State of Minnesota Before the Minnesota Public Utilities Commission I. INTRODUCTION
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1 State of Minnesota Before the Minnesota Public Utilities Commission Beverly Jones Heydinger Phyllis Reha David Boyd J. Dennis O Brien Betsy Wergin Chair Vice Chair Commissioner Commissioner Commissioner IN THE MATTER OF THE APPLICATION FOR A CERTIFICATE OF NEED FOR THE LINE 67 STATION UPGRADE PROJECT IN THE COUNTIES OF MARSHALL, CLEARWATER, AND ITASCA, MINNESOTA DOCKET No. PL9/CN REPLY COMMENTS AND REVISED NOTICE PLAN PROPOSAL I. INTRODUCTION Enbridge Energy, Limited Partnership, a Delaware limited liability partnership ( Enbridge ), submits this Revised Notice Plan as its reply comments in the abovecaptioned docket pursuant to Minnesota Rule This revised plan responds to and incorporates the comments of the Division of Energy Resources ( DER ), submitted on July 3, Enbridge s Line 67 Station Upgrade Project ( Project ) will provide the additional pipeline capacity necessary for Enbridge to meet its shippers transportation requirements in serving secure and reliable crude oil supplies to refineries and numerous marketing hubs throughout the Midwest and beyond. The Project will allow Enbridge to increase Line 67 s annual average capacity from 450,000 barrels per day ( bpd ) to 570,000 bpd, which is a 26.67% increase in capacity. No new land acquisition or pipeline construction will be required for the Project. The Project requires a certificate of need under Minn. R because it will expand the capacity of a large petroleum pipeline in excess of 20 percent of its rated capacity. A pipeline routing permit is not required because the Project only requires installation of additional pumping units and other modifications at the Viking, Clearbrook and Deer River Station sites in Marshall, Clearwater and Itasca Counties, respectively. This equipment is considered to be associated facilities under Minn. R , Subp. 7, so the Project is exempt from the pipeline routing permit requirement under Minn. R , Subp. 1.G. 1
2 II. REVISED NOTICE PLAN Enclosed as Attachment 1a is a revised overview map which shows general location of the existing Viking, Clearbrook and Deer River Station sites in Marshall, Clearwater and Itasca Counties, Minnesota. This revised map, as requested by the DER, also shows the eastern portion of Enbridge Pipeline (North Dakota) LLC s 1 North Dakota Mainline System as it extends from North Dakota to terminate at the Enbridge Clearbrook Station and Terminal Facility in Clearwater, Minnesota. No new land acquisition will be required and no landowners will be directly affected by the Line 67 Station Upgrade Project because all work activities will be performed at the existing station sites on land owned in fee by Enbridge. The proposed notice area is defined as the abutting properties located immediately adjacent to the three station sites where all Project work activities will be performed. That is the area reasonably likely to be affected by the Project. All three of the station sites are located in rural areas, and the abutting properties are shown on the related aerial maps listed on the table below. Name of Station Location County Map No. Viking Pump Station Section 28, T-155-N, Marshall Attachment 1b R-45-W Clearbrook Pump Station Sections 28, 29 & 33, Clearwater Attachment 1c and Terminal Facility T-149-N, R-37-W Deer River Pump Station Section 22, T-58N, R- 27-W Itasca Attachment 1d Enbridge submits this Revised Notice Plan to ensure that the notices are provided to interested parties. The components of the plan are: Revised Attachment 2 Direct mail notices to abutting residents with mailing addresses in the notice area. Revised Attachment 3 Direct mail notices to local, state and federal government officials Revised Attachment 4 General notice for publication in local and state-wide newspapers Revisions to the attachments are shown in underlined text. A. Direct Mail to Landowners Minnesota Rule , Subpart 3(A) requires Enbridge to provide direct mail notice to all landowners likely to be affected by the Project. As previously stated, the Project will be performed on land owned in fee by Enbridge. In addition, no new land acquisition or pipeline construction is required for the Project. No landowners will be directly impacted. Direct mail notice is therefore only required for those abutting property owners located immediately adjacent to the pump stations included in the Project. 1 Enbridge Pipelines (North Dakota) LLC is a wholly owned subsidiary of Enbridge Energy, Limited Partnership. 2
3 The direct mail letter has been revised, as requested by the DER, to include a statement clarifying that registering to receive documents or notifications does not equate to being a full party in the certificate of need proceeding. B. Direct Mail to Mailing Address Minnesota Rule , Subpart 3(B) requires an applicant for a Certificate of Need under Chapter 7853 to provide direct mail notice (see Attachment 2) to all mailing addresses likely to be affected by the Project. Enbridge will rely on its immediate contacts with abutting property owners, county tax records or mailing lists available from the United States Post Office to create a list of mailing addresses for the defined Notice Area at the applicable station sites. The letter has also been revised to include a statement clarifying that registering to receive documents or notifications does not equate to being a full party in the certificate of need proceeding. C. Direct Mail to Local Governments. Minnesota Rule , Subpart 3(C) requires an applicant for a Certificate of Need under Chapter 7853 to provide direct mail notice to tribal governments and to the governments of towns, statutory cities, home rule charter cities, and counties whose jurisdictions are reasonably likely to be affected by the Project. The Project will not impact any tribal properties or areas of interest, thus no direct mail notice will be required for tribal governments. Direct mail notice (see Attachment 3) will be provided to the mayor, city council or town board chair, the clerks of Viking, Clearbrook, and Deer River, Minnesota, and Viking Township, Leon Township and Wildwood Township, Minnesota, county commissioners and auditors of Marshall, Clearwater, and Itasca Counties, state Senators and state Representatives and U.S. Senators and U.S. Representatives representing constituents in the public notice area as summarized in Attachment 3a. The letter has been revised to include the same clarifying statement as the direct mail letters to be sent to landowners. The DER requested that Enbridge clarify the state legislators that represent the area where the Deer River station is located. The notice plan included the correct recipients since the station is on the border between two legislative districts. The station, located just east of the City of Deer River, is within Minnesota Senate District 3 and Minnesota House District 3B. The City of Deer River, however, is located in Minnesota Senate District 4 and Minnesota House District 4A. Enbridge believes this is a source of confusion, and has added elected officials from Districts 4 and 4a to the list of recipients included with Attachment 3. The DER also recommended that Enbridge include the governmental entities listed in Minn. R , subp. 6, which governs distribution of pipeline routing permit applications. While that rule does not apply to the Project because a pipeline routing permit is not required, Enbridge does not object to providing additional notice to development 3
4 agencies or watershed districts applicable to the three pump station locations. These entities have been added to the list of recipients. D. Published Notice Minnesota Rule , Subpart 3(D) requires an applicant for a Certificate of Need under Chapter 7853 to provide a published newspaper notice to members of the public in areas reasonably likely to be affected by the Project. The notice provided in Attachment 4, along with a black-and-white version of the Project map, will be published in the newspapers identified in Attachment 4a. The revised notice includes a statement clarifying that registering to receive documents or notifications does not equate to being a full party in the certificate of need proceeding. Enbridge will also publish the notice in the Duluth News Tribune, the Cass Lake Times (Cass Lake, MN), and the Pilot Independent (Walker, MN), as recommended by the DER. E. Content of Notice Enbridge does not propose any revisions to the content of the notice beyond those noted above. F. Notice Timing Minnesota Rule , Subpart 6, requires an applicant for a Certificate of Need to implement the Notice Plan within 30 days of its approval by the Commission. Enbridge still intends to implement the Notice Plan according to the timing contemplated by the rule. III. CONCLUSION Enbridge respectfully requests that the Commission approve its Notice Plan with the revisions discussed above. Dated July 20, 2012 Respectfully Submitted: Fryberger, Buchanan, Smith & Frederick, P.A. By: /s/ John R. Gasele Kevin T. Walli, # John R. Gasele, # Minnesota Street, Suite W1260 St. Paul, MN (651) Attorneys for Enbridge Energy, Limited Partnership, a Delaware limited liability company 4
5 Project Maps enclosed with Notice Letters to Abutting Residents & Government and Local Officials Attachment 1a Attachment 1b Attachment 1c Attachment 1d Revised Project Overview Map Aerial Map of Viking Pump Station Aerial Map of Clearbrook Pump Station and Terminal Facility Aerial Map of Deer River Pump Station
6 Attachment 1a Line 67 Station Upgrade Project - Overview Map
7 Attachment 1b: Viking Pump Station in Section 28, T-155-N, R-45-W, Marshall County
8 Attachment 1c: Clearbrook Station in Section 28, 29 and 33, T-149-N, R-37-W, Clearwater County
9 Attachment 1d: Deer River Station in Section 22, T-58N, R-27-W, Itasca County
10 Attachment 2: Notice Letter to Abutting Residents Enbridge Energy, Limited Partnership Douglas B. Aller 1409 Hammond Avenue Manager, U.S. Lands & Right- of- Way Superior, WI Major Projects Month xx, 2012 RE: Notice of Certificate of Need Application for Line 67 Station Upgrade Project No New Right-of-Way or Pipeline Construction Required MN-PUC Docket No. PL9/CN Dear Resident: Enbridge Energy, Limited Partnership ( Enbridge ) is proposing to expand the capacity of its Line 67 Pipeline as part of its ongoing efforts to meet North America s needs for reliable and secure transportation of petroleum energy supplies. The project, known as the Line 67 Station Upgrade Project ( Project ), will increase the annual average capacity of Line 67 from 450,000 barrels per day ( bpd ) to 570,000 bpd, providing Enbridge with the ability to deliver an incremental 120,000 barrels per day of secure and reliable crude oil supplies to refineries and numerous marketing hubs throughout the Midwest and beyond. Those refineries, in turn, supply the transportation fuels, heating oil, asphalt, jet fuel, petrochemicals and petrochemical feed stocks needed for our homes, industry, and transportation. The Project involves the installation of new pumping units, including all valves and appurtenances, and other minor station modification work at Enbridge s Viking, Clearbrook and Deer River Pump Station sites, which are located in Marshall, Clearwater and Itasca Counties, Minnesota. The Project will not require the acquisition of new land or require pipeline construction outside the pump stations. All work will be performed within the footprint of Enbridge s pump stations. A Project Overview Map is provided as Attachment 1a. Pending regulatory approval by the Minnesota Public Utilities Commission ( MPUC ), the Project would be in service by July 1, The additional capacity will help relieve capacity constraints on Enbridge s Mainline System and provide refineries access to secure and reliable crude oil supplies from western Canada, Montana and North Dakota, as supplies from these prolific production areas are continuing to rise.
11 Line 67 Station Upgrade Project Page 2 You are receiving this letter because you own property located immediately adjacent to one of the pump stations where the Project work will be performed and are therefore in the notice area. The following attached aerial maps show your property in relation to the pump stations involved in this Project. Name of Station Location County Map No. Viking Pump Station Section 28, T-155-N, Marshall Attachment 1b R-45-W Clearbrook Pump Station Sections 28, 29 & 33, Clearwater Attachment 1c and Terminal Facility T-149-N, R-37-W Deer River Pump Station Section 22, T-58N, R- 27-W Itasca Attachment 1d The purpose of this letter is to notify you of Enbridge s project plans and provide details on how you can participate in the MPUC s regulatory review process. A similar notice is being mailed to elected officials and community leaders within the project area. Enbridge has filed a certificate of need application with the MPUC for review and approval. To view a copy of the application, visit the MPUC s website at choose the Search E-Dockets link, select 12 from the first Docket Number dropdown box and enter 590 in the second box. The MPUC must certify that the Project is needed before Enbridge can construct the Line 67 Station Upgrade Project. The application process is governed by Minnesota Law, including Chapter 7853 of the Minnesota Rules and Chapter 216 of the Minnesota Statutes. To receive information from the MPUC regarding the Certificate of Need proceedings for the proposed Line 67 Station Upgrade Project, you may: Request to have your name added to the Line 67 Station Upgrade Project Certificate of Need mailing list to receive official mailings related to this Certificate of Need filing. Please send your request by mail, fax or to the attention of [insert Staff name] at the Minnesota Public Utilities Commission, th Place E., Suite 350, St. Paul, MN 55101, Fax: or [insert Staff ]. Register to receive notifications each time new information is filed within a corresponding docket by subscribing via the Commission s edocketing system. To subscribe, visit the MPUC s website at and click on the Subscribe to a Docket button, enter your address and select Docket Number from the Type of Subscription: drop-down box. Then select 12 from the first Docket Number dropdown box and enter 590 in the second box before clicking on the Add to List button. You must then click the Save button at the bottom of the page to confirm your subscription to the Line 67 Station Upgrade Project Docket.
12 Line 67 Station Upgrade Project Page 3 Requesting to have your name added to the Line 67 Station Upgrade Project Certificate of Need mailing list or registering to receive notifications will not make you a party to the certificate of need proceeding. For more information, you may also:contact MPUC staff directly using the information below. Minnesota Public Utilities Commission th Place E., Suite 350 St. Paul, Minnesota Contact Enbridge for more information about our proposed Line 67 Station Upgrade Project, please visit our project website at or call us toll free at , or us at Line67UpgradeProject@enbridge.com We value our relationship with you, and we look forward to addressing any questions you may have about our Project plans. Sincerely, Douglas B. Aller Manager, U.S. Lands & Right-of-Way Major Projects
13 Attachment 3: Notice Letter to Local & State Government Officials Enbridge Energy, Limited Partnership Lorraine Little 1409 Hammond Avenue Sr. Manager, U.S. Public Affairs Superior, WI Liquid Operations & Projects Month xx, 2012 RE: Notice of Certificate of Need Application for Line 67 Station Upgrade Project No New Right-of-Way or Pipeline Construction Required MN-PUC Docket No. PL9/CN Dear Elected Official/Community Leader: Enbridge Energy, Limited Partnership ( Enbridge ) is proposing to expand the capacity of its Line 67 Pipeline as part of its ongoing efforts to meet North America s needs for reliable and secure transportation of petroleum energy supplies. The project, known as the Line 67 Station Upgrade Project ( Project ), would increase the annual average capacity of Line 67 from 450,000 barrels per day ( bpd ) to 570,000 bpd, providing Enbridge with the ability to deliver an incremental 120,000 barrels per day of secure and reliable crude oil supplies to refineries and numerous marketing hubs throughout the Midwest and beyond. Those refineries, in turn, supply transportation fuels, heating oil, asphalt, jet fuel, petrochemicals and petrochemical feed stocks needed in our homes, industry, and transportation. The Project involves the installation of new pumping units, including all valves and appurtenances, and other minor station modification work at Enbridge s Viking, Clearbrook and Deer River Pump Station sites, which are located in Marshall, Clearwater and Itasca Counties, Minnesota. The Project will not require the acquisition of new land or require pipeline construction outside the pump stations. All work will be performed within the footprint of Enbridge s pump stations. A Project Overview Map is provided as Attachment 1a. Pending regulatory approval by the Minnesota Public Utilities Commission ( MPUC ), the Project would be in-service by the July 1, The additional capacity will help relieve capacity constraints on Enbridge s Mainline System and provide refineries access to crude oil supplies from western Canada, Montana and North Dakota, as supplies from these prolific production areas are continuing to rise.
14 Line 67 Station Upgrade Project Page 2 You are receiving this letter because you are an elected official, government agency representative, or community leader who has jurisdiction within the notice area. The notice area is defined as abutting property which is located immediately adjacent to Enbridge s pumping station sites where Project work will be performed. Please see the following attached aerial map which depicts abutting properties in your local area. Name of Station Location County Map No. Viking Pump Station Section 28, T-155-N, Marshall Attachment 1b R-45-W Clearbrook Pump Station Sections 28, 29 & 33, Clearwater Attachment 1c and Terminal Facility T-149-N, R-37-W Deer River Pump Station Section 22, T-58N, R- 27-W Itasca Attachment 1d The purpose of this letter is to notify you of Enbridge s Project plans and provide details on how you can participate in the MPUC s regulatory review process. A similar notice is being mailed to residents and abutting property owners who own land located immediately adjacent to Enbridge s pumping stations area where Project work will be performed. Enbridge has filed a certificate of need application with the MPUC for review and approval. To view a copy of the application, visit the MPUC s website at choose the Search E-Dockets link, select 12 from the first Docket Number dropdown box and enter 590 in the second box. The MPUC must certify that the Project is needed before Enbridge can construct the Project. The application process is governed by Minnesota Law, including Chapter 7853 of the Minnesota Rules and Chapter 216B of the Minnesota Statutes. To receive information from the MPUC regarding the Certificate of Need proceedings for the proposed Line 67 Station Upgrade Project, you may: Request to have your name added to the Line 67 Station Upgrade Project Certificate of Need mailing list to receive official mailings related to this Certificate of Need filing. Please send your request by mail, fax or to the attention of [insert name] at the Minnesota Public Utilities Commission, th Place E., Suite 350, St. Paul, MN 55101, Fax: or [insert mail]. Register to receive notifications each time new information is filed within a corresponding docket by subscribing via the Commission s edocketing system. To subscribe, visit the MPUC s website at and click on Subscribe to a Docket button, enter your address and select Docket Number from the Type of Subscription drop-down box. Then select 12 from the first Docket Number dropdown box and enter 590 in the second box before clicking on the Add to List button. You must then click the Save button at the bottom of the page to confirm your subscription to the Line 67 Station Upgrade Project Docket.
15 Line 67 Station Upgrade Project Page 3 Requesting to have your name added to the Line 67 Station Upgrade Project Certificate of Need mailing list or registering to receive notifications will not make you a party to the certificate of need proceeding. For more information, you may also: Contact MPUC staff directly using the information below. Minnesota Public Utilities Commission th Place E., Suite 350 St. Paul, Minnesota Contact Enbridge for more information about our proposed Line 67 Station Upgrade Project, please visit our project website at or call us toll free at or us at Line67UpgradeProject@enbridge.com. We value our relationship with you, and we look forward to addressing any questions you may have about our Project plans. Sincerely, Lorraine Little Senior Manager, U.S. Public Affairs, Liquids Operations & Projects
16 Attachment 3a: List of local government officials Cities City Clerk Mayor and City Council Chair Viking Laurie Ranum Michael Hestkeind Clearbrook Pamela Bodensteiner Mike Gibeau Deer River Victor R. William John O Brien Townships Township Clerk Township Board Chair Viking Township Suzan Larson Ken Krohn (Marshall) Leon Township (Clearwater) Lori Larson James Aakre Wildwood Township Darlene Vobejda Linda Winkler (Itasca) Counties County Commissioners County Auditor Marshall LeRoy Vonasek (Chair) Curtis Carlson Kenneth Borowicz Sharon Bring Gary Kiesow Scott Peters Clearwater Itasca John Nelson (Chair) Duane Hayes John Chevalier Dean Newland Daniel Stenseng Catherine McLynn (Chair) Davin Tinquist Leo Trunt Rusty Eichorn Mark Mandich Allen Paulson Jeff Walker State State Senators State Representatives Minnesota LeRoy Stumpf (Marshall) Rod Skoe (Clearwater) Tom Saxhaug (Itasca, 3) John Carlson (Itasca, 4) Debra Kiel (Marshall) David Hancock (Clearwater) Carolyn McElfatrick (Itasca, 3B) John Persell (Itasca, 4A) Federal U.S. Senators U.S.Representatives United States Sen. Amy Klobuchar Rep. Collin Peterson Sen. Al Franken Rep. Chip Cravaack
17 Notification to Agencies Name of Agency Address Contact Name Federal U.S. Army Corps of Engineers US Fish and Wildlife Service Twin Cities Field Office East Gull Lake Drive NW Brainerd, MN American Boulevard East Bloomington, MN Craig Jarnot Nick Rowse, Biologist State State Historic Preservation Office Minnesota Historical Society Minnesota Pollution Control Agency Endangered Species Review Coordinator Division of Ecological and Water Resources, Minnesota DNR Northwest Regional Development Commission Headwaters Regional Development Commission Arrowhead Regional Development Commission Middle-Snake-Tamarac Rivers Watershed District Red Lake Watershed District Marshall County Soil and Water Conservation District Clearwater County Soil and Water Conservation District Itasca County Soil and Water Conservation District 345 Kellogg Blvd. W. St. Paul, MN Lafayette Road St. Paul, MN Lafayette Road, Box 25 St Paul, MN South Main Avenue Warren, MN th St NW # 310 Bemidji, MN West First Street Duluth, MN N McKinley St PO Box 154 Warren, MN Pennington Avenue South in Thief River Falls, Minnesota, PO Box 74, Warren, MN Main Ave N Ste 3, Bagley, MN E Hwy 2, Grand Rapids, MN Barbara Mitchell Howard, Deputy State Historic Preservation Officer Lawrence Zdon; Kevin Molloy; & Deborah Idzorek Lisa Joyal Leon Heath Cliff Tweedale Pat Henderson Nick Drees Myron Jesme Danny Thorstad Kathy Rasch Jim Gustafson
18 Attachment 4 NOTICE Certificate of Need Application for the Line 67 Station Upgrade Project in Marshall, Clearwater and Itasca Counties, Minnesota NO NEW LAND ACQUISITION OR PIPELINE CONSTRUCTION REQUIRED Enbridge Energy, Limited Partnership ( Enbridge ), a Delaware limited liability partnership and wholly owned subsidiary of Enbridge Energy Partners, L.P., is proposing to make certain upgrades and station modifications at existing pumping station sites, in order to expand the capacity of its Line 67 Pipeline by the anticipated in-service date of July 1, Under the scope of the project, known as the Line 67 Station Upgrade Project ( Project ), Enbridge plans to install new pumping units, including all valves and appurtenances, and make certain station modifications at its Viking, Clearbrook and Deer River Station sites, which are located in Marshall, Clearwater and Itasca Counties, Minnesota. Those upgrades allow Enbridge to increase Line 67 s annual average capacity from 450,000 barrels per day ( bpd ) to 570,000 bpd. This notice is intended to provide notice of the Line 67 Station Upgrade Project details and information on how you can participate in the Minnesota regulatory process. All of the station facilities associated with this Project will be installed within the existing station sites on land for which Enbridge owns in fee. No new land acquisition or pipeline construction will be required for the planned Project. The Line 67 Station Upgrade Project will provide the additional pipeline transportation capacity needed by shippers to deliver secure and reliable crude oil supplies to refineries and numerous marketing hubs throughout the Midwest and beyond. Those refineries, in turn, supply the transportation fuels, heating oil, asphalt, jet fuel, petrochemicals and petrochemical feed stocks needed for our homes, industry, and transportation. The Project is part of Enbridge s ongoing efforts to meet North America s needs for reliable and secure transportation of petroleum energy supplies, and is in the public interest. The Project will require a Certificate of Need from the Minnesota Public Utilities Commission ( Commission ). The certification process is governed by Minnesota Law, including Section 216B.243 of Minnesota Statutes and Chapter 7853 of Minnesota Rules. In the Certificate of Need proceeding, the Commission will analyze whether Enbridge has proposed the most appropriate size, type, and timing for the Line 67 Station Upgrade Project. A copy of the Certificate of Need application can be obtained by visiting the Commission s website at choosing the Search E-Dockets link, selecting 12 from the first Docket Number dropdown box and entering 590 in the second box. To subscribe to the Line 67 Station Upgrade Project Docket and receive notifications when information is filed that is related to the Certificate of Need for the Line 67 Station Upgrade Project, please visit and click on the Subscribe to a Docket button. Next, enter your address and select Docket Number from the Type of Subscription dropdown box, then select 12 from the first Docket Number dropdown box and enter 590 in the second box before clicking on the Add to List button. You must then click the Save button at the bottom of the page to confirm your subscription to the Line 67 Station Upgrade Project Docket.
19 Please visit for more information on the Line 67 Station Upgrade Project. If you have any questions about the process, you may contact the Minnesota regulatory staff listed below: Minnesota Public Utilities Commission th Place East, Suite 350 St. Paul, Minnesota If you would like to have your name added to the Line 67 Station Upgrade Project Certificate of Need mailing list (MPUC Docket PL9/CN ), mail, fax, or [insert Staff name] at Minnesota Public Utilities Commission, th Place East, suite 350, St. Paul MN , Fax: or [insert Staff address]. Requesting to have your name added to the Line 67 Station Upgrade Project Certificate of Need mailing list or registering to receive notifications will not make you a party to the certificate of need proceeding. Questions you may have for Enbridge may also be directed to: Lorraine Little Sr. Manager, U.S. Public Affairs, Liquids Operations & Projects 1409 Hammond Avenue Superior, WI
20 Attachment 4a: List of local and state-wide newspapers Local Newspapers Marshall County Itasca County Clearwater County Stephen Messenger* Warren Sheaf Western Itasca-Review Grand Rapids Herald Review* Farmer s Independent* Leader-Record Cass County Regional Newspapers Minnesota Cass Lake Times (Cass Lake, MN) Pilot Independent (Walker, MN)* Grand Forks Herald Bemidji Pioneer Duluth News Tribune State-Wide Newspapers Minnesota Star Tribune Pioneer Press *Denotes county newspaper of record M:\DOCS\12554\000374\PLD\SH7069.DOCX
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