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Tell the MPCA by Sept. 10 to Focus on Clean Water, New Crops & Living Cover

Agency Accepting Comments on Nutrient Reduction Strategy

August 22, 2025

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The Minnesota Pollution Control Agency (MPCA) is accepting comments on updating its Minnesota Nutrient Reduction Strategy 2025 (full draft document found here), which establishes a roadmap for reaching both phosphorus and nitrate reduction goals. 

Please take a moment to review LSP’s comments and rationale for actionable items for this plan and submit your comments via the MPCA’s online form before Wednesday, Sept., 10 at 11:59 pm.

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 in water is one of the worst problems impacting human and ecosystem health in Minnesota. At the root of the nitrate pollution problem is a situation where cropland acres are dominated by corn, which is highly dependent on synthetic nitrogen fertilizers.

According to the 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 levels over time, reductions in the amount of  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 the Minnesota Department of Agriculture (MDA) and documentation of nitrogen fertilizer application rates by responsible parties (e.g. crop retailers).
  • Build a Small Grain Initiative and a safety net for farmers who want to reduce their nitrogen fertilizer applications by transitioning into more diverse cropping systems.
  • Grow farmer power, farmer networks, and locally led, flexible and outcome-based approaches like the Olmsted County Groundwater Protection and 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 officials hear not only about what changes you want to see but also what’s working when it comes to current nutrient reduction strategies.

MPCA provided the following guidance for submitting comments:

To submit comments online or by mail to the MPCA, you must state:

    1. Your interest in the Minnesota Nutrient Reduction Strategies draft report.
    2.  The action you wish the MPCA to take, including specific references to the section of the draft report(s) you believe should be changed.
    3. 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 send a letter, you can submit it electronically on this website or via U.S. mail to the following address:

Minnesota Pollution Control Agency
c/o Corrie Layfield
520 Lafayette Rd.
Saint Paul, MN 55155

What LSP Wants to see Build, Grow & Change in MPCA’s Nutrient Reduction Update:

• We strongly agree with the findings of the Updated Nutrient Reduction Strategies that align with the recommendations from the Southeastern Minnesota Nitrate Strategies Work Group to accelerate a transition to perennial crops, pasture, small grains and harvested cover crops on millions of acres.

• 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 four peer-to-peer Soil Health Hubs that we coordinate in southeastern Minnesota, that in total reaches 50 farmers.

• Expanded and increased investment in Soil and 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 the MPCA to strengthen the approaches to reducing the over-application of fertilizer and manure as outlined in the Nutrient Reduction Strategy draft report 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 the 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 nitrate reductions more quickly.

Comment: Develop a program that offers a safety net for farmers who want to reduce their nitrogen fertilizer applications. 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 nitrogen 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 that over-application results in surplus nitrates in the landscape. This surplus nitrate 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 nitrogen 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 the Olmsted County Groundwater Protection and 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 the Olmsted County initiative in phases across the whole state, starting with southern Minnesota.

Rationale: To accelerate the reduction of nitrate pollution 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). 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 over-application of fertilizers and decrease the amounts of nitrogen 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 nitrate reduction goals.

Comment: Change the language from state agencies “can” support to “must” support trustbuilding 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

More Information

If you want more information about these recommendations and information shared in the comments, check out these resources:

  • Report of recommendations: Southeast Minnesota Nitrate Strategies Collaborative Work Group
  • Forever Green’s Continuous Living Cover Supply Chain Fund
  • Fertilizer Nitrogen Sales in Minnesota and Fluctuations over Time, April 2025

LSP articles and podcasts:

  • Nitrate’s Season of Reckoning: Ag Pollution in Karst Country Offers a Critical Opportunity for Soil-Friendly Farming
  • Rooting Out Nitrates: Can One County’s Approach to Soil & Water Health be a Model of Disruption?
  • Kernza videos
  • Social Sustainability: Fostering Farmer-Focused Communities
Category: Action Alerts
Tags: clean water • crop diversity • MPCA • nitrates • nitrogen fertilizer • nutrient reduction • Phosphorus • soil health • water pollution

Contact

Amy Bacigalupo, LSP program director, 320-269-2105, e-mail

Upcoming Events

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October 2025

Tuesday October 7

6:30 pm – 8:00 pm
Book Event: We Can Do Better: Collected Writings on Land, Conservation, and Public Policy
Tuesday October 7
6:30 pm – 8:00 pm
Book Event: We Can Do Better: Collected Writings on Land, Conservation, and Public Policy
The Landing Market, 211 College Dr, Decorah, IA 52101, USA

The Johnson Center for Land Stewardship Policy is excited to share that one of our its primary pillars of work — a published collection of Paul Johnson’s writings —  is set for release on Oct. 2.  The book features a brief biography and a discussion of Paul’s ideas within the historical and future contexts of private lands conservation. Details on the event are available here.

For details on We Can Do Better: Collected Writings on Land, Conservation, and Public Policy click here.

 

Friday October 10

8:30 am – 3:00 pm
Weaving a Wider Community: Seeing & Countering Racism in Our Backyard
Friday October 10
8:30 am – 3:00 pm
Weaving a Wider Community: Seeing & Countering Racism in Our Backyard
111 N 1st St, Montevideo, MN 56265, USA

Join LSP and CURE for a community event at the Land Stewardship Project office in Montevideo (111 N. First St.), from 8:30 a.m. to 2 p.m., on Friday, Oct. 10. This event includes lunch catered by El Mana; please register by Oct. 3 to be included in the food count.

You can RSVP here.

The Racial Equity Conference, organized by the Greater Minnesota Partnership of the Facilitating Racial Equity Collaborative, has been specifically designed to bring engaging content to local communities through a unique pairing of online speakers and in-person local sessions. The morning’s online content will include a conversation focused on seeing and countering racism in rural communities, moderated by Eryn Gee Killough, paired with two outstanding keynote speakers, Jenna Grey Eagle and Ron Ferguson, who have experience working in rural communities. 

This online content will be exclusively available to local community gatherings. Each gathering will gear their in-person activity to their specific community with the goal of extending the impact of the conference to others throughout the following year. Join LSP and CURE for this western Minnesota gathering, or if a different location works better for you, check out all the local gatherings on the FREC site,

If you have any questions, do not hesitate to reach out. LSP’s Nick Olson can be reached via e-mail at nicko@landstewardshipproject.org.

9:00 am – 3:00 pm
Intensive Small-Scale Market Gardening Bus Tour
Friday October 10
9:00 am – 3:00 pm
Intensive Small-Scale Market Gardening Bus Tour
Leatherdale Equine Center, 1801 Dudley Ave, St Paul, MN 55108, USA

Explore profitable small-scale farming (1–5 acres) and soil care. Visit a cooperative incubator farm and a thriving suburban market garden. Learn about cover crops, reduced tillage, high tunnel soil health, and support for growers.

This is the second tour in a three-part soil health bus tour series. Participants can sign up for just one, two, or all three tours. Register at https://z.umn.edu/vegetablebustours. The cost is $15 (flat fee, covers 1, 2, or 3 tours). There are more details in the attached flyer.

Saturday October 11

11:00 am – 2:00 pm
LSP-COPAL Visita a la Granja | Farm Tour
Saturday October 11
11:00 am – 2:00 pm
LSP-COPAL Visita a la Granja | Farm Tour
36919 County 57 Blvd, Dennison, MN 55018, USA

Building off the success of last year’s farm event with COPAL in Austin, Minn., this year Land Stewardship Project and COPAL members and supporters will gather at the Young-Walser Family Farm in Dennison, Minn. for a festive and delicious farm tour on Saturday, Oct. 11, from 11 a.m. to 2 p.m. We invite you to come and meet new folks, learn new skills, and try new food! 
 
This year’s COPAL-LSP farm event offers a little something for everyone: 
 
🍯 Honey sampling and the opportunity to purchase from Homestead Honey Farm. 
 
🍎 Apple cider pressing and tasting. (BTW, we’re still looking for an apple press if you or a farmer friend have one nearby we could borrow for this event!) 
 
🌽 Nixtamalization workshop and fresh, homemade tortillas, made with corn grown by LSP and COPAL members at the Young-Walser Family Farm! 
 
🍅 Salsa making and cricket-eating competitions! Yes, you heard that right —we’ll have the opportunity to sample crickets, a delectable crispy and savory snack commonly enjoyed throughout Mexico and Central America. Stay tuned for details on how to enter either competition. 
 
🥾 A tour of the Young-Walser farm, nestled in the beautiful Sogn Valley not far from Cannon Falls, Minn. Enjoy a tromp through the corn and squash fields and hike in the nearby woods. 
 
🌮 A shared meal and opportunity to hear from LSP and COPAL organizers about our participation in the Immigrant Defense Network. 

Let us know you can make it to ensure we order enough food and supplies! Carpools from Minneapolis and Rochester will be available to all attendees. 

________________________________________________

¡Únete a LSP + COPAL para nuestro recorrido anual comunitario en la granja!
Un espacio divertido para tod@s donde exploraremos la agricultura, aprenderemos sobre el campo y participaremos en actividades prácticas. ¡Uno de los momentos más especiales será hacer tortillas frescas junt@s!

Compartiremos un delicioso almuerzo comunitario, preparando tacos en estilo potluck (tipo convivio). Te invitamos a traer un platillo o acompañamiento para compartir.

También estás invitado@ a llegar temprano (desde las 9 AM) para ayudar a cosechar calabazas que sembramos. Puedes llevarte algunas a casa, y el resto se donará a un banco de alimentos local.

El Land Stewardship Project (LSP) es una organización aliada de COPAL que trabaja por sistemas alimentarios y agrícolas más sostenibles y justos. LSP y COPAL están unidas en su lucha por instituciones democráticas sólidas, comunidades saludables y acogedoras, y una ética de cuidado hacia la tierra y las personas que nos alimentan.

Tuesday October 14

11:00 am – 12:00 pm
Birds as Pest Control Allies on the Farm
Tuesday October 14
11:00 am – 12:00 pm
Birds as Pest Control Allies on the Farm
Online

This 10-lesson Wild Farm Alliance virtual course teaches agricultural professionals and farmers how to support beneficial birds and manage pest birds on farms. By learning how to assess the farm’s avian needs and opportunities, farms can be designed to provide for a diversity of beneficial birds. 

If pest birds are a problem, they can be discouraged with specific practices during the shorter periods when they cause damage. The sessions cover the latest research, tools and resources, and are given by experts in avian pest control, entomology, ornithology and conservation. While many topics and species are specific to the Midwest, most of the principles discussed are applicable across regions. 

Continuing Education Credits have been requested and are expected to be approved from American Society of Agronomy.

For details and to register, click here. 

The Course Schedule:

LESSON 1

Why Birds Belong on the Farm: Biodiversity, Pest Control & A Thriving Landscape

Tuesday, September 23, 2 p.m. CT


LESSON 2

Birds as Pest Control Allies on the Farm

Tuesday, October 14, 11 a.m. CT


LESSON 3

Birds in the Balance: Pest Control Services Across Crop Types

Tuesday, November 4, 11 a.m. CT


LESSON 4

Integrating Habitat into Croplands: Prairie Strips and Bird Conservation

Tuesday, December 2, 11 a.m. CT


LESSON 5

Birds on the Farm: Balancing Biodiversity and Food Safety

Tuesday, January 13, 11 a.m. CT


LESSON 6

Beyond the Crop: Birds, Biodiversity, and the Power of Edge Habitat

Tuesday, February 3, 11 a.m. CT


LESSON 7

Bridging Forestry, Farming, and Habitat

Tuesday, February 24, 11 a.m. CT


LESSON 8

Perennial Pathways: Agroforestry for Birds and Biodiversity on Farms

Tuesday, March 17, 11 a.m. CT


LESSON 9

Birds on the Range: How Grazing Practices Shape Habitat for Grassland Species

Tuesday, April 7, 11 a.m. CT


LESSON 10

Birds at Risk: How Pesticides Shape Safety on Agricultural Lands

Tuesday, April 28, 11 a.m. CT

View Full Calendar

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