On Monday, June 24, the Minnesota Pollution Control Agency (MPCA) opened a public comment period for Minnesotans to respond to proposed changes to two permits that regulate the state’s largest animal feedlots. The aim of these changes is to protect Minnesota water by reducing nitrate contamination from manure produced by feedlots that are 1,000 animal units or more, especially in parts of the state with vulnerable groundwater such as southeastern Minnesota.

Some of the major changes in these permits include:

1. Required visual inspections of fields for signs of manure discharge both during and after manure application. The inspections must happen at:
   • Down gradient field edges.
   • Tile intakes.
   • Water features.
   • Any other potential point of discharge from the fields.
2. Required best management practices (BMPs) focused on reducing runoff and nitrate impacts. Some required BMPs include:
   • During the summer months, manure must be applied to a growing perennial or row crop.
   • Starting in 2028, from October to November a cover crop must be planted prior to or within 14 days of application.
   • From December to February, manure cannot be applied to vulnerable groundwater areas.

You can read more about the changes here.

The Land Stewardship Project supports these changes to the permits, but there is still more work to be done in order to clean up our water and protect local communities. Show your support for these changes and push the MPCA to do more by leaving a public comment today.

Click HERE to Leave a Public Comment

It is crucial that the MPCA hears from residents around the state about this issue. Public comments are a part of the official record and demonstrate to lawmakers the level of public concern on this issue. The public comment period is open until Tuesday, Sept. 3. Leave your comment to the MPCA today by clicking here.

Don’t know where to start? Use LSP’s sample comment.

We have written a comment for you to copy/paste into MPCA’s comment portal. Feel free to change and edit our comment with your own personal stories, scientific data, or any other way you see fit. Check out MPCA’s infographic on how to write an effective public comment here. 

Sample Comment:

Minnesota Pollution Control Agency Representative,

Thank you for the chance to comment on this important issue. My name is ____. I live in _____. I care about this issue because ______. [Share a little bit about yourself and your experiences.]

I am glad to see some of the changes and updates that the agency has proposed for the new NPDES and SDS permits. Many of them are commonsense ways to protect our shared land, water, and communities from the harmful effects of CAFOs, and I want to share my support for these changes including:

  – Protecting our shared groundwater by requiring that by 2028, all lands that have manure applied to them in vulnerable groundwater areas must have either a growing crop, a perennial crop planted, or have a cover crop planted with 14 days of manure application if spreading in October and November. I also support phasing out winter application entirely in these areas.

  – Protecting surface waters by limiting manure application within a 100-year floodplain to only application that incorporates the manure into the soil.

  – Monitoring spreading by requiring the permit holder do visual inspections of all land application areas.

  – Helping with cleanup and accountability by requiring the permit holder do water sampling after a manure discharge event.

  – And making our rules consistent by requiring people who buy manure from a permit holding operation or spread manure for one follow the permit requirements.

These new changes are a good start to what must be done to keep people and our shared water and land safe, but they also leave quite a bit of room for improvement. Here are some changes to your proposed permit that I think would make it stronger and would bring it closer to what people like me and my neighbors need:

  – While protecting water sources in Minnesota’s vulnerable groundwater areas is particularly important, all Minnesotans, regardless of where they live, deserve to have access to clean water. The additional requirements to the October, November, and winter applications of manure in vulnerable groundwater areas are good, commonsense management practices, and the requirement that those practices be followed should be extended to all lands where manure is applied.

  – While it is good that record-keeping of applications, including water sampling and ensuring that manure buyers are following permit rules, will be required to help make sure that permits are being followed, there needs to be a more robust requirement for permit holders to share this information with the agency so they can ensure permits are being followed. In addition, this information should be made available to the public. Communities that are at risk of CAFO pollution and its effects deserve to know that permits are being followed. Making this information publicly available will also allow community members to help the agency ensure that permit requirements are being met.

  – In addition to water sampling and testing being done after a discharge event, this permit should require more proactive water samplings to ensure long-term compliance with the permit and to help ensure accountability. These permits should require water sampling and testing be done regularly around the permit holding site and where liquid manure from the site is being spread so that the agency and the public can know that long-term damage and contamination is not occurring. These permits should also require that new constructions of manure basins and new lands used for spreading must undergo water sampling and testing before construction begins or manure is spread to establish a baseline nutrient load for future testing to be measured against.

I am encouraged by the steps the agency has taken to strengthen Minnesota’s NPDES and SDS permits to help keep us, our communities, and our shared water and land safe. I hope that you can continue these steps and incorporate some of the much-needed changes I have shared here into your new permits. Let’s make these new permits something that will protect all Minnesotans.

Thank you,

(your name)

Click HERE to Leave a Public Comment