WILD RICE LETTER SAMPLE DRAFT
NOTE: Rather than copy-and-paste, please use YOUR OWN WORDS.
Richard Clark (Richard.Clark@state.mn.us)
MPCA - Industrial Division
520 Lafayette Rd. N.
St. Paul, MN 55155
Steve Colvin (steve.colvin@state.mn.us)
MDNR – Environmental Management
500 Lafayette Rd. N.
St. Paul, MN 55155
Michael Sedlacek (sedlacek.michael@epa.gov)
USEPA – Region 5
77 West Jackson Boulevard
Mail Code: E-19J
Chicago, IL 60604-3507
Dear Mr. Clark, Mr. Colvin, Mr. Sedlacek:
I've learned that the Minnesota Pollution Control Agency has proposed
designating certain waters in the area of the LTV tailings basin and the
proposed PolyMet NorthMet mine site as waters used for the production of
wild rice. I am writing to you because I believe that the designation is too
narrow. [USE YOUR OWN WORDS – DOESN’T PROTECT WILD RICE, MAKES
NO SENSE ETC.]
[INCLUDE A SENTENCE OR TWO ABOUT YOUR OWN BACKGROUND. WHERE
YOU LIVE, ARE YOU A TRIBAL MEMBER, HAVE YOU HARVESTED WILD RICE,
ARE YOU CONCERNED ABOUT WILDLIFE AND HUNTING.]
The MPCA proposed that the Partridge River should be designated a wild
rice water from where Colvin Creek flows into the Partridge River until it
enters Colby Lake and from Colby Lake down to the St. Louis River. I agree
with that designation. In addition, based on the reports already provided to
the MPCA, portions of Longnose Creek near where the creek enters the
Partridge River should also be considered a wild rice water. [IF YOU HAVE
EXPERIENCE WITH THIS AREA AND CAN EITHER CONFIRM OR ADD TO
PARTRIDGE RIVER LOCATIONS BASED ON YOUR OWN EXPERIENCE, PLEASE
ADD HERE]
The MPCA also proposed that the Embarrass River should only be
considered a wild rice river as far upstream as Embarrass Lake. This is not
right and would not protect wild rice. Reports made to the MPCA and a
long history of experience shows that there is wild rice far upstream of
Embarrass Lake feeding both human harvesters and wildlife. [ADD ANY OR
ALL OF THE POINTS BELOW WHICH ARE BASED ON AGENCY FILES]
• The Barr Engineering consultants for the PolyMet Company found wild
rice upstream on the Embarrass River at Hay Lake and just upstream of Hay
Lake when they did surveys from 2009 to 2011.
• The Barr consultants for the PolyMet Company also found some wild rice
upstream on the Embarrass River between Spring Mine Creek and
Unnamed Creek.
• For many years, there was a paddy rice farm by Unnamed Creek, close to
the LTV tailings basin.
• [ADD ANY OF YOUR OWN SPECIFIC KNOWLEDGE ABOUT WILD RICE
FURTHER UPSTREAM ON THE EMBARRASS RIVER]
[ADD ANY THOUGHTS OR COMMENTS ABOUT WHY THE MPCA
RECOMMENDATION IS TOO NARROW. HERE ARE SOME IDEAS]
Waters further upstream on the Embarrass River should be included by the
MPCA and agencies reviewing the PolyMet NorthMet project as wild rice
waters. It makes no sense to say that an area where there was a paddy rice
farm several years ago is not an area where wild rice was used to support
human harvesting. [ADD ANY INFORMATION YOU MAY HAVE ABOUT
HARVESTING BY PEOPLE ON THE UPPER EMBARRASS]
In addition, [ADD IF YOU ARE A HUNTER, RICER, CANOER, NATURALIST],
ducks will feed on wild rice even if a specific wild rice stand is not being
used by people. The sulfate rule won't protect ducks and other wildlife if it
is limited to only the places where people more commonly harvest.
[PUT THIS IN YOUR OWN WORDS] If wild rice in some areas of the
Embarrass River is not thick, it could well be because of sulfate discharge
from the LTV tailings basin. It would defeat the whole purpose of the
sulfate standard to say that areas that are already thinned by pollution can
now be polluted even more because they won't be protected by the
standard.
Please include upstream areas of the Partridge and the Embarrass River
watersheds explained in this letter as designated wild rice waters and
protect the manoomin growing in these areas and feeding people and
wildlife.
Sincerely,
[NAME, ADDRESS, ANY AFFILIATION]