PETITION FOR ENVIRONMENTAL ASSESSMENT WORKSHEET

We, the undersigned individuals, petition the Environmental Quality Board (EQB) for
preparation of an Environmental Assessment Worksheet (EAW) for the proposed Midtown Eco
Energy LLC facility at 2850 20th Avenue South, Minneapolis. We, the undersigned, believe there are
still significant issues that the project must address before the Minnesota Pollution Control Agency
(MPCA) considers issuing a permit for the facility.

Project Description
Midtown Eco Energy is a proposed 24.5 MW biomass energy facility to be located at 2850
20th Avenue South in the East Phillips neighborhood of south Minneapolis. The surrounding area
consists of residential, commercial and industrial uses in a densely populated neighborhood that is
well known for its diverse population and abundance of community gardens. The facility will consist
of a 358.6 MMBtu/hr wood-fired Main Boiler, an emergency generator, a cooling tower and wood
handling equipment. According to the MPCA’s draft Air Emission Permit No. 05301187-001, the
primary fuel source for the facility would be tree trimmings and wood waste though the permit also
allows for the combustion of natural gas and other experimental fuels.

Petitioners’ representative
Petitioners are represented in this matter by Jullonne Glad, 3245 21st Avenue South,
Minneapolis, MN 55407, tel. 612-722-9514.

Environmental and Social Impacts that warrant an EAW

Given the dense urban location of the project, there are important environmental impacts of the
project for nearby residents and regulators to fully understand before making any final decision to
permit this facility in this location. We submit that the project has the potential for significant
environmental effects and are petitioning the EQB for the project developer to complete an EAW for
the project for the following reasons:

 Mandatory EAW threshold is 25 megawatts (MW), Midtown Eco Energy facility is 24.5
MW and would be situated in a dense urban setting using new technology that warrants
further testing - Minnesota Rules 4410.4300 establishes a threshold that determines whether
or not an EAW must be prepared for a particular project. The EAW threshold is at 25 MW
for Midtown Eco Energy, an electric generating facility as defined in 4410.4300 Subpart 3.
The project’s developers are seeking a permit for a 24.5 MW electric generating facility –
barely below the mandatory EAW threshold. It is highly likely that this electric generating
facility will run at 105-percent capacity on occasion and thus breach its 24.5 MW capacity.
However, even if the facility never exceeds its 24.5 MW capacity, the difference between a
24.5 MW and a 25 MW facility is so miniscule that closer scrutiny is necessary in this case
because the 24.5 MW facility would be situated in a densely populated neighborhood that is
already burdened by excessive emissions.[1] [2] [3] Placing a 24.5 MW facility in a dense urban
setting where cumulative impacts are already a significant factor is not the same as placing a
24.5 MW facility in a setting with fewer people and less existing pollution. In addition, the
project’s developers have already demonstrated their willingness to expand the size of their
project; according to the MPCA’s Impact Analysis Summary dated February 2007, Midtown
Eco Energy was originally slated to be a 22.5 MW facility and was increased to a 24.5 MW
facility.[4] Furthermore, this 24.5 MW biomass facility represents new technology for which
the MPCA recommends further study,[5] making an EAW vital to providing the general
 public with the clearest possible understanding of the project’s environmental and social
impacts.

 The net cumulative impact of the project on air emissions – The MPCA air permit
documents provide estimates of potential emissions from the Midtown Eco Energy
facility.[6] However, the MPCA’s air permit documents do not provide any benchmarks to
understand what the incremental effect of the project will be on local and regional air quality.
The proposed project is in close proximity to other large point source emitters. Smith
Foundry, Abbott Northwestern Hospital, Pechiney Plastics, the University of Minnesota,
Hiawatha Metalcraft & Hennepin County Energy Center all hold Title V air emission permits
and are located within 1.5 km (1 mile) of the facility. In addition, Bituminous Roadways and
the City of Minneapolis operate asphalt plants near the proposed facility.[7] The neighborhood
also experiences a higher level of air pollution due to the high volume of car and truck traffic
through the area on Lake Street, Highway 55 and Interstate Highway 94.[8] Midtown Eco
Energy will also be relying on up to 40 additional trucks a day, six days a week to haul wood
to the facility. All of this automobile traffic and its associated emissions should be included
as part of a cumulative impact analysis as air pollution from mobile sources can contribute to
breathing and heart problems, aggravate asthma and are suspected of causing cancer and
reproductive problems.[9] The need for and benefits of adding an additional major point
source of pollution to a high-density urban area with many vulnerable population groups and
higher-than-average (for the metro area) air pollution levels, warrant clear documentation in
an EAW. Furthermore, the MPCA’s air permit documents fail to estimate any potential
emissions reductions for the proposed district heating system (connecting the facility to
Abbott-Northwestern Hospital and the Midtown Exchange). Midtown Eco Energy’s main
selling point – that it will be carbon neutral – has no project-specific data available to
substantiate or refute it. In evaluating whether the project is justified, it is helpful to quantify
what reductions will occur due to the district heating system so the general public can more
accurately weigh the potential impacts with the potential benefits.

 PM2.5 impacts from wood burning, natural gas combustion and increased automobile
traffic – Particulate matter is the term used for a mixture of solid particles and liquid droplets
in the air. PM2.5 refers to particulate matter that is 2.5 micrometers or smaller in size.
According to the U.S. Environmental Protection Agency (EPA), the sources of PM2.5
include fuel combustion from automobiles, power plants, wood burning, industrial processes,
and diesel-powered vehicles such as buses and trucks. Fine particles are of concern because
they are a risk to the environment and to human health – particularly to children and the
elderly. Because these particles are so small they are able to penetrate to the deepest parts of
the lungs. Scientific studies have suggested links between fine particulate matter and
numerous health problems including asthma, bronchitis, acute and chronic respiratory
symptoms such as shortness of breath and painful breathing and premature death. [10] The
MPCA’s Air Quality Index (AQI) shows that even without Midtown Eco Energy and the
increased truck traffic it will bring, PM2.5 levels are on the rise at the South Minneapolis
monitoring station (site 0963) located at 2727 10th Ave. S. AQI data shows that the PM2.5
index reached 101 or more (unhealthy for sensitive groups) five times in 2007 compared to
only one time in 2006 and two times each in 2004 and 2005.[11] PM2.5 has not yet been
addressed specifically in permitting actions.[12]
  Environmental justice for vulnerable population groups in a densely populated
neighborhood – According to the 2000 U.S. Census, the population of the four Phillips
neighborhoods (East Phillips, Midtown Phillips, West Phillips and Ventura Village) is
19,805. Of this population, 68 percent are from minority groups, including: 29 percent black
or African American, 22 percent Hispanics or Latinos, 12 percent American Indians, 6
percent Asians and 9 percent multi-racial. The remaining 32 percent of the neighborhood’s
population is white. Phillips is home to the very young and very old alike. According to the
2000 U.S. Census, there were 1,955 children under the age of 5 living in the four Phillips
neighborhoods.[13] This age group represents 10 percent of the total population of Phillips,
which is higher than the national average for the same age group.[14] Phillips also has a fairly
high population of seniors. According to the 2000 U.S. Census, 10 percent of the Phillips
population was 55 years and older.[15] This data shows that Phillips has a higher number of
both elderly and children under the age of 5 within its boundaries. Each of these demographic
groups has lower tolerance and lower immunity when dealing with sickness, air pollution and
particulate emissions. According to a Minnesota Center for Environmental Advocacy report,
the costs associated with childhood illness like asthma and cancer are significant. The best
estimate of total costs of environmentally attributable childhood diseases in the state of
Minnesota is $1.569 billion per year, with a range of $1.393 to $1.890 billion.[16]

In addition, the percentage of people living in poverty is persistently higher in the Phillips
area than in the City of Minneapolis overall. In 1999, 32 percent of all families in Phillips
lived in poverty.[17] An impoverished community has less access to health information,
doctors and treatments for sickness. Specifically, asthma, which is exacerbated by air
pollution,[18] disproportionately affects communities of color and poverty. According to the
Center for Disease Control (2000-2005), 84 percent of asthma sufferers were non-white and
73 percent were at or below the poverty level.[19] Locally, the Minneapolis Foundation in a
July 2006 report found that the asthma rate for African American and American Indian adults
in Hennepin County is more than 25 percent higher than that of whites. [20] The composition
of Phillips’ population and its increased vulnerabilities, suggest a need for an EAW and a
more thorough Air Emissions Risk Analysis (AERA) normed on a more comparable
population so that environmental justice issues about the siting of Midtown Eco Energy can
be addressed.

 Benefit of doubt should err on the side of public safety – The EAW provides 31 questions
that must be answered, covering a broad range of environmental impacts. Some of these
impacts may not be significant for the project, and the EAW process can help rule out these
issues as insignificant, while focusing on the issues that are significant specifically with
regard to PM2.5, mercury, sulfur dioxide and lead emissions.[21]

Supporting evidence for statements made in this petition

[1]
U.S. Census Bureau, “Phillips General Demographic Characteristics” as produced by the City of
Minneapolis Planning Department, October 2001. (Online see
http://www.ci.minneapolis.mn.us/citywork/planning/census2000/maps/phillips.pdf)
[2]
MPCA AERA Internal Form-02 Impact Analysis Summary for Midtown Eco Energy, Answer to
question number 20 on P. 6, February 2007.
[3]
MPCA AERA Internal Form-02 Impact Analysis Summary for Midtown Eco Energy, Table.1.
Midtown Eco Energy Modeled Emission Rates on PP. 12-14, February 2007. The table shows an
emissions inventory for existing area and mobile source emissions.
[4]
MPCA AERA Internal Form-02 Impact Analysis Summary for Midtown Eco Energy, question
number 9a. on P. 1, February 2007.
[5]
MPCA AERA Internal Form-02 Impact Analysis Summary for Midtown Eco Energy, MPCA staff
team recommendations on P. 11, February 2007.
[6]
MPCA Technical Support Document to Draft Air Emission Permit No. 05301187-001 for
Midtown Eco Energy LLC. November 2007. (Online see
http://www.pca.state.mn.us/news/data/bdc.cfm?noticeID=277808&blobID=19790&docTypeID=4).
[7]
MPCA AERA Internal Form-02 Impact Analysis Summary for Midtown Eco Energy, Answer to
question number 20 on P. 6, February 2007.
[8]
MPCA AERA Internal Form-02 Impact Analysis Summary for Midtown Eco Energy, Table.1.
Midtown Eco Energy Modeled Emission Rates on PP. 12-14, February 2007. The table shows an
emissions inventory for existing area and mobile source emissions.

Minnesota Pollution Control Agency, “Background on Air Pollution from Mobile Sources,” P. 1,
[9]

April, 2005.
[10]
U.S. Environmental Protection Agency PM2.5 Objectives and History. (Online see
http://www.epa.gov/region4/sesd/pm25/p2.htm#4).
[11]
Minnesota Pollution Control Agency Air Quality Index. The index requires the general public to
have to check PM 2.5 figures for each day. This citation was a result of checking the AQI for PM 2.5
at monitoring station 0963 for all 365 days of each year. (Online see
http://aqi.pca.state.mn.us/hourly/region1.cfm?region=Twin%20Cities).
[12]
MPCA Technical Support Document to Draft Air Emission Permit No. 05301187-001 for
Midtown Eco Energy LLC. P.5. November 2007. (Online see
http://www.pca.state.mn.us/news/data/bdc.cfm?noticeID=277808&blobID=19790&docTypeID=4).

U.S. Census Bureau, “Phillips General Demographic Characteristics” as produced by the City of
[13]

Minneapolis Planning Department, October 2001. (Online see

http://www.ci.minneapolis.mn.us/citywork/planning/census2000/maps/phillips.pdf)

U.S. Census Bureau American Fact Finder, DP-1. “Profile of General Demographic
[14]

Characteristics: 2000 Data Set: Census 2000 Summary File 1 (SF 1) 100-Percent Data Geographic
Area: United States.” (Online see http://factfinder.census.gov/servlet/QTTable?_bm=y&-
geo_id=01000US&-qr_name=DEC_2000_SF1_U_DP1&-ds_name=DEC_2000_SF1_U).
[15]
U.S. Census Bureau, “Phillips General Demographic Characteristics” as produced by the City of
Minneapolis Planning Department, October 2001. (Online see
http://www.ci.minneapolis.mn.us/neighborhoods/phillips_population.asp#TopOfPage)
[16]
Minnesota Center for Environmental Advocacy, “The Price of Pollution: Cost Estimates of
Environment-Related Childhood Disease in Minnesota,” P. 3, June 2006.
[17]
City of Minneapolis Web site: Minneapolis Neighborhood Profiles, Poverty in Phillips. (Online
see http://www.ci.minneapolis.mn.us/neighborhoods/phillips_poverty.asp#TopOfPage).
[18]
Environmental Protection Agency, “Asthma and Outdoor Air Pollution,” P. 1.
[19]
Center for Disease Control “Asthma, All Ages: U.S. 2000-2005”. Source: National Health
Interview Survey. (Online see
http://209.217.72.34/HDAA/TableViewer/tableView.aspx?ReportId=211).
[20]
Minneapolis Foundation “Health and Racial Disparities Fact Sheet,” P. 1, July 2007.
[21]
Green Institute letter to MPCA raises several issues with Midtown Eco Energy project and
corroborates each of the points raised in this petition. The Green Institute had originally conceived of
this project and later deemed it untenable as their letter indicates. See item number 6 on P. 3 of
comments letter. December 2007.