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As states step up on climate action to fill the void left by the Trump administration, farming is often left on the sidelines. This is starting to change. In a first among Midwest farm states, Minnesota regulators are attempting to assess the climate impact of large-scale concentrated animal feeding operations (CAFOs).

The Minnesota Pollution Control Agency (MPCA) is assessing for the first time the climate impact of a proposed expansion of the Daley Farms dairy, which would grow the operation from 1,500 to 4,000 cows. Situated in Winona County, the dairy is located in the state’s karst region, an environmentally sensitive area prone to groundwater contamination. The MPCA initially reviewed and approved the expansion in 2018. However, Winona County residents and state organizations like the Land Stewardship Project and the Minnesota Center for Environmental Advocacy raised objections to the project, particularly over water pollution. The groups then filed a legal challenge charging that the MPCA had neglected to account for the climate impacts of the expansion. Last fall, the Minnesota Court of Appeals agreed and required the MPCA to consider the proposed expansion’s climate impact.

The MPCA took its first shot at assessing the climate impact of the Daley Farms expansion in January. In early March, IATP and other Minnesota environmental and farm groups criticized the MPCA for not fully capturing the proposed expansion’s greenhouse gas emissions (GHGs) and inadequately accounting for alternative farming practices that can protect the climate. The MPCA will respond to these comments later this spring. The agency’s final assessment will be precedent-setting and will influence the state’s future decisions about new and expanding CAFOs, while setting a benchmark for surrounding Midwest agriculture states.

IATP’s comment to the agency focused on five critical points where the MPCA came up short:

  • Undercounting emissions — The MPCA estimates that the expanded Daley farm will produce 32,000 tons of CO2 equivalent emissions, but this estimate ignores GHGs from building construction and associated energy use; transportation of manure, equipment and milk; and increases associated with animal feed production.
  • Downplaying the climate crisis — The MPCA downplayed the urgency of the climate crisis in multiple ways. First, it measured the methane emitted by dairy cows and their manure on a 100-year timeframe rather than a more accurate 20-year timeframe that reflects the urgency of the climate crisis. Second, the MPCA assessed Daley Farms’ greenhouse gas emissions in terms of its contribution to global climate change. No single project in Minnesota could measurably impact climate change on a global scale. Instead, the MPCA should consider Daley Farms’ emissions in terms of Minnesota’s climate goals.
  • Ignoring the climate benefits of alternative farming systems — The MPCA did not fully examine the climate benefits of alternative farming systems. Well-managed grazing systems, more diverse crop rotations and planting perennial grasses build soil health, protect water quality and increase a farm’s resilience to climate impacts. The MPCA should encourage these alternatives to new or expanding CAFOs.
  • Climate risk — When storms or floods hit, manure lagoons can breach and release their waste into the environment. This poses a massive risk to surrounding communities and waterways. As climate change worsens, Minnesota will experience more extreme weather events, including storms and floods. The MPCA did not account for the damage that breached or overflowed manure lagoons could cause.
  • Driving the dairy crisis — The dairy crisis that is pushing thousands of small and mid-sized dairies out in Minnesota and Wisconsin is largely caused by an over-production of milk, which drives prices down. Minnesota alone lost 315 dairies in 2019. The construction of large-scale mega dairies will increase this trend of overproduction, thereby further threatening small to mid-sized dairy farmers in the state.

By underplaying both the climate impact and the risk to the community from a climate-related severe weather event, the MPCA lessens the chance the state will reach its climate goals. Agriculture and forestry account for a quarter of Minnesota’s greenhouse gas emissions, and the state will not meet its climate goals to reduce emissions by 80% by 2050 without significant changes in the agriculture sector.

The agency’s climate assessment falls within a struggling farm economy where bankruptcies are up, debt is at dangerous levels and rising stress is leading to an emerging mental health crisis among farmers. The MPCA process does not address our deeply broken farm economics where farmers routinely see their costs rise above their return. As Minnesota and other farm states place large-scale operations under greater climate scrutiny, states’ examinations should be coupled with enactment of policies that support a transition toward systems that protect the planet and keep family farmers on the land.