Tell the Minnesota Pollution Control Agency (MPCA) that the time is now to change course toward new crops, living cover and clean water!
MPCA is accepting comments on updating its MN Nutrient Reduction Strategy 2025 (full draft document found here) which establishes a road map for reaching both phosphorus and nitrogen reductions. The deadline is September 10 at 11:59 pm.
If you want to amplify comments from LSP you can review our positions and rationale at the bottom of this website. Click here or scroll down to submit your comment.
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 89% to 95% of the nitrate in waters in Southern and Central Minnesota is coming from cropped fields. While crop diversification will lead to reduced application over time, reductions in the amount of N fertilizers being applied are needed now to mitigate the negative impacts of nitrate pollution.
LSP is asking MPCA to:
- Strengthen data collection and reporting requirements for fertilizer retailers by MDA and documentation of nitrogen fertilizer application rates by responsible parties (e.g. crop retailers to MDA).
- Build a Small Grain Initiative and a safety net for farmers who want to reduce their N fertilizer application.
- Grow farmer power, farmer networks and locally led, flexible and outcome-based approaches like Olmstead County Soil Health Program’
How you can contribute:
While comments from organizations like LSP and experts are important and will happen, the most impactful comments are from individual farmers and other Minnesotans who have personal stories that relate why the rules need to be changed.
Guidance on making comments:
This comment period is open to all, and it is critical that they hear from you not, only about what changes you want to see but also what is it you see that is good and working.
MPCA provided the following guidance for submitting comments.
To submit comments online or by mail to the MPCA, you must state:
- Your interest in the Minnesota Nutrient Reduction Strategies report.
- The action you wish the MPCA to take, including specific references to the section of the draft report(s) you believe should be changed.
- The reason(s) supporting your position, stated with sufficient specificity as to allow the MPCA to investigate the merits of the position
If you prefer to submit a letter, you can upload it electronically on this website, or submit it via U.S. mail to the following address:
Minnesota Pollution Control Agency
c/o Corrie Layfield
520 Lafayette Rd.
Saint Paul, MN 55155
What does LSP want to see build, grow, and change in MPCA’s Nutrient Reduction Update:
LSP Supports – We strongly agree with the findings of the Updated Nutrient Reduction Strategies that align with the recommendations from the SE Minnesota Nitrate Strategies Work Group to accelerate a transition to perennial crops, 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 Minnesota 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 – Expanded and increased investment in Soil Water Conservation Districts (SWCDs), as a trusted local partner and effective delivery mechanism for these nutrient reduction strategies.
To ensure Minnesota 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:
Build
Comment: Add language to pages 190 and 289 to create a Small Grain Initiative, with similar levels of funding and a long-term commitment from Minnesota Department of Agriculture (MDA) and the University of Minnesota, modeled 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: 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 modeled 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 may incur due to reducing N fertilizer application.
Grow
Comment: Add language on page 292 to 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 experience to develop and deliver solutions. This would build trust with farmers as the research and development of these crops continue.
Comment: Replicate proven incentives approaches like Olmstead County Soil Health Program to all SWCDs 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 Minnesota.
Rationale: To accelerate the reduction of Nitrates in Southern Minnesota by replicating this successful approach.
Change
Comment: Strengthen data collection and reporting requirements’ by adding documentation of nitrogen fertilizer application rates by responsible parties (e.g. crop retailers to MDA). Request a change to the language on page 262 under ‘Nutrient Management Tracking’ to make sure this reporting is mandatory and that MDA publishes the data annually.
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: 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
—
If you want more information about these recommendations and information shared in the comments check out these resources:
LSP articles and podcasts:
