February 23, 2000

                                                                                                                                19503 160^th Street

                                                                                                                                Wilmont, MN 56185-1025

 

Judge Allan W. Klein

Office of Administrative Hearings

100 Washington Square Suite 1700

Minneapolis, MN 55401-2138

 

Dear Judge Klein:

 

I am writing to comment on the proposed changes in the Minnesota Pollution Control regulations.  I was unable to attend the local meeting in Hadley, Minnesota. 

 

I have several concerns I would like to address in the proposed changes.  The first item I would like to address is the fact that the MPCA is changing rules before the Generic Environmental Impact Statement is completed.  The GEIS was supposed to address some of the concerns of livestock production in Minnesota and is being done at great expense.  I think the MPCA should wait until this is completed and has been studied by everyone involved in animal agriculture.

 

I will address my concerns by the identification number:

Recordkeeping (7020-0230):  This is make paperwork portion.  If a feedlot has a permit for a certain number of acres to be used for manure, they should know where the manure needs to be spread.  It is in the best interest of farmers to utilize manure in a rotational basis to gain the most fertilizer benefit.

 

Registration and permits:  (7020.0350):  This is a paperwork nightmare for the state of Minnesota and its citizens.  I believe it is designed to create jobs at the state level for no particular purpose.  The local counties have a decent idea of what is located in their county via tax assessments for buildings and feedlot/environmental departments. 

 

Fees (7020.0270):  Fees for permits should be confined to those very largest feed lots with the greatest amount of manure.   Small farmers have no way to recoup these costs and cannot pass the cost along—it comes out of our living budget.  Largest feed lots/confinements are contributing to the oversupply of livestock and causing the prices on the farm to be reduced to record low levels.   The feed lots/confinement are concentrating manure in record amounts. 

 

Open lot feedlot (7020.2100 and others):  This rule is designed to eliminate smaller feedlots with open lots for the housing of cattle, finishing hogs and gestating sows.   You can argue the 300 animal unit feed lots have until October, 2009, to reconstruct, but this would require additional capital, which is difficult to pass along the cost.  You need to raise the 300 animal unit feed lots since you cannot even run a 100 sow farrow to finish operation with this number of animal units and this is considered very small.  This animal limit needs to be raised and the open feedlot rule struck out as this eliminates the low building cost producer using labor rather than capital. 

 

Land Application of Manure (7020-2225):  Manure management plans for feedlots over 100 to 500 animal units also is a waste of producer time and money which cannot be passed along.  Manure varies greatly in nutrient content and even if you tested one spot, the next area could be different.  The vast majority of farmers already soil test and apply manure in a responsible manner.  This rule creates more unnecessary paperwork.    This rule would be especially difficult for people who need to apply manure more than twice a year such as a hoop structure, scrape barn or feedlot situation (low capital, higher labor farms).    Farmers already treat manure as a valuable fertilizer and would not just spread it  just anywhere.  I realize the majority largest feed lots are not traditional farmers, do not live near the feedlot/confinement site, and concentrate manure and will have to fall under special rules.   Stockpiling of manure rules (7020.2125) would also hurt small farms the most as they are the ones that do not have a lot of capital tied up in liquid manure handling facilities and rely more heavily on bedding and handling manure as a solid product. 

 

Overall my concerns are that these regulations will just accelerate the smaller farmer leaving the livestock industry by adding unnecessary regulations, paperwork and cost.  I know we need reasonable regulations. 

Page 2

Re:  Feedlot rules

February 23, 2000

 

I think the 300 animal unit boundary needs to be raised to at least 400 if not 450.  A 100 sow farrow/finish operation could not operate under these new rules without a raft of rules.   A diversified family dairy could not operate under these rules without burdensome rules.  As it is, it is already very difficult to earn a living with a smaller operation operating without burdensome debt.  This set of rules encourages farmers to borrow large sums of money to build facilities to meet the new regulations—not a smart proposition in my mind.  

 

I think we should wait for the GEIS to be finished and apply reasonable rules to those that need them, and do not encourage larger and larger feedlots with the new rules.    Thank you for your attention to this matter.

 

Sincerely,

 

 

 

Judy M. Christians