Doug Bruner and Michael Jimenez

September 26, 2013

Page 2
Each of your agencies is required to comply with NEPA, and therefore must follow this
authoritative interpretation. Although the Climate Change Guidance states: Agencies should
exercise judgment when considering whether to apply this guidance to the extent practicable to
an on-going NEPA process,3 the U.S. Environmental Protection Agencys (EPA) comments4
on the Northern Access 2016 Environmental Assessment,5 make it clear that the Guidance is
applicable to issued NEPA documents. Each federal agency remains accountable to analyze
greenhouse gas (GHG) emissions and mitigation measures even if the NEPA document came out
before the Climate Change Guidance became effective.6
The Climate Change Guidance is a tool for interpreting your agencies existing duties under
NEPA that does not change or substitute for any law.7 Exercising your judgment when
considering whether to apply this guidance cannot be used to excuse a failure to address climate
change issues in an Environmental Impact Statement (EIS) simply because the EIS was finalized
before August 5. Because your NEPA duty existed before the Guidance was issued, a proper
exercise of judgment would mean reviewing the EIS to determine whether climate change issues
were addressed at a comparable level as that described by the Guidance. If this is the case,
reopening the EIS to apply the Guidance would be unnecessary. But if an EIS has failed to
address climate change issues in significant ways, the Guidance makes it clear that the agency
has failed to comply with NEPA, regardless of the date that the EIS was finalized. This is
particularly true when those issues were raised by reviewing agencies and the public. The only
appropriate avenue in that situation is to reopen the EIS to address those issues, and the
Guidance provides the appropriate roadmap to do so.

Climate Change Guidance at 33.

EPA, Letter from Grace Musumeci, Chief of Environmental Review Section Sustainability and
Multimedia Programs Branch, to Kimberly D. Bose, Secretary of Federal Energy Regulatory
Commission, Regarding Docket Nos. CP15-115, Northern Access 2016 Project, (Aug. 25, 2016)
[hereinafter Letter from Grace Musumeci], available at
http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=14342422.
5
U.S. Federal Energy Regulatory Commission, Environmental Assessment: Northern Access
2016 Project, Docket No. CP15-115-000/CP15-115-001 (July 27, 2016), available at
http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=14316645.
6
Among other comments, EPA pointed out that the Northern Access 2016 Environmental
Assessment:
did not include estimates of GHG emissions from methane leakage along the
pipeline or indirect GHG emissions associated with the production and
combustion of the natural gas brought into production as an indirect effect of this
project. FERC also did not disclose measures considered to avoid, minimize, or
mitigate for any of these GHG sources, whether estimated or not in the EA.
Letter from Grace Musumeci, supra note 4, at 2. EPA explained that the way to cure these
deficiencies was to apply the Climate Change Guidance, and quoted relevant passages of the
Guidance for the Federal Energy Regulatory Commissions use in its NEPA process. Id.
7
Climate Change Guidance at 1, n.3.
4

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In the NorthMet case, the Climate Change Guidance indicates that the many comments your
agencies received about your duty to accurately and thoroughly address climate change issues
under NEPA were based on a correct understanding of the law. The Guidance also makes it clear
that your failure to do so violates NEPA. The appropriate exercise of judgment at this point
would be to reopen the EIS and to follow the Guidance.
This letter submission is ultimately made in order to help your agencies comply with your legal
obligations. The Climate Change Guidance makes clear your agency must ensure [its] analysis
of potential GHG emissions and effects of climate change . . . is commensurate with the extent
of the effects of the proposed action.8 This letter is intended to assist you in identifying the
extent of effects and issues raised in earlier comments that relate to your duties under NEPA.
Since these comments have as yet not been seriously considered or addressed, your agencies
should revisit their analysis with a supplemental review informed by the Climate Change
Guidance before issuing a Record of Decision (ROD). It is your duty to address the Guidance
and finally acknowledge and respond to timely-made comments on the NorthMet Final EIS
(FEIS) as set out below.
Greenhouse Gas Emissions
Calculating and balancing GHG emissions is required under NEPA. The Climate Change
Guidance makes clear that relevant emissions include both carbon as well as other GHGs, such
as methane.9 Moreover, the guidance states that emissions includes release of stored GHGs as
a result of land management activities affecting terrestrial GHG pools such as, but not limited to,
carbon stocks in forests and soils, as well as actions that affect the future changes in carbon
stocks.10 Emissions calculations are also, when possible, supposed to address the possibility of
carbon sequestration, and use net emissions as a proxy for climate change effects analysis.11
The potential emissions from the NorthMet project are significant and must be fully analyzed.
Eliminating any significance threshold (one had been suggested in the earlier draft of the

Id. at 3.
Id. at 1, n.1.
10
Id.
11
Climate Change Guidance at 4. Additionally, the Climate Change Guidance encourages
agencies to account for these emissions using the Federal Social Cost of Carbon (SCC), which
allows for a more valid cost-benefit analysis by quantifying some of the damages caused by
projected emissions. Developed through an interagency process committed to ensuring that the
SCC estimates reflect the best available science and methodologies and used to assess the social
benefits of reducing carbon dioxide emissions . . . it provides a harmonized, interagency metric
that can give decision makers and the public useful information . . . Id. at 33, n.86. The SCC has
been established since 2010, and was updated in 2015 with the most current science, and your
agencies had knowledge of its promulgation and usefulness in quantifying and comparing
impacts of projected emissions.
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Guidance), the Guidance: does not establish any particular quantity of GHG emissions as
significantly affecting the quality of the human environment . . .12 This is because all
emissions can be, and are, significant when taken in the context of the overall impact these
emissions are cumulatively having.13 The Climate Change Guidance explains why it is not
appropriate for agencies to try to casually dismiss emissions from their project as de minimis:
CEQ recognizes that the totality of climate change impacts is not attributable to
any single action, but are exacerbated by a series of actions including actions
taken pursuant to decisions of the Federal Government. Therefore, a statement
that emissions from a proposed Federal action represent only a small fraction of
global emissions is essentially a statement about the nature of the climate change
challenge, and is not an appropriate basis for deciding whether or to what extent
to consider climate change impacts under NEPA. Moreover, these comparisons
are also not an appropriate method for characterizing the potential impacts
associated with a proposed action and its alternatives and mitigations because this
approach does not reveal anything beyond the nature of the climate change
challenge itself: the fact that diverse individual sources of emissions each make a
relatively small addition to global atmospheric GHG concentrations that
collectively have a large impact.14
It goes on to say that agencies should quantify emissions for each alternative and compare these,
but avoid facile analogizing of the projects emissions against sector, nationwide, or global
emissions.15 Facile analogies to nationwide and global emissions is exactly the tactic that the
FEIS currently uses to dismiss the import of GHG emissions from the NorthMet project.
NEPA requires your agency to meaningfully consider lower-emission alternatives and compare
different alternatives against benchmarks set by Minnesota law. Considering alternatives,
including alternatives that mitigate GHG emissions, is fundamental to the NEPA process . . .16
and the alternatives analysis requires your agency to address alternatives with lesser or zero
GHG emissions.17 This point was brought up many times in public comments to this NEPA
review. The measures the Climate Change Guidance suggests include energy efficiency and
identified technologies with lower emissions.18 Emissions alternatives are especially useful and
important to analyze where an agency is addressing a project in a state with GHG reduction goals

12

Id. at 910.
Id. at 17 (for the purposes of NEPA, the analysis of the effects of GHG emissions is
essentially a cumulative effects analysis).
14
Id. at 11.
15
Climate Change Guidance at 11.
16
Id. at 14.
17
Id. at 15.
18
Id. at 19.
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so the agency can compare alternatives that either support or harm those goals,19 such as the
greenhouse gas reduction goals Minnesota has enacted in state statutes.20 It is also important for
the agency to compare its alternatives within the context of its existing commitments to
sustainability and emissions reductions. While broad department- or agency-wide goals may be
of a far larger scale than a particular program, policy, or proposed action, an analysis that
informs how a particular action affects that broader goal can be of value.21
With all of this information in mind, it is imperative that your agencies fully respond to
comments submitted on the NorthMet Supplemental Draft Environmental Impact Statement
(SDEIS) and FEIS. For example, comments such as:

MCEAs comments on the SDEIS regarding:

o the increased coal usage required by the project, the energy demand of the project,
the inconsistency of this project with the Minnesota legislatures goals of
reducing GHG emissions to certain percentage reductions by 2015, 2025, and
2050, the failure to explore the use of existing technology to reduce emissions, the
failure to consider alternative energy sources as urged by the Minnesota Pollution
Control Agency, and the failure to consider meeting energy demands with a
different electric utility that would not be so reliant on coal generation.22
o the failure to accurately account for terrestrial carbon loss.23
o the failure of adequate study of the impacts to wetlands and peatlands.24
o the failure to assess an alternative of on-site renewable generation at the facility.25
o the failure to analyze indirect impacts of increased demand on Minnesota Powers
energy generation mix.26
o the failure to analyze the emissions impacts of transporting NorthMets ore for
smelting elsewhere in North America,27 as well as the GHG and other emissions
that are the foreseeable impact of smelting that ore.28

19

Climate Change Guidance at 29.

Minn. Stat. 216C.05, subd. 2 & 216H.02, subd. 1.
21
Climate Change Guidance at 32.
22
Minnesota Center for Environmental Advocacy Comments on the Supplemental Draft EIS for
the NorthMet Project, Submitted to the Minnesota Department of Natural Resources, the U.S.
Army Corps of Engineers, and the U.S. Forest Service, Mar. 13, 2014, at 9497 [hereinafter
MCEA SDEIS comments].
23
Id. at 94.
24
Id. at 89; see also id. at 8284.
25
Id. at 97.
26
MCEA SDEIS comments at 97.
27
Id. at 105.
28
Id. at 10203.
20

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o insufficient discussion of cumulative impacts of emissions from this project along

with other foreseeable mining projects.29
Save Our Sky Blue Waters, Save Lake Superior Association, Center for Biological
Diversity, Friends of the Cloquet Valley State Forest, and the Sierra Clubs comments on
the SDEIS regarding:
o the failure to discuss carbon sequestration in peatlands and the state policy to
preserve peatlands for that purpose.30
o the failure to address the destruction of high quality wetlands and the consequent
loss of absorbed carbon as emissions.31
o omission of other GHG emissions source analysis for transportation and
processing emissions, and of any alternatives analysis for lower emissions
alternatives using clean energy.32
o perfunctory and inadequate comparisons of the project to Minnesotas overall
GHG emissions, and a failure to place the emissions from this project within the
existing regulatory efforts to limit these emissions.33
o the failure to address lack of progress towards the states goals at reducing GHG
emissions.34
Conservation Organizations35 comments on the FEIS regarding:
o the failure to correctly analyze carbon sequestration by peatlands and the
megatons of carbon and methane emissions risked by land management decisions
in Minnesota such as the drying of peatlands and direct and indirect effects from
the NorthMet project.36
o the failure to assess emissions effects from the increased coal burning associated
with the project, and failure to weigh the impacts of this project on the continued

29

Id. at 124.
Save Our Sky Blue Waters, Save Lake Superior Association, Center for Biological Diversity,
Friends of the Cloquet Valley State Forest, and the Sierra Club Comments on the Supplemental
Draft Environmental Impact Statement for the NorthMet Mining Project and Land Exchange,
Mar. 13, 2014, at 8486 [hereinafter SOS-SLSA-CBD-FCVSF-SC SDEIS comments].
31
Id. at 154.
32
Id. at 8687.
33
Id. at 83.
34
SOS-SLSA-CBD-FCVSF-SC SDEIS comments at 8384.
35
These organizations include: Minnesota Center for Environmental Advocacy, Center for
Biological Diversity, Earthjustice, Sierra Club North Star Chapter, Friends of the Boundary
Waters Wilderness, Save Our Sky Blue Waters, Northeastern Minnesotans for Wilderness,
Friends of the Cloquet Valley State Forest, Voyageurs National Park Association, and the
National Parks Conservation Association.
36
Conservation Organizations Comments on the Supplemental Final EIS for the NorthMet
Project, Submitted to the Minnesota Department of Natural Resources, Dec. 21, 2015, at 7375
[hereinafter Conservation Organizations FEIS comments].
30

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September 26, 2013
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profitability of coal and natural gas generation, leading to increased pollution, on
Minnesota Powers system.37
o the incomplete and flawed cumulative impacts analysis, that fails to take into
account the full range of connected actions and cumulative effects of the different
emissions sources and feedback loops that are linked to the NorthMet project.38
In light of the Climate Change Guidance and these comments it is clear that the analysis in the
FEIS is inadequate and your agencies have not satisfied your duties under the CEQ NEPA
regulations. Until these issues are resolved with a supplemental analysis, issuing a ROD on this
FEIS would be arbitrary and capricious, and obviously counter to your duties under NEPA.
Effects of Climate Change
Using existing resources your agency is required by NEPA to comprehensively analyze climate
change effects across the full spectrum of known impacts and communities. The Climate Change
Guidance advises agencies to use available information when assessing the potential future state
of the affected environment in a NEPA analysis39 and suggests using analyses from the United
States Global Change Research Program (USGCRP) to identify impacts. 40 Climate change
effects are known to have far-reaching impacts on many aspects of the human environment:
Broadly stated, the effects of climate change observed to date and projected to
occur in the future include more frequent and intense heat waves, longer fire
seasons and more severe wildfires, degraded air quality, more heavy downpours
and flooding, increased drought, greater sea-level rise, more intense storms, harm
to water resources, harm to agriculture, ocean acidification, and harm to wildlife
and ecosystems.41
More specifically, climate change poses particular threats to the health, well-being, and ways of
life of indigenous peoples in the U.S.42 Coupled with this truth is the agencys duty under
Executive Order 12898 to evaluate Environmental Justice impacts that harm minority and lowincome communities.43
Alternatives analysis must include multiple scenarios and project out for the entire life of the
projects potential impacts. NEPA review must account for the changes expected in the climate
over the hundreds of years that the NorthMet mine is expected to continue producing polluted

37

Id. at 79.
Id. at 9097.
39
Climate Change Guidance at 5.
40
Id. at 22.
41
Id. at 89.
42
Id. at 9, n.21.
43
Climate Change Guidance at 23.
38

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water.44 Using authoritative climate change reports already created by the federal government,
the agencies should project at least two possible scenarios for a changed climate, even within
the no-action alternative.45 This robust treatment of the no-action alternative would then allow
the agency to properly assess resources that are impacted by both the proposed action and
climate change46 in other alternatives. For example, a proposed action may require water from
a stream that has diminishing quantities of available water because of decreased snow pack . . .
or add heat to a water body that is already warming due to increasing atmospheric
temperatures.47 Examples of resources that would be affected by both climate change and
mining at the NorthMet site include wildlife such as Canada lynx and moose, imperiled
ecosystems such as the black spruce/jack pine forest, and water levels supporting wetlands and
streams. An assessment of the combined effects of climate change and mining on these resources
is completely absent from the FEIS, a point that has been made repeatedly throughout the
process.
With all of this information in mind, it is imperative that your agencies fully respond to
comments submitted on the NorthMet SDEIS and FEIS. For example, comments such as:

MCEAs comments on the SDEIS regarding:

o EPAs statement that climate change impacts will exacerbate . . . uncertainty
regarding mining accidents at hardrock mining facilities.48
o the failure of the NEPA review to address climate change effects on loss of
wetlands.49
o the need for additional analysis of impacts to ecosystems based on CEQ principles
and analytical steps necessary for cumulative impacts analysis.50
o water modeling that fails to account for seasonal variability and spring
snowmelt,51 and thus would not be able to account for differences in these model
inputs when they are changed under likely climate scenarios.
o variations in snowfall and deposition that, in turn, have impacts on vehicle traffic
that the presence of listed species such as lynx.52
o additional modeling approaches and geotechnical analyses needed to account for
the potential for tailings dam instability,53 likely aggravated by shifts in rainfall

44

Id. at 20.
Id. at 21.
46
Id. at 21.
47
Climate Change Guidance at 21.
48
MCEA SDEIS comments at 50.
49
Id. at 79
50
Id. at 11617.
51
Id. at 75.
52
MCEA SDEIS comments at 111.
53
Id. at 6 & 75.
45

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and other climate impacts that could stress the aging dam over the hundreds of
years it is required to hold.
Save Our Sky Blue Waters, Save Lake Superior Association, Center for Biological
Diversity, Friends of the Cloquet Valley State Forest, and the Sierra Clubs comments on
the SDEIS regarding:
o the general failure to address and adequately analyze the impacts of climate
change across the agencies analysis, including ecosystem and airpollution
deposition impacts that are further aggravated by the NorthMet project.54
o the need to look at wetland availability in the context of climate change and how
this might have impacts, for example, on mooses thermoregulation in warm
temperatures,55 as well as a general failure to discuss impacts and cumulative
impacts on moose that will be more severely impacted by climate change.56
o the failure to properly address the habitat impacts for important species of a land
exchange,57 which also consequently omits the aggravating impacts of climate
change.
o the failure to adequately discuss cumulative impacts to listed plant species, and
the threats to these species from any and all stressors related to climate change
and the project.58
o the failure to address the climate change impacts to black spruce/jack pine
forest,59 which is both imperiled as such and as a habitat for other species.
o the lack of analysis of water fluctuations and their probable impacts on mercury
pollution in the environment, which is likely to be further impacted by climate
shifts in water availability over time.60
o the failure to assess the volume of water that will need to be treated after facility
closure, or the water quality that is likely at that time and over the hundreds of
years of treatment,61 or the project impacts on stream flow over the same time
period,62 which will be further complicated by climate change impacts to both
water quantity and quality in was that were not assessed by agencies.
Conservation Organizations comments on the FEIS regarding:

54

SOS-SLSA-CBD-FCVSF-SC SDEIS comments at 87.

Id. at 63.
56
Id. at 6971 & 7475.
57
Id. at 13132 & 155.
58
SOS-SLSA-CBD-FCVSF-SC SDEIS comments at 76.
59
Id. at 63.
60
Id. at 31.
61
Id. at 4445.
62
SOS-SLSA-CBD-FCVSF-SC SDEIS comments at 4649.
55

Doug Bruner and Michael Jimenez

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o the omission of analysis, or even acknowledgement, of the decline of Minnesota
moose populations and moose habitat, which will be further aggravated by
climate change impacts and the NorthMet project.63
o the incomplete and flawed cumulative impacts analysis, that fails to take into
account the full range of connected actions and cumulative effects across a range
of issues that are impacted by climate change.64
o the incomplete information on sulfate and mercury methylation, which are
changed and impacted by changes in snowmelt and flooding, and therefore a
failure to address water quality impacts that are affected by climate change.65
o the failure to discuss increased chance of wildfire due to the drying of peatlands,
both an impact and a cause of climate change emissions.66
o the failure to address concerns with the tailings dam design and to include
analyses of more protective alternatives of tailings storage, only mentioning one
alternative that might be vulnerable to climate change impacts of water
availability changes stressing an already flawed storage dam.67
o the inadequacy of analysis of mitigation measure failure and reasonably
foreseeable accidents, which are similarly likely to be aggravated by climate
impacts (during the hundreds of years that these measures will have to endure)
that were not suitably assessed and compared.68
o the failure to address potential freeze and weather damage to liners and covers,
which will be complicated by shifting severe weather that was not properly
assessed in an incomplete discussion of these barriers.69
o the failure to adequately analyze and disclose impacts to federally listed species,
and to demonstrate compliance with the Endangered Species Act for these
species, analysis which needs to incorporate climate change impacts in order to be
adequate.70
o the use of a flawed water model that cannot be said to correctly incorporate
adequate inputs and parameters to assess the potential movement of water and
wastewater around the facility over the short term or long term, and therefore
cannot account for climate change impacts in a realistic way.71

63

Conservation Organizations FEIS comments at 8790.

Id. at 9097.
65
Id. at 66.
66
Id. at 74.
67
Conservation Organizations FEIS comments at 19, 3536.
68
Id. at 2435.
69
Id. at 4042.
70
Id. at 8386.
71
Conservation Organizations FEIS comments at 4954.
64

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Most of these above-identified issues have the potential to inequitably impact indigenous peoples
living in the area. To the extent that these issues were not adequately addressed, the agencies
have not satisfied their duties to address Environmental Justice in their NEPA review process.
In light of the Climate Change Guidance and these comments it is clear that the analysis in the
FEIS is inadequate and your agencies have not satisfied your duties under the CEQ NEPA
regulations. Until these issues are resolved with a supplemental analysis, issuing a ROD on this
FEIS would be arbitrary and capricious, and not in accordance with NEPA.
Mining Lifecycle Analysis Required Under NEPA
The Climate Change Guidance also sets out general principles of NEPA analysis for mining
projects your agency should review and follow. For example, the Guidance explains: NEPA
reviews for proposed resource extraction and development projects typically include the
reasonably foreseeable effects of various phases in the process, such as clearing land for the
project, building access roads, extraction, transport, refining, processing, using the resource,
disassembly, disposal, and reclamation.72 On this same point the Guidance goes on explain in
the mining context: For actions such as a Federal lease sale of coal for energy production, the
impacts associated with the end-use of the fossil fuel being extracted would be the reasonably
foreseeable combustion of that coal.73 From these examples it is clear that an FEIS regarding
the mining and processing of metals also must analyze refining, uses, disassembly, disposal, and
reclamationin short, a full lifecycle analysis of the metals and wastes produced, including end
uses.
With all of this information in mind, it is imperative that your agencies fully respond to
comments submitted on the NorthMet SDEIS and FEIS. For example, comments such as:

MCEAs comments on the SDEIS regarding the reviews failure to account for smelting
of ore produced at the NorthMet facility, failure to identify potential smelting locations
and assess the impacts of each location, failure to account for location-specific impacts
and to analyze potential air emissions impacts from increased smelting due to the
NorthMet project, and failure to account for the environmental impacts of transporting
NorthMets ore to a smelting facility and pollution impacts to soil and water from
smelting.74

72

Climate Change Guidance at 14.

Id. at 16, n.42.
74
MCEA SDEIS comments at 98105.
73

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September 26, 2013
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Conservation Organizations comments on the FEIS regarding the failure to account for
the full life-cycle of transport, smelting, processing, use, and emissions of all these steps
as a part of the analysis of the NorthMet project.75

Much like with the emissions and climate change impacts discussed above, the Guidance and
these comments together demonstrate that the analysis in the FEIS is inadequate and your
agencies have not satisfied your duties under the CEQ NEPA regulations in reviewing a mining
projects full impacts. Until these issues are resolved with a supplemental analysis, issuing a
ROD on this FEIS would be arbitrary and capricious, and not in accordance with NEPA.
Conclusion
While the Climate Change Guidance came out recently, it does not establish new requirements,
but rather interprets and clarifies the CEQ NEPA regulations that MCEA and other parties have
relied on in pointing out your duty to fully assess greenhouse gas emissions, carbon
sequestration, alternatives, and climate change impacts in your review of the NorthMet mine
proposal. The Guidance indicates that MCEA and other organizations were correct in their
understanding of the NEPA regulations, and provides an appropriate standard for rectifying your
agencies failure to address these issues. We urge you to announce a supplemental review period,
with notice and comment periods sufficient to fully address climate change issues.

Dated: September 28, 2016

/s/ Hudson Kingston

.
Hudson B. Kingston
Staff Attorney
Minnesota Center for Environmental Advocacy
26 East Exchange Street, Suite 206
St. Paul, MN 55101
Phone: (651) 287-4880
hkingston@mncenter.org
/s/ Marc Fink
Marc Fink
Senior Attorney
Center for Biological Diversity
209 East 7th Street
Duluth, MN 55805
Phone: (218) 464-0539
mfink@biologicaldiversity.org

75

Conservation Organizations FEIS comments at 8082.

Doug Bru
uner and Miichael Jimen
nez
September 26, 2013
Page 13
/s/ Paul Dannicic
.
Paul Daniciic
Executive D
Director
Friends of tthe Boundaryy Waters Wiilderness
401 N. Thirrd Street, Suuite 290
Minneapoliis, MN 554001
Phone: (6122) 332-9630
paul@friendds-bwca.orgg

.
Lori Andressen
President
Save Our Skky Blue Watters
P.O. Box 36661
Duluth, MN
N 55803
Phone: (2188) 340-2451
andres01@ccharter.net
Encl.
cc:

Lisa
L Fay MNDNR
M
Div
v. of Ecological Resourcces Environm
mental Revieew Unit
EIS
E Project Manager
M
(lisaa.fay@state.mn.us)
Tom
T
Landweehr MN Department
D
of
o Natural Reesources Coommissioner
(ttom.landweh
hr@state.mn
n.us)
Jo
ohn Linc Stiine MN Pollution
P
Con
ntrol Agencyy Commissiooner
(john.stine@sstate.mn.us)
Robert
R
A. Kaaplan EPA
A Region 5 Acting
A
Regioonal Adminiistrator
(k
kaplan.roberrt@Epa.gov))