VYFA Response to MPCA Riverside EIS denial

Executive Comment

Riverview LLP West River Dairy Expansion

Request for Additional Environmental Review

To: Minnesota Pollution Control Agency, Minnesota Legislature, and Interested Public Officials

Subject: Request for a More Comprehensive Evaluation of Cumulative Environmental Effects

The Veterans & Young Farmers Alliance (VYFA) respectfully submits this comment as part of its ongoing work to strengthen America's family farms, protect watersheds and natural resources, support rural communities, and promote long-term agricultural resilience. Through its National Family Farm & Rural Management Strategy (NFRMS), VYFA advocates for science-informed, transparent decision-making that helps ensure agricultural growth is balanced with responsible stewardship of land, water, and community resources. Our interest is not to oppose agriculture, but to support sustainable agricultural development that protects both current and future generations of farmers.

The proposed Riverview LLP West River Dairy expansion represents one of the largest dairy expansion projects considered in Minnesota in recent years. Given its scale, the public deserves confidence that the environmental review fully evaluates not only the direct impacts of the project, but also its long-term cumulative effects on groundwater, surface water, watersheds, rural communities, and agricultural resources.

Minnesota Rule 4410 requires an Environmental Impact Statement (EIS) when a project has the potential for significant environmental effects. That determination should be based on the complete environmental record, including cumulative impacts and the effectiveness of proposed mitigation measures.

The MPCA's Findings of Fact acknowledge that the project will increase:

• Manure generation and land application

• Groundwater demand

• Air emissions associated with dairy operations

• Regional agricultural activity requiring regulatory oversight

The Findings then conclude that these impacts do not require an Environmental Impact Statement because they are expected to be managed through existing permits and regulatory programs.

This approach raises an important public policy question:

Does the existence of regulatory permits alone demonstrate that cumulative environmental impacts will remain below the threshold of significance?

For a project of this magnitude, many Minnesotans may reasonably expect additional analysis demonstrating:

• Watershed-scale cumulative nutrient loading

• Long-term groundwater sustainability

• Regional impacts from multiple large livestock facilities operating within the same landscape

• The effectiveness of mitigation measures under long-term operating conditions

Environmental permits are an important regulatory tool. However, permitting and environmental significance are not identical questions. Permits establish operating requirements; an Environmental Impact Statement evaluates whether a project's overall environmental consequences warrant deeper analysis before major decisions are finalized.

This comment does not argue that the project should automatically be denied. Rather, it asks whether the current record provides sufficient evidence to conclude that a project of this scale lacks the potential for significant environmental effects under Minnesota's environmental review laws.

VYFA believes that strong environmental stewardship and a strong agricultural economy are mutually reinforcing goals. Transparent, science-based environmental review helps protect water resources, supports responsible farm growth, strengthens public confidence in regulatory decisions, and preserves the long-term viability of family farms and rural communities. These principles are central to the National Family Farm & Rural Management Strategy (NFRMS), which promotes collaborative, watershed-based planning and sustainable resource management across the United States.

Given the scale of the proposed expansion and the importance of protecting Minnesota's water resources, family farms, rural communities, and agricultural economy, we respectfully request that the MPCA reconsider whether additional cumulative environmental analysis is warranted to ensure the decision is supported by a complete and robust administrative record.

Respectfully submitted,

Amy Tilley

Veterans & Young Farmers Alliance (VYFA)

National Family Farm & Rural Management Strategy (NFRMS)