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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