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Project title and location
Environmental Results Program Applied to Feedlots

Applicant agency
Minnesota Pollution Control Agency

Project contact
Pat Mader; Regional Environmental Management Division; Minnesota Pollution Control Agency; 520 Lafayette Road North; St. Paul, MN 55155; Phone: (651) 297-7570; Fax: (651) 282-6247; Email: pat.mader@pca.state.mn.us

Required responses
The project has no relation to RCRA permitting.

Part of MPCA's Pollution Prevention Incentives for States grant will support the project.

The project requires no federal program approval or flexibility.

Commissioner Endorsement
MPCA Commissioner XXX is aware of, endorses, and supports this project.

Project Summary
This project would test and implement an Environmental Results Program (ERP) approach modeled by other states for feedlots that fall below the federal definition (roughly 29,000 entities in Minnesota), seeking improved environmental performance and compliance.

MPCA is implementing new feedlot rules, which include permits, registrations, and inspections of over 29,000 feedlots statewide. At existing rates of inspection (given tight state and county budgets), estimated time to reach all feedlots would be greater than 10 years. Self-certification and other ERP tools should help feedlots improve environmental performance and compliance in a more timely way, and without the typical level of MPCA and county effort. Partnership with University of Minnesota Extension Service and producer associations will aid development and distribution of the program. ERP-tested statistical tools will help MPCA draw conclusions about compliance rates in various feedlot sectors, and will guide targeting of compliance assistance and inspections.

The project will be split into three phases (correlating with the goals presented pages 3-5), with the results of each phase influencing the design and implementation of subsequent phases. Products would include self certification tools, guidance to complete self certification, statistical tools to track industry performance and sector compliance, and evaluation of at least 100 pilot site certifications within 3 years.

Should Minnesota be successful in applying the ERP approach to feedlots, this project could serve as a model to other states also working to improve the compliance and performance status of non-federal feedlots.

Project Narrative
This project would test and implement an Environmental Results Program approach for feedlots that fall below the federal definition, with a special focus on preventive and whole-farm Best Management Practices and management systems . Recognizing quality assurance and Farm Bill audit reimbursement leverage and producer association interest, MPCA projects that the feedlot sector most conducive for the test is dairy. A secondary sector could be swine, either as a stand-alone or integrated with the dairy sector, since many dairy farmers will add swine for cash flow.

This experiment relates to EPA's Environmental Innovation Strategy in several ways. First, it borrows from ERP experiences in other states (supported by EPA) as well as innovative approaches to animal agriculture environmental improvement being used in other states and in Minnesota, in partnership with producer associations and various rural governmental and non-governmental organizations. Second, the project deals with a priority environmental issue for both Minnesota and EPA: restoring the environmental quality of impaired surface and ground water and preventing future impairments. Third, the project demonstrates a focus on results by improving water quality using new environmental tools (self-certifications, farm management systems, and statistical assessment of sub-sector performance) and partnerships to obtain water quality protection sooner than could be obtained with conventional regulatory tools and current resources.

The probable focus on dairy in the experimental phases of this project would lead to applications in other species sub-sectors, so that within 5 years, MPCA would have a much better picture of performance and compliance rates across all 29,000 non-federal feedlots. This picture would guide MPCA and delegated Minnesota counties in their targeting of environmental improvement resources. In addition, this first in-state experience with ERP and its tools will undoubtedly lead to adaptation in other economic sectors besides animal agriculture, such as priority sectors within manufacturing.

ERP is a regulatory program that has seen use in sectors with numerous small facilities in several states that have typically be relatively unregulated (auto body shops, junkyards, photo processors, dry cleaners, printers). MPCA is unaware of other states using the ERP tools in animal agriculture. However, we are convinced that their adaptation is feasible and offers the environmental benefits mentioned above. The Commissioner supports the project because of its close connection to the Governor's water quality improvement initiative, much of which relies on public-private partnerships as illustrated by the feedlot ERP proposal. We have strong program manager-level support, which has translated into discussion and support from the Minnesota Milk Producers Association, high-intensity dairy counties, and internally with key feedlot staff. Two other large animal agriculture associations in the state (swine and egg producers) have been involved in innovative quality or management system-driven initiatives with environmental benefit, and a third (poultry) is in a high state of readiness for similar efforts. This tells us that success piloted in dairy will feasibly translate to use of ERP approaches in those feedlot sectors as well. MPCA is highly motivated to pursue the maximum penetration of ERP across animal agriculture sectors as a key tool in dealing with the sheer numbers of feedlot facilities.

While non-federal feedlots do not require the same level of permitting as do those over 1000 Animal Units, under recent Minnesota rules most of them do require registration and compliance with technical standards. Part of the discussion with stakeholders under this project will deal with the integration or possible substitution of the ERP self-audits and annual self-certifications for interim permits; permits issued to bring a facility back into compliance. One way value will be added is by extending the basic water quality protection and land application management aspects of the feedlot rule to deal with odors, dusts, pests, ancillary and maintenance operations, related feed crop production, and many other aspects of operations, pushing toward a multi-media, "whole-farm" management system.

MPCA requires permits of non-federal feedlot facilities that are found to be out of compliance with state requirements. These permits are interim permits wherein the facility must demonstrate conformance with state requirements. This project may replace these permits with ERP Return-to-Compliance (RTC) Plans. The extent of permits replaced by the project is difficult to estimate since MPCA has not yet inspected all 29,000 feedlot in the state. Also, should this project be successful, MPCA could enhance the current feedlot registration process through rulemaking to include (at least for some size facilities) the ERP self-audits and certifications every four years. Initial discussions with producer stakeholders have held open the possibility of a subsequent rulemaking.

Recognizing that the stakeholder process involved may alter them somewhat in the course of the project, goals, objectives, activities, milestones, and possible measures for the project include:

Understand and communicate the universe of state and federal feedlots in Minnesota and their compliance/performance vectors over time

OBJECTIVE 1: Maximize quality, and completeness of MPCA's feedlot database

ACTIVITIES: Since much of the data required is in place at MPCA, this requires reaching out to the partner organizations and updating based on their recent contact. Some fieldwork in targeted counties may also be necessary to verify data.

MILESTONE 1: Cooperative contact and agreed sharing process established

MILESTONE 2: Exchange and integration of data

MEASURE: Integration of county, MN Department of Agriculture, Minnesota Milk Producer, and audited feedlots databases into MPCA's with single facility identifier, producing, management, and compliance (if known) characteristics

TIMELINE: January-June 2004 (will begin prior to receiving any grant funds; updated thereafter)

OBJECTIVE 2 : Develop hard copy and electronic self-certification annual submittal system and integrate inspection data

ACTIVITIES: Develop self-certification (see Goal 2 below) with the purpose of enabling its electronic submittal; adopt electronic signature and internet-based exchange capability being developed by MPCA under other pilot projects

MILESTONE 1: Electronic self-certification form and web availability

MILESTONE 2: Submittals tested, de-bugged and operational

MEASURE: System operational and functional to users within timeline

TIMELINE: June 2004 - June 2005

Maximize leverage through partnerships

OBJECTIVE : Strengthen producer (association) partnerships through project planning and implementation

ACTIVITIES: Involve the Minnesota Milk Producers association contact, representative producers, state dairy inspectors and producer association auditors in project planning, setting geographic targets, defining compliance goals, developing species-specific guidance and self-certification documents

MILESTONE 1: Project work plan developed

MILESTONE 2: Compliance and performance goals and measures developed

MILESTONE 3: Guidance and self-certifications complete

MEASURES: Producer association involvement and value-added; products complete and bought-into

TIMELINE: January-September 2004 (will begin prior to any receiving any grant funds, but production of guidance and self-certification and field-testing would proceed with grant funds)

Test the ERP methodology in the field to determine effectiveness of self-certification process

OBJECTIVE 1 : Determine baseline conditions

ACTIVITIES: Prepare inspector guidance based upon sector certification statement requirements, performance indicators, and compliance requirements; train field staff on how to use the guidance to conduct the baseline inspections; conduct baseline inspections/audits of dairy operations in priority counties (including state, county and association participants, as determined); determine baseline rates of compliance as defined by compliance goal-setting; determine baseline rates of multi-media BMP adoption

MILESTONE 1: Inspector guidance and training for baseline inspections completed

MILESTONE 2: Statistically significant number of facilities to set a sector baseline determined

MILESTONE 3: Assuming roughly 30-50 such inspections, at least this number of baseline inspections completed

MILESTONE 4: Compliance determination and baseline performance levels set

MILESTONE 5: Baseline compliance rate based on sample inspections set for entire dairy sector; targets for improvement set, guidance updated, and compliance assistance provided

TIMELINE: September 2004 - June 2005

OBJECTIVE 2 : Operate facility self-certification cycle

ACTIVITIES: Assist roughly 100 facilities to complete certification statements using the workbook prepared for the sector; support facilities in submitting applicability statements, certifications and return-to-compliance plans electronically to the MPCA

MILESTONE 1: Notification to dairy sector regarding pilot ERP program mailed (during the pilot stage response is voluntary)

MILESTONE 2: Workshops in dairy areas to assist facilities in understanding ERP requirements and processes completed

MILESTONE 3: Data from dairies received and data from the certifications entered into the database for analysis (applicability, performance indicators, compliance rates, etc.)

MILESTONE 4: Certification data for evasion (non-filers) and fraud analyzed and baseline sector results prepared

TIMELINE: October 2005 - January 2006

OBJECTIVE 3 : F ollow-up inspections/assessments with all baseline facilities to gauge effectiveness of process, program materials and services in attaining compliance and multi-media performance goals

MILESTONE 1: Statistically significant number of follow-up facilities determined

MILESTONE 2: Follow-up inspections completed

MILESTONE 3: Completed comparison of inspector compliance determinations to self-certifications submitted

MILESTONE 4: Assessment of multi-media performance enhancements

MILESTONE 5: Determination of extension of the project

TIMELINE: January 2006 - September 2006

MEASURES: Number of facilities self audited vs. inspected; accuracy of self-audits and certifications; number (percentage) of participating facilities with signed certification statements; number of electronic submittals, number (percentage) of farmers adopting recommended manure and nutrient management practices; number (percentage) of facilities with approved manure management plans; pounds of phosphorus and nitrogen properly applied; pounds of phosphorus and nitrogen eliminated from direct discharge to surface water from open lots, reduction in fecal coliform discharge to surface waters, use and results of soil testing and other tools; other preventive, whole-farm techniques adopted; human resource efficiency of the approach.

Meeting program criteria requirements

  1. The proposed project demonstrates an innovation used in other states and supported by EPA (ERP), but applies it in an experimental sense to a sector in which it has not yet been deployed. As such, MPCA will be researching the applicability of ERP in this new area, gathering data on metrics for environmental improvement, compliance, and resource efficiency, applying this learning to other feedlot sectors and (eventually) economic sectors, and disseminating the results of the experiment via web and reports to citizens, state and national agencies, and NGOs.
  2. The focus of the project proposal is on techniques for preventing surface and ground water contamination at the source. However, to the extent a "whole farm" or integrated management approach can be expressed in the program materials and promoted in the field by staff and partners, this project will be multi-media. MPCA expects to leverage EMS-like approaches (including auditing) already being used by producers or promoted by their associations.
  3. Target priority environmental issues - Measures will get at how the project/program got producers to environmental improvement sooner than the existing alternatives, and encouraged improvement in impacts and farm management systems beyond the primary (and priority) area of water quality protection. To the extent that the project develops as an alternative or supplement to the existing interim permitting process (the existing state permitting minimum for small feedlots), the project will constitute an innovation in permitting which the feedlot program will integrate and carry forward.
  4. Likely improvement in results from project implementation
    • Differ from current methods - MPCA expects that participating feedlots will self-audit for compliance and adopt environmental improvement techniques for more areas of the farmstead and sooner than under a conventional inspection program. In addition, the association should be motivated to promote the ERP program more effectively than MPCA could on its own.
    • Build on "lessons learned" - Clearly, MPCA is adopting a process used and evolved successfully in other states. We also will be building on the work of producer associations and public/private pilots in Minnesota and other farm states, leveraging quality assurance programs, Farm Bill audit incentives, and EMS/auditing-based approaches promoted by producer associations.
    • Quantifiable environmental improvements - self-corrections for compliance, feed and supplement BMPs, soil-tested nutrients levels, nutrient management plans (both on-farm and at application sites), energy use reduced, water conserved, amounts composted, riparian buffers installed, drain tile inlets capped, etc. These measures will be developed further in the first phases of the project.
    • Improved administrative efficiency - MPCA and delegated counties fully expect to have their existing level of effort leveraged (at least by a factor of two, although this will be the subject of research) by producer associations and participating producers in the course of the project. The resource savings would escalate as the pilot is extended to other feedlot sectors.
    • Costs and efficiency improvements for producers - On a quicker basis than otherwise possible, participating producers should realize energy and water use cost reductions, soil loss, nutrient supplement reductions for animals and feed crops, and so on, and the net present value of completing compliance and environmental improvements sooner as opposed to in the future.
  5. Measuring improvement and accountability
    • Information on the project will be made available through reports, web pages, conferences, and trainings. All project participant performance data will be available to surrounding communities via the web page and local distribution.
    • Timeline for achievable results - As was mentioned earlier in this document, MPCA plans to begin work in January 2004, with baseline inspections complete by June 2005. Follow-up inspections, results analysis, and plans for extension to other sectors would be complete by September 2006.
    • Goals for environmental improvement - Mentioned elsewhere in more detail.
    • Indicators of environmental improvement - Mentioned elsewhere in more detail, although final measures will depend on the result of stakeholder discussions and what aspects of operations participating producers will agree to measure.
    • Baseline measurements - Stakeholder discussions will set compliance and performance goals; subsequent inspections will measure status against those compliance and performance goals and practices. Baseline inspections will be complete by June 2005.
    • Plan, timeline, and commitment for project evaluation - Agreed-upon goals and measures will receive baseline and follow-up data by early 2006, at which point final analysis of the project will take place, draft conclusions discussed with stakeholders including EPA, and final results distributed by September 2006.
    • Results expected within one to three years and how measured - Mentioned elsewhere in more detail.
    • Long-term results (three years plus) - These are difficult to project at this point, but if the results of the experiment warrant expansion into other feedlot sectors, than similar results could be expected based on species-specific goals and measures, and the size and readiness of those other sectors.
  6. Transferring Innovation
    • MPCA will use its feedlot database to assimilate all data gathered as a result of the project, will demonstrate that database to interested jurisdictions, and will make performance and project data available through public distribution.
    • MPCA expects eventual widespread participation with the ERP approach, across feedlot sectors. In addition, we believe other farm states with numerous animal agriculture operations will find the experience useful.
    • The feedlot ERP project will fundamentally change how MPCA and counties approach feedlot compliance, and more importantly, identification and targeting of resources towards under-performing sectors or locations. Feedlot ERP can be deployed to support priority TMDLs, as well. Finally, MPCA expects that this initial use of ERP within the agency and the state will diffuse to other sectors in manufacturing and commerce.
    • MPCA (on behalf of participating counties) will commit to provide consultation and mentoring to other States wishing to adopt a feedlot ERP approach.

Budget Summary

[Budgetary Information Withheld by U.S. EPA]

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