, PUC Filings, PUC Rulemaking Ch. 7849

Useful information? Please donate!

Cash-Register

Donate!!!  Yes, you!!   See that “PayPal” button up to the right?  Join the challenge to transmission that they don’t need and we don’t want!  Residents and Ratepayers Against Not-so-Great-Northern Transmission, an ad hoc advocacy association, has Intervened in the Certificate of Need, a public interest intervention focused on showing up to weigh in on the big picture issues (Important note, we’re aiding public participation, but not taking a position on route.).

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Filed under Certificate of Need, Environmental Review, Hearings, Information Requests, Need, Open Houses, Presidential Permit

Comment Period open through Friday 8/15

clockringing

It’s not too late!!!  Get your scoping comments in by Friday!

For some specific ideas, see this post:

DOE Scoping Hearings last week

There’s a conflict in the dates set for comments on scoping for the Environmental Impact Statement.  MN Dept. of Commerce deadline for comments is August 15, this Friday.  The DOE Comments were due August 11, Monday, but at the meetings held a couple of weeks ago, they announced they’d also accept comments through August 15, Friday.

Here’s the Commerce Notice.

From that page:

Bill Storm
Environmental Review Manager
Dept. of Commerce
85 – 7th Place E., Suite 500
St. Paul, MN  55101
 
email to: bill.storm@state.mn.us

Web Site Comment Form: Minnesota Department of Commerce Website (Comments due by August 15)

And I recommend you also send anything you send to Commerce to the DOE:

Julie Ann Smith                                                                 
Office of Electricity Delivery and Energy Reliability (OE-20)
U.S. Department of Energy
1000 Independence Avenue SW.
Washington, DC 20585

via email: Juliea.Smith@hq.doe.gov

Here’s their DRAFT Scoping that they’re planning — do review it and comment on what’s missing, things you know that others wouldn’t know.

DRAFT Scoping for EIS 20147-101149-01

Once more with feeling: It’s not too late!!!  Get your scoping comments in by Friday!

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Filed under DOE (Dept of Energy), Environmental Review

Wednesday & Thursday – DOE Scoping Hearings

Yes, it never ends.  Tomorrow, Wednesday, and Thursday, we’re having scoping hearings before the U.S. DOE (and also Commerce).  Yes, we’ve been through it before, but this is a MUCH more intense review of environmental impacts, and most importantly, ALTERNATIVES!  Please come to the meetings and let them know what SPECIFICALLY should be covered in the environmental review.

These meetings are in an open house format, and after that, a formal comment period where your comments will be taken down by a court reporter.  It’s important to give your comments to the court reporter because otherwise it won’t be part of the record and won’t be taken into consideration.  You can also send comments in to the DOE:

Comments are due by August 11, 2014.  Send comments to:

Julie Ann Smith                                                                  
Office of Electricity Delivery and Energy Reliability (OE-20)
U.S. Department of Energy
1000 Independence Avenue SW.
Washington, DC 20585
 
Via email: Juliea.Smith@hq.doe.gov

COME ON OUT TO THE MEETINGS!

Wednesday, July 23, 2014:

Kelliher, MN: Kelliher Public School, 345 4th Street NW., Kelliher, MN, 56650; Wednesday, July 23, 2014, at 11:00 a.m.

Bigfork, MN: Bigfork School, 100 Huskie Boulevard, Bigfork, MN, 56628; Wednesday, July 23, 2014, at 6:00 p.m.

Thursday, July 24, 2014:

Grand Rapids, MN: Sawmill Inn, 2301 South Hwy 169, Grand Rapids, MN, 55744; Thursday, July 24, 2014, at 11:00 a.m.

Grand Rapids, MN: Sawmill Inn, 2301 South Hwy 169, Grand Rapids, MN, 55744; Thursday, July 24, 2014, at 6:00 p.m.

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Filed under Environmental Review, Hearings, Meetings, Open Houses, Presidential Permit

July 23 & 24 — DOE & MN Dept. of Commerce Scoping

Scoping meetings — again — but this time it’s the DOE!  And Minnesota Dept. of Commerce for the Routing Permit.  You may ask why so many scoping meetings, it does get confusing.  The Dept. of Energy has been asked to issue a Presidential Permit for the border crossing for this project between Manitoba and Minnesota.  So in addition to the TWO proceedings before the Minnesota Public Utilities Commission, there’s another federal docket for this Presidential Permit (scroll down to bottom of this post for that application).  The Environmental Impact Statement for the state Routing Permit and the federal Routing Permit will be done by Commerce, and it will be more intense than their “Environmental Report” for the state Certificate of Need.

scope

So here we go again, it’s time to show up/write comments for this much more thorough Environmental Impact Statement.

Comments are due by August 11, 2014.  Send comments to:

Julie Ann Smith                                                                  
Office of Electricity Delivery and Energy Reliability (OE-20)
U.S. Department of Energy
1000 Independence Avenue SW.
Washington, DC 20585
Via email: Juliea.Smith@hq.doe.gov

Wednesday, July 23, 2014:

Kelliher, MN: Kelliher Public School, 345 4th Street NW., Kelliher, MN, 56650; Wednesday, July 23, 2014, at 11:00 a.m.

Bigfork, MN: Bigfork School, 100 Huskie Boulevard, Bigfork, MN, 56628; Wednesday, July 23, 2014, at 6:00 p.m.

Thursday, July 24, 2014:

Grand Rapids, MN: Sawmill Inn, 2301 South Hwy 169, Grand Rapids, MN, 55744; Thursday, July 24, 2014, at 11:00 a.m.

Grand Rapids, MN: Sawmill Inn, 2301 South Hwy 169, Grand Rapids, MN, 55744; Thursday, July 24, 2014, at 6:00 p.m.

Here’s the Federal Register Notice:

Federal Register — Notice of Intent to Prepare an Environmental Impact Statement and conduct Public Scoping Meetings, and Notice of Floodplains and Wetlands Involvement; Great Northern Transmission Line

What’s going to happen when?  So far we only have a Scheduling Order for the Certificate of Need Docket:

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Filed under Environmental Review, Presidential Permit, Routing Docket

TODAY! Notice of Intent to Prepare EIS

turkeyvulture

It’s official, and thanks to the little birdie for letting me know!

Here is is in pdf:

GNTL NOI 06272014

There is no way I’d ever catch anything in the Federal Register — guess I’d better fine tune my google alerts!

Federal Register — Notice of Intent to Prepare an Environmental Impact Statement and conduct Public Scoping Meetings, and Notice of Floodplains and Wetlands Involvement; Great Northern Transmission Line

Scoping meetings will be held at locations, below, on July 16th & 17th and 23rd & 24th.  Mark your calendars!

Interested parties are invited to participate in the scoping process, both to help define the environmental issues to be analyzed and to identify the range of reasonable alternatives. DOE invites interested agencies, organizations, Native American tribes, and members of the public to submit comments to assist in identifying significant environmental issues and in determining the appropriate scope of the EIS. Written and oral comments will be given equal weight. Public scoping meetings will be held at the locations, dates, and times as indicated below:

1. Roseau, MN: Roseau Civic Center, 121 Center Street East, Roseau, MN, 56751; Wednesday. July 16, 2014, at 11:00 a.m.

2. Baudette, MN: Lake of the Woods School, 236 15th Ave. SW., Baudette, MN, 56623; Wednesday, July 16, 2014, at 6:00 p.m.

3. Littlefork, MN: Littlefork Community Center, 220 Main Street, Littlefork, MN, 56653; Thursday, July 17, 2014, at 11:00 a.m.

4. International Falls, MN: AmericInn, 1500 Highway 71, International Falls, MN, 56649; Thursday, July 17, 2014, 6:00 p.m.

5. Kelliher, MN: Kelliher Public School, 345 4th Street NW., Kelliher, MN, 56650; Wednesday, July 23, 2014, at 11:00 a.m.

6. Bigfork, MN: Bigfork School, 100 Huskie Boulevard, Bigfork, MN, 56628; Wednesday, July 23, 2014, at 6:00 p.m.

7. Grand Rapids, MN: Sawmill Inn, 2301 South Hwy 169, Grand Rapids, MN, 55744; Thursday, July 24, 2014, at 11:00 a.m.

8. Grand Rapids, MN: Sawmill Inn, 2301 South Hwy 169, Grand Rapids, MN, 55744; Thursday, July 24, 2014, at 6:00 p.m.

The scoping meetings will be structured in two parts: first, a “workshop” period with presentations on the proposed GNTL Project, and the state and federal decisions, followed by informal discussion that will not be recorded; and, second, the formal taking of comments with transcription by a court stenographer. The meetings will provide interested parties the opportunity to view proposed project exhibits, ask questions, and make comments. The Applicant, DOE, and MN DOC-EERA will be available to answer questions and provide additional information to attendees to the extent that additional information is available at this early stage of the proceedings.

Persons submitting comments during the scoping process, whether orally or in writing, will receive either paper or electronic copies of the draft EIS, according to their preference. Persons who do not wish to submit comments or suggestions at this time but who would like to receive a copy of the document for review and comment when it is issued should notify Julie Ann Smith as provided above, with their paper-or-electronic preference.

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Filed under DOE (Dept of Energy), Environmental Review

Scoping Comments due Friday @ 4:30 p.m.

scope

No, not that kind of scoping, for scoping of the Environmental Report, or is it THIS Environmental Report… whichever, it’s this kind of scoping:

Scope involves getting information required to start a project, and the features the product would have that would meet its stakeholders requirements.

In this case, it’s Environmental Report, or Environmental Report, and not Environmental Impact Statement (that is an issue that should be raised, see below, and the rules pertaining to an EIS in a Certificate of Need proceeding), and they’re looking for what all specifically should be included in this “Environmental Report.”

RRANT Scoping Comment

There’s a “Draft” scoping decision that has the rough outline:

DRAFT ER Scoping document

What to submit for comments?  Well, it’s got to be specific!  They have general categories, and if you have something specific for consideration within these categories, send it in!  And if there is an environmental consideration NOT addressed here, send it in!

Comments are due by 4:30 p.m. on Friday, March 14, 2014.

Send to bill.storm@state.mn.us

Some ideas:

  • Cumulative impacts must be addressed.  I’ve heard of an instance where someone was hit with a pipeline and a transmission line recently, and now Minnesota Power is proposing getting hit AGAIN for the GNTL!  “You’ll get used to it?”  Nooooo, that’s not within the realm of rational response or probable outcomes.  How are the impacts of multiple projects balanced with Minnesota’s policy of “non-proliferation,” where transmission is to be run on “pre-existing” corridors?  Where transmission is routed on greenfield, and then followed by other infrastructure, over and over and over… how is this taken into account?
  • The full range of potential electric and magnetic fields must be addressed, not just a minimal number that’s a small percentage of potential capacity (as is usually done by Commerce’s EIS/ER — NOT acceptable).
  • Alternatives will be analyzed — but what alternatives — alternatives to what?  This is a project “needed” to transmit a nominal amount of electricity under a PPA between Minnesota Power and Manitoba Hydro, and the rest is for export.  So given that “need” claim, what alternatives are there?  This is transmission for profit.  Is the search on for another revenue stream for them?  Are there alternatives to satisfy this “want” that pretends to be a need?  How will the state handle this?
  • Because of the magnitude of this line, so many miles long and such high capacity, an Environmental Impact Statement should be completed, not just this Environmental Report (p.s., there’s no provision under MEPA, 116D, for “Environmental Report” as an environmental document).

And if you’re interested in the Canadian “Independent Expert” report on environmental considerations, and remember, this is for the WHOLE Canadian project:

 

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Filed under Certificate of Need, Environmental Review, PUC Filings

Electro-magnetic fields are dangerous

DSC01914

AAAAARGH… during last night’s meeting there was a question and concern expressed about electro-magnetic fields (I’ve focused primarily on magnetic fields, here and elsewhere).  The question was referred to Minnesota Power’s engineer, and was essentially dissed, then and also later by the engineer.

What Minnesota Power says about EMF in their CoN Application (201310-92766-02) (p. 45-46):

Maximum ampacity is defined for the Project as the expected capacity of the line, in this case 2,000 Amps. The projected peak loading of the line – 1,024 Amps – was derived from power system modeling of the Project under system normal conditions in a 2020 summer off-peak case with high Manitoba – United States transfers. Per IEEE Standard 644-1994 (R2008), IEEE Standard Procedures for Measurement of Power Frequency Electric and Magnetic Fields From AC Power Lines, values were calculated at minimum conductor-to-ground clearance (mid-span) at a height of one meter above ground.

Maximum amps 52.94-88.54 at the edge of the Right of Way… Projected loading at the edge of the Right of Way, 26.81 – 44.76 mG.  That’s HIGH!

Here’s their chart for the meetings:

DSC01915

Now, here is a chart showing ampacity and MVA for various voltages and configurations, taken from this chart from the SW MN 345 kV Certificate of Need proceeding (Ex 35 App 7 Conductor spec-ACSR):

Ex 35

They’re talking about ampacity of 2,000, which is higher than the chart goes.  And this is to be a 500 kV line with three conductors per phase, so the MVA rating at nominal voltage would be above 4,704 MVA.  And remember, MW are essentially MVA (ask an engineer to explain the difference).  Minnesota Power is saying that this project proposal is based on a 250 MW Power Purchase Agreement, and the potential of another 133 MW PPA.  250 + 133 = 383 MW.  Out of MVA rating at nominal voltage of 4,704.  Now I’m a math idiot, so let me get out the calculator:  4,704 – 383 = 4,321 MVA missing-in-action.  What do you think will comprise the excess capacity for this project?  Seems to me to be substantive size, type and timing issues here!

This is all about having a high capacity line to be able to market power south and eastward, let’s be clear about that.  And folks, that is NOT a public purpose, that’s all private profit for Manitoba Hydro and Minnesota Power.

Now utilities have been known to understate projected loading, and have typically never admitted potential capacity of these projects, and they’ve been outed on this before:

Bruce McKay_Affidavit_CapX 2020 Brookings-Hampton Routing 08-1474

Bruce McKay_Affidavit_Hiawatha CoN-10-694

Bruce McKay_Affidavit   CapX 2020 Hampton-La Crosse Routing 09-1448

The point?  They’re consistently under-representing the capacity of the line, the projected loading and the potential loading.  In calculating EMF exposures, it’s important to use both the utilities numbers (presumed low) and the MVA rating of the line.  These two points form a range of potential loading and potential EMF emissions.  This full range must be addressed in environmental review, and to not address this full range is misleading.  The full range has yet to be addressed in any environmental review I’ve seen in my nearly 20 years and that must change.

The Power Line Task Force went to the PUC about shutting down the existing 69kV line that was going to be converted to a 115 kV, a transmission line in people’s backyards.  The PUC didn’t regard it as a problem, Commissioner (former Rep.) LeRoy Koppendrayer made one of his famous statements about the safety of EMF, stating, on the record, that he had an electric blanket and every time they used it, 9 months later they had another kid.  Really… And he probably uses a cell phone without a headset too…

The Appellate Court also didn’t care… and it was probably the best oral argument I’ve done in my career…

Power Line Task Force, Inc. v.  Public Utilities Commission

The PUC and courts don’t want to get into the minefield of EMF.  Think about what it would mean if utilities were held liable for damages due to EMF?  Think of the liability!  It’d be bigger than asbestos!  Shades of The Distinguished Gentleman!

LOOKING FOR BASIC INFORMATION ABOUT ELECTRO-MAGNETIC FIELDS?

The best resource I know of is Roger Conant’s site on Power Line Health Facts, at www.powerlinefacts.com.  It looks like he’s let the site go, but it’s available on the Wayback Machine.  Here is the EMF page — CLICK HERE.  This was last captured in April, 2012.

The information that we presented in the Southeast Metro transmission line case in 2000-2001 resulted in the first denial of transmission permits by local government based on concerns about EMF.  Here’s a short version from the Power Line Facts site.  The cities of South St. Paul, Mendota Heights, and Sunfish Lake joined together to form a Steering Committee which heard the evidence (this was applied for by then Northern States Power as a local government permitting decision), and the Steering Committee decided the permits should not be granted, and then each of the local governments individually rejected the permit applications.  Great!  Until one by one, Northern States Power started throwing its weight around and filed suits against all the local governments.  Despite a thorough record and well substantiated decisions by all, they rolled and caved to Northern States Power.

Steering Committee Papers from www.powerlinefacts.com via Wayback Machine

In that case, we presented Dr. Martin Blank and Dr. Magda Havas.

Testimony of Magda Havas – SE Metro

Testimony of Dr. Martin Blank – SE Metro

We also used Dr. Blank for the Susquehanna-Roseland transmission line case to get information about EMF into the record:

Testimony of Dr. Martin Blank – Susquehanna-Roseland

Another good source is the World Health Organization:

WHO EMF home page

WHO EMF Research

WHO Environmental Health Criteria 137

Here’s their fact sheet in English on Static electric and magnetic fields: English

And their fact sheet in English on Electromagnetic hypersensitivity: English

On the  page there’s a “What’s New” (but I don’t think 2010 info is “new” though):

If you’re looking for information on EMF, you can find a lot in the internet.  Just filter it carefully, don’t believe everything you read!

You can by a Gauss Meter to go around the house and underneath operating transmission lines to get a feel for magnetic field levels.  You can get them online, pricey and cheap, and a cheaper one would probably be sufficient to learn about magnetic field levels in your environment — just google “Gauss meter” and many will pop up!

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Filed under Environmental Review, Information Requests, PUC Filings, Uncategorized

Tonight, Wednesday night, in Baudette

Live from Baudette — we’ve got internet access in the building!  Can you tell I’m trying to get today’s work done as we go?

We’re in the Ambulance Garage to talk about the “scope” of the Environmental Review, this isn’t posted on the PUC docket yet:

DRAFT ER Scoping document

Comments due by 4:30 p.m. March 14, 2014

Send to:

bill.storm@state.mn.us

DSC01911

Tracey Smetana, the Public Advisor, is presenting now:

DSC01907

Tonight we don’t have as many people as last night, but it’s a good crowd and we’re moving along through the presentation.

Now for Minnesota Power:

DSC01912

The PPA they now have is 250 MW and they’re looking at another for 133 MW.   250 + 133 = 383!  MP claims there’s an increase in demand.  They serve the Iron Range and are seeing substantial load growth and are projecting that into the future.

Now it’s Bill Storm, Dept. of Commerce:

DSC01913

One thing they’re doing a good job of is explaining the difference between Certificate of Need and Routing, and that this is all about “need.”  Each one of them raises this, and it seems people are getting the difference, but I think discounting this proceeding when/because they’re really concerned with the routing.  So if you look on p. 6 of the DRAFT ER Scoping document, now’s the time to, as Bill Storm says, to “fill in the details.”  Here’s the Draft Scope:

The environmental report will address/discuss the following matters:

1.0 INTRODUCTION
1.1 Purpose and Need
1.2 Regulatory requirements

2.0 PROJECT DESCRIPTION
2.1 General
2.2 Design
2.3 Right-of-Way Requirements and Acquisition
2.4 Construction
2.5 Operation and Maintenance
2.6 Permits

3.0 ALTERNATIVES TO THE PROPOSED HVTL
3.1 No-build Alternative
3.2 Demand Side Management
3.3 Purchase Power
3.3.1 Long term Purchase Power
3.3.2 Short term Purchase Power
3.5 Up-grading Existing Facilities
3.6 Facilities of a Different Size
3.7 New Generation

4.0 ENVIRONMENTAL AFFECTS
4.1 Air Quality
4.2 Biological Resources
4.3 Culture Resources
4.4 Geology and Soils
4.5 Health and Safety
4.6 Land Use
4.7 Noise
4.8 Socioeconomics
4.9 Transportation
4.10 Visual Impacts and Aesthetics
4.11 Water Resources (surface, groundwater, wetlands)
4.12 Waste Management and Disposal

For example, “3.5 Up-grading Existing Facilities” is one to think about, there are lines from Manitoba Hydro down to Minnesota Power territory, so why couldn’t they build those larger?  Reconductor, or raise the existing line voltage to 765 kV and that would increase the capacity.

Now David Leonhardt, and he’s the Chair of the Friends of the Big Bog State Recreation Area, which has the longest Bogwalk in the world!!  Concerned about impact of the line on the unspoiled view at the terminus of the bogwalk. He also suggests to follow the existing line that is there, but that’s in a SNAP area where they’re not allowed to put a line alongside the existing one.

John Paulsen – why can’t we follow one of the existing lines?  Bill Storm said that it’s a routing question, MP says that the routing through SNAP areas takes it off the table.  We’re following the existing as much as possible, and what we’re proposing is a much larger scale.

Charles Bruer – can you define Scientific and Natural Areas?  MP & B.S.: They’re designated tracts of lands due to characteristics, not altered by human activity.

Wendy Rogers – question about electro-magnetic force, how far does that go out from the line?  B.S.: This is one of the things I always must address in an Environmental Report.  What can we expect EMF for a 500 kV line and what do we know about it.  B.S.:  I get the normal levels from the Applicant, and then push it to failure, and report both.

Steve Weymore – wondering why the terminus east of Grand Rapids is need if it is needed for mining, I don’t see that as the terminus.  MP: Mining and expansion of load is the reason, and the number of lines going into Blackberry.

B.S.: Remember, this is need, and we’ll be getting into this again in the Routing, I expect it will probably be in May, and we’ll do a more detailed environmental review at that time.

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Filed under Certificate of Need, Environmental Review, Meetings, Open Houses