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The Institute for Agriculture and Trade Policy (IATP) thanks the Minnesota Pollution Control Agency (MPCA) for the opportunity to comment on the draft Supplemental Environmental Assessment Worksheet (SEAW) for Daley Farms of Lewiston, LLP 2018 Dairy Expansion.

IATP is a 33-year-old organization based in Minneapolis. We work at the local, state, national and international levels to create fair and sustainable agriculture and trade systems. IATP was born in response to the family farm crisis of the 1980s, and we continue to pursue policy solutions that benefit family farmers, rural communities and the environment. Minnesota, as one of the largest agricultural states in the country, has a critical role to play in setting the precedent for how state governments handle climate change and agriculture.

We envision an animal agriculture system that keeps small and mid-sized farmers on the land, sequesters carbon and protects water quality. However, agricultural consolidation has pushed dairy farmers off the land, resulting in mega-farms that concentrate profits in the hands of the few, emit potent greenhouse 1 gases methane and nitrous oxide and contaminate groundwater. Minnesota has an imperative to create an environment conducive to small and mid-sized dairy farmers raising animals in ways that protects the planet.

The Daley Farms expansion runs completely counter to the climate-friendly animal agriculture system that Minnesota needs. This proposal would expand one of the largest dairies in Minnesota by 3,000 cows to a total of 4,628 cows. This expansion would generate 46 million gallons of manure per year and make Daley Farms the 43rd largest greenhouse gas (GHG) emitter in the state, according to court documents filed by the Minnesota Center for Environmental Advocacy.

This expansion hinders Minnesota’s ability to meet the goals of the Next Generation Energy Act, which requires the state to reduce GHG emissions by 80% by 2050. It also violates the Minnesota Environmental Protection Act (MEPA), which says:

No state action significantly affecting the quality of the environment shall be allowed, nor shall any permit for natural resources management and development be granted, where such action or permit has caused or is likely to cause pollution, impairment, or destruction of the air, water, land or other natural resources located within the state, so long as there is a feasible and prudent alternative consistent with the reasonable requirements of the public health, safety, and welfare and the state's paramount concern for the protection of its air, water, land and other natural resources from pollution, impairment, or destruction. Economic considerations alone shall not justify such conduct.

We are commenting to urge the MPCA’s Environmental Review division to use its power to conduct environmental review as intended by the authors of MEPA. The SEAW for the proposed expansion of Daley Farms does not fully capture the operation’s environmental effects and underestimates its climate impacts. Furthermore, it does not consider the damaging impact of agricultural consolidation on the farm economy or adequately evaluate more climate-friendly methods of animal agriculture that also make farms more resilient to climate impacts. These oversights make it impossible for MPCA to fairly determine the significance of environmental effects from Daley Farms. We strongly urge MPCA to require an Environmental Impact Statement (EIS) for the Daley Farms expansion to fully measure its environmental impacts and outline alternatives. 


Read the comment in its entirety here