CONTACT: Bobby King, LSP, 612-722-6377, 507-450-7258 (cell)

11/23/05
SAINT PAUL, Minn.—Twenty-seven environmental and family farm groups are calling on Minnesota Gov. Tim Pawlenty to withdraw his proposal to significantly weaken the rules governing environmental review of the largest feedlots in the state.

“A healthy livestock industry and meaningful environmental protection are not incompatible. Weakening the rules for environmental review will harm Minnesota’s environment and is out of step with values important to Minnesotans,” wrote the coalition in a letter (see below) to Gov. Pawlenty.

The proposed rule change, which will be considered by the Environmental Quality Board (EQB) at a specially scheduled Dec. 9 meeting, would double the size feedlots can be before environmental review is required. The EQB will review the proposed rule and decide whether or not to begin the rulemaking process. The rulemaking process can require that the state defend the proposed change before an administrative law judge.

“Environmental review of the state’s largest feedlots is supported by the best science and by common sense,” said Bobby King of the Land Stewardship Project. “This proposal is driven by corporate special interests, not the interests of family farmers and rural residents. The Pawlenty administration wants to weaken the rules and bring more factory farms into Minnesota.”

Currently, environmental review is required for proposed feedlots that are 1,000 animal units or larger. This has affected only the largest 4 percent of feedlots in the state. One thousand animal units are equivalent to, for example, 3,333 hogs weighing between 55 and 300 pounds or 714 mature dairy cows. Eighty-three percent of the state’s livestock farms are less than 300 animal units, according to the Minnesota Department of Agriculture.

“Clearly, doubling the mandatory threshold from 1,000 to 2,000 animal units is not geared towards the needs of the many thousands of family livestock farmers in Minnesota, but rather the largest agribusiness interests,” wrote the groups.

The proposal to weaken the environmental review process was the result of recommendations from the Gov. Pawlenty’s Livestock Advisory Task Force.

The environmental review process, which is part of the Minnesota Environmental Policy Act, plays a unique and important role in safeguarding the state’s environment, according to the Generic Environmental Impact Statement (GEIS) on Animal Agriculture, the state’s most comprehensive science-based examination of the livestock industry. For example, because it assesses potential environmental harm before permits are issued, it allows for environmental harm to be avoided by identifying the need for alternative designs and locations. The environmental review process also gives citizens an effective means to contribute to the process via the public comment period and a public hearing, something often not available through the permitting process alone.

Despite the conclusions of the GEIS, the Minnesota Legislature weakened the environmental review process significantly in 2003 when they exempted most feedlots under 1,000 animal units in size from environmental review. Weakening the standards even further through the rulemaking process would pose a major threat to the state’s environment, say the environmental and family farm groups.

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The groups who signed onto the letter:
Land Stewardship Project, Mankato Area Environmentalists, Minnesota Center for Environmental Advocacy, Minnesota Lakes Association, Alliance for Sustainability, Clean Up the River Environment, Clean Water Action Alliance of Minnesota, CREED, Duluth Audubon Society, Friends of the Boundary Waters Wilderness, Institute for Local Self-Reliance, Institute for Agriculture & Trade Policy, Izaak Walton League of American-Midwest, Izaak Walton League of American-Minnesota Division, Audubon Minnesota, Environmental Association for Great Lakes Education, Mississippi Corridor Neighborhood Coalition, American Public Information on the Environment, Leech Lake Area Watershed Foundation, Minnesota COACT, Scenic Minnesota, League of Women Voters-Minnesota, Sweetwater Alliance, Environmental Justice Advocates of Minnesota, Southeastern Minnesotans for Environmental Protection, Carver County Concerned Citizens, Minnesota National Farmers Organization.

November 16, 2005

The Honorable Governor Tim Pawlenty
State Capitol-Room 130
75 Rev. Dr. Martin Luther King Jr. Blvd.
St. Paul, MN 55155-1606

Dear Gov. Pawlenty:
Minnesotans value clean air and water and democratic policies that allow citizens to play a meaningful role in protecting their environment. Minnesota’s Environmental Policy Act and the rules created to implement it reflect these key values and Minnesotans overwhelmingly oppose weakening them. However, your administration is proposing to dramatically weaken the standards for environmental review, which is at the heart of this environmental policy.

Despite its proven effectiveness and the broad public support for environmental review process, you have directed that the rules governing the environmental review of the largest feedlots in our state be dramatically weakened. As a result of recommendations created by your Livestock Advisory Task Force that you have endorsed, the Minnesota Department of Agriculture and Pollution Control Agency are drafting proposed rules to double the size feedlots can be before environmental review is required.

The environmental review process plays a critical and unique role in safeguarding Minnesota’s natural resources.

• Environmental review prevents environmental harm. Because it assesses potential environmental harm before permits are issued, it allows for environmental harm to be avoided by identifying the need for alternative designs or locations.

• Environmental review allows for meaningful citizen participation. Through the public comment period and a public hearing, citizens have an effective means to contribute to the process and to have concerns addressed. The permitting process often does not allow for meaningful public participation.

• Environmental review is comprehensive and so provides a forum for environmental issues that are not addressed in the permitting process.

• Environmental review provides a process for multi-disciplinary and multi-agency review of a proposed project. Environmental review allows state agencies not involved in the permitting to review and comment on projects. This allows for geologists, hydrologists, wildlife biologists and others to comment on a proposed development so that potential harm can be avoided.

Currently, mandatory environmental review of feedlots is required at 1,000 animal units and so applies only to the largest 4% of feedlots in our state. You are proposing to double the size to 2,000 animal units. As an example, 1,000 animal units are equivalent to 714 dairy cows. In Minnesota 96% of dairy farms are fewer than 280 animal units or 200 cows. Minnesota Department of Agriculture data shows that out of about 5,500 dairy farms in the state, only 14 are over 1,000 animal units. Clearly, doubling the mandatory threshold from 1,000 to 2,000 animal units is not geared towards the needs of the many thousands of family livestock farmers in Minnesota, but rather the largest agribusinesses interests.

The best science does not support this proposal. The Generic Environmental Impact Statement (GEIS) on Animal Agriculture is the most comprehensive look at the feedlot issue in our state and was created to serve as a comprehensive, science-based guide. The GEIS affirms the important role environmental review plays in avoiding environmental harm and the unique role it plays in aiding the permitting process. Despite the conclusions of the GEIS, our state’s environmental review policy has been substantially weakened through legislative action. Now, you are proposing to weaken it even further through the rulemaking process.

In contrast to the policy you are pursuing, family farm and environmental advocates have made it clear that the environmental review process needs to be strengthened. A healthy livestock industry and meaningful environmental protection are not incompatible. Weakening the rules for environmental review will harm Minnesota’s environment and is out of step with values important to Minnesotans. We request that you abandon this attempt to weaken one of Minnesota’s bedrock environmental policies.

Sincerely,

Land Stewardship Project
Mankato Area Environmentalists
Minnesota Center for Environmental Advocacy
Minnesota Lakes Association
Alliance for Sustainability
Clean Up the River Environment
Clean Water Action Alliance of Minnesota
CREED
Duluth Audubon Society
Friends of the Boundary Waters Wilderness
Institute for Local Self-Reliance
Institute for Agriculture & Trade Policy
Izaak Walton League of American-Midwest
Izaak Walton League of American-Minnesota Division
Audubon Minnesota
Environmental Association for Great Lakes Education
Mississippi Corridor Neighborhood Coalition
American Public Information on the Environment
Leech Lake Area Watershed Foundation
Minnesota COACT
Scenic Minnesota
League of Women Voters-Minnesota
Sweetwater Alliance
Environmental Justice Advocates of Minnesota
Southeastern Minnesotans for Environmental Protection
Carver County Concerned Citizens
Minnesota National Farmers Organization

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