July 2024

The Minnesota Pollution Control Agency is asking for public comment to proposed changes to feedlot general permits issued to large feedlots of 1,000 or more animal units for operation and construction. Minnesota Trout Unlimited supports the much-needed additional oversight and regulations included of applications of manure to the land. Manure being washed off the land by rainfall is the likely cause of recent fish kills in southeast Minnesota and is a serious threat to water quality and trout populations. Effective manure management is critical to maintaining healthy coldwater fisheries.

Revisions to these two waters permits for industrial-scale feedlots include changes for different times of the year and locations, specifically for vulnerable groundwater areas, including the coldwater trout stream abundant Driftless region of our state. This is of particular importance because this unique area is dominated by features such as sinkholes, disappearing streams, springs, and steep slopes that enable surface water runoff to quickly enter groundwater and streams. 

The permit changes beginning in 2028 require that in the Karst region there is no winter application of manure and in October or November, land applications of manure must:

(1) apply to growing crop,

(2) plant a cover crop within 14 days, or

(3) include a perennial crop for 2 of 5 years

These requirements are common sense and overdue.

We commend the MPCA for including restrictions on application of manure in a floodplain as a permit change, as it is a recommendation included in the recent Legislative Report on Preventing fish kills in Minnesota’s Driftless region.

Even modest rainfall events can wash manure applied to the land into streams and underground waterways.  For this reason, these proposed visual inspection requirements of land application areas are critical: inspect 1x per day during application, inspect at the end of the workday, and inspect any time there’s a half-inch rainfall within 14 days of application.  A water sampling requirement is also proposed.  If a Concentrated Animal Feeding Operation (CAFO) does discharge liquid manure, either because of a spill or a rain event or other reason, the operator must take water samples to determine the extent of the pollution.

While these revisions are important, there are some lingering questions to how these new requirements will be adequately enforced and monitored, and if there will be required training on water sampling and testing protocol for feedlot operators. MNTU feels there is urgency in addressing groundwater contamination with even more ambitious revisions.

MNTU feels it is important these restrictions on manure application be required of all 17,000 feedlots in Minnesota, not just the 1,000 largest with 1,000 animal units or more.

Finally, as the ongoing flooding throughout Minnesota demonstrates, extreme rainfall events caused by climate change are becoming common.  These events too often lead to runoff of improperly managed manure to our waterways. In May there were manure pit overflows reported at 17 sites on large farms in Southern Minnesota. More stringent rules preventing application of manure when rainfall is forecasted are critical to ensure the quality of the water in our streams and lakes, and the health of trout and aquatic organisms that live in these waters. 

The MPCA is accepting comments on the permit revisions through September 3, 2024 and we will be developing our own comments. We encourage individuals to submit comments as well that include why you, as an angler, think the recommended changes are important, as well as why they should apply to all feedlots. If you’re interested in writing your own opinion piece to submit to a local paper or share on our blog, please contact Kristen Poppleton.

Read more about the threats of Feedlots and Nitrates.