Ed Rudberg
ESPM 5242
Sphagnum Peat Mining in Minnesota
Exercise 1: Analysis Topic and Problem Definition
Problem Statement:
In the state of Minnesota, peat bogs are finite natural resources that are currently being
impacted by peat mining resulting in water quality degradation, the loss of habitat and the
loss of a carbon sink.
Background
Two kinds of peat mining occur in Minnesota. Reed-sedge peat mining occurs largely
through the excavation of reed-sedge wetlands to obtain the organic rich material. Peatsedge peat is not utilized as a growing media but rather as a soil conditioner. Minnesota
sphagnum peat is harvested by draining peat bogs, removing trees and vegetation, tilling
the peat and finally harvesting the peat by suction. The peat is subsequently utilized as a
growing medium or used to supplement soil with organic material. Peat has also been
considered as an alternative fuel source.
Peat mining falls under many levels of regulation from the national to the local level.
Peat mines generally require a 404 dredge and fill permit from the Army Corps of
Engineers, a 401 water quality certification from the MPCA, an NPDES permit from the
MPCA, a construction stormwater permit from the MPCA, potentially an air emissions
permit from the MPCA, and a permit to mine peat by the MDNR.
The process of peat mining has come under scrutiny of environmental advocacy groups
and has at times been the subject of fines from the Minnesota Pollution Control Agency.
Peat mining has historically been encouraged to promote economic progress in the
economically depressed region of northeast Minnesota. The cumulative environmental
and cultural impact of peat mining has not been assessed. Nor have the economic cost
and benefits been weighed.
Stakeholders
Peat mining industry: pro mining
Employees of peat mines: pro mining
Natural Resource Research Institute: given the task of promoting economic growth
through utilization of natural resources i.e. peat
Minnesota Department of Natural Resources
Minnesota Pollution Control Agency
Minnesota Environmental Partnership
Red Lake Nation Tribal Council: opposed to mining
Fond du Lac Nation: opposed to mining
Leach Lake Band of Ojibwe: opposed to mining
Friends of the Pine Island Bog: opposed to mining
Indigenous Environmental Network: opposed to mining
Information availability and adequacy
Information on the economic benefits of peat mining, the industries involved, and the
staff employed is accessible through NRRI. More difficult will be information on the
economic cost due to environmental degradation. Due to the difficulty in quantifying
environmental degradation, this is not a surprise. The laws and policy regulating mine
reclamation and mitigation are easily evaluated. More difficult will be unwritten policy
within the permitting bodies of the MPCA, the DNR and the ACOE.
Exercise 2: Evaluation Criteria
Description of Specific Outcomes to be Measured
The outcome of this policy analysis is an overall assessment of the impacts of current
peat mining practices in Minnesota and its affect on the natural environment. It will
provide an overall evaluation of current laws, policies and governmental entities
regulating peat mining in Minnesota. The policy analysis will provide evaluation criteria
and metrics used for the evaluation. Finally the policy analysis will describe policy
alternatives and recommendations.
Criteria/metrics
1. EquityThe economics of peat mining will be explored from the perspective of equity. This will
involve evaluating the economic benefits of the peat mining industry in the form of jobs,
permitting fees and overall economic contribution to the state. Economic costs stemming
from environmental degradation will also be explored. The metrics used will be
exploring “winners and losers” via a costs-benefits analysis to determine who is bearing
the burden of the costs and who is reaping the economic benefits. Additionally economic
externalities will be evaluated.
2. Ecological integrityThe ecological impact of peat mining will be evaluated to assess biological and physical
impacts to Minnesota’s natural resources. The metrics used to determine this impact will
be assessing spatial extent of peat mining impacts within the state. Additionally, the
degree and duration of impacts to water quality, habitat and carbon sequestration will be
examined.
3. Political viability
The political climate will be assessed to determine the political viability of changes to
current peat mining policies. The metrics used to address political viability will be an
evaluation of appropriateness, legal and to some extent equity of current policies and
potential alternatives. Determining the appropriateness of policy changes will entail
examining current societal attitudes and beliefs regarding peat bogs to determine whether
current policies are in line with societal values. An evaluation of the current legal
regulations affecting peat bog mining will be explored to evaluate alternatives. Finally
equity, although previously explored from an economic standpoint, will also be addressed
from a more general, political standpoint.
Exercise 3: Policy Alternatives
Alternatives
1) No action alternative:
The no action alternative will maintain the current policy towards peat mining. The
Natural Resource Research Institute will continue to promote peat mining and assist in
the permit application process. The permitting process will continue to go through the
Department of Natural Resources, the Army Corps of Engineers, and the Minnesota
Pollution Control Agency. The cost of the NOA will still be the status quo. This
alternative is perhaps the most simplistic because we are not changing the process, but
rather continuing our current efforts. The simplicity may come into question when we
have differing state agency perceptions and conceivably conflicting perceptions of peat
mining. The riskiness of the NOA is that the status quo results in permanent
environmental impacts. Therefore, the riskiness of not changing current policies is high.
2) Increase mitigation ratios of peat mining offset environmental impact
Currently mitigation ratios are 1:1 for in kind, in place and in time mitigation. For peat
mining, a temporal loss of resource function is usually mitigated through an additional
10% of restoration, wetland banking, or wetland creation is currently used, but it is not
standardized. Through the re-evaluation of mitigation ratios and increasing these ratios
to compensate for an overall functional loss of peat lands, environmental degradation can
be reversed. The cost associated with requiring additional mitigation for peat lands will
cost the peat mining industry as well as any part of the population that must mitigate for
impact to peat bogs. The riskiness is high. The restoration of peat bogs has not been
definitively shown to compensate for loss of function. Therefore, there is some risk in
failure. This alternative is highly compatible with other programs already in place. It
would simply require that the ACOE would standardize its requirements for temporal loss
with the PCA’s 401 water quality certification and BWSR’s WCA requirements. This
option is highly reversible and would simple require an additional memorandum of
understanding between the ACOE, PCA and BWSR.
3) Increase the cost of peat mining permits to fund environmental restoration
In order to offset the environmental degradation caused by peat mining, the cost of the
permit to undertake the activity on public and private land could be increased to more
viably fund the restoration of the environmental degradation. The cost associated with
this will again be born by the polluters, i.e. peat mining operations. The benefits would
then be returned to the public to offset the public burden of increased pollution. There is
risk associated with this alternative because mining may cause irreversible environmental
degradation that cannot be addressed via restoration. The communicability is easy and
straight forward and it follows the “polluter pays” ethos often popular to the public. The
alternative is quite simple as well. It will require a rule making or legislative action to
increase the cost, but following such an action, it should be quite simple.
4) Banning peat mining within the State of Minnesota
A total ban of peat mining within Minnesota is the final alternative. The ban would allow
currently permitted peat mining operations to continue their mining until the reclamation
of the sites are complete. This would halt further environmental degradation and
preserve a finite natural resource. The cost of this program initially would be low. There
could be litigation over the argument of a governmental taking. There would be an
eventual loss of job base and permit fees and jobs associated directly with peat mining
advocacy at the NRRI and with permitting may be lost. The alternative is quite simple,
but the sun setting of peat mining may be more difficult. The reliability is also quite
high. Environmental degradation due to mining will not increase if mining does not
occur.
Exercise 4: Data Sources and Analysis
Data Types (primary: interviews; secondary: academic journals, environmental
assessments, permit applications)
Environmental data- In order to assess environmental impacts caused by peat mining,
data must be collected on wildlife impacts, water quality impacts and the impacts of
mining on carbon sequestration. The data on impacts to wildlife will be collected
through academic journals. Although this information will be quantitative at the specific
site of research, the data will be used to make a qualitative assessment of overall impacts
to habitat of mined areas. If the habitats and the mitigation employed are similar, one can
correlate the data to Minnesota.
This process will be similar for carbon sequestration data. Data on the carbon
sequestration rate of pre-mined sphagnum peat bogs will be compared to that of
mitigation sites to determine a net loss or gain in function. This may prove to be more
difficult as the scientific process for determining carbon sequestration rates has many
more variables and is highly complex.
Water quality data can be obtained from academic journals and through data obtained
through NPDES permits issued from the PCA. Academic journal information will give a
general idea of peat mining impacts to water quality. Site specific discharge data
obtained through the PCA may be more difficult to obtain and evaluate.
In addition to academic journals, environmental assessments of recent Minnesota projects
may be used to obtain additional data on environmental impacts. In particular, the Pine
Island EIS will be utilized. Using this data is quite feasible for wildlife impacts and
water quality, but the loss of function for carbon sequestration may have fallen outside of
the scope of environmental assessments.
Economic data- Economic data will be largely obtained through the Pine Island EIS and
primary data collection will occur through interviewing research staff at the NRRI and
the DNR to determine number of operating sites, employment numbers, relative salaries
of employees and state leasing rates. This information will be largely qualitatively
assessed through cost benefits of environmental costs versus economic benefits to the
state. The economic “losers” and “winners” will also be evaluated for equity. Assuming
staff are available and willing to be interviewed and environmental assessments can be
obtained from the DNR, this data it is quite feasible to use this data in the analysis. The
data from interviews will be spatially and temporally relevant, but depending on the date
of the environmental assessments, it may be less temporally relevant.
Analytic Methods
Implementation Analysis: An implementation analysis has various advantages. First, the
policy alternatives would likely be implemented by the PCA, DNR, BWSR and/or the
ACOE. Therefore, in order for policy to be implemented it must be feasible to do so in
each organization that it is affecting. Conducting this analysis will also determine the
steps needed to be taken; whether it is a rule making, guidance, or legislative action; in
order for the policy to be legally implemented.
The negatives to this analysis are first its uncertainty and second its complexity. If the
actions needed to be taken to implement the policy simply involve guidance, the
implementation can be quite simple. If on the other hand the governmental bodies must
undertake a rule making, assessing the resources available to undertake the time and
resource intensive process will be difficult and complex. If legislative action must occur
for implementation, a political feasibility analysis should also occur.
Political Feasibility Analysis: A political feasibility analysis has the advantages of
evaluating political climate to determine acceptability of potential policy alternatives
there must be a political will to do so. This allows the analyst to forecast what will and
will not be acceptable. It also aids in the identification of political stakeholders and
potential lobbying stakeholders. The negatives of this analysis are the complexity of the
political process and political motivations. Peat mining occurs in the northern and north
eastern Minnesota an area that is ecologically sensitive and largely economically
depressed. Therefore, the motivations for environmental protection are confounded to a
greater extent by economic factors.
Scenario Writing: The advantages of scenario writing are that it will aid in both
ascertaining implementation problems as well as identifying potential additional
alternatives. The disadvantage of scenario writing is that creating “best”, “worst”, and a
mid range scenarios may not adequately identify pitfalls, road blocks or alternatives.
This may be the case because scenario writing builds upon previous implementation and
political feasibility analysis. Therefore, errors in previous analysis will be compounded
in the scenario writing. Also, because of the complexity of the political and
implementation feasibility, the scenario writing can be difficult and tedious.