Administrative Law Judge Allan W. Klein

Office of Administrative Hearings

100 Washington Square, Suite 1700

Minneapolis, Minnesota 55401-2138

 

January 21, 2000

 

Honorable Judge Klein,

 

Please accept this email message as my citizen comments regarding the

Proposed Amendment to Rules Governing Animal Feedlots and Storage,

Transportation, and Utilization of Animal Manure (Chapter 7020 and parts

7001.0020 and 7002.0210 to 7002.0280).

 

Please amend the regulations to require that feedlots either have contracts

with local farmers (within 20 miles) to utilize the waste associated with

their operation as a field-applied fertilizer (at no charge) or that the

feedlot operators treat the waste in a sewage treatment system similar to

that used to treat human wastes in municipal settings.  Large ponds of

animal manure should be severely restricted and eliminated whenever

possible. Please establish volume limits on these ponds which require that

they be emptied on a weekly basis. These ponds have dramatically impacted

the rural environment in Minnesota.  A drive on any one of the highways in

West-Central Minnesota on a hot, August day will quickly tell you there is

something stinking up the air in too many of the townships.

 

Also, feedlots and manure storage facilities should not be allowed in any

area within a reasonable distance (1,000 feet) of a natural or created

waterway, open or abandoned well, natural or created wetland, or other

water features which may be polluted by a waste spill or overflow.

 

By protecting and promoting feedlots through regulations which do not

adequately charge the operators for their environmental impacts, we are

putting smaller, lower-impact farmers at a disadvantage.  Please draft

regulations to internalize the environmental costs of large feedlot

operation and manure management.  Only by doing full-cost accounting can we

clearly illustrate the severe impact of these operations and make

traditional,small-scale operations more economical and comparable.

 

Let us not be fooled into believing that bigger is better when it comes to

manure.

 

Thank you for your hard work and serious consideration.

 

In Common Interest,

Kathryn Fernholz

 

1301 Hwy 7 #135

Hopkins, MN 55305