# Letter to Administrator Lee Zeldin, Environmental Protection Agency --- MTN Minneapolis, Minnesota [email protected] May 13, 2026 The Honorable Lee Zeldin Administrator, U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460 **Re: 3M PFAS / PFOS Settlement, MPCA Delegated Authority, Iron Range Air-Quality Orders, and the Swanson/Hatch University of Minnesota Law School AG Pipeline — Coordination Request Under the Task Force to Eliminate Fraud (E.O. of March 16, 2026)** Dear Administrator Zeldin: I write to identify the Environmental Protection Agency's Minnesota portfolio — 25 NPL Superfund sites, the 3M PFAS / PFOS settlement, SE Minnesota nitrate contamination, MPCA delegated-authority review, and the Iron Range taconite air-quality orders — as one operational context in which the University of Minnesota Law School pipeline has structured both the regulatory enforcement architecture and the institutional defense posture. **The Portfolio Issue.** The EPA holds active or pending: 25 Minnesota Superfund sites on the National Priorities List; 3M PFAS / PFOS settlement oversight (East Metro); nitrate contamination in the SE Minnesota karst region (Winona, Fillmore, and Olmsted counties); review of MPCA's delegated authority; and Iron Range taconite air-quality orders affecting the Mesabi Range mining operations. The 3M settlement, finalized under former Minnesota Attorneys General Lori Swanson and Mike Hatch, is among the largest state-AG environmental settlements in U.S. history. **The University of Minnesota Origin — AG Pipeline.** Lori Swanson (UMN Law 1990) served as Minnesota Attorney General from 2007 to 2019; her predecessor Mike Hatch (UMN Law 1973) served from 1999 to 2007. Together their tenures span 20 years of the Minnesota AG office. Both prosecuted under the Rajender-era compliance infrastructure that the §43A.191 statute codifies. The University of Minnesota Law School has produced 78 years of consecutive Minnesota Attorney General succession, with a Herfindahl-Hirschman Index of 7,549 for the pipeline by years of service — three times the Department of Justice's threshold for "highly concentrated" markets. The State of Minnesota's environmental regulatory architecture, MPCA's delegated authority operation, and the negotiated settlements that the EPA accepts as state-action equivalents all sit downstream of this credentialing concentration. https://www.lrl.mn.gov/mngov/attygen | https://www.justice.gov/atr/horizontal-merger-guidelines-08192010 **The University of Minnesota Origin — Scientific Credentialing.** The MPCA scientific staff is credentialed substantially by the University of Minnesota School of Public Health (environmental health division) and the University of Minnesota College of Science and Engineering. The Iron Range taconite-industry scientific class — including the engineering and metallurgical staff at industry operators and consulting firms — is credentialed predominantly by the same UMN-CSE pipeline. The 3M PFAS scientific record was developed in significant part at UMN. The institutional incentives that shape both the regulatory science and the regulated-entity science are anchored at the same University. https://www.sph.umn.edu/ | https://cse.umn.edu/ **The Institutional Admissions.** The University of Minnesota's own commissioned Truth Report (April 11, 2023) states that the founding board "committed genocide and ethnic cleansing of Indigenous peoples for financial gain." In October 2025, the University signed an Office for Civil Rights Resolution Agreement acknowledging that its PhD Project partnership violated Title VI by discriminating against white and Asian students. https://mn.gov/indian-affairs/assets/full-report_tcm1193-572488.pdf | https://www.startribune.com/the-u-signs-agreement-acknowledging-discrimination-against-white-and-asian-students-cuts-ties-with-recruiting-nonprofit/601564669 **The Consolidated Federal Posture.** The Task Force to Eliminate Fraud, established by the March 16, 2026 Executive Order, coordinates the cross-agency response. The DOJ has filed United States v. State of Minnesota (0:25-cv-03798) against §43A.191. The Title IX referral to DOJ is active. The House Oversight investigation has documented the broader $9 billion Medicaid fraud architecture operating downstream of the same UMN Law-credentialed AG office that has overseen Minnesota environmental enforcement. https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud/ **The Ask.** I respectfully request that the Environmental Protection Agency: 1. **Review MPCA's delegated authority** in light of the documented institutional pattern in Minnesota state-government operations, with particular attention to the concentration of UMN Law credentialing in the AG and senior regulatory leadership; 2. **Audit the 3M PFAS / PFOS settlement administration** for consistency with EPA's national PFAS posture, treating the settlement-architect AGs' UMN Law credentialing as a relevant institutional context; 3. **Coordinate Iron Range taconite air-quality enforcement** with the federal posture under the Task Force framework, in coordination with the Department of the Interior's mining-related review and the Department of Justice's environmental enforcement docket; and 4. **Report findings to the Task Force to Eliminate Fraud** under the March 16, 2026 Executive Order coordination framework. This letter is one of approximately twenty Cabinet-level briefings I am submitting under the Task Force framework. Respectfully submitted, MTN [email protected] --- **Primary Sources Cited:** - E.O. Task Force to Eliminate Fraud: https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud/ - Minnesota AG succession: https://www.lrl.mn.gov/mngov/attygen - DOJ Horizontal Merger Guidelines (HHI): https://www.justice.gov/atr/horizontal-merger-guidelines-08192010 - US v. State of Minnesota: https://www.justice.gov/opa/media/1415681/dl - UMN School of Public Health: https://www.sph.umn.edu/ - UMN College of Science and Engineering: https://cse.umn.edu/ - UMN TRUTH Report: https://mn.gov/indian-affairs/assets/full-report_tcm1193-572488.pdf - UMN OCR Resolution Agreement: https://www.startribune.com/the-u-signs-agreement-acknowledging-discrimination-against-white-and-asian-students-cuts-ties-with-recruiting-nonprofit/601564669 #Addresses_Advisories_and_Archives