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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 Environmental Assessment Worksheet (EAW) for Riverview’s proposed Waukon Dairy in Norman County. 
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 a precedent for how state governments respond to the climate crisis. 

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,1 resulting in mega-farms that concentrate profits in the hands of the few, emit potent greenhouse gases (GHGs) methane and nitrous oxide and contaminate waterways. Minnesota has an imperative to create an environment conducive to small and mid-sized dairy farmers raising animals in ways that protect the water and the planet.  

The EAW for the proposed Waukon Dairy does not fully capture the operation’s environmental effects and underestimates its climate impacts. It also does not consider the damaging impact of agricultural consolidation on the farm economy and rural communities or adequately evaluate more climate-friendly methods of animal agriculture that also make farms more resilient to climate impacts. Furthermore, a large hog operation (Barrick Farms) is being started in Norman County at the same time, and the combined environmental impact of these operations on water and the climate is not considered. These oversights make it impossible for MPCA to determine the significance of environmental effects fairly. We strongly urge MPCA to require an Environmental Impact Statement (EIS) for Waukon Dairy to measure fully its environmental impacts and outline alternatives. 

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