Fresh Energy is committed to ensuring that Minnesota’s transition to clean energy is both equitable and just. As we work toward a future without carbon pollution, we know that not all communities are treated equally. Some communities — especially those that are under-resourced (defined as low-income in the technical rulemaking language) communities of color, and tribal nations — have historically borne disproportionate environmental burdens from multiple sources of pollution.
In 2023, the Minnesota Legislature passed the Frontline Communities Protection Act thanks to advocacy by the Frontline Communities Protection Coalition, of which Fresh Energy is a member. This law gives certain communities in the Twin Cities Metro area, Duluth, and Rochester stronger protections against air pollution. In particular, it makes sure that when a new polluting facility is proposed, the cumulative impacts of its pollution are considered; that means that the state measures the total pollution that’s already in the area before making a decision about adding another polluting facility.
This year, the Minnesota Pollution Control Agency (MPCA), the state agency that monitors environmental quality and enforces environmental regulations, is making rules for analyzing the cumulative impacts of pollution. As the MPCA hosts community meetings about this rulemaking process, we have an opportunity to make sure the rules are fair and protect the people who need it most.
Community voices must be centered in the cumulative impacts rulemaking process
For the cumulative impacts rule to work well and be equitable, it must put the experiences of the most affected communities first. This means using the most granular available data — preferably at the census block group level — to understand both environmental and health burdens.
A comprehensive analysis should consider:
- Current and historical pollution levels, recognizing that pollution’s long-term effects have harmed the health and quality of life of many Minnesotans.
- Health indicators, including both chronic conditions (e.g., asthma, heart disease) and acute events (e.g., respiratory hospitalizations during high-pollution days), which are linked to pollutant exposure.
- Social vulnerability factors including poverty rates, energy burden, housing quality and costs, educational attainment, employment opportunities, access to healthcare, food security, traffic conditions, and availability of green spaces.
While numbers and data are important, the most important thing is making sure communities most affected by pollution help shape the rules and final outcomes from the beginning.
When the MPCA talks directly with people in affected communities, it builds trust. By listening to community members in-person, they can learn things that data can’t show, like cultural values, cumulative stresses, and the community’s history with pollution and environmental harm.
By meeting directly with affected communities, the MPCA shows respect for the community and their expertise. It recognizes that communities aren’t just receiving decisions — they’re helping to make them from the get-go.
To include affected communities well, Fresh Energy believes that the MPCA should:
- Create clear, transparent, and accessible processes for how analyses will inform permitting decisions.
- Create public materials in plain, non-technical language that communities can understand and engage with.
- Include opportunities for public review, comment, and appeal.
- Ensure their representatives are culturally competent and knowledgeable about how to work directly with community members.
We also think that Community Benefit Agreements can help. These are deals made between the companies that want to build something and the surrounding community, where both can agree on how the community will benefit from the project. There are many resources available online to make this work well, including a helpful 2023 paper from Columbia University.
What’s next?
The MPCA will be holding public meetings in different communities in the summer of 2025 as part of its cumulative impacts rulemaking process. You can learn more about the rulemaking process and upcoming meeting dates here on MPCA’s website. Fresh Energy will continue to monitor developments and work with community partners to make sure that these new rules include communities fairly and are truly equitable for everyone. We encourage all Minnesotans who care about pollution-affected communities to participate in these upcoming opportunities to shape this important rule.
By including affected communities and using best data analysis practices, Minnesota can develop a cleaner, more equitable future for our state and build trust with our environmental decision-making process.
