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

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:

LSP articles and podcasts:

Land Stewardship Project