The following comments were submitted on July 21, 2025, to the Minnesota Environmental Quality Board in response to a call for feedback on the Minnesota Climate Action Framework.
1.2.1 Reduce the carbon intensity of transportation fuels
IATP has concerns about any Clean Transportation Fuel Standard (CTFS) that expands corn and soy-based biofuel production in the state. An expansion of corn and soy production in the state will come at the expense of other crops and farming systems that could improve
soil health, reduce nitrogen fertilizer use, protect our water and support more local food production. A CTFS that expands biofuel production threatens to undercut Section 5.4.5 of the framework, which focuses on building local, community-based food systems as a climate resilience strategy. Finally, most industry projections continue to show the steady growth in electric-powered vehicles, a trend that will shrink the need for biofuels over time. The state should consider the impact of a decline in the biofuels market on the farm economy, and develop a just transition strategy that creates new agriculture market opportunities for farmers growing corn and soy and invested in biofuels.
We are also deeply concerned about the inclusion of Renewable Natural Gas within any CTFS as we expressed in our previous comments on the Climate Action Framework.i Those concerns have increased given the Trump administration’s climate denial and actions to fully embrace the fossil fuel industry through a series of policies. The expansion of agriculture-based RNG is enormously expensive and deeply reliant on state and federal subsidies. It also further expands the methane gas infrastructure and market — effectively competing with the state’s priorities transition to more clean energy and electric vehicles. The high cost of agriculture RNG projects means they are primarily only accessible to the largest farm operations. The projects incentivize farms to get bigger to produce more manure (potentially creating additional greenhouse gas emissions). Further, digesters do not eliminate methane emissions, leak significant amounts of methane, and can worsen other pollutants.ii They have been associated with dangerous gas buildup, methane explosions, and storage tank ruptures.iii Additionally, digestate, the remaining manure after methane gas has been captured in a biogas facility, has higher concentrations of ammonia and when applied as fertilizer can lead to higher emissions of nitrous oxide.iv While we don’t believe RNG belongs in any section of Minnesota’s Climate Action Framework, if it is included it must include guardrails that limit further expansion of large operations, account for digestate’s unique pollution risks, and for public health risks associated with non-GHG pollutants.
2.1.1.1 Accelerate tree planting to expand forest cover where ecologically appropriate
IATP supports this action step as a strategy to capture carbon dioxide while increasing wildlife habitat throughout the state. The document’s inclusion of the phrase “ecologically appropriate” is key — varieties of trees that are not well-suited to Minnesota’s expected climate over the next few centuries should be avoided, and in some cases native grasses may be more appropriate than trees.
2.1.1.2 Increase statewide seedling production to support tree planting efforts, including rectifying pinch points in seed supply and enhancing production of climate-adapted species
This action step is important for creating a strong and stable pipeline for tree planting throughout the state. Planting the scale of trees needed in Minnesota is more complicated than just going to the local nursery and buying the ones you need — it takes years of careful planning. The tree varieties planted today are not the same mix as were planted 50 years ago — planning for future climactic conditions is essential in keeping healthy trees and forests.
2.1.1.3 Invest in active forest management on public and private lands as a tool for promoting carbon uptake and reducing emissions from diseases, pests, and wildfires
For thousands of years, humans have actively managed forestland and been an essential part of forest ecosystems. Some human or animal-caused disturbance can fit into a larger forest management plan with the goal of reducing future emissions from die-offs and fires. Working with the best available science is critical here, and safeguards should be in place to ensure state policy follows the science and not market incentives.
To continue reading, download the PDF with the full comments.
Footnotes
i https://www.iatp.org/sites/default/files/2025-01/IATP%20Climate%20Framework%20Comment.pdf
ii Thomas Flesch et al., Fugitive Methane Emissions from an Agricultural Biodigester, 35 Biomass & Bioenergy 3927, 3927 (2011); Semra Bakkaloglu et al., Methane Emissions Along Biomethane and Biogas Supply Chains Are Underestimated, 5 One Earth 724, 730–731 (2022); Norah Efosa et al., Emissions of Nitrous Oxide and Methane After Field Application of Liquid Organic Fertilizers and Biochar, 356 Agric., Ecosystems & Env’t 1, 1 (2023); Thomas Kupper et al., Ammonia and Greenhouse Gas Emissions from Slurry Storage – A Review, 300 Agric., Ecosystems & Env’t 1, 1 (2020).
iii Ji-Qin Ni, Cases, Causes, and Impacts of Safety Incidents at AD Systems, Purdue (Mar. 10, 2023), https://engineering.purdue.edu/adt/workshop/230310/ni.pdf.
iv https://pubmed.ncbi.nlm.nih.gov/37967706/
