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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 proposed 2021 General National Pollutant Discharge Elimination System (NPDES) Animal Feedlot Permit (referred to throughout this comment as the Proposed General Permit). 
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.  
As MPCA updates the Proposed General Permit, it’s imperative to consider the damaging impacts of Concentrated Animal Feeding Operations (CAFOs) on water quality. CAFOs contribute to nitrate contamination of waterways through runoff from land application of manure, leaching from manure that has been improperly spread on land, or through manure lagoon leaks or breaks. In the southwestern region of the state, about 20% of the monitored wells have nitrate concentrations higher than the EPA allows for drinking water. Across southern Minnesota, most of the sand and gravel aquifers have nitrate concentrations that exceed EPA guidelines for human health. And 27% of surface water in the state has nitrate levels that exceed EPA guidelines. Much of this comes from agriculture. 
The Proposed General Permit states that its goal is “to reduce pollutant levels in point source discharges and protect water quality in accordance with the U.S. Clean Water Act, Minnesota statutes and rules, and federal laws and regulations.” Yet, Minnesota’s nitrate contamination increased under the previous 2016 General Permit. Although the Proposed General Permit includes requirements to address nitrate leaching, they are not stringent enough to adequately address the increasing nitrate contamination of Minnesota’s waterways for the reasons outlined in this comment. 
Farmers are facing the most difficult farm economy since the 1980s. Increases in farm debt, bankruptcies and land values have far outstripped farm assets and income, making it more and more difficult for farmers to hold on to their land. According to data from the Minnesota Department of Agriculture, the state lost over 300 dairy farms in 2019 for the second year in a row. Much of this is a result of agricultural consolidation, which is putting many farmers out of business. 
The financial stress caused by agricultural consolidation is most acute for small to midsized farms — the exact type of farm needed to build a resilient agricultural system. As CAFOs have increased production, prices paid to farmers have plummeted, often below the cost of production. Across the country and in Minnesota, small and mid-sized farms are struggling to operate with little to no farm income, often wiping out their savings and credit to stay in business, if they’re able to stay in business at all. Increasing and expanding CAFOs in Minnesota will worsen the agricultural consolidation that is driving small and mid-sized farmers out of business. 
MPCA should ensure an appropriately stringent permitting process for CAFOs. Not only are they harmful to the environment and our state’s water resources, they are also undercutting the small and mid-sized farmers that we need on the land to restore our water resources, combat climate change, steward our land and support our rural communities. MPCA must include these considerations within the updated Proposed General Permit. 

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