Judge Allan Klein

Office of Administrative Hearings

100 Washington Square Suite 1700

Minneapolis, MN 55401-2138

 

 

Honorable Judge Allan Klein;

 

My name is:   Dave Wulf

Address:        R. R.  3     Box 234

                     Morris,  MN  56267-9426

Phone:           320-392-5225

e-mail:           davewulf@info-link.net

 

    I am currently President of West Central Cattlemen's Ass'n --  a local cattlemen's group consisting of about 100 members from a five county area in West Central Minnesota.  I am also a family partner in a cattle feedlot and cow/calf operation and I wish to express my views on the proposed MPCA feedlot and manure management rules -- Minnesota Rules Chapter 7020.

   

    If implemented as currently written, it will cause severe financial hardship for not only feedlot operators, but for other grain and feed producing farmers who depend on livestock for consumption of their products and associated business that furnish supplies and services to them.  I believe it will cause many to be forced out of business and possibly seek opportunities in other states.  For others it will cause a large financial setback and restructuring of their farming operation in areas of less interest to them due to an already depressed farm economy.  Minnesota farmers and livestock producers cannot afford at a time as this to be burdened with unnecessary expenditures and seemingly harsh and tedious regulations.

 

    To quote a few facts from Minnesota Ag Statistics, the number of farms in Minnesota in 1998 was at 80,000, down from 92,000 in 1987.  This is not due to the huge mega-farms we often hear about in recent years as average farm size increased only slightly from 326 acres in '87 to 361acres in '98.  The real reason for the drop in numbers is that many were forced out of business because of the slim profit margins in producing ag commodities in recent years.  Another noteworthy statistic is average typical farm income in Minnesota in the past several years as follows:

        1993 ---  $  1,878.

        1994 ---  $17,129.

        1995 ---  $11,076.

        1996 ---  $27,590.

        1997 ---  $11,776.

        1998 ---  $15,754.

                        

    In the December issue of CATTLE-FAX newsletter (a well respected industry publication), they reported that the huge losses from fed cattle marketings for the year 1998 was the worst in 25 years due to high feed costs and low fed cattle prices.

 

    Another interesting statistic from Minnesota Ag Statistics is the 'all cattle peak numbers' in Minnesota for the years of:

        1965 --- 4,518,000 cattle

        1999 --- 2,500,000 cattle

With only 55% of the cattle today as compared to 1965, how can the pollution problem due to livestock be greater today?  Furthermore, the modern beef breeds of today are much more efficient utilizing feedstuff thereby producing less manure.  The manure being handled today is with much larger machines carrying it farther from the producing facility on many more acres and better spreading capabilities; hence, much less runoff is apt to occur.

 

    The agricultural and food sector of Minnesota employs 22% of the state's work force and produces 17% of Minnesota's gross state product ( #1 industry in the state ) with a worth of about $2.6 billion which ranks 7th in the U.S. in ag goods.  Our state government and its agencies along with the people of Minnesota must decide whether or not they want agriculture and the associated businesses to continue in Minnesota!  If not, place these overbearing rules upon us and many will eventually be forced to shut down.  The scope  of these rules go far beyond simply protecting the environment by imposing excessive unwarranted regulations and record keeping requirements on our industry.  I believe our state needs the support of our ag and livestock industries to help maintain a healthy economy and our prestigious agricultural rankings.  We need to relax or withdraw the imposed regulations and work with a more unified effort to clean up our environment.

 

    I suggest that the current proposed rules ( 7020 ) be withdrawn temporarily until further studies can be accomplished as to who exactly is causing the pollution problems to the lakes, rivers, and streams and to what degree.  I was understood that the Generic Environmental Impact Study ( GEIS ) that is ongoing by the State of Minnesota was to address the causes therof.  Is it not feasible that we could wait for the results of this unbiased study?

 

    Barring the rules ( 7020 ) being thrown out, there are several changes in the rules that would help considerably lighten the regulation burden on producers; listed as follows:

 

7002.0270

Annual fee should be eliminated or reduced as not to cause hardship on producers.  Additional funding can possibly be picked up by Minnesota Dept. of Natural Resources.

7020.0300 subpart 13b.

A liquid such as rain water that comes in contact with animals only should not be classified as "Manure-contaminated runoff"

7020.0300 subp. 26

"Waters of the state" should include waters only on state and public property and not on any private property, specifically drainage systems

7020.2015 subpart 1

There should be an exemption on lakes under 5 acres and under 15 feet of depth.

7020.2125 subpart 2  item A

180 calendar days should be increased to 240 days as many producers must wait until after wheat harvest ( Aug.) to apply manure

7020.2225 subpart 7

The ban of surface manure in 300 ft. radius of tile intakes seems unfounded as manure aids in preventing wind and water erosion

 

    Thank you for your time and consideration of my comments.

 

        Dave Wulf