# 2007 Consent Order *Minnesota consent order (2007) making 3M responsible for safe drinking water and cleanup at its PFAS-contaminated sites.* The **2007 Consent Order** is the [[Minnesota]] order under which 3M was made responsible for safe drinking water and for cleanup of its sites. This is how a Minnesota Pollution Control Agency (MPCA) presentation describes it.[^1] The order included an $8 million grant for remediation of the [[Washington County Landfill]] and a $5 million grant for statewide PFAS environmental studies.[^2] Under it, 3M excavated soil and sediment at all three of its sites from 2008 to 2012.[^3] The MPCA's frequently asked questions for the later 3M settlement describe what happens if settlement money is exhausted. In that case "the 2007 Consent Order will remain in place." The same answer says the order "only covers costs for wells that meet or exceed MDH's established health index."[^4] That threshold is a health index of 1 or more. Settlement funds treat wells at 0.5 of the index.[^5] The settlement's Fall 2025 meeting notes record cumulative capital commitments of $515 million. The same notes put estimated need at $575 million by the end of fiscal year 2026, with a capital shortfall of about $26 million.[^6] The notes place the transition back to the 2007 Consent Order as "estimated to be in the second half of calendar year 2027."[^7] ## Who The parties named in the record are 3M, which the order made responsible for drinking water and site cleanup, and the MPCA.[^1] The MPCA describes the order's coverage in its own settlement FAQ.[^4] The MPCA / 3M Settlement [[Working Group]] recorded the settlement's finances and the timing of the handoff to the order in its Fall 2025 notes.[^6] The cities named in the record are [[Cottage Grove]], [[Oakdale]], [[Woodbury]] and [[Hastings]]. Their drinking-water projects are funded by the settlement until that handoff.[^8] The *[[Star Tribune]]* reports that 3M is contesting whether some projects meet the "reasonable and necessary" standard under the 2007 Consent Order.[^9] ## What The order made 3M responsible for safe drinking water and site cleanup.[^1] It also carried two grants: - $8 million for remediation of the Washington County Landfill. - $5 million for statewide PFAS environmental studies.[^2] Under the order, 3M performed soil and sediment excavations at all three of its sites. It disposed of over 100,000 cubic yards of material in a dedicated 3M cell at the SKB Industrial Landfill.[^3] The MPCA states that the order remains in place if settlement money is exhausted. It also states that the order pays only for wells at or above the health index, not for wells at the 0.5 level the settlement treats.[^4][^5] The MPCA also states that 3M remains obligated to continue investigating groundwater contamination at the Oakdale site.[^10] ## When The order dates from 2007. MPR News covered it at the time.[^11] The excavations carried out under it ran from 2008 to 2012.[^3] As of the Fall 2025 Working Group notes, the transition back to the order was estimated for the second half of calendar year 2027.[^7] The *Star Tribune* reported that the settlement fund "could run out by 2027."[^12] ## Where The record places the order's cleanup work at 3M's three sites, at the Washington County Landfill, and at the SKB Industrial Landfill, where excavated material was disposed of.[^2][^3] The Fall 2025 notes record two groups of city systems:[^8] - Cottage Grove and Oakdale on temporary systems. - Woodbury and Hastings under construction and over budget. ## How much The order's grants were $8 million for the Washington County Landfill and $5 million for statewide PFAS studies.[^2] The Fall 2025 Working Group notes record the following figures: - Cumulative settlement capital commitments of $515 million. - Estimated need of $575 million by the end of FY2026. - A capital shortfall of about $26 million.[^6] - About $137 million projected to remain unobligated at the end of FY2026.[^13] The *Star Tribune* reported that Hastings needs $68.9 million and has received $14 million. It also reported that the city is raising rates to cover roughly $54.9 million.[^14] ## How many Under the order, 3M disposed of over 100,000 cubic yards of soil and sediment.[^3] The *Star Tribune* reported two well counts:[^15] - All 12 Cottage Grove wells exceed PFAS limits. - All six Hastings wells exceed EPA limits. ## In the at-issue record Two at-issue entries in the project's Washington County package concern the order. The first (AI-Washington-020) sets the settlement's commitments beside its needs. It records $515 million committed against an estimated $575 million needed by the end of FY2026, with the handoff to the order estimated for the second half of 2027. Its anchor is the Working Group's Fall 2025 notes.[^6][^7] The second (AI-Washington-021) sets the order's coverage beside the settlement's. The order covers wells at or above the health index, while settlement funds treat wells at half that index. Its anchor is the MPCA's own FAQ.[^4][^5] ## In the Minnesota record ### What - The order made 3M responsible for safe drinking water and site cleanup.[^1] - Under the order, 3M disposed of over 100,000 cubic yards of soil and sediment at the SKB Industrial Landfill.[^3] - The order covers costs only for wells at or above MDH's health index of 1. Settlement funds treat wells at 0.5.[^4][^5] ### When - The order dates from 2007. Excavations under it ran from 2008 to 2012.[^3][^11] - The handoff back to the order is estimated for the second half of calendar year 2027.[^7] ## Notes [^1]: Minnesota Pollution Control Agency, *Presentation to ASDWA* (2019) — the 2007 Consent Order made 3M responsible for safe drinking water and site cleanup. https://www.asdwa.org/wp-content/uploads/2019/06/Krueger-MN-3M-PFAS-Actions.pdf [^2]: Minnesota Pollution Control Agency, *Presentation to ASDWA* (2019) — the order included an $8 million grant for Washington County Landfill remediation and a $5 million grant for statewide PFAS environmental studies. https://www.asdwa.org/wp-content/uploads/2019/06/Krueger-MN-3M-PFAS-Actions.pdf [^3]: Minnesota Pollution Control Agency, *Presentation to ASDWA* (2019) — 3M's soil and sediment excavations at all three sites (2008–2012) and disposal of over 100,000 cubic yards in a dedicated 3M cell at the SKB Industrial Landfill. https://www.asdwa.org/wp-content/uploads/2019/06/Krueger-MN-3M-PFAS-Actions.pdf [^4]: Minnesota Pollution Control Agency, *Priority 1 Frequently Asked Questions* (undated) — if settlement money is exhausted, the 2007 Consent Order remains in place but covers only wells that meet or exceed MDH's established health index. https://3msettlement.state.mn.us/about/priority-1-frequently-asked-questions [^5]: Minnesota Pollution Control Agency, *Priority 1 Frequently Asked Questions* (undated) — the order's threshold is a health index of 1 or more, while settlement funds treat wells at 0.5 of the index. https://3msettlement.state.mn.us/about/priority-1-frequently-asked-questions [^6]: MPCA / 3M Settlement Working Group, *Fall 2025 meeting notes* (Fall 2025) — cumulative capital commitments of $515 million, estimated need of $575 million by the end of FY2026, and a capital shortfall of about $26 million. https://3msettlement.state.mn.us/sites/3msettlement/files/2025-12/Fall%202025%20-%20Notes.pdf [^7]: MPCA / 3M Settlement Working Group, *Fall 2025 meeting notes* (Fall 2025) — transition back to the 2007 Consent Order "estimated to be in the second half of calendar year 2027." https://3msettlement.state.mn.us/sites/3msettlement/files/2025-12/Fall%202025%20-%20Notes.pdf [^8]: MPCA / 3M Settlement Working Group, *Fall 2025 meeting notes* (Fall 2025) — Cottage Grove and Oakdale on temporary systems; Woodbury and Hastings under construction and over budget. https://3msettlement.state.mn.us/sites/3msettlement/files/2025-12/Fall%202025%20-%20Notes.pdf [^9]: *Star Tribune*, article on the 3M settlement and PFAS in Minnesota water (date not given in the pack) — 3M contesting whether projects meet the "reasonable and necessary" standard under the 2007 Consent Order. https://www.startribune.com/3m-settlement-minnesota-pfas-water/601287204 [^10]: Minnesota Pollution Control Agency, *Priority 1 Frequently Asked Questions* (undated) — 3M remains obligated to continue investigating groundwater contamination at the Oakdale site. https://3msettlement.state.mn.us/about/priority-1-frequently-asked-questions [^11]: MPR News, *contemporaneous coverage of the 2007 Consent Order* (2007) — the order's 2007 date. https://www.mprnews.org/story/2007/05/11/contamdeal [^12]: *Star Tribune*, article on the 3M settlement and PFAS in Minnesota water (date not given in the pack) — the fund "could run out by 2027." https://www.startribune.com/3m-settlement-minnesota-pfas-water/601287204 [^13]: MPCA / 3M Settlement Working Group, *Fall 2025 meeting notes* (Fall 2025) — about $137 million projected unobligated at the end of FY2026. https://3msettlement.state.mn.us/sites/3msettlement/files/2025-12/Fall%202025%20-%20Notes.pdf [^14]: *Star Tribune*, article on the 3M settlement and PFAS in Minnesota water (date not given in the pack) — Hastings needs $68.9 million against $14 million received and is raising rates to cover roughly $54.9 million. https://www.startribune.com/3m-settlement-minnesota-pfas-water/601287204 [^15]: *Star Tribune*, article on the 3M settlement and PFAS in Minnesota water (date not given in the pack) — all 12 Cottage Grove wells exceed PFAS limits; all six Hastings wells exceed EPA limits. https://www.startribune.com/3m-settlement-minnesota-pfas-water/601287204