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The Institute for Agriculture and Trade Policy (IATP) thanks the Environmental Quality Board (EQB) for the opportunity to comment on the draft recommendations for integrating climate change information into Minnesota Environmental Policy Act (MEPA) program requirements.

IATP is a 35-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 climate.

The Environmental Protection Agency (EPA) reports that agriculture accounts for 10% of the country’s greenhouse gas (GHG) emissions, and a 2019 MPCA report says that agriculture accounts for approximately one-quarter of Minnesota’s GHG emissions. As one of the largest agricultural states in the country, Minnesota must take action to reduce agriculture’s climate footprint. The EQB’s effort to integrate climate change into environmental review is one of the first in the country and can set an important precedent for how state governments respond to agriculture’s contribution to the climate crisis.

We want to thank the EQB for this process and for putting forth these proposed changes to require all projects to consider climate change as part of Environmental Review. They are critical to guide state agencies and future climate policy in the state. And essential if the state is going to meet its climate goals.

Minnesota is missing the mark on the Next Generation Energy Act

Minnesota’s Next Generation Energy Act requires the state to reduce GHGs by 80% between 2005 and 2050. Minnesota missed the Act’s goal of a 15% reduction by 2015 and is far off-track from meeting the 2025 goal of reducing emissions by 30%. Since 2005, Minnesota’s emissions have only reduced 8%. Worse, emissions since 2016 actually have been increasing, signaling that strong and additional efforts are needed to reduce Minnesota’s GHG emissions.

While most other sectors, like electricity, are reducing emissions, agriculture and forestry emissions (the state combines the two) are flat and in recent years have risen. Agriculture is the highest source in the state of two potent GHGs, methane and nitrous oxide. In MPCA’s January report to the state legislature updating data on the state’s GHGs, the agency reported that since 2005 methane emissions from animal agriculture have increased 15% in the state, and nitrous oxide emissions related to both manure and synthetic fertilizer use have increased 12%. The MPCA reports that methane and nitrous oxide emissions sourced to feedlots, fertilizers linked to feed production, manure, manure soil application, ruminants and runoff all increased from 2005 to 2018. Much of this increase in emissions is linked to the state’s continued approval of permits for new and expanding feedlots.

Over the last several decades, Minnesota has seen significant losses in the number of pork, dairy and beef producers — even as the number of animals has increased. According to the latest USDA Agriculture Census, Minnesota lost 130 hog producers from 2012 to 2017, but the annual number of hogs produced in the state grew by 850,000. The state lost 16% of its dairy farms from 2016-2019, while dairy herd size grew 16% over the same period, according to the Minnesota Department of Agriculture (MDA). The shift toward large-scale confined operations has steadily reduced the number of farmers, while taking animals off pasture. Since 2012, Minnesota experienced a 27% loss of pasture land.

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