IATP Comments on Minnesota Animal Feedlot Rule

Ben Lilliston

Jul 22, 2025

IATP submitted the following comments on July 21, 2025 to the Minnesota Pollution Control Agency on its proposed amendment to Minnesota Rules Chapter 7020 governing animal feedlots.

The Institute for Agriculture and Trade Policy (IATP) appreciates the opportunity to comment on the Minnesota Pollution Control Agency’s proposed amendment to Minnesota Rules Chapter 7020 governing animal feedlots.

It has been 25 years since Minnesota significantly revised the rules for animal feedlots and the massive amounts of manure they produce. As the MPCA acknowledges, much has changed since that time. Minnesota now has about 17,000 feedlots and those operations are getting far bigger and far more industrialized, storing much more manure in large waste facilities. We also have increased use of liquified manure systems that are leading to the over-application of manure on farmland and increasing the potential for runoff into waterways.

Our knowledge about how feedlots affect our water, climate, and public health has also improved. We have a better understanding of nitrate pollution and the number of impaired waters in the state.¹ Throughout the state, nitrogen loads in river systems are staying elevated or even increasing in some cases. Manure continues to be a major threat to water quality in the state. As the MPCA reports, the state is experiencing more extreme weather events that have affected the feedlot industry, including manure overflows.² The state has also seen a loss of small grains and accompanying grazing lands that could help improve water quality, even as the feedlot system has expanded.

According to a recent analysis by the Environmental Working Group, the state’s feedlots house up to 1.03 million dairy cattle, 1.6 million beef cattle, 10.8 million hogs and 58.7 million turkeys and chickens, which together produced over 48.9 million tons of manure that year. Many of the state’s feedlots are located near vulnerable groundwater areas. EWG found that almost 6,500 feedlots in the state are located in vulnerable areas.³

Facilities under 1,000 animal units do not need a water pollution permit under the EPA’s NPDES or the State Disposal System (SDS, just a construction permit. For that reason, many operators keep their animal unit numbers just below the 1,000-animal unit threshold to avoid having a water pollution permit. The EWG analysis found that 374 animal operations in the state had between 950 and 999 animal units in Minnesota in 2024. We applaud the MPCA for updating the feedlot rule. Given the enormous changes over the last 25 years, we encourage the MPCA to take significant steps to protect the state’s water and air. We recommend the following actions to strengthen the current feedlot rules.

The feedlot permit should lower the animal unit threshold for feedlots required to complete a NDS or SDS permit to 600 animal units. This simple step will greatly improve the effectiveness of the program by covering more feedlots.
The updated rule should include stronger limits on manure applications, including lowering manure application rates, best practice requirements for fall application, limits on winter application, and requirements for enough storage capacity to avoid winter application. These reforms are particularly needed in areas facing water quality problems such as the karst region and the central sands region.
Strong groundwater monitoring should be included in the permit. Permitted, large facilities should be required to monitor subsurface discharges, including where manure has been transferred to neighboring farms, to see how much nitrate ends up in water. There is currently no way to make sure these operations do not violate Minnesota’s water quality standards.
Require permitted feedlots to create a risk-assessment plan to monitor their manure storage areas and land application sites for above-ground discharges to ensure feedlots are not polluting lakes and rivers. Such risk assessment plans should incorporate climate risk, including expected extreme weather events.
The state should make more manure managing data and mapping available to the public, including information about anerobic digesters and manure spreading plans. Communities near feedlots deserve to understand the impact of manure on their nearby environment.
Feedlots that include anerobic digester plants producing digestate should be required to have a specific digestate application plan to mitigate the unique risks associated with digestate that include higher concentrations of nitrogen and phosphorous, and the potential for PFAS and other chemical contamination.
IATP has signed onto and strongly supports a comment submitted in collaboration with other organizations, including the Minnesota Center for Environmental Advocacy, calling for the MPCA to include the regulation of greenhouse gas emissions for large feedlots as part of an updated feedlot rule. This action for greater reporting on climate impacts and mitigation plans aligns with the current Environmental Quality Board’s Environmental Assessment Worksheet (EAW) and should include: monitoring and reporting provisions specific to GHG emissions; mitigation strategies to reduce emissions from manure management and livestock operations; and enforcement measures to ensure compliance with existing air emission plan requirements.

We hope the MPCA will consider the feedlot rule within the larger context of the climate crisis, increasing farmland consolidation and the loss of farmers in the state. New feedlot rules should be coupled with farmer-focused programs to support more sustainable, regenerative systems for raising animals that do not require the storage of mass quantities of manure.

Download a PDF with the full comments here.