Tell the MPCA that the time is now to change course toward new crops, living cover and clean water!

The goal of achieving clean water for all Minnesotans requires reductions of 42% of phosphorus on average in lakes and rivers and 40% of nitrates in rivers and vulnerable groundwaters by 2040 (based on recent conditions). High levels of nitrates is one of the worst problems impacting human and ecosystem health in Minnesota. At the root of the nitrate pollution problem are cropland acres dominated by corn which is the primary crop that utilizes synthetic nitrogen fertilizers.

According to MPCA, areas of the state where nitrate pollution is high, like southeastern Minnesota, commercial application of fertilizer on cropland contributes more than 70% of the nitrate pollution. Given the high volume of nitrogen (N) fertilizers used in MN every year and the extent of its use across more than 8 million acres of corn in a typical year, even modest reductions on a per acre basis will have a collectively large impact. While crop diversification will lead to reduced application over time because of reduced corn acres, reductions in the amount of N fertilizers being applied are needed now to mitigate the negative impacts of nitrate pollution.

Fill Out the MPCA Comment Form Below:

What LSP Is Looking For:

LSP applauds the bold strategies that MPCA is putting forward, and we are invested in working collectively on them including:

LSP Supports – We strongly agree with the findings of the Updated NRS that align with the recommendations from the SE MN Nitrate Strategies Work Group to accelerate a transition to perennial, pasture, small grains and harvested cover crops on millions of acres.

LSP Supports – We strongly agree that social factors are important to achieving wide-scale adoption of practices. Unpublished results from the MN Office of Soil Health survey lifted up the key role of other farmers in the adoption process. Other farmers were top ranked as the group with the most influence when farmers want to learn more about a new soil management practice. LSP has seen this firsthand with the 4 peer-to-peer hubs that we coordinate in SE Minnesota, that in total reaches 50 farmers.

LSP Supports further and increased investment in SWCD, as a trusted local partner and effective delivery mechanism for these nutrient reduction strategies.

To ensure MN achieves clean water LSP is asking MPCA to strengthen the approaches to reduce the over-application of fertilizer and manure as outlined in the NRS Update in the following ways:

Comment: Require commercial fertilizer retailers to report N fertilizer application rates. Request a change to the language on page 262 under ‘Nutrient Management Tracking’ to make sure this reporting is mandatory and that the information is publicly available every year.

Rationale: This will reduce the overapplication of fertilizers and decrease the amounts of N applied across the state. This data addresses a gap in the reliability and frequency of data that can be used to inform actions needed to hold retailers accountable to N reduction goals.

Comment: Require that the new Continuous Living Cover Task Force have 50% farmer and farmer-led organization representation.

Rationale: To move toward a transition to perennial cover as a critical strategy for achieving clean water we want to see the new Continuous Living Cover task force and the visionary work of the Forever Green Initiative succeed. To increase the success of this initiative farmers and farmer-led organizations most impacted by the problem of Nitrate pollution bring the best knowledge and agency to develop and deliver solutions. This would build trust with farmers as the research and development of these crops continues.

Comment– Add a Small Grain Initiative, with similar levels of funding and a long-term commitment from MDA and UMN modelled after the visionary Forever Green Initiative.

Rationale: To accelerate the diversification of our cropping systems and move away from corn and achieve the N reductions more quickly.

Comment: Replicate proven incentives approaches like Olmstead County Soil Health program to all SWCD in the area as a first step. On page 288 add a bullet that describes a plan with the leadership of BWSR and SWCDs to replicate a similar approach to Olmstead County Soil Health program in phases across the whole state starting with Southern MN.

Rationale: To accelerate the reduction of Nitrates in Southern Minnesota by replicating this successful approach.

Comment – Develop a program that offers a safety net for farmers who want to reduce their N fertilizer application. Add language on page 285 to require the state in partnership with private organizations to develop a safety net for farmers who want to trial reduced amounts of synthetic fertilizers modelled after other successful indemnification programs.

Rationale: Indemnification approaches are successful because they provide a safety net while farmers learn how a new practice performs on their farm. These approaches rely on farmers’ own common sense. Using the least amount of N fertilizer needed to achieve optimal yield is common sense. It is well established that there is a point that applying more fertilizers will not contribute to greater yield and results in surplus N. This surplus nitrogen is not only an environmental pollutant… causing harm to human health and aquatic life downstream — it is also costly to the farmer. Successful approaches like Practical Farmers of Iowa’s Nitrogen Rate Risk Protection Program and the BMP Challenges compensate farmers for losses they have incurred due to reducing N fertilizer application.

Comment: Change the language from state agencies ‘can’ support to ‘must’ support trust building by funding farmer-led groups on page 192.

Rationale: Given that farmers have ranked other farmers as the group with the most influence when they want to learn more about a new soil management practice it is imperative that funding move to efforts that foster farmer leadership. This is the best investment we can make toward accelerating adoption of conservation practices

Guidance on making comments:

This comment period is open to all, and it is critical that they hear from farmers and concerned citizens not only about what we want to see as changes but also…what is good in the strategies they have prioritized. As with most public comment periods they are legally required to respond to all comments they receive.