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  LWV Upper Mississippi River Region

UMRR blog

Groundwater and Surface Water - hey, it's all water

1/1/2023

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We all know the water cycle... rain and snow falls from the sky, soaks into the ground, runs into streams, rivers, lakes, oceans.  The linkage of all these water systems is what makes life possible here on Earth, and our disruption of the cycle comes at our own risk.   When groundwater is depleted, streams don't flow, lakes dry up and people don't have water in their wells to drink. 

The video to the right shows how contamination affects our water supplies.   
The LWV UMRR blog is going to focus on groundwater for the next few months.  This month we have two posts on the transfer of groundwater from state to state and country to country through bottled beverages and agricultural products.  In "Exporting Water from the Mississippi - one 0.5liter Bottle at  a Time", we take a look at the efforts of Niagara Bottling to site water bottling facilities in Minnesota and Wisconsin.  This California company is seeking to expand in areas where cities will use their water supplies to encourage economic growth - the catch is that municipal water supplies are rated a higher priority than industrial uses, so an industrial use of municipal water takes advantage of a loophole in the system.  The second post, "Groundwater is moving across the world in products" looks at the use of Arizona groundwater to raise alfalfa for dairy herds in Saudi Arabia.  Arizona passed an act requiring the big cities to manage groundwater sustainably, but that law does not apply outside these major population centers... another loophole being exploited to access water.  

Minnesota also passed a Ground Water Protection Act, back in 1989.  The Minnesota Ground Water Association charged a team with developing a white paper that looks at implementation of the Act in the past 30 years, and then looks ahead to what more needs to be done.  (You can view a video on this Act and White Paper at this link.)  One issue that stands out through all of these is the movement of water from one state, or one country, to another.  Without clear policies to govern sharing (and not sharing) of water, there will be piecemeal protections and continuing over-withdrawals.  
Our April 3 meeting will focus on groundwater and surface water in the Driftless Area.  We will talk about how groundwater moves from the surface, through the ground, to come to the surface again in this Karst landscape, and then look at specific examples of how land use and drinking water quality are as integrally linked as surface and groundwater are.  We will get out specifics on this expanded educational program in our next newsletter.    The video to the right is an excellent presentation of how pollution moves in Karst.  ​
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Exporting water from the Mississippi River Basin, one .5liter bottle at a time...

12/13/2022

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There's a lot of water in Minnesota.  With extensive resources of both groundwater and surface water, this is becoming a draw for water-intensive industries.  The current proposal that's in the news is a water bottling plant that is proposing to use municipal water from the City of Elko New Market (locals call it ENM).  The company proposing the plant is California-based Niagara Bottling.  

This plant would be located in a newly-approved industrial park being built along Interstate 35 in Scott County, on the south edge of the Twin Cities Metro area.  The City of ENM draws it's water from wells finished in the Jordan Aquifer, a major water supply aquifer for many other cities in the area.  Springs from this aquifer form the headwaters of the near-by Vermillion River, a tributary to the Mississippi.    

​Residents have raised concerns about the project, citing noise, traffic and well interference.  They are fighting the project through social media, demonstrations and advocacy in various ways.  This blog post will focus on the issues of water use increase and water export, not the other local issues of concern.  The City of ENM held a public meeting on the project - there were so many testifiers at the meeting that it was held over from December 15 to December 20.  This story on KARE11 provides a good update on this process.   Here's the link to view the recorded City Council meetings that include these hearings.  

Water appropriations in Minnesota are regulated by the Minnesota Department of Natural Resources,this page on the DNR website provides statutory reference and information on how it works.  In this case, expansion of the amount allowed to be withdrawn from the Jordan by the City of ENM requires modification of the city's appropriation permit.  DNR staff has confirmed that DNR has received a permit amendment request from the City, and advised the City that they must first update their Water Supply Plan if they want to increase water usage related to a bottling plant.  This plan will identify
 what measures will be implemented in case of a water crisis in order to maintain aquifer levels, and reduce potential well interference and water use conflicts.

Once the Water Supply Plan is updated, DNR and the Metropolitan Council (a coordinative body of government responsible for planning in the Twin Cities) will evaluate the plan for sustainability and environmental impacts.  If the proposed project does not meet state sustainability standards, DNR will not authorize the increase in water appropriation.  Conversely, if the proposal meets the standards, the expansion of the city's appropriation permit will be allowed.  The author of this post has requested more information on what standards DNR will specifically apply, but no answer was received as of noon on December 19.  

The concerned citizens in ENM also have filed a request for specific environmental review of the project.  They filed a petition with the Minnesota Environmental Quality Board with 400 signatures requesting that an Environmental Review Worksheet for the project.  The EQB approved the petition and assigned the EAW preparation to DNR; this will move forward in a separate process.  This type of project has been seen elsewhere, where water-intensive industries plan to use municipal water supplies to supply water for their projects.  


Niagara will be opening a new plant in Baltimore County, Maryland in the spring of 2023.  The city's 'robust water supply' was listed as a reason this location was chosen - read more here in an April 2022 press release from the Governor of Maryland. Niagara had also proposed a similar plant in Eau Claire, Wisconsin, which fell through earlier this year amid local opposition.  Here's a link to a Wisconsin Public Radio story on the project. There, Niagara pulled the proposal before the Eau Claire City Council could vote, but WQOQ News 18 reports the plans could be resubmitted.  

The interstate transfer of water, and inter-basin transfer of water, is an area that needs more policy work.  One example is a project where a Rural Water system in northwestern Iowa draws water that's 'sold' to users in the surrounding four-state area.  This article in the Iowa Capitol Dispatch shows the impacts that water withdrawals have had on the Ocheyedan River, which has now run dry four out of the last seven years.   The water is being pumped from shallow aquifers by the Osceola County Rural Water System, which sells water to the Lincoln-Pipestone Rural Water system used largely by southwestern Minnesotans.  (This is not the only source of water used by Lincoln-Pipestone.) According to the Iowa Capitol Dispatch article, the Osceola County Rural Water System has a deadline of March 31, 2023, to submit a plan to potentially reduce its pumping rates when river levels are low.  If it doesn’t, “the DNR may unilaterally proceed with other actions to protect the use of the water supply,” according to the letter the department sent to the utility in November.

We will continue to report on progress of this project on this blog.  Here's a link to a recent on-line news report about the controversy.  This news story on the local Twin Cities Fox affiliate provides a video: 
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LWV Climate Interest Group

6/25/2022

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The LWV Climate Interest Group is open to all members of League of Women Voters.  Here's their raison d'être:
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As citizens of the world we must protect our planet from the physical, economic and public health effects of climate change while also providing pathways to economic prosperity. To advance League action on this urgent issue, we have formed a nationwide collaboration effort: the LWV Climate Interest Group. We are a group of League members from across the United States working together to fight climate change. We have teams in important climate issue areas to provide materials for local and state Leagues to use in their education and advocacy.
Breaking News! (added July 15, 2022)
Deadline Extended:
​COP27 UN Climate Conference in Egypt
LWV US announced that there are scholarships available for League members who identify as Black, Indigenous, or People of Color (BIPOC), or those members between 18 – 35 years of age to attend the UN Climate Change Conference of the Parties (COP27) in Sharm el-Sheikh, Egypt, on Nov. 8 – 20, 2022. The deadline to apply is July 25th at 5pm ET. To apply, please complete the applicant interest form. If you have questions about the application or process, contact Robin Tokmakian at rtokmakian@lwv.org.

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Membership in the Climate Interest Group is open to all LWV members.  The CIG has ten teams that are organized around ten topic areas - you can link to these teams from the CIG website.  The teams meet monthly by Zoom, sharing information on research and events linked to their topic.    
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LWV UMRR would welcome members from these groups providing updates on these meetings to UMRR so that we can all benefit from the work of the CIG.  If you are interested in being a link between UMRR and these groups, please email us at lwvumrr@lwvmn.org.  Thanks!  
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States' Progress in Nutrient Loss Reduction

12/20/2021

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On December 14, 2021, the Hypoxia Task Force (HTF) met.  This group, with representatives from 12 states, one tribe and an impressive array of federal agencies, coordinates the activities of the participating groups in attempting to move forward the Nutrient Reduction Strategy with a goal of 45% lower levels of nutrient loss from the land to the Mississippi River and the Gulf.  The HTF was formed in 1997.  The deadline for achieving the nutrient reduction goal keeps moving back.  

Each state has developed its own nutrient reduction strategy to meet its needed share of the nutrient loss reduction.  The map to the right shows the priority watersheds that have been designated in each state as a focus of work.   Progress on the goal is reported every five years, with the last one in 2018 and the next one due in 2023.  

This process has not been universally successful at reducing nutrient losses.  There has been significant success at reducing losses from point sources, but nonpoint sources (i.e. agriculture) are not showing the same level of success.
 Areas of improvement that could be pursued by the Hypoxia Task Force:
1.  States should move to reporting tools that are helpful in understanding the scale of change needed.  This article by the Iowa Environmental Council does a good job of explaining how just recording the number of projects doesn't help really measure progress unless the total number of projects that need to be undertaken is actually known.  They site the website that Kentucky is now using to track progress as a positive example.  


2.  The Hypoxia Task Force should be expanded to include one or more non-governmental entities, for example a non-profit organization like the Mississippi River Network, to represent this sector.  This will increase public participation in the work of the Task Force as well.  

To really make a dent in the nutrient loss that is washing into the Mississippi will require significant change in behavior of people throughout the basin.  This can't be accomplished by agency actions alone.  Public engagement and buy-in is necessary.  


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In a December 20 article "Illinois — a major feeder to the Gulf of Mexico dead zone — falls behind federal goal to reduce phosphorus and nitrogen flowing into its waterways", Morgan Greene wrote for the Chicago Tribune:    By 2025, Illinois aims to reduce nitrogen and nitrate by 15% and phosphorus by 25%, with a goal of greater long-term reductions.  Instead, averaged from 2015 to 2019, nitrogen loads increased by 13% compared with a baseline period from 1980 to 1996, and phosphorus loads increased by 35%, according to the latest biennial report on the state’s reduction strategy, released this fall.

The LWV UMRR Blog has covered many aspects of nutrient loss strategies and the Dead Zone in the Gulf.  You can read more about them at the links below:
  •  Nutrient pollution
  • Farm Bill
  • Government policy
  • Outreach and engagement
Nutrient loss reduction is a major goal of the LWV UMRR, and we work through education and advocacy to promote policies and practices in this direction.

Here is a quote from comments that the Mississippi River Network's Masiah Kahn made at the December 14 HTF virtual public meeting:

 This annual public meeting is the only opportunity that the public, non-profit organizations, and other stakeholders get to engage the Task Force as a whole – and we think the Task Force can do much better to encourage and enable robust public participation in a meeting like this.

I echo the concerns raised about the fact that despite incremental progress in reduction strategies and the increased adoption of innovative conservation practices, we are nowhere near the interim target of reducing nitrogen and phosphorus loading by 20 percent by 2025. We can no longer keep doing the same thing and expecting different results. It’s also hard to see the forest for the trees when the Task Force’s overarching goals are not front and center in meetings like this. 


You can find the presentations and comments from Dec 14 Hypoxia Task Force meeting at this link.  
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LWVWI—ASCE WI “Invest in Wisconsin’s Infrastructure"

9/22/2021

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The Wisconsin Section of the American Society of Civil Engineers and LWV Wisconsin co-sponsored a series of meetings on Wisconsin's infrastructure in the past year.  The videos from these 11 meetings are now posted.  Here's the information on the meetings that  Carol Diggelman (Emerita Professor, Civil & Architectural Engineering & Construction Management Department, MSOE; Co-Chair, LWV of Milwaukee County Natural Resources Committee and Member, LWVWI and ASCE WI Section) shared recently.  
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ASCE WI-LWVWI “Invest in Wisconsin’s Infrastructure” Overview and Category Series are now complete. You will find the links to video recordings of all programs below. Overview meeting links can also be found on the ASCE WI YouTube channel. Category meeting links can be found on the LWVWI website at this link. 

We encourage everyone to forward these program links to others, particularly your elected officials.

 
Recordings:


Overview Series
  • SE Quadrant Meeting  - March 4  https://www.youtube.com/watch?v=SZRhDpjBmEA
  • SW Quadrant Meeting - March 1  https://www.youtube.com/watch?v=FL8uvolJZzM
  • NW Quadrant Meeting -April 1  https://www.youtube.com/watch?v=GfNIJ7Wjwk8
  • NE Quadrant Meeting - April 15  https://www.youtube.com/watch?v=WgIfFcRbBUI

Category Series
  • Energy - May 6  https://youtu.be/THzNDryfUf4
  • Bridges & Roads - May 27  https://www.youtube.com/watch?v=e1tQt12AOpg
  • Aviation & Transit - June 17  https://www.youtube.com/watch?v=tX4lWEtdm0Y
  • Inland Waterways & Ports - July 8  https://www.youtube.com/watch?v=stjEaZ4OEUc
  • Stormwater & Dams - July 29  https://youtu.be/ICb03c2orl0 
  • Water & Wastewater - August 5  https://youtu.be/NRUCBKreJ3I
  • Hazardous & Solid Waste - August 19  https://youtu.be/DZMCVMVuAA0
 


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Should You Drink That?                                                                              The Unfolding Story of PFAS in our Lives

8/12/2021

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The video of this webinar is available for viewing now at this link:  https://youtu.be/SodForAydqQ
Since the 1940s, manufacturers have relied upon a class of man-made toxic chemicals that is resistant to heat, water, stains, grease, oil and friction. PFAS, or Per- and Polyfluoroalkyl Substances, have provided consumers with popular products such as nonstick cookware, stain-resistant furniture, and water-repellent clothing. Teflon, Scotchgard, Stainmaster, and Gore-Tex are just a few examples of brand names containing PFAS. The manufacture and use of PFAS in consumer products and firefighting foam are so widespread that 99% of Americans have PFAS in their blood today.
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On October 4, LWV UMRR hosted a panel discussion on PFAS. Our presenters helped us understand how PFAS have become a big part of our lives – present in food packaging, household products and drinking water – and what we know about how they affect our health. As awareness of PFAS contamination grows, communities are struggling to cope with tainted drinking water while engaging in advocacy to increase public awareness and bring about constructive change. Watch the video to learn what the federal government and states are doing to establish safe standards for drinking water and ban the use of PFAS in manufacturing. Most importantly, learn what you can do to help protect yourself, your family and your community.
                                                                          
                                                                                   
                 OUR  PANEL

Jeff Lamont – Retired hydrogeologist, works with SOH2O (Save Our H2O) to ensure safe drinking water for residents in Northeast Wisconsin and to advocate for state and federal standards for PFAS compounds. Jeff resides in the Tyco/JCI groundwater contamination plume in the Marinette and Town of Peshtigo area and has a private well impacted by PFAS. Jeff and his wife have been living with bottled water for drinking and cooking for the last 3.5 years.

Erika Schreder – Science Director, Toxic-Free Future, conducts and publishes research on toxic chemicals, their presence in people and products, and safer alternatives.

Deanna White – Minnesota Director, Clean Water Action, coordinates EPA and state level interactions for policy and legislation. Deanna has an extensive background in community organizing and advocacy.

To learn more about how you are exposed to PFAS and PFAS regulation in your state, check out this LWV UMRR-researched background sheet with information on PFAS  from Minnesota, Illinois, Iowa, and Wisconsin.  
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​This event will be recorded and made available in this blog post after editing.  
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Managing Human Use and Impact on Groundwater Resources

11/6/2019

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Program at LWV Park Rapids (MN), October 24, 2019

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The League of Women Voters Park Rapids Area tackled ground water sustainability concerns in their October 24 meeting.  Ground water sustainability is a critical issue to people in the Park Rapids area.  The City of Park Rapids has had to deal with excess nitrates in one city well. Many rural residents need to buy bottled water for drinking and cooking because of nitrate concerns. Is this the “tip of the iceberg” or are there ways to manage our groundwater that will allow for industry, agriculture and citizens to share this valuable resource? (photo - Park Rapids Enterprise)

Two speakers were on hand for this meeting.  The first speaker was Dr. George Kraft, a hydrologist and Professor Emeritus of Water Resources at the University of Wisconsin, Stevens Point.  In his thirty years at UW Stevens Point, Dr. Kraft has performed research, advised on policy and doing Extension education on groundwater sustainability issues. His work has concentrated on nitrate pollution of groundwater and drinking water, and how groundwater irrigation pumping has caused a decline in streamflows and lake levels in central Wisconsin. He has published extensively on groundwater concerns, and is sought after as an advisor on scientific and policy workgroups.  Dr. Kraft spoke at an LWV UMRR meeting in Stevens Point in April of 2018.

Dr. Kraft’s Park Rapids presentation reflected on his 30 year record of research on how irrigated farming, mainly for potato, other vegetables and field corn have affected groundwater quality and quantity in central Wisconsin. In central Wisconsin, the main issues are extensive nitrate pollution, as over 40 percent of wells in some townships exceed standards, and drying of lakes and streams by unlimited irrigation.  This sounds familiar to folks in the Park Rapids area. 

Dr. Kraft discussed how politics and a strong industry lobby have stymied even discussing the causes and effects of water challenges, let alone suggesting policies on how to manage them. Though Park Rapids area industry, geography, geology and politics may differ from those that exist in central Wisconsin, that region’s experiences may be a help in advancing more proactive discussion and avoiding pitfalls.

The second speaker was Minnesota Department of Natural Resources (DNR) Area Hydrologist Darrin Hoverson. Darrin’s responsibilities include surface and groundwater resource management, water resource compliance and regulation as well as providing technical analysis, assistance and information to the public, local and state units of government and other water resource professionals. Having grown up in the Park Rapids area, being an active member of this community and with his 12 years of work at the DNR, Hoverson provides a deep understanding of the area’s natural resources, the community and local issues and concerns. His education includes a Master’s in Water Resources from the University of Wisconsin, Stevens Point, and a Bachelor’s degree in Aquatic Biology from St. Cloud State University.

In his candid and thorough presentation, Hoverson provided a brief history and update on DNR groundwater management efforts within the Pineland Sands & Straight River Groundwater Management Areas, ongoing and future monitoring and groundwater studies and private/public partnerships.  He focused on DNR’s roles and authority in ensuring the sustainable use of the region’s groundwater and groundwater dependent resources.
 
The session was recorded, and is available on You Tube here.  There was lively discussion following the presentations, which is included with the video here.  
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The Nature Conservancy's big idea to protect the upper Upper Mississippi - talk by Matt Gladue on June 1

6/4/2019

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The upper Upper Mississippi  is that part of the Mississippi that starts at the Headwaters and flows to the Twin Cities.  Water quality in the upper Upper Mississippi River is very good.  The river, especially in the furthest north reaches, is protected by extensive forests and wetlands.  But threats to this river are growing - threats from land conversion and development.  The river is in danger of becoming polluted, like the Minnesota, which would endanger the water supply of millions of Minnesotans as well as damage this invaluable natural resource.
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Matt Gladue's talk at the Annual Meeting engaged the audience in understanding the value of the upper Upper Mississippi - in the heart and soul of Minnesotans, as the source of drinking water for millions, and as an invaluable natural resource for wildlife and recreation.  The threats to the river are many, but it is within the power of Minnesotans to make a changes that will save the river.  

The Nature Conservancy has a big idea for saving the river.  They have identified critical conservation lands, about 2% of the land in the watershed, that if protected from development or restored to forest will help to protect the river.  Matt talked about this project, and that The Nature Conservancy is working on doing grass-roots organizing to develop public support.  They are also seeking organizations to partner with them in this effort.  To learn more about TNC's big idea, click here.

The videos below are broken up in part because Matt provided discussion periods during his talk and in part due to technical difficulties that resulted in small gaps.  
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LWV UMRR Advocacy Update - and how you can get involved in comments to the proposed Clean Water Rule

12/11/2018

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The dual mission of League of Women Voters - to educate voters and advocate on issues - is exemplified in the work of the LWV Upper Mississippi River Region.  We provide information on a variety of topics in this blog, through our newsletter, and in the educational meetings we co-sponsor with local Leagues.  And we advocate,  through taking and advocating for positions on key issues.  This post provides an update on work we are doing in three areas; the Farm Bill, the Clean Water Rule and  Foxconn.   

Farm Bill:
  The conference committee report, which reconciles the differences between the House and Senate versions of the bill, was released early today.  The Senate has already approved it, and a vote is expected in the House tomorrow.  Here's a link to a summary of the bill, from the National Sustainable Agriculture Coalition.  LWV UMRR has been participating in conference calls with this coalition, and on Dec 11 signed on to a letter to Congressional leadership urging final passage of the bill .  The bill has many positive components, including continued support for income-based food support, strong and expanded conservation program funding, additional supports for dairy farmers and even a provision to ease restrictions on the growing of hemp.  We will include more information on this bill in blog posts to come, so stay tuned.  The full text of the bill can be read here. 
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Clean Water Act preservation and support:  LWV US was very involved supporting the initial passage of the Clean Water Act in 1970.   (Read the history of LWV Clean Water Act advocacy here.) We are continuing this work through advocacy in two areas where our current federal administration is seeking to roll back Clean Water Act protections.   One rollback is the rewrite of the Clean Water Rule.  This multi-part rulemaking revolves around the definition of "Waters of the US".  Here is the US, EPA rulemaking page, proposed changes were just announced on December 11, and a 60-day comment period will soon begin.  LWV UMRR will work with LWV US to participate in this rule making.   If you are interested in learning more about this proposed rule, and helping LWV UMRR prepare comments, please email us at lwvumrr@lwvmn.org.  We will send you materials and set up a conference call to discuss possible comment areas.    ADDITIONAL INFORMATION:  The Environmental Integrity Project has issued a report on the impact of this potential rule change on Chesapeake Bay - Read more about it here.  

LWV UMRR and LWV US have also signed on to a letter to EPA, urging them to maintain the existing Clean Water Act 404(c) rules.  These rules have been used by environmental groups to counter environmentally damaging projects.   The sign-on letter was started by the National Wildlife Federation.
Click here to read  the letter.  Click here to see the list of organizations that have signed on to the letter.  

Foxconn​:  LWV Wisconsin has lead LWV efforts to oppose the withdrawal of more than 7 million gallons per day of Lake Michigan water for this new industrial development near Racine.  LWV Lake Michigan is party to the Petition seeking reconsideration by WI DNR.  LWV Upper Mississippi has made a resolution in opposition, and will continue to find ways to work against this transfer.  You can read the resolution here. 

LWV UMRR will be traveling to southeastern Wisconsin for our February Board meeting.  We will seek to meet with Leagues in the area to talk about the project, get an update and see how the recent change of administration in Wisconsin may affect things.  Once the plans for this meeting are set, we will share them here on our 'Upcoming Events" page.   There are three previous blog posts on Foxconn:  
  • Foxconn Update - the scale of the plant is shrinking...
  • Foxconn takes Wisconsin by storm
  • Update on the Racine diversion
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Minnesota's ongoing battle over nitrate in groundwater

7/24/2018

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Groundwater is a critical resource for Minnesota - it feeds our streams, fills our lakes and is a (mostly) clean and reliable source of drinking water for about 75% of the population.  Many areas have localized problems, some with natural contaminants like arsenic, man-made toxics from unsound disposal of industrial wastes and many areas with nitrate contamination at levels that are of concern.   Here's a link to a video from an LWV UMRR meeting last October where Chris Parthun from the Minnesota Department of Health describes the problems with nitrate contamination in our water.  

In 1989, the Minnesota Legislature passed a law aimed at increasing protection of Minnesota's groundwater resources.  Click
here to watch a video detailing Minnesota's 1989 Groundwater Protection Act.  This act included a set of tiered actions to be taken to address everyday sources of groundwater contamination not addressed by programs like Superfund or the Leaking Underground Storage Tank program.  This Act also established a groundwater protection goal of preventing degradation and reducing pollution where is has already occured.
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One area where groundwater protection is particularly thorny is in agricultural areas, where nitrate contamination is affecting both public and private wells, and the levels are  rising.   As laid out in the Groundwater Protection Act, the Minnesota Department of Agriculture is responsible for developing and administering programs and laws to address this.  This has not been an easy course, and the twists and turns abound.  This link leads to a blog post on the Loon Commons Blog by Matt Doll of the Minnesota Environmental Partnership.  Here, Matt describes the rule that the Minnesota Department of Agriculture proposed to address the growing problem of nitrate in groundwater. 

The Minnesota Legislature introduced bills to stop this rule.  LWV UMRR Chair Gretchen Sabel testified in both the House and Senate, on behalf of LWV Minnesota, in opposition to these bills.  This link will take you to a copy of her testimony in the House.  In the end, the bills were passed and Governor Dayton vetoed it.  The Ag Committees in both houses have taken steps to use an administrative procedure to further slow the rule.  Here's another blog post from Matt Doll on the topic.  

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The saga continues... the Minnesota Department of Agriculture is now in the process of finalizing the rule.  Public comment will be taken until August 15 - read about it here.  And comment!  Clean water is important for all of us in the Upper Mississippi - Minnesota is the headwaters state, and this rule is just one part of the solution.   
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