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Notice of Availability of an Environmental Assessment

Worksheet (EAW) Forsman Farms - Litchfield Farm

Doc Type: Public Notice

Public comment information

EAW public comment period begins: May 11, 2020

EAW public comment period ends: June 10, 2020

Notice published in the EQB Monitor: May 11, 2020

Permit public comment period begins: May 11, 2020

Permit public comment period ends: June 10, 2020

Facility specific information

Facility name and location:

Forsman Farms - Litchfield Farm Section: 15 Township: 120N Range: 31W Meeker County, Minnesota

Facility contact:

Forsman Farms, Inc. Nate Taylor, Director of Risk Management & Business Development 1200 Commerce Blvd Howard Lake, MN 55349 Phone: 320-286-5905 Email: ntaylor@forsmanfarms.com

MPCA contact information

MPCA EAW contact person: MPCA Permit contact person:

Jenna Ness

Resource Management and Assistance Division

Minnesota Pollution Control Agency

520 Lafayette Road North

St. Paul, MN 55155

Phone: 651-757-2276

Email: jenna.ness@state.mn.us

Admin staff phone: 651-757-2100

Dana Leibfried West Feedlot Unit, Watershed Division Minnesota Pollution Control Agency 504 Fairgrounds Road, Suite 200 Marshall, MN 56258 Phone: 507-421-7648 Email; Dana.leibfried@state.mn.us

General information

The Minnesota Pollution Control Agency (MPCA) is distributing this Environmental Assessment Worksheet (EAW) for a 30-day review and comment period pursuant to the Environmental Quality Board (EQB) rules. The MPCA uses the EAW and any comments received to evaluate the potential for significant environmental effects from the project and decide on the need for an Environmental Impact Statement (EIS).

An electronic version of the EAW is available on the MPCA Environmental Review webpage at https://www.pca.state.mn.us/eaw. If you would like a copy of the EAW or NPDES permit, have any questions on the EAW or NPDES permit, contact the appropriate person(s)

Description of proposed project

Forsman Farms, Inc. proposes to construct and operate a new 4,950 animal unit poultry feedlot (1,650,000 head) in Section 15 of Harvey Township, Meeker County. The construction will include five power ventilated total confinement poultry barns, a manure storage building, a pelletizing building, an egg packing plant, permanent stormwater basins, and 10 water supply wells.

http://www.pca.state.mn.us/mailto:jenna.ness@state.mn.usmailto:Dana.leibfried@state.mn.ushttps://www.pca.state.mn.us/eaw

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To submit written comments on the EAW and NPDES Permit

Written comments on the EAW must be received by the MPCA EAW contact person within the comment period listed above. For information on how to comment on the NPDES Permit, contact the person listed above.

NOTE: All comment letters are public documents and will be part of the official public record for this project.

Need for an EIS

The MPCA Commissioner will make a final decision on the need for an EIS after the end of the comment period.

http://www.pca.state.mn.us/

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Alternative EAW Form for Animal Feedlots

ENVIRONMENTAL ASSESSMENT WORKSHEET

Note to preparers: This form is authorized for use only for the preparation of Environmental Assessment Worksheets (EAWs) for animal feedlots. Project Proposers should consult the guidance Guidelines for Alternative EAW Form for Animal Feedlots (also available at the Minnesota Environmental Quality Board (EQB) website http://www.eqb.state.mn.us/review.html or by calling 651-201-2476) regarding how to supply information needed by the Responsible Government Unit (RGU) to complete the worksheet form. Note to reviewers: The Environmental Assessment Worksheet (EAW) provides information about a Project that may have the potential for significant environmental effects. This EAW was prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU), to determine whether an Environmental Impact Statement (EIS) should be prepared. The Project Proposer supplied reasonably accessible data for, but did not complete the final worksheet. Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor. Comments on the EAW should address the accuracy and completeness of information, potential impacts that are reasonably expected to occur that warrant further investigation, and the need for an EIS. A copy of the EAW may be obtained from the MPCA by calling 651-757-2101. An electronic version of the completed EAW is available at the MPCA website http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Basic Project Information.

A. Feedlot Name:

Forsman Farms - Litchfield Farm

B.

Feedlot Proposer:

Forsman Farms, Inc.

C.

RGU:

Minnesota Pollution Control Agency

Technical

Contact Person

Nate Taylor

Contact Person

Jenna Ness

and Title

Director of Risk Management & Business Development

and Title Project Manager

Environmental Review Unit

Address 1200 Commerce Blvd. Address 520 Lafayette Road North

Howard Lake, MN 55349 St. Paul, MN 55155-4194

Phone 320-286-5905 Phone 651-757-2276

Fax 320-286-5935 Fax

E-mail ntaylor@forsmanfarms.com E-mail jenna.ness@state.mn.us

D. Reason for EAW Preparation: (check one)

EIS

Scoping

Mandatory EAW

X

Citizen Petition

RGU Discretion

Proposer Volunteered

http://www.eqb.state.mn.us/review.htmlhttp://www.pca.state.mn.us/news/eaw/index.html#open-eawmailto:ntaylor@forsmanfarms.commailto:jenna.ness@state.mn.us

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If EAW or EIS is mandatory, give EQB rule category subpart number and name:

Minnesota Rules 4410.4300 Subpart 29 (A)

E. Project Location: County Meeker City/Twp Harvey Township

1/4 East 1/2 Section 15 Township 120N Range 31W

Watershed (name and 4-digit code):

North Fork Crow River : Major (07010204)

F. Attach each of the following to the EAW:

Figure 1: Project Location Map Figure 2: USGS Topographic Map Figure 3: Site Plan Map Figure 4: One Mile Radius Map Figure 5: Meeker County Soil Survey Map Figure 6: Wetland Delineation Map Figure 7: Cumulative Potential Effects Map Figure 8: Groundwater Pollution Sensitivity Map Exhibit A: State Historical Preservation Office (SHPO) Correspondence Exhibit B: Minnesota Department of Natural Resources (DNR) Natural Heritage Database Review

Correspondence Exhibit C: Minnesota DNR Preliminary Well Assessment Exhibit D: Wetland Conservation Act Notice of Decision Exhibit E: Air Quality Modeling Report Exhibit F: Animal Feedlot Permit Application The National Pollutant Discharge Elimination System Concentrated Animal Feeding Operation Permit (Feedlot Permit) application and associated documents, including the Animal Feedlot Operation and Maintenance Plan, Manure Management Plan, Air Emissions Plan, Animal Mortality Plan, and Emergency Response Plan, are available for review by contacting Dana Leibfried of the MPCA’s Marshall Office at dana.leibfried@state.mn.us.

G. Project summary of 50 words or less to be published in the EQB Monitor.

Forsman Farms, Inc. proposes to construct and operate a new 4,950 animal unit poultry feedlot (1,650,000 head) in Section 15 of Harvey Township, Meeker County. The construction will include five power ventilated total confinement poultry barns, a manure storage building, a pelletizing building, an egg packing plant, permanent stormwater basins, and 10 water supply wells.

H. Please check all boxes that apply and fill in requested data:

Animal Type Number Proposed Type of Confinement

Finishing swine

Sows

Nursery pigs

Dairy cows

Beef cattle

Turkeys

Layer Hens 1,320,000 head Total confinement in barns

Chickens

Pullets 330,000 head Total confinement in barns

Other (Please identify species)

mailto:dana.leibfried@state.mn.us

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I. Project magnitude data.

Total acreage of farm: 81.2 Acres

Number of animal units proposed in this Project: 4,950 Total animal unit capacity at this location after Project construction: 4,950 Acreage required for manure application: ~2.5 tons/acre or 6,400 total acres

J. Describe construction methods and timing.

Forsman Farms, Inc. (Forsman) proposes to construct and operate a new poultry feedlot in Section 15 of Harvey Township in Meeker County as outlined in Figures 1 and 2 (Project). The Project will house up to 330,000 pullets and 1.32 million layer hens, totaling 4,950 animal units (AU)1. The four layer barns will include 333,000 hens each, divided into two houses in each barn. Construction of the Project consists of the following:

Four Layer Barns (672’ x 196’ each)

One Pullet Barn (576’ x 196’)

One Dry Manure Storage Building (307’ x 160’)

One Pelletizing Building (90’ x 30’)

One Egg Packing Plant (280’ x 80’)

One Backup Generator Shed (60’ x 40’)

One Electrical Service Shed (40’ x 18’)

Two permanent stormwater basins and drainage swales (combined storage capacity of 3.6 million gallons)

Ten water wells for livestock (annual pumping capacity of up to 25 million gallons total)

Because the feedlot will house greater than 1,000 AUs, Forsman will obtain a Feedlot Permit. A separate National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Construction Stormwater General Permit (CSW Permit) is not required because the requirements are incorporated in, and enforced through, the Feedlot Permit.

Construction phasing will begin with the installation of sediment control best management practices (BMPs) prior to initiating general site grading and interior road construction. These will include a silt fence and rock construction entrance. Forsman will install BMPs for erosion prevention by utilizing check dams, erosion blankets, and rip rap. Constructing a temporary sediment basin is also required. Forsman will maintain BMPs for the duration of all activities that disturb land until post-construction stabilization. Forsman will construct all of the buildings with pole frames and painted steel siding. Construction will start with the pullet building, packing plant, and manure storage building. Construction of the layer barns will follow, designed with a tiered cage, manure belt conveyor, and integrated dry manure storage system. The barns’ belt conveyor design will continuously capture manure on multiple belts and dry it as it automatically moves through the barns towards the offloading end. The pullet barn is designed to operate in a similar fashion, except that manual removal of manure to the manure drying chamber is required multiple times a week.

1 An “animal unit” or “AU” is a unit of measure developed to compare the differences in production of manure by livestock species. The “AU” is standardized to the amount of manure produced on a regular basis by a slaughter steer or heifer. This is calculated by multiplying the number of animals of each type in Minn. R. 7020.0250, subp. 5 by their multiplication factor and summing the values for the total number of animal units. The “AU” is used for administrative purposes by governmental entities for various permitting and recordkeeping regulations.

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Ten new wells (one primary and one backup) will be drilled for the Project site, two for each barn; five barns total (one pullet and four layer barns). They will be spaced evenly to the north and south approximately 100 feet east of the buildings (Figure 3). All wells are intended to be approximately 200 feet deep. Forsman plans to begin construction in 2020 once they obtain applicable permits. Operations can begin in the spring of 2021 barring any setbacks. Forsman’s actual construction dates are dependent on completion of the environmental review process, issuance of the Minnesota Department of Natural Resources (DNR) Water Appropriation Permit, MPCA Feedlot Permit, and applicable local permits (e.g. Conditional Use Permit, Building Permit, Grading Permit, etc.).

K. Past and future stages. Is this Project an expansion or addition to an existing feedlot? Yes No Are future expansions of this feedlot planned or likely? Yes No If either question is answered yes, briefly describe the existing feedlot (species, number of

animals and animal units, and type of operation) and any past environmental review or the anticipated expansion.

There are no planned expansions or additions for the Project in the future. Therefore, the Project will not result in a phased action.

2. Land uses and noteworthy resources in proximity to the site.

A. Adjacent land uses. Describe the uses of adjacent lands and give the distances and directions to nearby residences, schools, daycare facilities, senior citizen housing, places of worship, and other places accessible to the public (including roads) within one mile of the feedlot and within or adjacent to the boundaries of the manure application sites.

The Project is in Harvey Township, Meeker County, Minnesota. Meeker County is in central Minnesota and is primarily rural. Most of the land in the unincorporated areas of the County are in agricultural production. Permitted uses in the Harvey Township Agricultural District include, but are not limited to, feedlots, feedlot expansions, and level 1 home occupation. Zoning for the Project area and the surrounding area is considered General Agricultural District2, which complies with the Meeker County Comprehensive Plan and Zoning Ordinance3. According to the Meeker County Feedlot Ordinance, any feedlot containing 50 AUs or more outside a shoreline district requires an animal Feedlot Permit. Any proposed feedlot also requires a Meeker County Conditional Use Permit if the capacity is 300 or more AUs. The nearest incorporated towns (Litchfield and Forest City, Minnesota) are approximately 4 miles south and 4 miles east of the Project, respectively. There are currently 17 rural residences within 1 mile of the Project (Figure 4). The closest adjacent residences to the Project are:

Three residences 0.25 to 0.29 miles (1,319 to 1,545 feet) southwest

Residence 0.23 miles (1,194 feet) southeast

Residence 0.28 miles (1,474 feet) north

Residence 0.39 miles (2,066 feet) northwest

Two residences 0.43 and 0.47 miles (2,294 and 2,494 feet) northeast

2 https://www.co.meeker.mn.us/DocumentCenter/View/3124/Comprehensice-Land-Use-Plan--Future-Land-Use-Map-9Apdf 3 Meeker County Zoning Ordinances. Available Online at: https://www.co.meeker.mn.us/DocumentCenter/View/2719/Meeker-County-Land-Development-Ordinances-PDF

https://www.co.meeker.mn.us/DocumentCenter/View/3124/Comprehensice-Land-Use-Plan--Future-Land-Use-Map-9Apdfhttps://www.co.meeker.mn.us/DocumentCenter/View/2719/Meeker-County-Land-Development-Ordinances-PDF

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There are no known schools, daycare facilities, senior citizen housing units, or places of worship within 1 mile of the Project. Several public roads are within 1 mile, including:

Minnesota Trunk Highway 22 to the east

County State Aid Highway (CSAH) 16 (320th Street) to the north

310th Street to the south

600th Avenue to the northwest

615th Avenue to the northeast

Discussion of manure application sites is not included because manure will be dried, pelletized, and sold to a third party as fertilizer. Ownership of manure will be 100% transferred to the third party.

B. Compatibility with plans and land use regulations. Is the Project subject to any of the following adopted plans or ordinances? Check all that apply:

Local comprehensive plan Land use plan or ordinance Shoreland zoning ordinance Flood plain ordinance Wild or scenic river land use district ordinance Local wellhead protection plan

Is there anything about the proposed feedlot that is not consistent with any provision of any ordinance or plan checked? Yes No.

If yes, describe the inconsistency and how it will be resolved.

Are there any lands in proximity to the feedlot that are officially planned for or zoned for future uses that might be incompatible with a feedlot (such as residential development)? Yes No

If yes, describe the potentially affected use and its location relative to the feedlot, its anticipated development schedule, and any plans to avoid or minimize potential conflicts with the feedlot.

C. Nearby resources. Are any of the following resources on or in proximity to the feedlot, manure storage areas, or within or adjacent to the boundaries of the manure application sites?

Drinking Water Supply Management Areas designated by the Minnesota Department of Health? Yes No

Public water supply wells (within two miles)? Yes No

Archaeological, historical or architectural resources? Yes No

Designated public parks, recreation areas or trails? Yes No

Lakes or Wildlife Management Areas? Yes No

State-listed (endangered, threatened or special concern) species, rare plant communities or other sensitive ecological resources such as native prairie habitat, colonial waterbird nesting colonies or regionally rare plant communities? Yes No

Scenic views and vistas? Yes No

Other unique resources? Yes No

If yes, describe the resource and identify any Project-related impacts on the resource. Describe any measures to minimize or avoid adverse impacts.

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Lakes or Wildlife Management Areas There are four DNR Public Waters (as defined in Minn. Stat. 103G.005, subd. 15) within a 1 mile radius of the proposed site (Figure 4). This includes Lake Mary (47014300) 0.47 miles to the west, Half Moon Lake (47014400) 0.88 miles to the southwest, Madsen Lake (47014600) 0.82 miles to the southeast, and an unnamed public waters wetland (47014500) 0.26 miles to the south. The Madsen Wildlife Management Area is 0.71 miles to the southeast of the proposed site. Sensitive Ecological Resources While no state listed species were discovered within 1 mile of the Project, there are features less than 2 miles away. These include locations where bald eagles have been reported to nest, several native plant communities, and an area of Moderate Biodiversity Significance surrounding the North Fork Crow River.

3. Geologic and soil conditions.

A. Groundwater and bedrock depths

Approximate depth (in feet) to: Feedlot and Manure Storage Area

Manure Application Sites

Groundwater (minimum) 1.48 Not applicable

(average) 1.48 Not applicable

Bedrock (minimum) 237 Not applicable

(average) 242 Not applicable

The Natural Resource Conservation Service (NRCS) Soil Survey provided the groundwater information for the Project area. NRCS defines depth to groundwater (the shallow water table) as “a saturated zone in the soil that occurs during specified months, lasting longer than one month at selected sites based on evidence of a saturated zone, namely grayish colors redoximorphic features in the soil.” Groundwater depth is affected by weather, time of year, and other factors. In the NRCS database, a representative value indicates where the water table is expected for the soil property as represented by the report from the Web Soil Survey. Shallow groundwater tables can be vulnerable to environmental impacts. Permanent stormwater treatment that is required for this Project will be near a seasonally high groundwater table and could make infiltration of stormwater challenging. Forsman submitted a Stormwater Pollution Prevention Plan (SWPPP) to the MPCA for approval to address this. The SWPPP is discussed in more detail in Section 8. The Minnesota Geological Survey4 supplied bedrock depth data. These features overlay an aquifer that is approximately 200’ deep in the Project area. This is an indication that the aquifer should have low vulnerability to manmade contamination infiltrating from the land surface.

B. Natural Resources Conservation Service (NRCS) Soil Classification

NRCS Soil Classification Project Area

(Acres) Manure Application Sites

101B - Truman silt loam, 2 to 6% slopes 1175 - Swedegrove loam, 0 to 2% slopes 136 - Madelia silty clay loam, 0 to 2% slopes 197 - Kingston silty clay loam, 1 to 3% slopes 229 - Waldorf silty clay loam, 0 to 2% slopes

81.2 Not applicable

Figure 5 shows a comprehensive view of the NRCS soil classifications within the Project area.

4 Lively, R.S., Bauer, E.J., and Chandler, V.M. January 2006. Maps of Gridded Bedrock in Minnesota (GIS File). Minnesota Geological Survey Open File Report OFR2006_02.

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C. Indicate with a yes or no whether any of the following geologic site hazards to groundwater are present at the feedlot, manure storage area, or manure application sites.

Hazard Feedlot/Manure Storage Area

Manure Application Sites

Karst features (sinkhole, cave, resurgent spring, disappearing spring, karst window, blind valley, or dry valley)

No N/A

Exposed bedrock No N/A

Soils developed in bedrock (as shown on soils maps) No N/A

For items answered yes (in C), describe the features, show them on a map, and discuss proposed design and mitigation measures to avoid or minimize potential impacts.

Not applicable.

4. Water Use, Tiling and Drainage, and Physical Alterations.

A. Will the Project involve installation or abandonment of any water wells, appropriation of any ground or surface water (including dewatering), or connection to any public water supply?

Yes No If yes, as applicable, give location and purpose of any new wells; the source, duration, quantity and

purpose of any appropriations or public supply connections; and unique well numbers and the Department of Natural Resources (DNR) appropriation permit numbers, if available. Identify any existing and new wells on the site map. If there are no wells known on-site, explain methodology used to determine that none are present.

There are no existing wells within the Project area. The closest well is a domestic well approximately 1,350 feet to the southwest. Forsman plans to construct 10 new wells at the Project as indicated in the DNR Preliminary Well Construction Assessment (Exhibit C). These wells will appropriate groundwater from an approximately 200’ deep buried sand and gravel aquifer, and will not be connected to a public water supply.

Forsman will use water from the 10 new wells for livestock watering. Minnesota Department of Health (MDH) well code requires that all water supply wells be at least 50 feet away from poultry buildings. Construction will comply with these requirements. Following construction of the wells, Forsman will register them with MDH. There are no Drinking Water Supply Management Areas or Public Water Supply wells within a 2 mile radius of the Project according to the MDH County Well Index (CWI). There are no other delineated wellhead protection areas or special well construction areas within a 2 mile radius of the Project. The nearest wellhead protection area is around the City of Litchfield to the south of the Project. The total projected water usage from the 10 new wells is approximately 25 million gallons per year. The preliminary assessment received from the DNR will assist in deciding whether to proceed with constructing a well, but it is not a guarantee of permit approval or authorization to construct. The DNR requires a Water Appropriation Permit for users that withdraw more than 10,000 gallons of water per day or 1,000,000 gallons per year. The 10 proposed wells will need to apply for individual permits for water appropriation. Additional information submitted during the water appropriation process will be used to determine the need for any additional testing, which may include utilizing monitoring wells or an aquifer performance test. The purpose of the DNR Water Appropriation Permit

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program is to manage water resources to ensure an adequate supply to meet long-range seasonal requirements. The DNR Water Appropriation Permit allows for a reasonable use of water provided that the use does not negatively impact surrounding wells or other water resources. Table 1 below lists all wells within a 1 mile radius of the Project.

Table 1: Wells within a 1 Mile Radius

Well ID Well Type Approximate Distance From Site (ft)

00211656 Domestic 1,350

00148209 Domestic 1,370

00744948 Domestic 1,480

00132461 Irrigation 1,750

00229578 Test Well 2,015

00773822 Domestic 2,275

00102895 Domestic 3,740

B. Will the Project involve installation of drain tiling, tile inlets or outlets? Yes No

If yes, describe.

There are no installation plans for drain tiles, tile inlets or outlets.

C. Will the Project involve the physical or hydrologic alteration — dredging, filling, stream diversion, outfall structure, diking, and impoundment — of any surface waters such as a lake, pond, wetland, stream or drainage ditch? Yes No

If yes, identify water resource affected and give the DNR Protected Waters Inventory number(s) if

the water resources affected are on the PWI. Describe proposed mitigation measures to avoid or minimize impacts.

5. Manure management.

A. Check the box or boxes below which best describe the manure management system proposed for this feedlot.

Stockpiling for land application Containment storage under barns for land application Containment storage outside of barns for land application Dry litter pack on barn floors for eventual land application Composting system Treatment of manure to remove solids and/or to recover energy Other (please describe)

Forsman will install manure belt conveyors underneath the aviary housing systems in each barn. Each barn will have two levels of aviary housing. The birds continually defecate on belts that convey the manure to the end of the aviary housing where it drops to another conveyor. This conveyor brings that manure to a manure drying chamber in the middle of the barn. The manure will dry in the manure drying chamber before moving through another enclosed conveyor to the manure storage building where pelletization occurs.

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B. Manure collection, handling, and storage.

Quantities of manure generated: ~16,000 tons/year when pelletized

Frequency and duration of manure removal: number of days per cycle: Daily

Total days per year: 365

Give a brief description of how manures will be collected, handled (including methods of removal), and stored at this feedlot:

Forsman will install manure belt conveyors underneath the aviary housing systems in each barn. Each barn will have two levels of aviary housing. The birds continually defecate on belts that convey the manure to the end of the aviary housing where it drops to another conveyor. This conveyor brings that manure to a manure drying chamber in the middle of the barn. The manure will dry in the manure drying chamber before moving through another enclosed conveyor to the manure storage building where pelletization occurs. Each of the four barns housing the egg layers will have its own manure drying chamber. The manure drying chambers will have fans that utilize the heat generated by the birds to dry the manure. The wet manure passes through the dryer over 2 to 3 days, depending on the season. The manure is dry once the moisture content decreases from the 60-70% range to a 10-18% range. The annual quantity of wet manure generated will be approximately 40,200 tons. Once manure is dried and pelletized, the total will be approximately 16,000 tons per year. Daily, enclosed automatic conveyors will transport dried manure from each manure drying chamber in the layer barns to the manure storage building. The manure storage building is where dry manure pelletizes through a hammermill, which ensures consistency of the final product. After the hammermill, manure goes to the pellet machine to form manure pellets. When a buyer purchases fertilizer, a front end loader will load the pellets into a truck. This will generally occur on a monthly basis. Significant load outs take place in the spring and fall to meet local farmers’ fertilizer needs. Manure from the pullet barn will dry in a manure drying chamber, similar to the layer barn process. When the manure is dry enough and ready to transport to the manure storage building, it will be loaded into a container in the back of the barn. The manure container will be covered and then driven outside to the manure storage shed, where it will be mixed with layer barn manure. Pullet manure is pelletized through the same process as layer manure before sale to a third party licensed commercial fertilizer vendor. This will occur on a weekly basis, depending on the age of the pullets. The composting of manure that occurs in the manure storage building will further reduce the moisture content. The manure storage building will include a roof and a concrete floor to prevent any contact with precipitation, surface and/or groundwater while housing the fertilizer before sale. Once dried, the manure becomes a lesser source for odor, ammonia, and hydrogen sulfide emissions. The Air Quality Modeling Report incorporates manure drying into the emission factors used for the barns (Exhibit E). Forsman will follow Operation and Maintenance Plans specified per the Feedlot Permit to prevent potential issues that could result from mishandling of manure. The Operation and Maintenance Plan will also outline procedures for keeping the conveying system in good operating order, a routine preventative maintenance schedule, and common corrective actions to take to restore equipment to proper operation in the event of unexpected failures. The proposed design of the barns has demonstrated reduced ammonia and odor emissions. For example, in high-rise barn configurations, manure drops through the aviary housing system or cages onto the first floor. This can cause prolonged manure drying time. Alternatively, in the proposed configuration, manure is less likely to fester in a growing pile that creates additional off-gas. Instead,

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exhaust fans are used inside of a chimney on one side of each barn. The aviary housing systems vent air and dust from the structure through internal exhaust fans that flow to the chimney. The configuration allows dust to settle in the chimney for collection rather than exhausting directly outside.

C. Manure utilization.

Physical state of manure to be applied: liquid solid other - describe:

Forsman will not apply any manure on-site or off-site. Forsman will sell all manure generated at the Project to a third party as pelletized commercial fertilizer and will be applied by the purchaser at other off-site locations. Forsman will sell and transfer 100% ownership of the manure generated at the Project to a licensed third-party Commercial Animal Waste Technician (CAWT). If a CAWT is hired to spread the manure, they must keep records of the quantity and nutrient content of the manure delivered as well as the location and rate of application. Third parties will follow BMPs in the transportation of manure to prevent manure from spilling on a public roadway. If manure spills on a public roadway, the hauler must remove and properly dispose of it in accordance with Minn. R. 7020.2010, Transportation of Manure.

D. Manure application.

1. Describe application technology, technique, frequency, time of year and locations.

Not applicable.

2. Describe the agronomic rates of application (per acre) to be used and whether the rates are based on nitrogen or phosphorus. Will there be a nutrient management plan?

Yes No

Not applicable.

3. Discuss the capacity of the sites to handle the volume and composition of manure. Identify any improvements necessary.

As described in Section 5B, the manure will be dried, pelletized, and sold as a commercial fertilizer product. The purchaser will land apply it at offsite locations.

Forsman estimates that the Project will generate approximately 40,200 wet tons of manure per year. The manure will be dried and pelletized to approximately 16,000 tons. The dried manure will be stored in an approximately 49,000 square foot manure storage building with concrete floors. Dried pelletized manure will be sold throughout the year. The size of the storage space is expected to meet supply and demand.

Forsman will sell and transfer ownership of the manure generated at the Project to third parties. Parties receiving the manure are required to follow state and local requirements for manure application. There is demand for pelletized manure in agricultural areas, including the areas surrounding the Project, for the estimated 6,400 acres required for application. The third parties have sold other Forsman Farm’s pelletized manure in six Minnesota counties (Carver, Meeker, Sibley, Wright, Stearns, and McLeod). The manure recipient must ensure manure is tested prior to land application by conducting composite tests from Forsman’s manure storage areas. Fertilizer must be applied in accordance with Minn. R. 7020.2225.

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4. Describe any required setbacks for land application systems.

Not applicable for Forsman’s Project. However, CAWTs who purchase the manure must comply with the maximum setback from either Minnesota Rule or Meeker County requirements for manure application regarding manure application practices and environmentally sensitive features (Minn. R. 7020.2005 and Minn. Stat. 103F.48). MPCA feedlot regulations also contain setback distances. Meeker County Ordinances, Section 22.10, I. Land Application of Manure, contain more stringent requirements.

Minnesota Animal Waste Land Application Setback Distances

Feature Winter

Non-Winter With Immediate

Incorporation (

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Construction

Total confinement barns will reduce the amount of outside air exposed to manure odor. The total enclosure of the manure storage building will prevent exposure to open air and weather conditions.

The chimney system as described in Section 5B will also prevent barn odor from direct exposure to outside air. Exhaust fans will ventilate barn air through chimneys, which allows dust to settle before exiting.

Each of the four layer barns will be constructed with a two level aviary housing system. The aviary housing system is a multi-tier system that provides living space at several levels. The ammonia and odor emissions from the manure belt conveyor are expected to be lesser than other configurations, as described in Section 5B. Throughout the transport and drying process, manure tends not to fester and create additional odor. Once dried, the manure is a lesser source for odor, ammonia, and hydrogen sulfide emissions.

Manure Management

The birds are fed a diet based on digestible amino acids, which decreases protein levels in feed and nitrogen output. Additionally, synthetic amino acids, such as methionine, lysine, and threonine, are used to decrease nitrogen levels in feed and odor levels in manure. A series of conveyor belts will continuously capture manure dropping through each level of the aviary housing system in the barn. The manure begins to dry as it moves through the building. Belts convey manure to the end of the aviary housing system where it drops. A second conveyor brings the manure to the manure drying chamber on a daily basis. All manure is dried in a manure drying chamber before transfer to the manure storage building.

o In the layer barns, an enclosed conveyor brings manure from the manure drying chamber to the manure storage building.

o In the pullet barns, manure is moved manually from the manure storage chamber to the manure storage building weekly.

The manure conveyor belt design reduces the potential for dust, odor, and other air contaminants when compared to other feedlot manure management practices. The manure storage building will not create additional sources of odor since the manure is pelletized and dry when placed into the building.

Operation and Maintenance

Forsman will attend to the following practices as described in the Operation and Maintenance Plan:

o Cleaning the ventilation fans and exhaust fans on a regular basis. o Dry cleaning the manure drying chamber weekly. o Dry cleaning the front and the back of the barns daily. o Fully dry cleaning the barns between flock change outs. o Maintaining clean and dry floors, eliminating manure buildup, and regularly cleaning

up any spilled feed.

In the event the MPCA, County Feedlot Officer, or Forsman receive odor complaints, Forsman will identify and administer appropriate corrective action to reduce odor.

C. Answer this item only if no feedlot design features or mitigations were proposed in item 6.B. Provide a summary of the results of an air emissions modeling study designed to compare predicted emissions at the property boundaries with state standards, health risk values, or odor threshold concentrations. The modeling must incorporate an appropriate background concentration for hydrogen sulfide to account for potential cumulative air quality impacts.

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Though Forsman outlines design and mitigation features in Section 6B above, an air emission modeling study was prepared (Exhibit E). The air quality modeling calculated the gas concentrations at 32 neighboring residences. One feedlot exists within a 1 mile radius, and therefore was included in the modeling as a nearby source for hydrogen sulfide, ammonia, and odor. The modeling study predicts Project compliance with the current state standards, health risk values, and odor threshold concentrations.

Hydrogen Sulfide - Minnesota Ambient Air Quality Standard (MAAQS) The American Meteorological Society Regulatory Model (AERMOD) air quality modeling results suggest that the Project will comply with the MAAQS for hydrogen sulfide. The standard outlines the third exceedance of 30 parts per billion by volume (ppb) within any 5-day period as a violation. Compliance is demonstrated when the high-third-high (H3H) concentration and background concentration for any 5-day period at each property line receptor is less than 30 ppb. The air quality modeling results calculated a maximum H3H hydrogen sulfide concentration of 5.1 ppb at the Project’s property lines. When a background concentration of 17 ppb is added to the AERMOD calculated concentration, the H3H hydrogen sulfide concentration is 22.1 ppb, which is below the ambient standard of 30 ppb. Thus, no violation of the 30 ppb ambient hydrogen sulfide standard was modeled for the Project. Hydrogen Sulfide - Sub-chronic Inhalation Health Risk Value (iHRV) The AERMOD results indicate that the Project and neighboring feedlot will not create exceedances of the subchronic (13-week) hydrogen sulfide iHRV at the neighboring residences. The calculated maximum monthly hydrogen sulfide concentration for the neighboring residences is 0.14 micrograms per cubic meter (µg/m3). When a background concentration of 1.0 µg/m3 is added to the AERMOD calculated concentration, the maximum monthly neighbor hydrogen sulfide concentration is 1.14 µg/m3, which is below the subchronic hydrogen sulfide iHRV of 10 µg/m3. Ammonia – Acute iHRV The modeling results suggest that the Project will not create exceedances of the acute ammonia iHRV. AERMOD calculated a maximum hourly property-line ammonia concentration of 1,430 µg/m3. When a background concentration of 148 µg/m3 is added to the AERMOD calculated concentration, the maximum property-line ammonia concentration is 1,578 µg/m3, which is below the acute ammonia iHRV of 3,200 µg/m3. Thus, no exceedance of the acute ammonia iHRV was modeled at the property lines for the Project.

Ammonia – Chronic iHRV The AERMOD results indicate that the Project and the one neighboring feedlot will not create exceedances of the chronic ammonia iHRV at the neighboring residences. The calculated maximum 1-year time-averaged ammonia concentration for the neighbors is 11.95 µg/m3. When a background ammonia concentration of 5.72 µg/m3 is added to the AERMOD concentration, the maximum annual ammonia concentration at the neighboring residence is 17.67 µg/m3, which is below the chronic ammonia iHRV of 80 µg/m3. Odor – At Property Line and Nearest Residences The AERMOD modeling results suggest that the Project will comply with the ambient air quality standard for hydrogen sulfide and will not create exceedances of the acute ammonia iHRV at the property lines. AERMOD calculated the ground-level atmospheric concentrations of hydrogen sulfide and ammonia at the property lines for the Project and at the neighboring residences. The maximum hourly odor intensity at the Project’s property lines is 95 odor units (OU), which is above the “faint” odor detection threshold, and below the “moderate” odor threshold. The calculated frequency at which the faint odor threshold of 72 OU was exceeded at any property-line receptor was less than or equal to 0.12% of the time. Thus, the calculated hourly odor intensity at any property line receptor

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was less than or equal to 72 OU for at least 99.88% of the time. The calculated maximum odor intensity for a neighboring residence is 52 OU, which is below the 72-OU threshold for faint odors and is considered “very faint”.

Maximum Property Boundary AERMOD Air Quality Modeling Results

Modeled value

Background value

Modeled plus Background value

Threshold

Percent of Threshold

1-hour H2S H3H 5.1 ppb 17 ppb 22.1 ppb 30 ppb 73.7%

1-hour NH3 1,430 µg/m3 148 µg/m3 1,578 µg/m3 3,200 µg/m3 49.3%

Maximum Hourly Odor Intensity

95 OU/m3 NA 95 OU/m3 72 OU/m3 (Faint)

131.9%

Maximum Nearest Neighbor AERMOD Air Quality Modeling Results

Modeled value

Background value

Modeled plus Background value

Threshold

Percent of Threshold

13-week H2S 0.14 µg/m3 1.0 µg/m3 1.14 µg/m3 10.0 µg/m3 11.4%

Annual NH3 11.95 µg/m3 5.72 µg/m3 17.67 µg/m3 80.00 µg/m3 22.1%

Maximum Hourly Odor Intensity

52 OU/m3 NA 52 OU/m3 72 OU/m3 (Faint)

72.2%

Thus, the AERMOD modeling results for the Project predict compliance with the hydrogen sulfide air quality standard, no exceedances of the subchronic hydrogen sulfide iHRV, no exceedances of the acute ammonia iHRV, and no exceedances of chronic ammonia iHRV.

Greenhouse Gases The MPCA estimates the Project would directly release GHG emissions and indirectly affect GHG emissions from related activities. In general, the primary GHG emissions from poultry operations are methane (CH4) and nitrous oxide (N2O). Direct GHG emissions are released from the barn and manure storage. Indirectly, GHG emissions are released as a result of pelletized fertilizer being applied elsewhere. Carbon dioxide (CO2) is the most abundant GHG on earth and has had the largest effect on our climate. Other GHGs –including those associated with typical feedlot operations - are emitted in smaller amounts but can trap heat more effectively than CO2. Some GHGs stay in our atmosphere for a very long time while other GHGs stay in our atmosphere for a relatively shorter time. “Global warming potential” is a relative measure of a GHG’s ability to trap heat and how long it stays in the atmosphere. To compare all the GHGs in common terms to CO2, the MPCA multiplies each pollutant’s emissions by its global warming potential to produce the pollutant’s CO2-equivalent (CO2-e) emissions. In the context of a feedlot (such as the Project), the actual amount of GHG emissions that may be produced will depend on numerous variables, including without limitation: manure storage and management practices, designs of buildings and manure storage facilities, local climate and geography, and other operational and site-specific factors. The U. S. Environmental Protection Agency (EPA) has developed emission factors from a large population of feedlots for use in estimating total feedlot GHG emissions, and the MPCA has previously used these emission factors to estimate GHG emissions from all feedlots in Minnesota in preparing statewide inventories of emissions. The MPCA has calculated the potential emissions for the Project using these population-based emission factors. These projections reflect an estimated inventory of GHGs the Project may contribute. The table below provides estimates of potential emissions for the Project in CO2-e tons.

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Emission Type and Source: Project Increase

(tons CO2-e/yr) Total – Post-Project Construction

(tons CO2-e/yr)

CH4 – barn and manure drying/storage process

400 400

N2O - barn and manure drying/storage process

9,200 9,200

N2O - fertilizer land application 7,200 7,200

ESTIMATED TOTAL: 16,800 16,800

Note: Table values were rounded to the nearest hundred tons.

The potential GHG emissions in the table above are only estimates and do not consider all GHG emissions that the Project could create or induce. For example, GHG emissions are not calculated for electricity generation that is required to operate lighting, heating, etc. Also not included are GHG emissions from fuel combustion required to deliver feed and animals, and to operate farm equipment used in growing feed, processing feed, and managing manure. Some agricultural practices can offset estimated greenhouse gas emissions. The land application of the pelletized fertilizer generated by the Project will replace nutrients otherwise derived from chemical fertilizers, thereby avoiding GHG emissions associated with chemical fertilizer production. The MPCA had to apply its technical expertise and experience with GHG emissions inventories to determine which Project-related activities to quantify because EQB guidance and information needed to conduct a full GHG life-cycle analysis is not currently available. The MPCA chose to quantify the sources listed in the above table because these are the sources MPCA uses to estimate GHG emissions for the entire agricultural sector on a statewide basis, and the EPA provides emission factors for these sources. Therefore, quantifying these sources for the Project enhances comparison between this Project’s GHG emissions and other GHG emissions in Minnesota.

D. Describe any plans to notify neighbors of operational events (such as manure storage agitation and

pumpout) that may result in higher-than-usual levels of air or odor emissions.

The Project will use dry manure handling methods as described in Section 5B. Conducting routine preventative maintenance or fixing a broken conveyor will not impact regular operation of the system. Thus, Forsman does not expect higher-than-usual odors with manure equipment failures. The belts have a simple design, resulting in easy repairs and the ability to keep replacement parts on hand. Dry manure is manually handled twice while onsite. The first move is from the manure drying chamber in the pullet barn into the manure storage building. The second handling occurs when a licensed commercial fertilizer vendor hauls the fertilizer off-site. The layer barns utilize an enclosed automatic conveyor system to transfer manure from the drying chamber to the storage building. Forsman has established working relationships with numerous licensed vendors and does not anticipate selling delays that may induce higher-than-usual odor events. Wet manure is not turned or agitated once the manure enters storage.

Due to the manure handling process, an exceptional event that could result in high odor is not expected. An Emergency Response Plan covers catastrophic events such as a barn fire, tornadoes, and the like. Forsman will address such occurrences on a case-by-case basis with the MPCA and Meeker County feedlot officer. Most events can be resolved by communicating with neighbors, conducting maintenance, following regulations, and maintaining a hygienic farm.

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Daily mortalities will be removed from the aviary system daily, bagged, and stored in a waste bin until they can be transferred off-site to a licensed landfill. Transfers will occur three times a week, therefore odor from this process should be minimal. Forsman will comply with the following for the control and disposal of all animal mortalities:

Minnesota Board of Animal Health rules

The approved Animal Mortality Plan through the Feedlot Permit

The approved Emergency Response Plan through the Feedlot Permit

Documenting all actions related to animal mortality disposal activities

E. Noise and dust. Describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. Forsman’s contractor will generate temporary noise and fugitive dust during construction activities. The quantity of dust generated is expected to be minimal. Construction will be limited to daytime hours only and will inhibit additional noise. All equipment will operate within it’s designed decibel rating during construction. Forsman or their contractor will deploy dust abatement when applicable, using methods including but not limited to spraying water. Fugitive dust that becomes a nuisance condition to nearby neighbors or the public will be reduced and surveyed closely during dry conditions. Dust generated from daily traffic and Project operations will be minimized by good housekeeping practices. Additionally, Forsman is paving all parking areas and roads. This will significantly reduce dust from trucks. Animal feed is also a possible source of fugitive dust. To reduce the amount of dust from animal feed, all feed storage is housed within the barns. The only opportunity for feed dust to generate is from the feed truck outside emptying into the feed conveyor inside. The conveyor runs from the front of each layer and pullet barn to a feed bin inside each barn. Inside, flex augers will carry feed from the feed bins to the birds in each aviary housing system. Feeders will fill via enclosed plastic tubing. Any spills will occur inside the barn and therefore will not be a source of fugitive dust.

Once the Project is operational, Forsman expects noise and fugitive dust levels to be consistent with similar agricultural operations and land use in the area. Daily haul vehicle operation will cause additional noise and dust not currently present in the area. Forsman expects barn exhaust and ventilation fans to be the Project’s largest source of exterior noise, as the majority of noise generating activities will be indoors. However, no fans will blow directly to the outside, which will also avoid generating additional dust. Fans will blow into an enclosed chimney system and further mitigate noise.

The nearest residence is approximately 1,194 feet to the southeast of the Project. Along with the items listed above, distance from the Project will mitigate noise and dust for this resident. Any exceptional noise or dust event will be addressed on a case-by-case basis. This may involve a corrective action, maintenance response, or contact with the MPCA/County feedlot officer. Forsman must address all complaints in a timely manner.

7. Dead Animal Disposal.

Describe the quantities of dead animals anticipated, the method for storing and disposing of carcasses, and frequency of disposal.

Forsman has prepared an Animal Mortality Plan in accordance with Minn. Stat. §35.82 and Minn. R. 1719.0100-4600 and 7011.1215. Forsman submitted the Animal Mortality Plan with the Feedlot Permit application to the MPCA. The Animal Mortality Plan is an enforceable condition of the Feedlot Permit, which will require recordkeeping of the mortality management and practice.

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Forsman experiences a mortality rate of approximately 0.05% per day from their existing facilities. This Project will likely experience similar mortality rates. The barns will contain 1,625,000 birds, thus calculations project 812.5 bird casualties per day. Forsman will remove carcasses from the aviary system daily, bag them, and store them in a bin until transfer off-site to a licensed landfill. Transfers will occur three times a week, keeping odor from the process minimized. Forsman will follow the Minnesota Board of Animal Health rules for disposal of all animal mortalities.

8. Surface Water Runoff.

Compare the quantity and quality of site runoff before and after the Project. Describe permanent controls to manage or treat runoff.

Surface water runoff in the Project area currently includes stormwater that flows across cultivated agricultural land and eventually conveys offsite into the low-lying Battle Creek floodplain to the east of the Project. Stormwater runoff will potentially contain sediment, herbicides, pesticides, or other farming related compounds such as manure. Since the buildings will be enclosed total confinements, stormwater runoff is not expected to come into contact with livestock or manure from the Project. All of the operations associated with the feedlot will be covered by rooftops.

The proposed layer barns, pullet barn, manure storage building, packing plant, parking lot, and roadways will create approximately 26 acres of new impervious areas, causing stormwater runoff volume to increase once the Project is complete. A CSW Permit is required when construction disturbs 1 acre or more of soil. The CSW Permit, which will be regulated through the Feedlot Permit, will ensure that additional stormwater created by the Project will not degrade the quality of the surrounding water in the area. In addition, since more than 50 acres will be disturbed for the Project, the MPCA requires approval of a permanent SWPPP. Forsman submitted a SWPPP application to the MPCA for approval which defines:

Temporary and permanent erosion and sediment control BMPs

Permanent stormwater management practices after construction is complete BMPs will incorporate the most effective and practicable means of erosion prevention and sediment control. Water quality management practices that are the most effective and practicable means to control, prevent, and minimize degradation of surface water include:

Avoidance of impacts

Construction-phasing

Minimizing the length of time soil areas are exposed

Prohibitions

Pollution prevention through good housekeeping

Unnamed Creek (Battle Creek) 07010204-552 is the closest impaired water body to the Project (Figure 7). The impaired water body is less than a mile away from the Project area. The CSW Permit identifies more stringent requirements for impaired waters less than a mile away. This includes initiating immediate stabilization of exposed soil areas after construction ceases, and complete stabilization within 7 calendar days. Stabilization may include mulches, rip rap, sod erosion blankets, or other methods. In addition, if more than 5 acres are disturbed at any one time during construction, Forsman must provide a temporary sediment basin for common drainage locations. This basin will be used during construction, and after construction it will be converted into a permanent stormwater basin.

A water quality volume of 1 inch of runoff from the cumulative new impervious surfaces must be retained on site through infiltration unless site specific circumstances are not favorable for the use of infiltration. For this Project, the MPCA and Forsman determined that six stormwater basins would be appropriate to utilize. Of the six stormwater basins, five of them will be used as filtration basins to provide treatment, and

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one will be a detention basin to provide volume. The basin used during construction that will be converted after will be the detention basin. After the Project is constructed, stormwater runoff generated from impervious surfaces will be collected by grass swales and culverts which will allow for filtration before flowing into the permanent stormwater basins. Check dams and underdrains will assist filtration in the grass swales, and have the capacity to hold and filter the water quality volume. Forsman will construct permanent stormwater basins to the east of the pullet barn and to the south of all of the layer barns for post-construction management (Figure 3). The estimated combined capacity of the basins and drainage swales is 3.6 million gallons of water. The five filtration basins will collect stormwater, treat it, and flow to the detention basin that will provide peak flow reduction from the proposed site. If the stormwater basins overflow, the water would flow to the east and then to Battle Creek. These protections, in conjunction with the rest of the CSW Permit, are expected to mitigate further impairments to Battle Creek and other adverse impacts to nearby surface waters.

9. Traffic and Public Infrastructure Impacts.

A. Estimate the number of heavy truck trips generated per week and describe their routing over local roads. Describe any road improvements to be made.

When the Project is constructed and operating at full capacity, it will generate the following truck trip increases on local roads:

An average of 95 trucks per week will deliver feed and supplies, pick up eggs, and purchase commercial fertilizer.

42 full time employees are expected, resulting in an additional 30-35 vehicles per day.

Forsman does not expect the need for road or intersection improvements. Operation of the Project should not cause traffic backups. Truck drivers will abide by the seasonal road restrictions, which may require more trips at lower weights to reduce impacts on the roads. A driveway permit has been obtained from the Minnesota Department of Transportation (MnDOT) for an access point off Minnesota Trunk Highway 22. Forsman will pave all driveways and parking areas. Table 2 below demonstrates current traffic counts and estimated increases5.

Table 2: Projected Traffic Counts Post-Project Road Average Vehicle/Day Average Vehicle/Week Average Increase/Week

Minnesota Trunk Highway 22 1,550 10,850 322.5

CSAH 16 335 2,345 322.5

CSAH 31 280 1,960 322.5

B. Will new or expanded utilities, roads, other infrastructure, or public services be required to serve the Project? Yes No

If yes, please describe.

No new or expanded utilities, roads, other infrastructure, or public services will be needed to serve the Project.

5 Traffic counts from MnDOT: https://www.dot.state.mn.us/traffic/data/tma.html

https://www.dot.state.mn.us/traffic/data/tma.html

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10. Permits and approvals required. Mark required permits and give status of application:

Unit of government Type of Application Status

MPCA NPDES/SDS Feedlot Permit (includes NPDES/SDS CSW Permit) Submitted

Meeker County Conditional Use Permit To be submitted

Meeker County Feedlot Permit To be submitted

DNR Preliminary Well Assessment Attached (Exhibit C)

DNR Water Appropriation Permit To be submitted

MnDOT Right of Way (Driveway) Permit Obtained

11. Other potential environmental impacts, including cumulative impacts. If the Project may cause any

adverse environmental impacts not addressed by items 1 to 10, identify and discuss them here, along with any proposed mitigation. This includes any cumulative impacts caused by the Project in combination with other existing, proposed, and reasonably foreseeable future Projects that may interact with the Project described in this EAW in such a way as to cause cumulative impacts. Examples of cumulative impacts to consider include air quality, stormwater volume or quality, and surface water quality. (Cumulative impacts may be discussed here or under the appropriate item(s) elsewhere on this form.)

The MPCA is required to evaluate whether a proposed Project, which may not individually have the potential to cause significant environmental effects, could have a significant effect when considered along with other projects. This type of impact is known as a cumulative potential effect. In order to assess the proposed project’s “cumulative potential effects of related or anticipated future projects,” the MPCA conducted an analysis that addressed other projects or operations in context to the potential direct or indirect impacts of the proposed Project that: (1) are already in existence or planned for the future; (2) are in the surrounding area; and (3) might reasonably be expected to affect the same natural resources. The following is a review of the analysis conducted to determine if the proposed Project would contribute to an adverse cumulative potential effect.

Surface Water Quality Land use within the Project is predominantly agricultural, which can contribute to non-point source pollution of surface waters. The layer hens and pullets will be housed in total confinement barns and do not have access to surface waters. The Project is within the North Fork Crow River watershed (Hydrologic Unit 07010204). Forsman conducted a search of the MPCA “Feedlots in Minnesota” GIS dataset to identify the number of feedlots and other projects within the same sub watersheds of the Project. The data reviewed included the most recent MPCA feedlot registration database and related databases for other operations that may hold an air quality, water quality, hazardous waste, or solid waste permit. Results found one horse feedlot with 0-450 AUs within a 1 mile radius of the Project. Existing feedlot operations in conjunction with the Project are not expected to cause significant environmental effects. Stormwater runoff volume will increase in the area due to the addition of approximately 26 acres of impervious surfaces once the Project is complete. Per the CSW Permit, a temporary sediment basin for common drainage locations will be provided during construction of the Project if more than 5 acres is disturbed at any time. After construction of the Project, Forsman will construct permanent stormwater dry detention basins to the east of the pullet barn and to the south of the layer barns to collect stormwater generated at the Project. The basins will collect stormwater after its been filtered through swales and culverts. The CSW requirements will ensure that additional stormwater created by the Project will not degrade the quality of the surrounding water in the area. This is especially pertinent for the impaired Battle Creek (07010204-758) less than 1 mile away from the Project. Section 8 discusses the CSW Permit’s more stringent requirements for impaired waters within 1 mile. The Feedlot Permit requires the Project to meet a zero direct discharge standard. The SWPPP requires BMPs for the construction and operation of the Project. These requirements will minimize the contribution of the Project to cumulative effects on surface water resources.

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Impaired Waters and Total Maximum Daily Loads (TMDLs) The Federal Clean Water Act (CWA) (33 U.S.C. § 303(d)) requires each state to develop a plan to identify and restore any waterbody that is deemed impaired by state regulations. The EPA requires a total maximum daily load (TMDL) plan to comply with the CWA. A TMDL identifies the pollutant that is causing the impairment and how much of that pollutant can enter the water body while still meeting water quality standards. Battle Creek is the closest impaired water body to the Project.

Unnamed Creek (Battle Creek) (07010204-758) Battle Creek is approximately 0.3 miles east of the Project within the North Fork Crow River major watershed. MPCA’s Draft 2020 impaired waters list identifies Battle Creek as impaired due to benthic macroinvertebrates bioassessments and fish bioassessments. Once a body of water is added to the Minnesota Impaired Waters List, the MPCA must develop a TMDL plan for it. Currently, there is no plan in place. The TMDL target completion year is 2021.

Groundwater Quality Forsman reviewed the Minnesota CWI and found that there are five domestic, one irrigation, and one test well within 1 mile of the Project. These wells range from a depth of 64 to 146 feet below the land surface. There are no wells currently in the Project area.

Forsman plans to install 10 new wells at the Project with an annual estimated use of 25 million gallons of water total. The DNR has preliminarily approved the construction of Forsman’s wells (Exhibit C). The preliminary approval does not constitute an authorization or guarantee permit approval by the DNR. Additional well monitoring or aquifer testing may be required. Forsman will construct all wells according to the requirements of Minn. Stat. 1031 and Minn. R. 4725. Appropriate notification will be provided to the MDH Well Management program before well construction begins. The Project’s wells will require a Water Appropriation Permit from the DNR. Minn. Stat. 103G.261 establishes domestic water use as the highest priority of the State’s water when supplies are limited, and other uses may be limited, or even prohibited. Further, when there are concerns of a localized problem with getting water, and there are claims that a well is causing interference, Minn. R. 6115.0730 contains DNR procedures for resolving well interferences. If the DNR determines that there is well interference, the operator is required to fix the causes of the interference. During its Water Appropriation Permit review process, DNR will evaluate potential short-term impacts such as well interferences, and long-term cumulative effects. Cumulative effects is one of the considerations DNR evaluates in the Water Appropriation Permit program, particularly in areas of high groundwater use, such as in this area.

Feedlot operations and the land application of manure can adversely affect groundwater resources. This is especially true in areas with karst topography, where pollutants can travel to groundwater through bedrock fractures. No known karst topography exists at the Project. In addition, the Project area will not be land applied with manure. Although the dried fertilizer is being transferred to other parties who will apply the manure, the Feedlot Permit requirements provide a framework to track and determine compliance. Groundwater depth in the Project area is on average 1.48 feet. In agricultural areas, shallow groundwater often has detectable concentrations of pesticides and high concentrations of nitrate. Deep aquifers, such as the one the 10 wells in the Project will utilize, are generally not vulnerable to contamination. Sand and gravel aquifers, which make up over 95% of the constructed wells in Meeker County6, that are near rivers can have higher contamination rates. However, the DNR reports that the majority of the Project area has a low susceptibility to groundwater contamination (Figure 8), which determines aquifer pollution

6 DNR Groundwater Atlas of Meeker County, Minnesota: https://files.dnr.state.mn.us/waters/groundwater_section/mapping/cga/c35_meeker/meeker_report.pdf

https://files.dnr.state.mn.us/waters/groundwater_section/mapping/cga/c35_meeker/meeker_report.pdf

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vulnerability. In addition, surface water and stormwater BMPs that have been discussed throughout the EAW will assist in preventing infiltration and groundwater contamination. The Groundwater Contamination Susceptibility in Minnesota report7 estimates the potential for groundwater pollution. The DNR updated the report in June of 20168. The report uses a matrix for determining a sensitivity rating of the water table ranging from very high to very low based on aquifer material, recharge potential, soil materials, and vadose zone materials. A geologic susceptibility rating is based on the vertical travel time range required for water to travel from the land surface to a depth of 10 feet6. It is intended to estimate the time of travel through the unsaturated zone to reach the water table, which for the purposes of this method, is assumed to be 10 feet below land surface everywhere. A rating of “low” indicates that it would take contaminates with or within water through geological material >430-1600 hours to reach the water table (Table 3).

Table 3: Geologic Sensitivity Rating Descriptions

Near- Surface Pollution Sensitivity

Time of Travel Description

High ≤ 170 hours Hours to a week

Moderate > 170-430 hours A week to weeks

Low > 430-1600 hours Weeks to months

Very Low > 1600-8000 hours Months to a year

Ultra Low > 8000 hours More than a year

There are no DNR Protected Waters Inventory (PWI) features within the Project area. The closest Protected Waters are the Lake Mary water basin (143P) and Half Moon Lake water basin (144P) to the southwest. Meeker County Soil and Water Conservation District reviewed and approved a wetland delineation submitted by Forsman for the Project. On January 17, 2018, a Notice of Decision was issued for that wetland delineation (Exhibit D). The approval is valid for 3 years from the date of decision. Delineation of one wetland in the Project area totaled 0.10 acres (Figure 6; label SP 12-Up). The wetland is not considered a PWI and does not have a PWI number. Other wetlands are mentioned in the Notice of Decision, however the Project area has been redefined since the delineation was submitted. The Project area is only to the west of Minnesota Trunk Highway 22, making wetland delineations to the east irrelevant to this Project. The Project will not impact the wetland by excavation, drainage, direct filling or other wetland alterations (such as sedimentation caused by erosion). Therefore, no permanent impacts are expected. The wetland onsite is a seasonally flooded basin within a low spot in the field that refills with surface water. The proposed wells will be dug to an aquifer around 200’ deep and groundwater appropriation from it will have no effect on the wetland. To protect groundwater, Forsman is required to construct and operate the hen and pullet barns and dry manure storage building, which is considered a permanent stockpile site, in accordance with the applicable requirements of Minn. R. 7020.2125, Manure Stockpiling Sites. MPCA staff will review the permit application, Project design plans, and construction specifications for proposed construction of the hen and pullet barns and the dry manure storage building. These documents contain integral and enforceable conditions of the Feedlot Permit. Forsman will reduce the Project’s potential impacts to groundwater by following the design, construction, and operation requirements identified in Minn. R. 7020 (Animal Feedlots). These rules are designed to protect groundwater.

7Geologic Sensitivity Workgroup, 1991, Criteria and guidelines for assessing geologic sensitivity of groundwater resources in Minnesota: Minnesota Department of Natural Resources, Division of Waters, St. Paul, MN, 122 p. Retrieved July 2016. http://files.dnr.state.mn.us/waters/groundwater_section/mapping/sensitivity/docs/assessing_geologic_sensitivity.pdf 8 Adams, R. Pollution Sensitivity of Near-Surface Materials. Minnesota Department of Natural Resources. June 2016. Available at: http://files.dnr.state.mn.us/waters/groundwater_section/mapping/mha/hg02_report.pdf

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Air Quality Forsman conducted air dispersion modeling with AERMOD to predict how the Project’s emissions of hydrogen sulfide, ammonia, and odorous gases would impact air quality at the Project’s property lines and at the residences nearest to the Project site. The cumulative impacts associated with the emissions from the Project and the one neighboring feedlot in a 1-mile radius were explicitly modeled. The air quality impacts associated with any other sources in the modeled 3-section by 3-section grid were considered implicitly as contributors to the background concentrations and added to the modeling results. The MPCA provided data on background hydrogen sulfide and ammonia concentrations. A background concentration is the amount of pollutants already in the air from other sources that is used to address cumulative air impacts. This is consistent with EPA’s User Guide for AERMOD. Odorous gases at the nearest neighbors’ property lines at the maximum calculated odor intensity are all modeled below the threshold for faint odors. Based on the results, the Project modeled compliance with hydrogen sulfide, ammonia, and odorous gas standards, therefore, the MPCA does not expect significant or cumulative air quality impacts from the Project (Exhibit E). Annual GHG emissions fluctuate, but fortunately, the State has been on a general downward trend since 2005. While there are no state or federal caps on GHG emissions, the Next Generation Energy Act, Minn. Stat. § 215H.02, sets Minnesota GHG emission reduction goals of 15% from 2005 levels by 2015, 30% from 2005 levels by 2025, and 80% by 2050. The most recently available data (2016) shows the state’s total annual GHG emissions at 12% below the 2005 baseline. The MPCA estimates that, in 2016, activities in Minnesota released 154.2 million tons of CO2-e. Of the total 154.2 million, about 35 million tons of CO2-e came from Minnesota’s agriculture sector. Animal agriculture accounted for about 10.5 million tons of CO2-e, and crop agriculture accounted for nearly 27 million tons of CO2-e. Together, Minnesota’s agriculture and forestry sector have decreased about 12% compared to the 2005 baseline, but emissions were highly variable between 2005 and 2016. Global climate change results from the total accumulation of GHGs in the Earth’s atmosphere, as well as other man-made and natural factors. The GHG composition in the Earth’s atmosphere is changing and causing the planet’s climate to change. The Project’s incremental contribution to global GHGs cannot be translated into effects on climate change globally or regionally. In general, regional impacts from climate change may include the following effects: increased mean annual air temperature (summer and winter warming); increased surface water temperatures; later onset of winter and earlier onset of spring; precipitation may fall in fewer, but more intense, storms; species adapted to cold climates may shift out of the Great Lakes basin into Canada; and aspen and birch forests may be replaced by hardwood forests of oak and hickory. Moderate climate change may increase agricultural yields and food production, with some regional and annual variability. As indicated in Section 6c, the Project will directly release GHG emissions and indirectly cause GHG emissions from related activities, with total projected emissions from the feedlot after the Project is completed estimated at 16,800 tons of CO2-e per year. There are no Minnesota or National Ambient Air Quality Standards for GHGs. The assessment of GHG emissions and climate change is extremely complex. Currently it is not possible to model the physical impacts of global or regional climate change, such as storm frequency/intensity or temperature increases, caused by incremental GHG emissions, such as those from the Project. In other words, while agriculture contributes to climate change generally, existing scientific tools do not allow MPCA to quantify the specific effects of a particular feedlot or project on global or regional climate change impacts. There is currently an absence of regulatory guidance for analyzing GHG emission impacts. If, in the future, climate models improve in their predictive capacity or more regulatory guidance is provided, MPCA will incorporate those tools into its environmental review process at that time.

23

Land Use The Project is in areas already zoned and used for agricultural production. The Project will not change the existing land area or use. No natural areas will be impacted as a result of the Project. The MPCA does not expect the Project to result in a regionally significant decline in wildlife abundance or species diversity since the Project will not disrupt wildlife habitat.

12. Summary of issues. List any impacts and issues identified above that may require further investigation before the Project is begun. Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues, including those that have been or may be ordered as permit conditions.

There are no known additional impacts or issues that may require investigation at this time.

RGU CERTIFICATION.

I hereby certify that:

The information contained in this document is accurate and complete to the best of my knowledge.

The EAW describes the complete Project; there are no other Projects, stages or components other than those described in this document, which are related to the Project as “phased actions,” pursuant to Minn. R. 4410.0200, subp. 60, 4410.1000, subp. 4, and 4410.4300, subp. 1.

Copies of this EAW are being sent to the entire EQB distribution list.

Name and Title of Signer: Dan R. Card, P.E.

Dan R. Card, P.E., Supervisor, Environmental Review Unit St. Paul Office

Resource Management and Assistance Division

Date: May 4, 2020

The format for the alternative Environmental Assessment Worksheet form has been approved by the Chair of the Environmental Quality Board pursuant to Minn. R. 4410.1300 for use for animal feedlot Projects. For additional information contact: Environmental Quality Board, Room 300, 658 Cedar St., St. Paul, Minnesota, 55155, 651-201-2476, or voice mail: 800-657-3794. For TTY, call 800-627-3529 and ask for Minnesota Planning. This form can be made available in an alternative format, such as audiotape. This form is available at http://www.eqb.state.mn.us/review.html.

http://www.eqb.state.mn.us/review.html

Architecture + Engineering + Environmental + Planning Figures

Figures: Figure 1. Project Location Map Figure 2. USGS Topographic Map Figure 3. Site Plan Map Figure 4. One Mile Radius Map Figure 5. Meeker County Soil Survey Map Figure 6. Wetland Delineation Map Figure 7. Cumulative Potential Effects Map Figure 8. Groundwater Pollution Sensitivity Map

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Project Location MapForsman Farms - Litchfield Farm

Harvey Twp, Meeker County, Minnesota1 in = 2 miles

Friday, October 11, 2019

Source(s):Municipalities (MN DOT, 6/24/2016)

Lakes (MN DNR, July, 2008)Counties (MN DNR, July 2013)

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USGS Topo MapForsman Farms - Litchfield Farm

Harvey Twp, Meeker County, Minnesota1 in = 1,500 ft

Friday, October 11, 2019

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Figure 3Site Plan MapForsman Farms - Litchfield FarmHarvey Twp, Meeker County, Minnesota1 in = 400 ft

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One Mile Radius MapForsman Farms - Litchfield Farm

Harvey Twp, Meeker County, Minnesota1 in = 3,500 ft

Thursday, February 13, 2020

Source(s):Orthophoto (MnGeo, 2017)

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229 - Waldorfsilty clay loam, 0 to2 percent slopes

197 - Kingstonsilty clay loam, 1to 3 percent slopes

136 - Madelia siltyclay loam, 0 to 2percent slopes

197 - Kingstonsilty clay loam,1 to 3 percent slopes

101B - Trumansilt loam, 2 to 6percent slopes

101B - Trumansilt loam, 2 to 6percent slopes

136 - Madelia siltyclay loam, 0 to 2percent slopes

136 - Madelia siltyclay loam, 0 to 2percent slopes

101B - Trumansilt loam, 2 to 6percent slopes

805C2 - Sunburg-Wadenillcomplex, 6 to 12percent slopes, eroded

1178 - Uniongroveloam, 0 to2 percent slopes

101B - Trumansilt loam, 2 to 6percent slopes

101B - Trumansilt loam, 2 to 6percent slopes

197 - Kingstonsilty clay loam, 1to 3 percent slopes

136 - Madeliasilty clay loam,0 to 2 percent slopes

197 - Kingston siltyclay loam, 1to 3 percent slopes

101B - Trumansilt loam, 2 to6 percent slopes

1175 - Swedegroveloam, 0 to 2percent slopes

136 - Madeliasilty clay loam, 0to 2 percent slopes

136 - Madeliasilty clay loam, 0 to2 percent slopes

101B - Trumansilt loam, 2 to 6percent slopes

101B - Trumansilt loam, 2 to 6percent slopes

136 - Madelia siltyclay loam,0 to 2 percent slopes

140 - Spicersilty clay loam, 0to 2 percent slopes

L13A - Klossner muck,0 to 1 percent slopes

101B - Trumansilt loam, 2 to 6percent slopes

LegendProject Area

Proposed Stormwater Ponds

Proposed Concrete Roadway

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Meeker County Soil Survey

Hydric Soil

Predominantly Hydric Soil

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Predominantly Non-Hydric Soil

Non-Hydric Soil