Minnesota Statute 1989, Chapter 326, Article 6, Section 33, Subdivision 2b directed the nitrogen task force to develop recommendations for a nitrogen fertilizer management plan (NFMP) for the prevention, evaluation and mitigation of nonpoint source occurrences of nitrogen fertilizer in waters of the State. The nitrogen fertilizer management plan must include components which promote the prevention of contamination of water resources by inorganic nitrogen and develop appropriate responses to the detection of inorganic nitrogen from fertilizer sources in ground or surface water.
The NFMP must allow for evaluation of, and response to, nitrogen contamination of water resources on a state, regional or local basis. The structure of the NFMP must be flexible, in order to address the site specific nature of water resource contamination problems, and dynamic, to allow for adjustments to advancements in soil and crop management technology as well as water resource monitoring technology. The Act mandates that the NFMP contain both a voluntary BMP component and a component which allows for regulatory action in the form of Water Resource Protection Requirements (WRPRs).
In response to the legislative mandate, the task force developed a nitrogen fertilizer management plan with a coordinated, threephased structure. The three phases of the nitrogen fertilizer management plan are: (1) promotion of the voluntary adoption and implementation of BMPs; (2) evaluation of the adoption and effectiveness of the voluntary BMPs; and (3) response to instances wherein voluntary BMPs have not been adopted or are ineffective in mitigating the occurrence of nitrate in ground or surface water (this potentially includes regulatory action).
Best Management Practices are the cornerstone of the Nitrogen Fertilizer Management Plan; if effective BMPs are adopted widely by fertilizer users, nitrate levels in groundwater should decrease on a both a local and statewide basis. The individual BMPs promoted by the NFMP are based upon field research and practicality.
The practicality makes adoption of the BMPs more attractive while the research basis ensures that management practices which are adopted will minimize nitrate contamination of Minnesota water resources.
A three-tier approach was taken in the development of BMPs. The first tier consists of a set of statewide BMPs to be applied in a variety of agronomic situations. The second tier consists of BMPs tailored to regions defined primarily by very general soil characteristics and climatic conditions. The third tier addresses the existence of special situations which present unique management problems, These include such situations as irrigation agriculture, turf, areas near surface water, and coarse textured, non-irrigated soils. The BMPs of all three tiers are discussed in detail in Chapter 4.
The goal of the first phase of the NFMP is the promotion of the BMPs by various government and private entities. Successful promotion should result in the concomitant adoption of the BMPs by fertilizer users. Ideally, the promotion of the BMPs to fertilizer users should use existing delivery mechanisms when possible. This avoids the creation of new bureaucracies and allows fertilizer users to deal with known entities. It is important that all promotion activities be coordinated in order to ensure program consistency. The MDA and the University of Minnesota, with the local Soil and Water Conservation Districts (SWCD) providing a local coordination role especially in significantly contaminated regions, will act as the lead agencies in coordinating promotion efforts.
The benefit of including various groups in the promotion of BMPs is that each group has a traditional audience and will be most effective at reaching that audience. Repetition of a common or identical message will encourage BMP adoption. Furthermore, different individuals and user groups are more receptive to certain information sources than others. By providing a number of channels for education and information dissemination, there is an increased likelihood that most fertilizer users will be reached. A list of the recommended government agencies and private entities who will have a role in BMP information dissemination is included in the list of participants in section 3.5.
The task force recommends a variety of strategies be used by the various groups to promote the adoption of the BMPs, BMP adoption will be increased if there is wide demonstration of the BMPs to nitrogen fertilizer users. The following is a list of strategies that can be used in cooperative efforts among private groups, state agencies, local government and the UM.
a) Develop voluntary training programs for farmers, dealers, homeowners and gardeners
These programs should be incorporated into existing adult or citizen education programs. If no adult education programs are available in a given area, an alternative forum should be identified. Also, incentives should be offered to dealers and fertilizer users to encourage attendance at the courses.
b) Establish demonstration projects in conjunction with research on the effects of agricultural impacts on water quality on Agricultural Experiment Stations. Develop demonstrations of proven BMPs based on agronomic and fertilizer research on farms and develop model farms to conduct research, evaluate and demonstrate. Identify a similar formats for turf demonstration projects in urban areas.
The Experiment Stations provide a recognized research entity at which BMPs can be developed, evaluated and demonstrated under controlled field research conditions. Model farms such as the Lawler farm in Olmsted county provide an opportunity to research and demonstrate BMPs in various soil and hydrologically sensitive conditions. The model farms are also valuable because they are highly visible in regions of groundwater sensitivity. Demonstration farms and model farms should be highly visible to fertilizer users in the same region or sensitive area. By using local farms to demonstrate BMPs, the peer review system is brought into play.
It is important to distinguish between demonstration farms and model farms. Both may be established on private farms with fertilizer users working closely with Extension and/or the MDA. Each demonstration or model farm will follow a set of operating protocol which will be established by the University in conjunction with the MDA.
The primary goal of the demonstration farm is to demonstrate BMPs that have been developed through research and designated as BMPs by the MDA. The demonstration farms are intended to be highly visible to the public. These can be organized by the University, the Extension Service, or farm organizations.
The primary purpose of model farms is the evaluation of BMPs with proper scientific controls The information gained from model farm operation will be used to modify or endorse BMPs as well as develop research opportunities in a farm system. Model farms should be maintained longer than are demonstration farms because of the investment in the research capacity. Model farms are discussed further in Section 3.3.2.
c) Integrate nitrogen fertilizer BMPs into PAT programs. Include BMPs in related regulatory activities, such as mailings to restricted-use pesticide license holders.
This essentially provides another avenue by which to inform a variety of fertilizer users.
d) Include promotion of nitrogen fertilizer BMPs in the proposed crop consultant certification program to be administered by the MDA.
e) Develop a package of promotional materials directed at the fertilizer user. This information will be distributed by all promotional groups. This should include many media forms, including fliers, slide shows, and video demonstrations.
By using identical materials in promoting BMPs, program consistency is ensured and incorrect interpretation of NFMP intent is avoided. Also, the repetition of a common message will encourage adoption.
f) Educate the non-regulated (non-agricultural) public about the efforts being made toward minimizing nitrogen fertilizer affects on water quality.
Make press releases to newspapers and radio stations with local or statewide audiences. Encourage attendance of citizen groups at demonstration farms and model farms.
The Nitrogen Fertilizer Management Plan evaluation phase has two components: (1) evaluation of BMP adoption, and (2) evaluation of BMP effectiveness. Each component must be evaluated individually, and their combined effect must be evaluated as well. Evaluation of either component will be a complex process.
The results of BMP implementation may not be discernable at the level of changes in nitrate concentration of ground or surface water for a long period of time. Furthermore, changes in nitrate concentration observed over the course of a single year may or may not be related to the adoption of BMPs, In view of these difficulties, it is recognized that BMP adoption must be evaluated as well as BMP effectiveness in preventing or reversing the degradation of water quality.
BMP promotion and water quality must be evaluated on an ongoing basis so that promotion methods can be modified as necessary and so that the need for response to water quality degradation is identified. Evaluation is also important once the response phase is enacted to judge the effectiveness of the response action and to adjust and direct response activities.
The evaluation methods that follow are intended to be used at the state, regional and local level; movement from one level to another depends upon the scale and severity of the problem that is identified through evaluation. The methods can be used individually or in consort.
Evaluation of BMP adoption is important on a number of levels, Information on BMP adoption success can be collected in the interim following inception of BMP promotion but prior to completing full investigations of water resource quality. Adoption evaluation results at this point will provide feedback on promotion and information dissemination techniques and responsibilities. This can then provide an opportunity for modification and refinement of the promotion strategy. Adoption success information, interpreted at the regional level, may indicate areas where adoption rate is poor. These areas would then require intensified BMP promotion.
Although several strategies have been proposed, the task force has not produced final recommendations on BMP adoption evaluation strategies. The following are possible BMP adoption evaluation methods which have been discussed by the task force (these could be used concurrently or individually):
a) Mail Survey: A BMP adoption mail survey could be used prior to the initiation of BMP promotion and again at the end of a designated time period. This survey would indicate change in adoption rate over time and the percent of growers using BMPs both before and after NFMP implementation. Surveys could be designed to address each BMP tier; state, regional and special situation. The survey would be conducted by the MDA, for statewide surveys, or the appropriate Soil and Water conservation District, for localized surveys.
The survey should be statistically designed. It is recommended that fertilizer user surveys be designed to ask questions regarding rate, timing and form of nitrogen fertilizer applications rather than questions on implementation of specific BMPs. The answers to these questions would be translated to reflect whether BMPs are or aren't being adopted. This method ensures greater accuracy than asking questions specifically on adoption of specific BMPs.
b) Applicator and Dealer Survey: Private applicators (farmers), commercial applicators and dealers could be surveyed on awareness and implementation of BMPs at the certification and licensing training programs administered by the MDA.
Testing, required as a condition for certification for applicators of Restricted Use Pesticides, could be used as an opportunity to survey this segment of growers and applicators. Specific BMP training programs could also be developed.
c) Interviews: Farmers, dealers and extension agents selected as representative of a region or local area could be interviewed on adoption of BMPs. This information could supplement the survey data but would be available sooner and with greater frequency. Results would be extrapolated to represent a region or area. This could also occur on a statewide level.
This option would evaluate on-farm practices at a more personal level and would allow for interpretation of why BMPs had or had not been adopted at a state, region or local level. A potential problem may be the cost and/or the intrusive nature of an on-farm visit.
The intent of the NFMP is to prevent, reduce and mitigate the contamination of water resources by fertilizer nitrogen. The evaluation of BMP effectiveness, via water quality, vadose zone monitoring, and soil solution monitoring, is, in effect, a check on whether the NFMP is achieving this goal. Evaluation of BMP effectiveness is thus the critical juncture of the NFMP. The results of this evaluation provide a point of departure from which to refine BMP promotion strategies, launch further research or regulatory action, or define additional Special BMP Protection Areas.
Ground and surface water quality monitoring for effectiveness evaluation must take two directions:
1) Monitoring the effectiveness of individual BMPs by monitoring soil nitrate, and water quality through field research conducted by University personnel and in possible cooperation with other investigative units; and
2) Monitoring water quality on a state-wide and region-wide basis, and monitoring water quality and soil nitrates in Special BMP Promotion Areas, to provide an index of the overall effectiveness of BMP implementation.
The task force did not produce final recommendations on effectiveness monitoring methods, but did discuss some general directions for the effectiveness monitoring component; these are discussed below.
a) Monitoring Water Quality at Model Farms (see section 3.2.2) and Agricultural Experiment Stations (AES).
This provides a secondary check on whether BMPs are effective at the field level and under specific conditions. Such systems could be established in each region and Special BMP Promotion Area. The monitoring for this purpose could include soil analysis and vadose zone monitoring; these would provide indicators of nitrate movement in the soil profile prior to the time that effects would be noticed in groundwater.
Agricultural Experiment Stations present an obvious location for effectiveness evaluation of individual or multiple BMPs. The AES offer an established status and research role for this purpose.
Model Farms can be used to evaluate the effectiveness of BMPs in a relatively controlled environment, while maintaining high visibility to fertilizer users in the vicinity of the model farm. Model farms may include individual farms or clusters of farmers in a given area. Participation in a model farm program requires assessment and preparation of a nitrogen inventory, adherence to BMPs and carefully designed groundwater and soil solution monitoring. Cooperative efforts between the landowner/operator, research institutions and the various agencies and organizations is to be encouraged. Such farms would have a secondary purpose of demonstrating BMPs to neighboring farmers and other interested parties.
The model farm program would be designed to include representative farms for an area and would provide a method for evaluation of BMP effectiveness. A single model farm could demonstrate individual or multiple BMPs.
b) Water Resource Monitoring
Ground and surf ace water monitoring provides the field data necessary to judge whether nitrate concentrations in ground and surf ace water are increasing, decreasing, or staying the same. This information will be used to make decisions within the NFMP framework. Because this is perhaps the most important aspect of the evaluation phase, it is crucial that a strict and detailed protocol is developed for the design of monitoring networks, the collection and analysis of water samples and analysis of water quality data.
All monitoring participants must then adhere closely to this protocol. In selecting wells for inclusion in groundwater quality monitoring networks, it is important to identify wells which are vulnerable to contamination by alternative nitrogen sources (septic systems, livestock yards, etc,) and to eliminate such wells from the network. For sites where surface water is monitored, it is important to select appropriately representative sampling sites. If surface water sampling sites are selected in mixing zones, it is necessary to inventory potential alternative sources of nitrate which could contribute nitrate to the drainage system node above the mixing zone.
Many state and local agencies maintain or are developing various ground and surface monitoring networks. Existing nitrate data sources include municipal well testing programs, private well sampling programs, the MDA monitoring programs, the MPCA ambient monitoring programs and local monitoring efforts. It is desirable to use these existing data to the extent possible, yet it is also important to coordinate participating monitoring activities.
When existing monitoring efforts indicate areas where nitrate contamination is a problem, these areas are designated as special BMP Promotion Areas (see section 3.4.1). Monitoring in these areas must then be intensified and a monitoring network specific to that area must be designed. Concurrently, BMP promotion is also intensified. Existing ambient monitoring programs can continue to address overall water quality. Ongoing monitoring can be used to add, subtract, or modify the special BMP promotion area.
A nitrogen inventory of potential nitrogen sources, storage and use practices should be compiled by farmers in the Special BMP Promotion Area. This inventory would include on-farm septic systems, fertilizer storage, manure storage, feedlots, and nitrogen fertilizer use. Also, as part of the assessment of these areas, an inventory of other potential non-agricultural nitrate sources must be conducted. The inventories essentially allow for accounting of point-sources of nitrates.
The monitoring program described recognizes that there are areas which warrant greater concern than others and uses existing efforts to identify these areas. This approach also presents an opportunity for immediate action in areas which warrant it.
The general intent of the NFMP is to attempt, initially, to resolve nitrogen contamination problems by voluntary action and utilize a regulatory approach if the voluntary approach is ineffective. The framework for this philosophy is established by the Groundwater Protection Act of 1989 which mandates that Water Resource Protection Requirements (WRPRS) may be promulgated by rule by the MDA if the voluntary BMP approach is proven to be ineffective. If WRPRs are determined to be necessary, they should be based on proven agronomic or turf management BMPs and should be incorporated into the regional concept proposed. Adoption of WRPRs for fertilizer is prohibited by the legislature until after January 1, 1991.
Mitigation efforts may begin in response to either of two indicators: (1) ground and surface water quality monitoring results [effectiveness evaluation], and (2) the combined effects of BMP adoption evaluation and water quality monitoring. The response phase is intimately associated with the evaluation phase as reflected by its presentation in this section.
The structure of the response phase was an area of much discussion on the part of the task force. The task force discussion indicated that the structure must answer the following needs:
These components need to be considered at the state, regional, local or special situation level. The response may include voluntary or regulatory actions as stipulated in statute.
The task force recognized that the most acute and immediate need for response will likely occur at a local level. Therefore, a more detailed framework was discussed and recommended for this situation. This framework is described in Figure 3.2.
The same aspects of the recommendations for the Nitrogen Fertilizer Management Plan were applied to this framework. This framework is not meant to be applied at the state, regional or special situation level.
The following is a list of the various participants and their roles in the various phases of the Nitrogen Fertilizer Management Plan. The compilations of both the participants and their roles are dynamic and subject to adjustment.
Nitrogen Fertilizer BMPs: The State of Minnesota shall use turf BMPs in state parks, preserves, property, right-of-ways, etc.
The state should implement nitrogen fertilizer BMPs to utilize the technology, set an example and to demonstrate the BMP's effectiveness.
BMP Distribution: The RDCs should serve as an additional resource in distributing information about BMPs.
The RDCs can assist in the distribution of BMP information because of their contacts with various organizations and groups at the local level.
BMP Implementation: Township government should aid in distributing BMP information and evaluating the effectiveness of the BMPs.
Township government has the closest proximity to farmers in the rural areas. Iowa has used township boundaries in delineating sensitive areas for atrazine use. Township boundaries may be useful in delineating unique BMP areas within regions.
BMP Implementation: City government should help distribute nitrogen fertilizer information to lawn care industries, homeowners, municipal parks and golf courses. It should also evaluate the effectiveness of turf BMPs.
Some cities currently license or otherwise monitor fertilizer use. Nitrogen fertilizer usage in an urban setting requires additional monitoring. There is not a pre-emption statute for local ordinances regulating the sale and use of fertilizers.
BMP Promotion. SWCDs should promote local BMPs in a coordinated manner with other organizations and groups. The SWCD should be involved in demonstrations and model farm programs. SWCDs have an important function in local areas with significant nitrate contamination.
Local SWCDs are in frequent contact with growers and can provide an immediate contact and source of information regarding local BMPs. This is especially important in Special BMP Promotion Areas. In these areas the SWCD is responsible for information gathering and BMP implementation evaluation as well as co chairing public meetings and hearings.
BMP Promotion: The SCS should promote BMPs through their traditional role of technical advisors to the farmer. Existing programs such as the Anoka Sand Plains Initiative, cost shares and other water quality programs can be used to provide this information.
The SCS has a long standing role of providing technical assistance to the farmer. Water quality initiatives are now joining with soil conservation in the non-regulatory approach the SCS offers.
BMP Promotion: The MPCA and MDNR should be involved in the promotion and demonstration of BMPs in urban and rural areas.
These and other state and federal agencies have research and demonstration capabilities which can be used to communicate BMPs and to further promote their adoption.
BMP Evaluation: Existing water quality monitoring efforts conducted by these agencies are central to effectiveness monitoring.
BMP Promotion and Demonstration. FFA participation should be encouraged in programs involving BMP promotion and demonstration. Vocational-agricultural and adult education courses can also complement these efforts.
FFA projects can provide a method of training future farmers in the use of nitrogen fertilizer BMPs. Vocational-agricultural and adult education programs can be utilized to influence farmers and homeowners to adopt BMPs.
BMP Promotion and Demonstration: Private, profit and nonprofit organizations should involved in the promotion and demonstration of BMPs, especially when focusing on groups or individuals unwilling to deal with existing education structures.
Crop consultants, sustainable agriculture and environmental groups, community, service and religious organizations, educational consultants, etc. can be incorporated into BMP promotion to reach their respective audience.
BMP Promotion and Demonstration: These groups should be involved in the promotion and demonstration of nitrogen fertilizer BMPs, particularly to their membership.
Membership in these associations consists of fertilizer dealers, corn and soybean growers' associations, promotion councils, co-ops, vegetable processors, turf specialists, and others. Other associations can be incorporated as educators for their own members.
The Nitrogen Fertilizer Management Plan should complement other state and federal programs where possible. Programs that affect shoreland management and crop production, such as Reinvest in Minnesota (RIM), Conservation Reserve Program (CRP), and Shoreland Regulations need to be coordinated with the management plan. Efforts underway to provide technical expertise or funding such as the MPCA's Clean Water Partnership Program, or the Anoka Sandplain Project should be utilized and coordinated.
Programs currently under development, such as the Pesticide Management Plan and Well Head Protection need to consider the Fertilizer Management Plan. The programs may need to coordinate efforts significantly so as not to duplicate groundwater protection efforts. Finally, the Fertilizer Management Plan needs to incorporate the sensitivity mapping effort of the DNR when completed as appropriate and mandated by the Groundwater Protection Act.
Pesticide & Fertilizer Management Division
Minnesota Department of Agriculture (MDA), 625 Robert Street N, St. Paul, MN 55155-2538, email@example.com