What we like (and what we're not sure about) in MN's latest Nutrient Reduction Strategy draft

The Minnesota Pollution Control Agency just finished accepting comments on its first-ever update to the Minnesota Nutrient Reduction Strategy — the state’s flagship plan to address the stubborn, long-running nitrate and phosphorus pollution issues plaguing many of the state’s waters.

First developed in 2015, the strategy calls for a 45% reduction in nutrient pollution to the Mississippi River by 2040. So far, progress toward that goal has been mixed. 

We’ve seen only marginal statewide reductions in nitrate pollution, while reductions in phosphorus pollution have been more significant, but still lag.

Some major pollution sources (such as municipal wastewater treatment plants) have greatly improved their performance. However, the top source of these pollutants — agriculture — remains well behind the curve, and accounts for the vast majority of nitrogen and phosphorus pollution to the Mississippi River. 

The upcoming revision is an opportunity for the MPCA to consider what has worked (as well as what hasn’t), and adjust going forward. We’re excited to see that the draft has some encouraging improvements, particularly with its new emphasis on sustainable agriculture practices and living cover.

The MPCA is expected to finalize the plan later this year. If the current language stays, and if the agency includes some of the suggestions FMR and other partners submitted, it could be a sign of positive things to come for the Mississippi River, drinking water and aquatic ecosystems in Minnesota.

What we like in the draft

Leaning into CLC as a concept

When the state first developed the strategy a decade ago, continuous living cover ("CLC" for short) was a minor focus. The document instead leaned heavily on tactics like fertilizer management and technology upgrades at wastewater plants. 

The current iteration puts CLC cropping systems front and center, acknowledging that without millions of acres of living plants on the agricultural landscape year-round, we have no shot at reaching our nutrient reduction goals. 

As Dave Wall, lead scientist on the Nutrient Reduction Strategy, said during a July webinar, continuous living cover is "where we have the biggest potential for reductions in nitrogen moving to our waters."

The strategy calls for 8 million acres of CLC cropping systems in Minnesota, which would represent a massive increase in living roots in cropland soils year-round. 

This new emphasis is a validation of FMR’s approach to solving persistent water quality issues in the Mississippi River. A consensus is building that CLC agriculture is our best opportunity to protect the environment and public health, while also boosting rural economies and giving farmers more choice.

Our colleagues at the Forever Green Initiative deserve an enormous amount of credit for this. Without their work to develop new crops and build new markets, CLC would just be an idea without the substance to succeed in the real world. As more and more Forever Green-related products reach consumers, the proof of concept is becoming indisputable.

Creating a new CLC campaign, task force

A centerpiece of the updated draft Nutrient Reduction Strategy is the creation of a new "CLC Campaign & Task Force" that will develop a detailed plan to establish continuous living cover statewide. While many of the particulars for launching the task force still need to be worked out, this is an important step forward for statewide adoption of CLC cropping systems. 

We anticipate it will build on the example and lessons learned by our Forever Green Partnership, which has brought together many of the same stakeholders — researchers, farmers, agribusiness, policymakers and advocates like FMR — to chart the path toward more living cover.

Setting numeric goals for CLC acres

The draft strategy outlines specific numeric goals for CLC acreage in Minnesota, focusing on the first 1 million acres with a longer-term goal of 8 million acres. This reflects the reality that we can’t nibble around the edges of the agricultural system. We need impacts at a landscape scale. 

Creating a new CLC 'Index' and dashboard. 

The draft also proposes the development of an agricultural CLC index to track annual changes in landscape coverage over time, which would be included in a future dashboard that reports on progress toward the Nutrient Reduction Strategy’s goals/

One potential model is found in the 2023 Putting Down Roots report, which measures the proportion of the year that Minnesota’s crop portfolio provides living vegetative cover on the landscape. 

What we’re not sure about

How do we pay for it? 

The draft Nutrient Reduction Strategy is nothing if not ambitious. It estimates that doing all of the work to reach our nutrient reduction goals could cost on the order of $1 billion every year. We don’t see a scenario where that level of state funding is available during the lifespan of this plan. 

Yes we need CLC on millions of acres, but it also has to be financially sustainable. Prioritizing market-based CLC crops is how the state can thread that needle.

A prime example is winter camelina compared to winter rye. Both are cover crops that are planted in the fall (after primary crops are harvested), providing living roots in the soil through spring. 

• Winter camelina can then be harvested and used for biofuel, bioplastics and other industrial-scale end uses. As a result, it can be profitable for farmers and allows for farmer adoption with limited public support — reducing long-term costs for the state.
• In contrast, winter rye is typically killed in the field rather than harvested. Because it has limited market value, farmers who want to plant winter rye often need taxpayer aid to buy and plant seed. 

This subtle distinction adds up fast. Subsidizing 8 million acres of winter rye would cost Minnesota hundreds of millions of dollars every year, while a mature Camelina market could become largely self-funding over the long term. 

Unfortunately, the current draft of the Nutrient Reduction Strategy doesn’t draw that distinction as clearly as it needs to. In our comments to the MPCA, we stressed the absolute necessity to prioritize market-based practices over the cost-share model.

How will this play out in state policy and funding? 

The state has generally taken the Nutrient Reduction Strategy seriously as a lodestar for agency decisionmaking, designing programs to emphasize the strategy’s preferred tactics. Whether the plan’s reorientation toward CLC is reflected in future policy and budget decisions remains to be seen. 

The upcoming legislative session is not a regular budget year within the state’s two-year cycle, but we’ll still see some early signals of how seriously our leaders are taking this shift. 

We’ll be keeping a close eye on supplemental budget decisions from the Clean Water Council, as well as possible policy moves related to sustainable aviation fuel and other CLC programming. We’ll simultaneously be preparing for 2027, when agencies make their major asks for funding for the biennium.