FAQs on greenhouse gas emissions in feedlot environmental assessment worksheets

What approach is the MPCA taking to include greenhouse gas emissions in environmental assessment worksheets for feedlot proposals?

MPCA staff will estimate greenhouse gas emissions for environmental assessment worksheets on feedlot proposals. The MPCA uses environmental assessment worksheets and information received during the public comment process to determine if a more in-depth environmental impact statement is needed for the project. The information is also used to establish permit conditions that will protect the environment. The worksheets cover several factors, including potential for runoff, traffic changes, and air emissions such as hydrogen sulfide.

What are greenhouse gases and why are they important?

Greenhouse gases are chemicals that contribute to warming of the earth’s atmosphere and climate change. They include carbon dioxide, nitrous oxide and methane sulfur hexafluoride, hydrofluorocarbons, and perfluorocarbons. Those most commonly associated with feedlots are nitrous oxide and methane.

Minnesota’s climate is changing rapidly, and these changes — driven largely by human-caused emissions of greenhouse gases — are affecting people’s health, well-being, ways of life, and natural resources. For more information: Climate change in Minnesota

What feedlot proposals will be affected?

Only those proposals requiring an environmental assessment worksheet will be affected.

Minnesota law requires an environmental assessment worksheet for proposed feedlots with:

  • More than 1,000 animal units
  • More than 500 animal units in a sensitive area

Note: Minnesota uses "animal units" to quantify the size of livestock feedlots. One animal unit is equivalent to the amount of manure produced by a 1,000-lb. steer.

The requirement applies to both new facilities, and existing facilities proposing to expand.

When does this approach take effect?

It takes effect now. Going forward, the MPCA will estimate greenhouse gas emissions for all feedlot proposals requiring environmental review.

Why is the MPCA taking this approach?

For several reasons:

  • Environmental groups legally challenged the MPCA’s decision that an environmental impact statement on Daley Farms’ proposed expansion was not needed, and for issuing a feedlot permit to the project. In October 2019, the Minnesota Court of Appeals sent the environmental review process back to the MPCA, saying the agency failed to consider greenhouse gas emissions. To address the court’s decision, the agency supplemented the environmental assessment worksheet for Daley Farms with an estimate of greenhouse gas emissions.
  • Minnesota is addressing climate change on several fronts. The Environmental Quality Board is studying how state and local governments can effectively use Minnesota’s environmental review program to consider potential climate impacts. This approach allows the EQB’s work on incorporating climate change impacts into Minnesota’s environmental review processes to continue. Earlier this year, the MPCA released a study on how several agricultural practices that benefit water quality also reduce greenhouse gas emissions.
  • This approach provides consistency across projects, providing comparable and usable information about greenhouse gas emissions from feedlots.
  • This consistency also reduces the chance for future legal challenges on inclusion of greenhouse gas emissions in environmental review.
  • This approach allows MPCA to refine estimates of the amount of emissions from different agricultural practices and work with the industry to reduce those emissions.


Will this mean more work for feedlot proposers?

No. MPCA staff will estimate the greenhouse gas emissions for feedlot environmental assessment worksheets.

How will the MPCA estimate greenhouse gas emissions?

The MPCA will use a calculator from the U.S. Environmental Protection Agency that estimates emissions from:

  • Animal digestion: the number and size of animals determines how much methane is generated.
  • Manure storage: the number and size of animals determines how much manure is produced. The manner of storage (lagoon, barn floor, etc.) determines how the emissions are generated and whether the emissions are methane and/or nitrous oxide.
  • Manure land application: the number and size of animals determines how much manure is produced and the amount of nitrous oxide generated when land applied.

The calculator then converts the tons per source to tons of carbon dioxide for ease of reporting and comparing.

How will this approach affect permitting?

In order for the MPCA to issue a permit for a feedlot with 1,000 animal units, or 500 animal units in a sensitive area, the project’s environmental review will need to include an estimate for greenhouse gas emissions.

Environmental review and permitting are different in purpose and scope:

Environmental review generates information about a project’s effect on the environment. That information helps to inform permitting, other governmental decisions, and the public.

  • Environmental review is not approval or denial of a permit or project.
  • With respect to scope, environmental review is intended to be broad and address all aspects of a project that may affect the environment, regardless of whether such aspects are regulated through permitting.

Permitting identifies and specifies the conditions and requirements that ensure a project operates in a way that protects the environment.

  • It is decisional; if a permit cannot ensure compliance with environmental requirements, then the MPCA cannot issue the permit and the project cannot move forward. 
  • With respect to scope, a permit is typically more narrow, usually focusing on one specific environmental impact, such as wastewater discharge. A project undergoing environmental review might require more than one kind of permit.

Both environmental review and permitting typically involve a public process.

Is there a standard for greenhouse gas emissions?

There are no Minnesota or national air quality standards for greenhouse gas emissions.

Do projects other than feedlots need to include greenhouse gas emissions in their environmental review?

Yes. Proposals that require permits for air emissions, such as energy and ethanol plants, already include estimates of greenhouse gas emissions in their environmental review.

How can feedlot producers reduce greenhouse gas emissions?

While there is no standard for greenhouse gas emissions, all Minnesotans, including feedlot producers, can reduce greenhouse gas emissions by several means, mainly by reducing energy use. There are specific voluntary practices that producers can implement that reduce greenhouse gas emissions and improve water quality as outlined in this study: Agriculture and climate change.

For more information about what all Minnesotans can do: Effects of climate change in Minnesota

MPCA contact

Dan Card, MPCA Environmental Review Unit
651-757-2261 or dan.card@state.mn.us