[Project title:]{.underline} Environmental Results Program Applied to
Feedlots

[Applicant agency:]{.underline} Minnesota Pollution Control Agency

[Project contact:]{.underline} Kate Brigman

> Regional Environmental Division
>
> Minnesota Pollution Control Agency
>
> 1230 South Victory Drive
>
> Mankato, MN 56001
>
> Voice 507-389-1775 Fax 507-389-5422
>
> kate.brigman@pca.state.mn.us

[Funding requested:]{.underline} **[\[Financial information
redacted\]]{.mark}**

[Project period:]{.underline} January 1, 2005 -- December 31, 2006

(work begins before the anticipated award date of January 1, 2005)

***Current situation and need***

The MPCA has the responsibility to regulate the collection,
transportation, storage, processing, and land application of animal
manure for the prevention and abatement of water, air, and land
pollution. As of August 2004, MPCA estimates that over 30,000 regulated
animal feedlot and manure storage sites exist in Minnesota. Those sites
regulated are feedlots over 10 animal units (AU) if within shoreland and
over 50 AU if outside shoreland. Regulated storage areas store manure
for 100 or more animal units. Minnesota also regulates the rate,
location, and timing of manure application to soil. Current data shows
that 11,460 feedlots are located within 1000 feet of surface water (an
approximation of "within shoreland"). Beyond the issues present at the
animal holding area or manure storage site, manure application
activities have the potential to release nutrients into surface and
ground water supplies. It is important to prevent the contaminants in
manure from moving from the animal holding areas and manure storage
areas as well as from land application areas.

In manure, the constituents most impacting water quality include
phosphorus, nitrogen, biological oxygen demand, and disease-causing
organisms (pathogens). Human health and the environment are put at risk
from these water quality impact factors. The problems caused by the
contaminants or the results of environmental contamination have
different pathways of entry and source areas. Various types of gaseous
compounds emanating from manure are an additional human health and
environmental concern.

Watershed projects conducted through the Minnesota Clean Water
Partnership Program have diagnosed water quality problems in 37 project
sites throughout the state. Sixteen projects identified feedlots as
significant contributors of contaminants to lakes and streams. While the
statewide effects of contaminants from manure have not been completely
separated from other sources of pollution, it is clear that surface
water quality is being impacted from agricultural sources in general,
which includes discharges and runoff from feedlots and manure
application sites.

To address these issues, MPCA implemented its updated feedlot rules in
October 2000, which included a requirement that owners register their
feedlots and manure storage areas. Additionally, the MPCA focused its
staff on inspection and compliance. Over 30,000 sites are now
registered. Of the registered sites, approximately 600 are currently
regulated through NPDES permits; an additional estimated 200 will
require NPDES permits under EPA's new CAFO rules; the remaining sites
are regulated through state rules and permits.

In addition to permitting and registration requirements, all livestock
facilities required to have a permit, NPDES or state-issued, are
required to have a comprehensive nutrient management plan. Review of
plan record keeping is conducted as a portion of site inspections. State
rules will require nutrient management plans for all livestock
facilities greater than 300 AU by January 2006.

***Problem statement***

At existing rates of inspection, and given tight state and county
budgets, the estimated time to reach all 30,000 state feedlots would
exceed 10 years. In the meantime, MPCA and the citizens of Minnesota
have an incomplete grasp of whether these feedlots comply with the state
and federal rules. In addition, focusing only on the regulatory program
ignores the possibility that non-regulatory tools could be effective in
improving environmental performance and bringing feedlots into
compliance long before an inspection and formal compliance tools would
discover issues of poor performance or noncompliance.

***Project purpose***

The MPCA proposes to test an Environmental Results Program approach for
feedlots, with a special focus on preventive and whole-farm Best
Management Practices and management systems*.*

The Environmental Results Program (ERP) has the potential to
cost-effectively reduce environmental impacts in industry sectors
comprised of large numbers of facilities that, on their own might have
low impacts but taken together, may present a substantial cumulative
environmental risk. Businesses targeted so far by ERP include gas
stations, auto salvage yards, auto body and mechanical repair shops, dry
cleaners, and printers. ERP can help environmental agencies identify
previously unknown facilities, measure performance, increase regulatory
efficiency, and help improve overall environmental performance. ERP is
in part designed to help facilities that want to comply but don't
understand their requirements. Evidence suggests that ERP can motivate
operators to comprehensively review their environmental performance and
take needed action to come into compliance and adopt best practices.

Self-certification, assistance in partnership with the Minnesota Milk
Producers Association, and other ERP tools will help feedlots improve
environmental performance and compliance in a more timely way, and
without the typical level of MPCA and county effort. Partnership with
the producer associations will aid development and distribution of the
program. Statistical approaches will be used to help MPCA draw
conclusions about compliance rates in various feedlot sectors and sized
facilities, and will guide targeting of compliance assistance and
inspections.

The project also aims to extend the basic water quality protection and
land application management aspects of the feedlot rule to deal with
odors, dusts, pests, ancillary and maintenance operations, related feed
crop production, and many other aspects of operations, pushing toward a
multi-media, "whole-farm" management system.

***Project goals and objectives***

Recognizing that the stakeholder process involved may alter them
somewhat in the course of the project, goals and objectives for the
project include:

**GOAL 1**: Understand and communicate the universe of state and federal
feedlots in Minnesota and their compliance/performance vectors over time

> [OBJECTIVE 1]{.underline}: Maximize quality and completeness of MPCA's
> feedlot database
>
> [OBJECTIVE 2]{.underline}: Develop hard copy and electronic
> self-certification annual submittal system and integrate inspection
> data

**GOAL 2**: Maximize leverage through partnerships

> [OBJECTIVE 1]{.underline}: Strengthen producer (association)
> partnerships through project planning and implementation
>
> [OBJECTIVE]{.underline} 2: Develop partnerships such that performance
> improvement is lead by the producer associations.

**GOAL 3**: Test the ERP methodology in the field to determine
effectiveness of self-certification process on this regulated sector.

> [OBJECTIVE 1]{.underline}: Determine baseline conditions
>
> [OBJECTIVE 2]{.underline}: Operate facility self-certification cycle
>
> [OBJECTIVE 3]{.underline}: Follow-up inspections/assessments with all
> baseline facilities to gauge effectiveness of process, program
> materials and services in attaining compliance and multi-media
> performance goals
>
> [OBJECTIVE 4]{.underline}: Explore these possible research questions:

-   Does self-certification with Minnesota Milk Producers Association
    (MMPA) or state or county assistance yield equal, better, or earlier
    compliance results and better overall performance than that
    accomplished by dairies that do not undergo a self-certification
    process? What are the relative costs?

-   Does self-certification without significant MMPA or state or county
    assistance yield equal, better, or earlier compliance results and
    better overall performance than that accomplished by dairies that do
    not undergo a self-certification process? What are the relative
    costs?

-   Does self-certification with MMPA or state or county assistance
    yield equal, better, or earlier compliance results and better
    overall performance than that accomplished under the state interim
    permit or Open Lot Agreement programs? What are the relative costs?

Interim permits, issued by counties and the MPCA, are essentially
return-to-compliance schedules of 24-27 months for non-CAFO feedlots
(larger than 300 AU) inspected and found to be out of compliance. Open
Lot Agreements allow feedlots under 300 AU to attain 100% compliance by
2010.

This project will allow MPCA to explore whether an approach modeled upon
the Environmental Results Program can help achieve these goals, while
improving regulatory cost-effectiveness.

### **Geographic focus**

Initially, MPCA intends to pilot the ERP approach in 2 dairy-rich
counties along the Mississippi River: Stearns in central Minnesota and
Winona in southeastern Minnesota. Depending on results, MPCA may then
extend the experiment to dairies statewide or test the approach in other
feedlot sectors such as swine or turkeys (or both).

***Partners, Roles and Responsibilities***

-   Minnesota Milk Producers Association staff and members will assist
    in project design, in definition of compliance goals, in drafting
    the compliance/performance workbook and self-certification, in
    recruiting participants, and in deploying certifying technicians. If
    possible, MPCA will contract with MMPA to help cover the cost of
    on-farm technician assistance.

-   Winona and Stearns County staff will assist in project design, in
    definition of compliance goals, in drafting the
    compliance/performance workbook and certification materials, in
    training of MMPA technicians, and in conducting baseline and
    verification inspections.

-   MPCA has built its current workplan assuming a minimum of 150
    participants: 50 undertaking baseline inspection, ERP certification,
    and post-certification inspection; 50 having already undertaken MMPA
    Five-Star certification and undergoing post-certification inspection
    as part of this project, and; 50 undergoing baseline and follow-up
    inspection concurrently with ERP inspections. More sites will be
    added if enough volunteers and resources are available.

-   EPA will provide partial support for the project through an
    Innovations cooperative agreement, and assist in project design and
    review of data gathered and results reported.

-   MPCA staff will lead project design, assist in definition of
    compliance goals, in drafting the compliance/performance workbook
    and certification materials, in training of MMPA technicians and
    county staff, and in conducting baseline and verification
    inspections. MPCA staff will work with external experts to determine
    appropriate sample sizes, and to collect and analyze metrics
    appropriately.

-   MPCA Agency-wide Planning and Assistance staff will provide
    technical assistance and administration of the EPA cooperative
    agreement.

***Stakeholder involvement***

Throughout the project, MPCA will consult with the partners listed above
as an advisory group. In the initial stages, this group will advise on
compliance and performance goals for project participants, project
design and the timing of tasks. Further on, the group will provide input
on the content and presentation of workbooks, outreach, reporting forms,
the electronic reporting interface, and ultimately the conclusions
reached based on data generated by the pilot.

Beyond the participants, MPCA will seek opportunities for communication
with the MN Department of Agriculture, Board of Soil and Water Resources
(BWSR) and local Soil and Water Conservation Districts (SWCD), the
MPCA's Citizens Board, commissioners in the participating counties, and
Clean Water Partnership (CWP) citizens groups in the participating
counties. Communication with these groups would occur at intervals: soon
after initial project design is complete; after the initial round of
inspections; after the certification phase; after the post-certification
inspections and draft conclusions are complete, and; upon completion of
the final project report when recommendations are made on future steps.

***Bios***

Project Manager -- Kate Brigman

-   MPCA water quality staff, feedlot compliance, enforcement and
    permitting four years;

-   Lead CAFO staff for six south-central Minnesota counties;

-   Feedlot program contact for a Supplemental Environmental Project
    (SEP) for ongoing enforcement with a NPDES water treatment facility
    at a Carver County creamery. Project is to apply MMPA Environmental
    Quality Assurance program to dairies supplying milk to the creamery;

-   MPCA liaison to Minnesota Association of County Feedlot Officers
    annual conference agenda committee;

-   County zoning administrator and delegated county feedlot officer in
    Waseca County for one year;

-   Prior to Waseca County, was the local water planner for Le Sueur
    County for six and a half years where she was the lead program
    assistant for three Phase I and two Phase II Clean Water Partnership
    Projects and was the non-delegated county contact for livestock
    producers until the county became delegated.

Grant Champion/Lead Investigator -- Bob Finley

-   MPCA Southwest Region Manager;

-   MPCA Feedlot Program Manager;

-   For the previous 4 years, was the Director of the Water Resources
    Center at Minnesota State University, Mankato;

-   Served for a number of years as the Executive Director of the
    Redwood-Cottonwood Rivers Control Area;

-   Over the past 20 years, has managed dozens of research and
    implementation projects at the watershed and basin scale, most of
    which examined the relationship between agriculture and surface
    water quality in southern Minnesota;

-   Considerable experience interpreting and managing water quality data
    along with experience in the design and application of surface water
    monitoring plans.

Project Consultant -- Myrna Halbach

-   Feedlot program manager for MPCA for 4.5 years (oversaw final rule
    development and implementation from October 1999) - in that time,
    29,000 feedlots were registered and nearly 600 NPDES permits issued
    including the largest dairy in the state (\~5000 head);

-   Worked closely with Minnesota Milk Producers on a number of
    projects, including

    -   Development of mapping tool to account for regulations,
        environmentally sensitive features, population, etc. in siting
        or expanding dairies;

    -   Development of Five-Star whole farm audit program conducted by
        technicians, assisting in developing the concept, reviewing
        materials for accuracy and appropriateness, training technicians
        and reviewing achievements;

-   Worked with MN Pork Producers on a similar third party audit
    program;

-   Licensed, registered professional engineer (Civil Engineering -
    Environmental specialty) and biochemistry Major.

***Project workplan***

Applying ERP to feedlots presents unique challenges. MPCA and others
spent considerable energy in the 1990s to enact revised rules regulating
feedlots in Minnesota. Increased or different regulation was not popular
for livestock, particularly smaller dairies, which were going out of
business at an increasing rate. A rule or policy mandating a universal
environmental protection and compliance certification program such as
ERP under the program is viewed by MPCA as unworkable, at least until
such a program is piloted successfully. Therefore, MPCA has proposed a
voluntary ERP model for the feedlot pilot.

As MPCA staff have discussed the project plan with EPA and others in
greater detail, it has become clear that using only volunteers in the
pilot will have significant implications for project design. First and
foremost, it will be impossible in advance of actually recruiting the
volunteers to know how many will be available and of what types of
dairies. Both the number and types of dairies volunteering will affect
the extent to which the volunteer population reflects the variability in
the overall population of dairies. Further, the fact that dairies will
be volunteering to certify, rather than being randomly selected,
represents a source of measurement bias that will make it difficult to
definitively compare their performance to the control group and to
extrapolate the results of this experiment to the rest of the
population. As a result, MPCA will have to accept up-front uncertainty
as to the scope of conclusions.

Following are some descriptors of dairies which MPCA has discussed as
potentially-significant variables that may influence the environmental
performance of dairies. To the extent possible, the control group will
be matched to key characteristics of the volunteer group to better
facilitate comparison. Note that only the first two or three will likely
be used to actually limit subsets of the sample or control group.

1.  Size (under 300 animal units, 300-1000 A.U., and over 1000 A.U., or
    714 head of dairy cows over 1000 pounds) -- inclusion of the 1000+
    A.U. group would help understand the status of dairies previously in
    the state program but now subject to federal CAFO regulations and
    NPDES permitting -- this would include farmers with 714-1000 head of
    cows who were previously unpermitted;

2.  Previous one-on-one contact (inspection or assistance) with MPCA, a
    county, or the MMPA;

3.  County location;

4.  Presence of an open lot (but not in an Open Lot Agreement);

5.  Sites where no treatment structure exists to receive milkhouse
    waste;

6.  Proximity to surface water (less than 1000 feet from a lake; less
    than 300 feet from a stream);

7.  Presence of surface tile inlet(s) in fields receiving open lot
    runoff;

8.  Existing certification to the MMPA Environmental Quality Assurance
    ("Five-Star") standard;

9.  MMPA membership.

Under number 1 above, the MPCA has no intention of using the ERP process
as a stand-in for issuing individual or general NPDES permits to those
facilities required to apply for them under federal and state law. In
addition, due to the voluntary nature of the pilot and the resulting
small sample size, MPCA does not expect that self-certifications during
the project period will serve as functional equivalents for inspections.
That would require full implementation of a mandatory ERP program and
further discussion with EPA.

Uncertainty about the final size of the volunteer pool will also mean
that resource commitments and timelines can only be finalized after
recruitment is complete. Therefore, this project workplan will be based
on a goal of 50 participating volunteers and a control group of 50
non-participants, chosen as randomly as possible while also being
selected to match the volunteer group's profile. Both groups would
undergo baseline and follow-up inspections, but only the participants
would have access to MMPA technician assistance and submit their
certifications.

Another significant group will also be inspected by MPCA. So far, MMPA
has successfully guided 50 dairies to "Five-Star" status, which means
the dairies have been certified by the association as in compliance and
as addressing a list of "whole-farm" performance issues beyond those
regulated by MPCA. This group is entirely self-selected and very likely
not representative. However, a post-certification inspection will yield
useful data on the accuracy of their self-certifications. MPCA and
stakeholders will make final decisions on the timing of such inspections
later. It could be advantageous to inspect some of the Five-Star sites
right away so that if there are compliance or performance gaps between
MPCA and MMPA expectations of a Five-Star dairy, resolution of these
gaps can be built into the pilot project.

The timeline for implementation is another challenge that will strongly
influence the results measured and reported *within the project period*,
particularly for smaller dairies with fewer resources. MPCA will attempt
to leverage as much existing lake and stream monitoring effort and data
as possible to draw conclusions about the impacts of improvement efforts
by farmers, particularly where they are grouped or located in priority
areas (like watersheds being actively studied for TMDL development). In
addition, Board of Water and Soil Resources (BWSR) models and the
Feedlot Evaluation (FLEval) model should allow MPCA to project impacts
based on improvements completed within the project period, or planned
but not completed within the project period. These models will be
especially useful where open lots exist (as is the case in a majority of
dairies). MPCA expects to rely on models rather than actual data to
estimate environmental impacts, since it is unlikely that monitoring
data can be linked to the control group.

We should also note that we cannot say with certainty at this point
whether both Stearns and Winona counties will participate in the same
functions. Stearns would be MPCA's first choice for recruiting the
volunteer dairies because of the number of dairies (1240, over 3 times
as many as the next largest dairy county) and because MMPA is officed
there. Winona County would add geographic and demographic diversity.
However, if having samples from 2 separate counties makes statistical
analysis too difficult, then Winona or another county or counties could
be the source of the control group. These decisions will have to await
deeper discussion with stakeholders and a statistician.

Following are tasks, subtasks, timelines for completion, measures, and
where applicable, deliverables and milestones.

  -----------------------------------------------------------------------
  Shaded areas occur prior to or after MPCA expenditure of cooperative
  agreement (CA) funds.

  -----------------------------------------------------------------------

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **1. Stakeholder Process**    | *    | *    |           |           |
|                               | *Mon | *Fri |           |           |
|                               | 8/9/ | 12   |           |           |
|                               | 04** | /29/ |           |           |
|                               |      | 06** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Establish internal        | Mon  | Tue  |           |           |
|     stakeholder group to      | 8/   | 8/3  |           |           |
|     provide feedback on the   | 9/04 | 1/04 |           |           |
|     project                   |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Maintain external partner | Wed  | Wed  | Meeting   |           |
|     group                     | 9/   | 10/1 | minutes,  |           |
|                               | 1/04 | 3/04 | network   |           |
+-------------------------------+------+------+-----------+-----------+
| (c) With external partner     | Wed  | Wed  | Completed | EBPIs     |
|     group, develop            | 9/   | 10/1 | EBPIs     | needed    |
|     environmental business    | 1/04 | 3/04 |           | for       |
|     practice indicators       |      |      |           | inspector |
|     (EBPIs), including shared |      |      |           | c         |
|     compliance goals          |      |      |           | hecklist, |
|                               |      |      |           | t         |
|                               |      |      |           | rainings, |
|                               |      |      |           | database  |
+-------------------------------+------+------+-----------+-----------+
| (d) With external partner     | Wed  | Wed  | Completed |           |
|     group, develop marketing  | 9/   | 10/1 | strategy  |           |
|     strategy                  | 1/04 | 3/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Determine if policy       | Th   | Fri  | Agreement | I         |
|     changes are necessary     | 10/1 | 12/3 | on        | ncentives |
|     (e.g., self-audit         | 4/04 | 1/04 | workable  | must be   |
|     protection or             |      |      | i         | in place  |
|     project-specific          |      |      | ncentives | before    |
|     enforcement policy to act |      |      |           | program   |
|     as incentive)             |      |      |           | materials |
|                               |      |      |           | and       |
|                               |      |      |           | marketing |
+-------------------------------+------+------+-----------+-----------+
| (f) With external partner     | Mon  | Fri  | Completed |           |
|     group, develop a plan for | 1/   | 1/2  | comm      |           |
|     communicating with all    | 3/05 | 8/05 | unication |           |
|     relevant stakeholder      |      |      | plan      |           |
|     groups                    |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (g) With external partner     | Mon  | Mon  | Plan      | Available |
|     group, develop a plan for | 2/   | 12/1 | complete  | for final |
|     long-term measurement of  | 7/05 | 8/06 |           | report to |
|     environmental impacts of  |      |      |           | EPA,      |
|     project results           |      |      |           | state     |
|                               |      |      |           | sta       |
|                               |      |      |           | keholders |
+-------------------------------+------+------+-----------+-----------+
| (h) With external partner     | Mon  | Fri  |           |           |
|     group, develop data,      | 1/   | 12/2 |           |           |
|     draft conclusions, and    | 3/05 | 9/06 |           |           |
|     reports to EPA and other  |      |      |           |           |
|     stakeholders              |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (i) Periodic check-in with    | Mon  |      |           |           |
|     Feedlot Management Team   | thly |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (j) Communication with        | Info |      |           |           |
|     Governor's Livestock Task | rmal |      |           |           |
|     Force                     |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+

Stakeholder Process Measures:

1.  Partners understand project goals -- indicated by consensus and
    satisfaction coming out of external partner meetings.

2.  Partners' willingness to market on MPCA's behalf -- indicated by
    consensus and partners delivering the product and level of effort
    identified in marketing strategy.

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **2. EPA cooperative          | *    | *    |           |           |
| agreement**                   | *Thu | *Mon |           |           |
|                               | 6    | 2    |           |           |
|                               | /17/ | /28/ |           |           |
|                               | 04** | 05** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Attend Chicago meeting    | Thu  | Fri  |           |           |
|     for SIG winners           | 6/1  | 6/1  |           |           |
|                               | 7/04 | 8/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Develop detailed ERP      | Tue  | Mon  | MS        |           |
|     Gantt chart               | 7/   | 8/1  | Project   |           |
|                               | 6/04 | 6/04 | workplan  |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Develop a detailed ERP    | Tue  | Mon  |           | Needed    |
|     implementation strategy   | 7/2  | 8/1  |           | for CA    |
|                               | 0/04 | 6/04 |           | proposal  |
+-------------------------------+------+------+-----------+-----------+
| (d) Revise EPA CA proposal    | Mon  | Mon  |           |           |
|                               | 6/2  | 8/1  |           |           |
|                               | 1/04 | 6/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Develop EPA performance   | Mon  | Fri  |           | Needed    |
|     measurements              | 6/2  | 7/1  |           | for CA    |
|                               | 1/04 | 6/04 |           | proposal  |
+-------------------------------+------+------+-----------+-----------+
| (f) Develop EPA Quality       | Mon  | Fri  | Draft     |           |
|     Assurance Project Plan    | 7/1  | 7/3  | 8/3/04    |           |
|     Framework                 | 9/04 | 0/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (g) Internal stakeholder and  | Wed  | Thu  | Draft     |           |
|     EPA review process        | 8/   | 8/1  | 8/3/04    |           |
|                               | 4/04 | 2/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (h) Finalize proposal         | Fri  | Tue  |           | 2 wks     |
|     narrative                 | 8/1  | 8/1  |           | approval  |
|                               | 3/04 | 7/04 |           | at MPCA   |
+-------------------------------+------+------+-----------+-----------+
| (i) Submit final proposal to  | Tue  | Tue  | Target    | To        |
|     EPA                       | 8/3  | 8/3  | 8/31/04   | execute   |
|                               | 1/04 | 1/04 |           | CA by     |
|                               |      |      |           | 12/31     |
+-------------------------------+------+------+-----------+-----------+
| (j) EPA review and approval   | Tue  | Mon  |           |           |
|     of CA proposal            | 8/1  | 10/1 |           |           |
|                               | 7/04 | 1/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (k) EPA delivers money to     | Mon  | Wed  |           | Assume    |
|     MPCA                      | 12/  | 12/3 |           | 12/31/04  |
|                               | 1/04 | 1/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (l) Revise full project       | Mon  | Mon  |           | Finalize  |
|     workplan                  | 1/   | 1/3  |           | partner   |
|                               | 3/05 | 1/05 |           | roles     |
+-------------------------------+------+------+-----------+-----------+
| (m) Finalize full project     | Tue  | Mon  | Final     | Goals for |
|     workplan                  | 2/   | 2/2  | workplan  | end use   |
|                               | 1/05 | 8/05 |           | of ERP    |
|                               |      |      |           | tool set, |
|                               |      |      |           | guiding   |
|                               |      |      |           | st        |
|                               |      |      |           | atistical |
|                               |      |      |           | me        |
|                               |      |      |           | thodology |
|                               |      |      |           | (if       |
|                               |      |      |           | feasible) |
+-------------------------------+------+------+-----------+-----------+

EPA Cooperative Agreement Measures:

1.  Completed at MPCA by 8/31/04

2.  Executed by EPA by 12/31/04

3.  Final project workplan by 2/28/05

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **3. Contract(s) for          | *    | *    |           |           |
| support**                     | *Wed | *Mon |           |           |
|                               | 9/1/ | 1/3/ |           |           |
|                               | 04** | 05** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) MPCA develops RFP and/or  | Wed  | Wed  |           | St        |
|     sole source as needed     | 9/   | 10/1 |           | akeholder |
|                               | 1/04 | 3/04 |           | input     |
+-------------------------------+------+------+-----------+-----------+
| (b) Contractor(s) develops    | Mon  | Fri  |           |           |
|     workplan and              | 10/1 | 11/1 |           |           |
|     qualifications            | 8/04 | 2/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (c) MPCA awards contract(s)   | Mon  | Mon  | Contract  | Awaits    |
|     for entire project period | 11/1 | 1/   | paperwork | EPA       |
|                               | 5/04 | 3/05 |           | execution |
+-------------------------------+------+------+-----------+-----------+

Contract for Support Measures:

1.  On-time execution (1/3/05)

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **4. Facility ERP database**  | *    | *    |           |           |
|                               | *Wed | *Mon |           |           |
|                               | 9/1/ | 6    |           |           |
|                               | 04** | /20/ |           |           |
|                               |      | 05** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Define facility universe  | Wed  | Thu  |           |           |
|     characteristics           | 9/   | 9/3  |           |           |
|                               | 1/04 | 0/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Develop quality assurance | Wed  | Thu  |           |           |
|     procedures for            | 9/   | 9/3  |           |           |
|     development of facility   | 1/04 | 0/04 |           |           |
|     universe                  |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Identify facilities from  | Wed  | Wed  | Full      | All EBPIs |
|     various sources           | 9/   | 10/1 | facility  | and       |
|                               | 1/04 | 3/04 | set for   | facility  |
|                               |      |      | part      | d         |
|                               |      |      | icipating | atapoints |
|                               |      |      | counties  | known     |
|                               |      |      |           | before    |
|                               |      |      |           | d         |
|                               |      |      |           | eveloping |
|                               |      |      |           | database  |
+-------------------------------+------+------+-----------+-----------+
| (d) Develop data entry points | Thu  | Mon  | Delta     |           |
|     (to accommodate ALL       | 10/1 | 2/2  | feedlot   |           |
|     project data, not just    | 4/04 | 1/05 | database  |           |
|     inspections) within       |      |      | adapted   |           |
|     existing feedlot database |      |      |           |           |
|     in Delta system           |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Draft certification and   | Mon  | Fri  |           |           |
|     notification form content | 1/   | 2/1  |           |           |
|                               | 3/05 | 1/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (f) Revise forms and conduct  | Mon  | Fri  | Paper     | Adaptable |
|     further internal review   | 2/1  | 3/1  | forms     | to web    |
|                               | 4/05 | 8/05 | complete  | interface |
+-------------------------------+------+------+-----------+-----------+
| (g) Input facility data into  | Tue  | Mon  |           |           |
|     database                  | 2/2  | 2/2  |           |           |
|                               | 2/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (h) Quality Assurance for     | Tue  | Mon  | QA/QC     | QAPP (and |
|     Facility Universe         | 3/   | 3/2  |           | staff) in |
|                               | 1/05 | 8/05 |           | place     |
+-------------------------------+------+------+-----------+-----------+
| (i) Finalize facility         | Mon  | Mon  | Facility  | Universe  |
|     universe                  | 3/2  | 3/2  | universe  | data      |
|                               | 8/05 | 8/05 | data      | available |
|                               |      |      | entry     | for       |
|                               |      |      |           | sample    |
|                               |      |      |           | g         |
|                               |      |      |           | eneration |
+-------------------------------+------+------+-----------+-----------+
| (j) Develop a procedure for   | Tue  | Mon  |           | Program   |
|     handling inspection/cert  | 3/   | 3/2  |           | staff     |
|     data collection/entry     | 8/05 | 1/05 |           | trained   |
+-------------------------------+------+------+-----------+-----------+
| (k) Draft the database        | Tue  | Mon  |           |           |
|     screens for               | 3/2  | 5/   |           |           |
|     inspection/certification  | 2/05 | 2/05 |           |           |
|     inputs                    |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (l) Internal review of        | Tue  | Mon  |           | Use data  |
|     database screens          | 5/   | 5/   |           | from      |
|                               | 3/05 | 9/05 |           | Five-Star |
|                               |      |      |           | dry run   |
|                               |      |      |           | in        |
|                               |      |      |           | spections |
|                               |      |      |           | (7a)      |
+-------------------------------+------+------+-----------+-----------+
| (m) Internally test database  | Tue  | Mon  |           |           |
|                               | 6/   | 6/1  |           |           |
|                               | 7/05 | 3/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (n) Finalize database for     | Tue  | Mon  | Final     |           |
|     inputs                    | 6/1  | 6/2  | screens   |           |
|                               | 4/05 | 0/05 | set       |           |
+-------------------------------+------+------+-----------+-----------+
| (o) Program statistical       | Tue  | Mon  |           | Report    |
|     reporting functions into  | 6/2  | 7/1  |           | functions |
|     the database, if possible | 1/05 | 8/05 |           | developed |
|                               |      |      |           | or easily |
|                               |      |      |           | provided  |
|                               |      |      |           | by        |
|                               |      |      |           | s         |
|                               |      |      |           | ubstitute |
|                               |      |      |           | function  |
|                               |      |      |           | (i.e.     |
|                               |      |      |           | download  |
|                               |      |      |           | elect     |
|                               |      |      |           | ronically |
|                               |      |      |           | to        |
|                               |      |      |           | existing  |
|                               |      |      |           | st        |
|                               |      |      |           | atistical |
|                               |      |      |           | package   |
|                               |      |      |           | like      |
|                               |      |      |           | Minitab)  |
+-------------------------------+------+------+-----------+-----------+
| (p) Develop the database      | Tue  | Mon  | Final     | Ready for |
|     screens for outputs       | 7/   | 7/2  | database  | use       |
|                               | 5/05 | 5/05 |           |           |
+-------------------------------+------+------+-----------+-----------+

Facility ERP Database Measures:

1.  Universe of dairies well-documented statewide and in participating
    counties -- indicated by number of dairies missed and later located
    by CFOs or MPCA staff.

2.  MPCA users able to input, use, analyze -- indicated by training
    post-test, longer-term satisfaction, and documented error rate.

+-------------------------------+------+------+-----------+-----------+
| *NOTE: This task may be       | S    | Fi   | Del       | M         |
| delayed depending on MPCA     | tart | nish | iverables | ilestones |
| priority-setting.*            |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| **5. Electronic interchange** | *    | *    |           |           |
|                               | *Mon | *Fri |           |           |
|                               | 9/6/ | 7    |           |           |
|                               | 04** | /28/ |           |           |
|                               |      | 06** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Negotiate with            | Mon  | Mon  |           | Decision  |
|     Information Systems to    | 9/   | 2/2  |           | on        |
|     get into queue for Web    | 6/04 | 8/05 |           | fe        |
|     interface development     |      |      |           | asibility |
|                               |      |      |           | of        |
|                               |      |      |           | c         |
|                               |      |      |           | ontinuing |
|                               |      |      |           | EI        |
|                               |      |      |           | de        |
|                               |      |      |           | velopment |
+-------------------------------+------+------+-----------+-----------+
| (b) Agree on division of      | Mon  | Fri  | M         |           |
|     labor between counties on | 1/3  | 3/1  | emorandum |           |
|     data entry                | 1/05 | 8/05 | of        |           |
|                               |      |      | Agreement |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Draft Web interface for   | Tue  | Fri  |           |           |
|     certifications and        | 3/2  | 12/3 |           |           |
|     notifications (as needed) | 2/05 | 0/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (d) External review of        | Tue  | Fri  |           | User      |
|     interface for             | 1/   | 2/2  |           | workshop  |
|     certification &           | 3/06 | 4/06 |           |           |
|     notification forms        |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Revise and beta test Web  | Mon  | Fri  |           | User beta |
|     interface                 | 2/2  | 5/   |           | test      |
|                               | 7/06 | 5/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (f) Prepare near final        | Mon  | Fri  |           |           |
|     database, including       | 5/   | 6/   |           |           |
|     integrated input/web      | 8/06 | 2/06 |           |           |
|     interfaces                |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (g) Finalize Web interface    | Mon  | Fri  | Web       |           |
|     and database links        | 6/   | 7/2  | interface |           |
|                               | 5/06 | 8/06 | /firewall |           |
+-------------------------------+------+------+-----------+-----------+

Electronic Interchange Measures:

1.  Replicate stormwater interchange at lower cost -- time to completion
    versus stormwater or other web exchange projects (from time-tracking
    records)

2.  Dairies able and willing to use EDI -- (short-term) evaluations from
    user workshop/beta test, (long-term) electronic versus paper
    submittals

3.  Decreased paper use and cost of handling -- based on average
    sheets/envelopes/mailing and mailing costs

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **6. Statistical              | *    | *    |           |           |
| design/sampling**             | *Wed | *Fri |           |           |
|                               | 9/1/ | 6    |           |           |
|                               | 04** | /20/ |           |           |
|                               |      | 05** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Locate (and retain if     | Wed  | Fri  | Contract, | Optimize  |
|     necessary) statistical    | 9/   | 10/1 | if needed | Cadmus'   |
|     expertise                 | 1/04 | 5/04 |           | time with |
|                               |      |      |           | a         |
|                               |      |      |           | ssistance |
|                               |      |      |           | by MPCA   |
|                               |      |      |           | staff     |
|                               |      |      |           | p         |
|                               |      |      |           | roficient |
|                               |      |      |           | in        |
|                               |      |      |           | st        |
|                               |      |      |           | atistical |
|                               |      |      |           | analysis  |
+-------------------------------+------+------+-----------+-----------+
| (b) Generate 2 to 3 scenarios | Mon  | Fri  |           | Be        |
|     based on different        | 1/   | 4/   |           | prepared  |
|     responses by participants | 3/05 | 1/05 |           | for       |
|                               |      |      |           | r         |
|                               |      |      |           | ecruiting |
|                               |      |      |           | results,  |
|                               |      |      |           | when      |
|                               |      |      |           | known     |
+-------------------------------+------+------+-----------+-----------+
| (c) Draft the statistical     | Mon  | Fri  | Draft     |           |
|     methodology               | 4/   | 4/2  | me        |           |
|                               | 4/05 | 9/05 | thodology |           |
+-------------------------------+------+------+-----------+-----------+
| (d) Internal and external     | Mon  | Fri  |           | C         |
|     review of statistical     | 5/   | 5/2  |           | oordinate |
|     methodology (includes EPA | 2/05 | 7/05 |           | with      |
|     review and comment)       |      |      |           | stak      |
|                               |      |      |           | eholders, |
|                               |      |      |           | EBPI, and |
|                               |      |      |           | workplan  |
|                               |      |      |           | de        |
|                               |      |      |           | velopment |
+-------------------------------+------+------+-----------+-----------+
| (e) Finalize statistical      | Mon  | Mon  | Final     | Volunteer |
|     methodology               | 5/3  | 6/   | me        | pool      |
|                               | 0/05 | 6/05 | thodology | c         |
|                               |      |      |           | ompletion |
|                               |      |      |           | required  |
|                               |      |      |           | before    |
|                               |      |      |           | method    |
|                               |      |      |           | finalized |
+-------------------------------+------+------+-----------+-----------+
| (f) Amend and secure final    | Tue  | Tue  | Final     | QAPP      |
|     approval of QAPP          | 6/   | 6/1  | QAPP      | final     |
|                               | 7/05 | 4/05 |           | before    |
|                               |      |      |           | sampling  |
|                               |      |      |           | begins    |
+-------------------------------+------+------+-----------+-----------+
| (g) Generate sample from      | Wed  | Mon  | Complete  | Samples   |
|     volunteer participants,   | 6/1  | 6/2  | samples   | ready for |
|     and sample for control    | 5/05 | 0/05 |           | data      |
|     group                     |      |      |           | entry     |
|                               |      |      |           | when      |
|                               |      |      |           | database  |
|                               |      |      |           | de        |
|                               |      |      |           | velopment |
|                               |      |      |           | allows    |
+-------------------------------+------+------+-----------+-----------+

Statistical Design/Sampling Measures:

1.  Study design maximizes insights into research questions (see
    Objective #4 under Goal 3), within policy and resource constraints.

2.  Feasibility overlay -- representative samples can be processed
    without drawing significantly on program staff not already assigned
    to the project.

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **7. Inspector checklist**    | *    | *    |           |           |
|                               | *Wed | *Fri |           |           |
|                               | 9/1/ | 4    |           |           |
|                               | 04** | /29/ |           |           |
|                               |      | 05** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Identify state inspectors | Wed  | Fri  |           |           |
|                               | 9/   | 9/2  |           |           |
|                               | 1/04 | 4/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Identify county           | Mon  | Fri  |           |           |
|     inspectors                | 9/2  | 10/2 |           |           |
|                               | 7/04 | 2/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Draft environmental       | Tue  | Mon  |           | EBPIs and |
|     business practice         | 11/  | 12/2 |           | c         |
|     indicators (EBPIs),       | 9/04 | 0/04 |           | ompliance |
|     inspector checklist       |      |      |           | goals     |
|     (includes red-flag        |      |      |           | drafted   |
|     decision tree)            |      |      |           | with      |
|                               |      |      |           | sta       |
|                               |      |      |           | keholders |
+-------------------------------+------+------+-----------+-----------+
| (d) Internal review cycle for | Tue  | Mon  |           |           |
|     EBPIs, inspector          | 12/2 | 1/1  |           |           |
|     checklist                 | 1/04 | 0/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Revise EBPIs, inspector   | Tue  | Mon  |           |           |
|     checklist                 | 1/1  | 1/2  |           |           |
|                               | 1/05 | 4/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (f) External review of EBPIs  | Tue  | Mon  |           | St        |
|                               | 1/2  | 2/1  |           | akeholder |
|                               | 5/05 | 4/05 |           | support   |
|                               |      |      |           | before    |
|                               |      |      |           | next      |
|                               |      |      |           | step.     |
+-------------------------------+------+------+-----------+-----------+
| (g) Revise EBPIs, inspector   | Tue  | Mon  |           |           |
|     checklist                 | 2/1  | 2/2  |           |           |
|                               | 5/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (h) Finalize EBPIs            | Tue  | Mon  | Final     | EBPIs     |
|                               | 3/   | 3/2  | EBPIs,    | must be   |
|                               | 1/05 | 1/05 | including | finalized |
|                               |      |      | c         | before    |
|                               |      |      | ompliance | inspector |
|                               |      |      | goals     | c         |
|                               |      |      |           | hecklists |
|                               |      |      |           | --        |
|                               |      |      |           | st        |
|                               |      |      |           | akeholder |
|                               |      |      |           | support   |
|                               |      |      |           | before    |
|                               |      |      |           | "dry run" |
+-------------------------------+------+------+-----------+-----------+
| (i) Dry run checklist with 5  | Tue  | Mon  |           | This      |
|     "Five-Star" dairies, 5    | 3/2  | 4/   |           | initial   |
|     "regular" facilities      | 2/05 | 4/05 |           | data      |
|                               |      |      |           | informs   |
|                               |      |      |           | c         |
|                               |      |      |           | hecklist, |
|                               |      |      |           | database  |
|                               |      |      |           | dev       |
|                               |      |      |           | elopment, |
|                               |      |      |           | and other |
|                               |      |      |           | areas of  |
|                               |      |      |           | the       |
|                               |      |      |           | project   |
+-------------------------------+------+------+-----------+-----------+
| (j) Finalize inspector        | Tue  | Fri  | Checklist |           |
|     checklist                 | 4/   | 4/2  | with      |           |
|                               | 5/05 | 9/05 | EBPIs and |           |
|                               |      |      | project   |           |
|                               |      |      | metrics   |           |
|                               |      |      | i         |           |
|                               |      |      | ntegrated |           |
+-------------------------------+------+------+-----------+-----------+

Inspector Checklist Measures:

1.  Combines multiple programs and issues in maximum half-day visit --
    results of dry runs

2.  Inspectors & technicians accept the checklist -- attitudinal survey
    following completion

3.  Checklist helps communicate project issues to dairies -- survey of
    dry run dairies

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **8. ERP                      | *    | *    |           |           |
| outreach/participation**      | *Mon | *Fri |           |           |
|                               | 10   | 4    |           |           |
|                               | /18/ | /29/ |           |           |
|                               | 04** | 05** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Draft any flexibility     | Mon  | Fri  |           |           |
|     incentives agreed to      | 10/1 | 12/3 |           |           |
|     during stakeholder        | 8/04 | 1/04 |           |           |
|     process                   |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Finalize flexibility      | Mon  | Fri  | Policies  | Policies  |
|     incentives (if any)       | 1/   | 2/2  | approved, | stated in |
|                               | 3/05 | 5/05 | final     | outreach  |
+-------------------------------+------+------+-----------+-----------+
| (c) Prepare preliminary       | Mon  | Fri  |           |           |
|     brochure for distribution | 2/2  | 3/   |           |           |
|     to potential volunteers   | 8/05 | 4/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (d) Internal review of        | Mon  | Mon  |           |           |
|     brochure                  | 3/   | 3/   |           |           |
|                               | 7/05 | 7/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Revise brochure based     | Tue  | Tue  |           |           |
|     upon internal feedback    | 3/   | 3/   |           |           |
|                               | 8/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (f) External review of        | Wed  | Wed  |           | Custom    |
|     brochure                  | 3/   | 3/   |           | er-tested |
|                               | 9/05 | 9/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (g) Develop final ERP         | Thu  | Wed  |           |           |
|     brochure                  | 3/1  | 3/2  |           |           |
|                               | 0/05 | 3/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (h) Print final ERP brochure  | Thu  | Thu  | Final     |           |
|                               | 3/2  | 3/2  | brochures |           |
|                               | 4/05 | 4/05 | printed   |           |
+-------------------------------+------+------+-----------+-----------+
| (i) Mailings and              | Mon  | Fri  | 1,        |           |
|     co-presentations with     | 3/2  | 4/   | 600-piece |           |
|     MMPA; MPCA web site       | 8/05 | 1/05 | mailing   |           |
|     notice                    |      |      | and 2     |           |
|                               |      |      | pres      |           |
|                               |      |      | entations |           |
|                               |      |      | per       |           |
|                               |      |      | county    |           |
+-------------------------------+------+------+-----------+-----------+
| (j) Review progress and       | Mon  | Fri  |           | Reach 50  |
|     follow up as necessary    | 4/   | 4/2  |           | v         |
|                               | 4/05 | 9/05 |           | olunteers |
+-------------------------------+------+------+-----------+-----------+

ERP Outreach Measures:

1.  Number of mailings (minus number of returns)

2.  Web site hits

3.  Requests for further information (either MPCA or MMPA)

4.  Number of brochures and information requests managed by Dept of Ag
    Dairy inspectors

5.  Sign-ups

6.  MMPA membership increased

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **9. Training inspectors**    | *    | *    |           |           |
|                               | *Tue | *Tue |           |           |
|                               | 6    | 7    |           |           |
|                               | /21/ | /12/ |           |           |
|                               | 05** | 05** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Basic project awareness   | Tue  | Mon  | Basic     | Complete  |
|     training for MPCA, county | 3/   | 3/2  | awareness | before    |
|     feedlot staff, Dept of    | 1/05 | 1/05 | of        | re        |
|     Agriculture dairy         |      |      | project   | cruitment |
|     inspectors, and MMPA      |      |      | up to     | (8i)      |
|     technicians               |      |      | EBPIs     |           |
|                               |      |      | (7h)      |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Prepare inspector         | Tue  | Mon  | Inspector |           |
|     training for all pilot    | 6/2  | 7/   | training  |           |
|     project inspectors and    | 1/05 | 4/05 | for       |           |
|     technicians               |      |      | purposes  |           |
|                               |      |      | of        |           |
|                               |      |      | c         |           |
|                               |      |      | ompleting |           |
|                               |      |      | pilot     |           |
|                               |      |      | project   |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Dry run of inspector      | Tue  | Tue  |           |           |
|     training for all pilot    | 7/   | 7/   |           |           |
|     project inspectors and    | 5/05 | 5/05 |           |           |
|     technicians               |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (d) Revise the inspector      | Wed  | Fri  |           |           |
|     training for all pilot    | 7/   | 7/   |           |           |
|     project inspectors and    | 6/05 | 8/05 |           |           |
|     technicians               |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Deliver training for all  | Mon  | Tue  | 2-3       | Te        |
|     inspectors and            | 7/1  | 7/1  | trainings | chnicians |
|     technicians (each county) | 1/05 | 2/05 | completed | c         |
|                               |      |      |           | o-trained |
|                               |      |      |           | so        |
|                               |      |      |           | they're   |
|                               |      |      |           | aware of  |
|                               |      |      |           | i         |
|                               |      |      |           | nspection |
|                               |      |      |           | protocol  |
+-------------------------------+------+------+-----------+-----------+

Training Inspectors Measures:

1.  Number of county and MPCA staff, MMPA technicians trained

2.  Hours in development - timetracking records

3.  Inspector satisfaction -- training evaluations

4.  MMPA techs work effectively with dairies -- MPCA survey calls to
    dairies

5.  MPCA, county inspectors' effectiveness in working with dairies --
    MPCA (third-party) calls to dairies

6.  MMPA technician performance (complete checklists, operator
    satisfaction) -- MPCA survey calls to dairies

7.  High-quality data collection (longer-term) -- accuracy of
    certifications, data reported

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **10. Baseline inspections    | *    | *    |           |           |
| and analysis (includes most   | *Wed | *Tue |           |           |
| data entry)**                 | 7    | 11   |           |           |
|                               | /13/ | /15/ |           |           |
|                               | 05** | 05** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Inspections and ongoing   | Wed  | Mon  |           |           |
|     data entry                | 7/1  | 10/  |           |           |
|                               | 3/05 | 3/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Initial inspector         | Tue  | Tue  |           |           |
|     debriefing (one week into | 7/1  | 7/1  |           |           |
|     inspections)              | 9/05 | 9/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Data entry wrap up and    | Tue  | Mon  | X         | Complete  |
|     quality assurance         | 10/  | 10/1 | in        | before    |
|                               | 4/05 | 7/05 | spections | harvest   |
|                               |      |      | complete  |           |
+-------------------------------+------+------+-----------+-----------+
| (d) Final inspection          | Tue  | Tue  |           |           |
|     debriefing                | 10/1 | 10/1 |           |           |
|                               | 8/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Post-baseline follow-up   | Tue  | Tue  |           |           |
|     and analysis              | 10/1 | 11/1 |           |           |
|                               | 8/05 | 5/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (f) Follow up on              | Tue  | Tue  | Complete  |           |
|     non-compliant facilities. | 10/1 | 11/1 | baseline  |           |
|                               | 8/05 | 5/05 | data set  |           |
+-------------------------------+------+------+-----------+-----------+
| (g) Analysis of baseline      | Tue  | Tue  | Completed | Initial   |
|     inspection data.          | 10/1 | 11/1 | analysis  | co        |
|                               | 8/05 | 5/05 | of        | nclusions |
|                               |      |      | c         | on        |
|                               |      |      | ompliance | re        |
|                               |      |      | and       | liability |
|                               |      |      | pe        | of sample |
|                               |      |      | rformance |           |
|                               |      |      | levels    |           |
+-------------------------------+------+------+-----------+-----------+

Baseline Inspections Measures:

1.  Time investment relative to standard dairy inspections -- from
    timetracking records, relative to historical average for this type
    of dairy

2.  Inspectors able (not able) to cover material projected in checklist
    -- inspector records

3.  Response of operators during inspectors -- qualitative, from
    inspector records

4.  Number of operators requesting assistance from MMPA technicians
    during inspections -- inspector records

5.  Compliance rates -- inspector records

6.  BMPs in place -- inspector records

7.  Number of enforcement actions required (after any amnesty period) --
    longer term

8.  Percentage of facilities that reregister every year -- long term

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **11. Assistance**            | *    | *    |           |           |
|                               | *Tue | *Wed |           |           |
|                               | 12   | 4    |           |           |
|                               | /21/ | /19/ |           |           |
|                               | 04** | 06** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Draft outline/sample      | Tue  | Mon  |           | Feedback  |
|     section for compliance    | 12/2 | 1/1  |           | from      |
|     assistance workbook       | 1/04 | 0/05 |           | baseline  |
|                               |      |      |           | in        |
|                               |      |      |           | spections |
|                               |      |      |           | i         |
|                               |      |      |           | ntegrated |
+-------------------------------+------+------+-----------+-----------+
| (b) Internal review of        | Tue  | Mon  |           |           |
|     workbook sample           | 1/1  | 1/2  |           |           |
|                               | 1/05 | 4/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Revise workbook sample    | Tue  | Mon  |           |           |
|                               | 1/2  | 2/   |           |           |
|                               | 5/05 | 7/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (d) External review of        | Tue  | Mon  |           | MMPA      |
|     compliance assistance     | 2/1  | 3/   |           | feedback  |
|     workbook sample.          | 5/05 | 7/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Debriefing on results of  | Tue  | Mon  |           |           |
|     external review           | 3/   | 3/1  |           |           |
|                               | 8/05 | 4/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (f) Develop Complete Draft of | Tue  | Mon  | Draft     |           |
|     Workbook and Forms, and   | 3/1  | 5/   | package   |           |
|     cover letter              | 5/05 | 9/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (g) Internal review of all    | Tue  | Mon  |           |           |
|     certification materials   | 5/1  | 6/   |           |           |
|                               | 0/05 | 6/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (h) Revise all certification  | Tue  | Mon  |           |           |
|     materials based upon      | 6/   | 7/   |           |           |
|     internal feedback         | 7/05 | 4/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (i) External review of all    | Tue  | Mon  |           | MMPA and  |
|     certification materials   | 7/   | 7/1  |           | dairy     |
|                               | 5/05 | 1/05 |           | feedback  |
+-------------------------------+------+------+-----------+-----------+
| (j) Finalize facility forms   | Tue  | Mon  |           |           |
|                               | 7/1  | 7/2  |           |           |
|                               | 2/05 | 5/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (k) Finalize cover letter     | Tue  | Mon  |           |           |
|                               | 7/1  | 7/1  |           |           |
|                               | 2/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (l) Finalize workbook         | Tue  | Mon  |           |           |
|                               | 7/2  | 8/2  |           |           |
|                               | 6/05 | 2/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (m) Finalize the entire       | Mon  | Mon  | N         |           |
|     certification package     | 8/2  | 8/2  | ear-final |           |
|                               | 2/05 | 2/05 | package   |           |
+-------------------------------+------+------+-----------+-----------+
| (n) Schedule facility         | Tue  | Mon  |           |           |
|     workshops                 | 7/1  | 7/1  |           |           |
|                               | 2/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (o) Draft facility workshops, | Tue  | Mon  |           |           |
|     including participant     | 8/2  | 9/   |           |           |
|     evaluation forms          | 3/05 | 5/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (p) Internal review of        | Tue  | Mon  |           |           |
|     facility workshops        | 9/   | 9/1  |           |           |
|                               | 6/05 | 2/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (q) Revise facility workshops | Tue  | Mon  |           |           |
|                               | 9/1  | 9/1  |           |           |
|                               | 3/05 | 9/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (r) Technician assistance     | Tue  | Tue  |           | Effort    |
|     on-farm                   | 10/  | 3/   |           | and roles |
|                               | 4/05 | 7/06 |           | as        |
|                               |      |      |           | designed  |
|                               |      |      |           | with      |
|                               |      |      |           | sta       |
|                               |      |      |           | keholders |
+-------------------------------+------+------+-----------+-----------+
| (s) Dry run of workshops      | Tue  | Fri  | 2 dry     | MMPA and  |
|     (includes external        | 10/  | 10/  | runs?     | dairy     |
|     review)                   | 4/05 | 7/05 |           | part      |
|                               |      |      |           | icipation |
+-------------------------------+------+------+-----------+-----------+
| (t) Finalize facility         | Mon  | Fri  | Final     |           |
|     workshops (and package)   | 10/1 | 10/2 | package   |           |
|     based upon dry run        | 0/05 | 1/05 | and       |           |
|                               |      |      | workshop  |           |
|                               |      |      | syllabus  |           |
+-------------------------------+------+------+-----------+-----------+
| (u) Deliver facility          | Tue  | Fri  | 2         | Workshops |
|     workshops                 | 11/  | 11/1 | workshops | timed to  |
|                               | 1/05 | 1/05 | completed | balance   |
|                               |      |      |           | ins       |
|                               |      |      |           | pections, |
|                               |      |      |           | harvest,  |
|                               |      |      |           | cert.     |
|                               |      |      |           | deadline  |
+-------------------------------+------+------+-----------+-----------+
| (v) Analyze participant       | Mon  | Fri  |           |           |
|     evaluations of workshops  | 11/1 | 11/1 |           |           |
|                               | 4/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+

Assistance Measures:

1.  Workshop attendance -- operators in attendance

2.  Workbooks distributed

3.  Technician requests and deliveries -- MMPA records

4.  Number of facilities assisted vs. self-certified -- MMPA records

5.  Accuracy of self-certification vs. technician-assisted --
    longer-term, involves data from post-certification inspections
    (requires flags in database)

6.  Number (percentage) of facilities claiming to have used assistance
    materials, but did not certify -- MPCA survey of those not
    completing certification, others.

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **12. Certification**         | *    | *    |           |           |
|                               | *Tue | *Wed |           |           |
|                               | 8    | 5    |           |           |
|                               | /23/ | /17/ |           |           |
|                               | 05** | 06** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Print certification       | Tue  | Mon  | Cert      |           |
|     packages                  | 8/2  | 9/   | ification |           |
|                               | 3/05 | 5/05 | mailing   |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Prepare certification     | Tue  | Mon  |           | Mailed to |
|     packages for mail and     | 9/   | 10/1 |           | coincide  |
|     mail them                 | 6/05 | 7/05 |           | with end  |
|                               |      |      |           | of        |
|                               |      |      |           | baseline  |
|                               |      |      |           | in        |
|                               |      |      |           | spections |
+-------------------------------+------+------+-----------+-----------+
| (c) Feedlots fill out         | Tue  | Tue  |           | Set       |
|     compliance certification  | 10/1 | 3/   |           | deadline  |
|     forms (set deadline)      | 8/05 | 7/06 |           | with      |
|                               |      |      |           | st        |
|                               |      |      |           | akeholder |
|                               |      |      |           | input     |
+-------------------------------+------+------+-----------+-----------+
| (d) Certification deadline    | Tue  | Tue  |           |           |
|                               | 3/   | 3/   |           |           |
|                               | 7/06 | 7/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Technician assistance     | Tue  | Tue  | On-farm   | Effort    |
|     (same as 11r)             | 10/  | 3/   | a         | and roles |
|                               | 4/05 | 7/06 | ssistance | as        |
|                               |      |      |           | designed  |
|                               |      |      |           | with      |
|                               |      |      |           | sta       |
|                               |      |      |           | keholders |
+-------------------------------+------+------+-----------+-----------+
| (f) Data entry for            | Tue  | Tue  |           |           |
|     self-certification forms  | 3/   | 3/2  |           |           |
|     (if not submitted on      | 7/06 | 8/06 |           |           |
|     line).                    |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (g) Initial analysis of       | Tue  | Tue  |           |           |
|     self-certification data   | 3/2  | 4/1  |           |           |
|                               | 8/06 | 8/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (h) Follow-up with            | Tue  | Wed  |           |           |
|     non-responders?? NOTE:    | 4/1  | 4/1  |           |           |
|     This is tentative         | 8/06 | 9/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (i) Follow-up with red flag,  | Tue  | Wed  |           | RTC forms |
|     other facilities          | 4/1  | 4/1  |           | completed |
|     (including RTC\'s)        | 8/06 | 9/06 |           |           |
|     Tentative                 |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+
| (j) Final analysis of         | Wed  | Wed  | Analysis  |           |
|     self-certification data   | 4/1  | 5/   | complete  |           |
|                               | 9/06 | 3/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (k) Internal presentations    | Wed  | Wed  |           | Comm      |
|     and feedback on           | 5/   | 5/1  |           | unication |
|     self-certification data   | 3/06 | 7/06 |           | and       |
|     results                   |      |      |           | unde      |
|                               |      |      |           | rstanding |
|                               |      |      |           | among     |
|                               |      |      |           | i         |
|                               |      |      |           | nspectors |
|                               |      |      |           | --        |
|                               |      |      |           | consensus |
|                               |      |      |           | on        |
|                               |      |      |           | co        |
|                               |      |      |           | nclusions |
+-------------------------------+------+------+-----------+-----------+

Measures:

1.  Time spent in managing data electronically vs. what it would have
    been had the entire process been manual -- from time-tracking
    records, based on data submittals similar to certifications.

2.  Number (percentage) of baseline operations completing certification

3.  Number of return to compliance submittals

4.  Number reporting compliance vs. non-compliance

5.  Overall accuracy of certification forms -- (longer-term) waits for
    post-certification inspector records

6.  Return to compliance forms submitted and RTC plans implemented --
    requires post-certification or other inspection records

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **13. Post-certification      | *    | *    |           |           |
| inspections**                 | *Wed | *Mon |           |           |
|                               | 5/3/ | 10   |           |           |
|                               | 06** | /16/ |           |           |
|                               |      | 06** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Revisit statistical       | Wed  | Wed  | Final     | QAPP      |
|     methodology               | 5/   | 5/2  | me        | would     |
|                               | 3/06 | 4/06 | thodology | determine |
|                               |      |      | (revised) | if        |
|                               |      |      |           | ad        |
|                               |      |      |           | justments |
|                               |      |      |           | are made  |
|                               |      |      |           | within    |
|                               |      |      |           | the       |
|                               |      |      |           | project   |
|                               |      |      |           | or later  |
+-------------------------------+------+------+-----------+-----------+
| (b) Preparation for inspector | Wed  | Wed  |           |           |
|     training                  | 5/2  | 5/3  |           |           |
|                               | 4/06 | 1/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Generate inspection list  | Wed  | Thu  |           |           |
|                               | 5/3  | 6/   |           |           |
|                               | 1/06 | 1/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (d) Inspector                 | Thu  | Fri  |           | Inspector |
|     training/debriefing       | 6/   | 6/   |           | protocol/ |
|                               | 1/06 | 2/06 |           | checklist |
|                               |      |      |           | modified  |
|                               |      |      |           | (if       |
|                               |      |      |           | necessary |
|                               |      |      |           | to        |
|                               |      |      |           | improve   |
|                               |      |      |           | data      |
|                               |      |      |           | c         |
|                               |      |      |           | ollection |
|                               |      |      |           | and if    |
|                               |      |      |           | possible  |
|                               |      |      |           | without   |
|                               |      |      |           | skewing   |
|                               |      |      |           | earlier   |
|                               |      |      |           | data)     |
+-------------------------------+------+------+-----------+-----------+
| (e) Inspections and ongoing   | Fri  | Fri  |           | QAPP      |
|     data entry                | 6/   | 9/   |           | would     |
|                               | 2/06 | 1/06 |           | determine |
|                               |      |      |           | if        |
|                               |      |      |           | starting  |
|                               |      |      |           | one month |
|                               |      |      |           | earlier   |
|                               |      |      |           | than      |
|                               |      |      |           | baselines |
|                               |      |      |           | is OK     |
|                               |      |      |           | (i.e.,    |
|                               |      |      |           | does not  |
|                               |      |      |           | introduce |
|                               |      |      |           | su        |
|                               |      |      |           | bstantial |
|                               |      |      |           | seasonal  |
|                               |      |      |           | bias)     |
+-------------------------------+------+------+-----------+-----------+
| (f) Initial inspector         | Fri  | Mon  |           |           |
|     debriefing (one week into | 6/   | 6/1  |           |           |
|     inspections)              | 9/06 | 2/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (g) Data entry wrap up and    | Fri  | Fri  |           |           |
|     quality assurance         | 9/   | 9/1  |           |           |
|                               | 1/06 | 5/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (h) Final inspection          | Fri  | Mon  | X         |           |
|     debriefing                | 9/1  | 9/1  | post-cert |           |
|                               | 5/06 | 8/06 | in        |           |
|                               |      |      | spections |           |
+-------------------------------+------+------+-----------+-----------+
| (i) Post-certification        | Mon  | Mon  |           |           |
|     follow-up and analysis    | 9/1  | 10/1 |           |           |
|                               | 8/06 | 6/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (j) Follow up on              | Mon  | Mon  | En        |           |
|     non-compliant facilities. | 9/1  | 10/1 | forcement |           |
|                               | 8/06 | 6/06 | actions   |           |
+-------------------------------+------+------+-----------+-----------+
| (k) Analysis of               | Mon  | Mon  | Analysis  |           |
|     post-certification        | 9/1  | 10/1 | completed |           |
|     inspections \[predecessor | 8/06 | 6/06 |           |           |
|     OK?\]                     |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+

Measures:

1.  Number of inspections completed vs. number needed for sample

2.  Time elapsed to complete all planned inspections

3.  Time/cost per post-cert inspection vs. standard and vs. baseline --
    timetracking records

4.  Accuracy of self-certifications -- baseline and post-cert inspector
    records

5.  Consideration of (progress on) whole farm issues -- inspection
    records and longer-term MPCA followup

6.  Number (percentage) of farmers adopting recommended NM practices --
    inspection records and longer-term MPCA followup

7.  Performance of certifying facilities vs. others -- longer-term (site
    visits)

8.  (Increased) use of soil testing and other site assessment tools --
    longer-term (site visits)

9.  Use of P2 and BMPs reported -- annual reports

10. Number (percentage) of farmers with approved manure management plans
    -- followup submittals, inspections?

11. Estimated pollutant reductions based on FLEval and BWSR models

+-------------------------------+------+------+-----------+-----------+
|                               | S    | Fi   | Del       | M         |
|                               | tart | nish | iverables | ilestones |
+-------------------------------+------+------+-----------+-----------+
| **14. Reporting**             | *    | *    |           |           |
|                               | *Thu | *Fri |           |           |
|                               | 1    | 12   |           |           |
|                               | 2/2/ | /29/ |           |           |
|                               | 04** | 06** |           |           |
+-------------------------------+------+------+-----------+-----------+
| (a) Revise and Submit QAPP    | Thu  | Wed  |           |           |
|     for EPA                   | 12/  | 12/2 |           |           |
|                               | 2/04 | 2/04 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (b) Get QAPP Approval from    | Thu  | Wed  |           |           |
|     EPA                       | 12/2 | 2/1  |           |           |
|                               | 3/04 | 6/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (c) Quarterly Report 1, Year  | Mon  | Fri  | Quarterly |           |
|     1                         | 12/2 | 12/3 | report,   |           |
|                               | 0/04 | 1/04 | web site, |           |
|                               |      |      | mail to   |           |
|                               |      |      | ALL       |           |
|                               |      |      | sta       |           |
|                               |      |      | keholders |           |
+-------------------------------+------+------+-----------+-----------+
| (d) Quarterly Report 2, Year  | Fri  | Thu  | Quarterly |           |
|     1                         | 3/1  | 3/3  | report,   |           |
|                               | 8/05 | 1/05 | web site  |           |
|                               |      |      | post,     |           |
|                               |      |      | mail to   |           |
|                               |      |      | ALL       |           |
+-------------------------------+------+------+-----------+-----------+
| (e) Quarterly Report 3, Year  | Fri  | Thu  | Quarterly |           |
|     1                         | 6/1  | 6/3  | report,   |           |
|                               | 7/05 | 0/05 | web site  |           |
|                               |      |      | post,     |           |
|                               |      |      | mail to   |           |
|                               |      |      | ALL       |           |
+-------------------------------+------+------+-----------+-----------+
| (f) Annual Report 1 (Year 1)  | Mon  | Fri  | Annual    | Raw data  |
|                               | 9/1  | 9/3  | report,   | from      |
|                               | 2/05 | 0/05 | web site  | baselines |
|                               |      |      | post      | being     |
|                               |      |      |           | tabulated |
+-------------------------------+------+------+-----------+-----------+
| (g) Present at MN Association | Mon  | Fri  |           |           |
|     of County Feedlot         | 10/  | 10/2 |           |           |
|     Officers conference       | 3/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (h) Meeting offered for all   | Mon  | Fri  |           |           |
|     stakeholders, including   | 10/  | 10/2 |           |           |
|     non-participants          | 3/05 | 8/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (i) Informational item for    | Thu  | Tue  |           |           |
|     MPCA Citizens Board       | 10/  | 10/2 |           |           |
|                               | 6/05 | 5/05 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (j) Quarterly Report 1, Year  | Mon  | Fri  | Quarterly | First     |
|     2                         | 12/1 | 12/3 | report,   | round     |
|                               | 9/05 | 0/05 | web site  | i         |
|                               |      |      | post,     | nspection |
|                               |      |      | mail to   | data      |
|                               |      |      | ALL       | available |
|                               |      |      | sta       |           |
|                               |      |      | keholders |           |
+-------------------------------+------+------+-----------+-----------+
| (k) Quarterly Report 2, Year  | Mon  | Fri  | Quarterly | Raw data  |
|     2                         | 3/2  | 3/3  | report,   | from      |
|                               | 0/06 | 1/06 | web site  | early     |
|                               |      |      | post,     | certi     |
|                               |      |      | mail to   | fications |
|                               |      |      | ALL       |           |
+-------------------------------+------+------+-----------+-----------+
| (l) Quarterly Report 3, Year  | Mon  | Fri  | Quarterly |           |
|     2                         | 6/1  | 6/3  | report,   |           |
|                               | 9/06 | 0/06 | web site  |           |
|                               |      |      | post,     |           |
|                               |      |      | mail to   |           |
|                               |      |      | ALL       |           |
+-------------------------------+------+------+-----------+-----------+
| (m) Review of program results | Mon  | Fri  |           |           |
|                               | 9/1  | 10/2 |           |           |
|                               | 8/06 | 7/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (n) Present at MN Association | Mon  | Fri  |           |           |
|     of County Feedlot         | 10/  | 10/2 |           |           |
|     Officers conference       | 2/06 | 7/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (o) Meeting offered for all   | Mon  | Fri  |           |           |
|     stakeholders, including   | 11/  | 11/2 |           |           |
|     non-participants          | 6/06 | 4/06 |           |           |
+-------------------------------+------+------+-----------+-----------+
| (p) Informational item for    | Thu  | Tue  | Potential |           |
|     MPCA Citizens Board       | 11/3 | 12/1 | program   |           |
|                               | 0/06 | 9/06 | changes   |           |
|                               |      |      | by rule   |           |
|                               |      |      | or        |           |
|                               |      |      | le        |           |
|                               |      |      | gislative |           |
|                               |      |      | action    |           |
+-------------------------------+------+------+-----------+-----------+
| (q) Prepare and submit final  | Mon  | Fri  | Final     | All data  |
|     report to EPA             | 10/3 | 12/2 | report,   |           |
|                               | 0/06 | 9/06 | web site  |           |
|                               |      |      | post      |           |
+-------------------------------+------+------+-----------+-----------+
| (r) Distribution to other     | Mon  | Fri  |           |           |
|     states -- conference      | 1/   | 12/2 |           |           |
|     calls, presentations, web | 3/05 | 9/06 |           |           |
|     page                      |      |      |           |           |
+-------------------------------+------+------+-----------+-----------+

Measures:

1.  Reports delivered on time

2.  Interest from other states -- program staff phone logs

3.  Interest from other MPCA program managers -- program records (staff
    training)

4.  Interest from other livestock sectors

5.  Adaptation by other states (long term) -- EPA records

6.  Adaptation by other MPCA programs (long term) -- MPCA records

**15. Long-term measurement**

MPCA has discussed long-term measurement of project impacts. The costs
and difficulties of such efforts are well-known. Nevertheless, MPCA
commits to continue exploration of feasible means of measuring the
project's environmental impacts within the project period, with the goal
of producing a plan for long-term measurement, which can be feasibly
implemented, either within or after the project period. Some of the
possible tools or approaches that MPCA will consider in establishing its
long-term results measurement plan are:

-   Report form for 50 participants to insert in existing annual report
    or submit separately on which they indicate progress towards BMPs
    and needed corrections;

-   Phone survey of 20-50 participants - product: list of BMPs
    implemented, compliance correction;

-   On-farm survey (not an inspection) of 20-50 participants - product:
    list of BMPs implemented, compliance correction, information to
    complete FLEval;

-   Follow-up inspections of a sample or of all 50 participants after 2
    years (or other meaningful interval), looking at all or most of the
    vectors in the baseline and post-cert inspections -- product: same
    as #2 but direct verification plus credit for a formal inspection;

-   Work with state and local water monitoring staff to determine if
    existing sampling sites can be used to draw reliable conclusions
    about project impacts on water quality parameters;

-   Work with state and local water monitoring staff to determine if in
    the project timeline the partners could set up any new sampling
    sites, particularly in priority TMDL watersheds or if a number of
    participants are conveniently clustered. If so, then project staff
    could work with monitoring experts to determine proper site setup
    for data collection. Other sources of support for the monitoring or
    for the participating site's implementation would be necessary in
    order to pursue this option.

Possible measures:

1.  Changes in surface water ambient conditions

2.  Diversions of pollutant runoff based on modeling

3.  Activity measures (e.g. structures receiving milkhouse wastes, open
    lots addressed and how, surface tile inlets closed, etc.)

4.  Environmental gains not directly associated with feedlot management,
    such as solid waste, chemical storage, habit restoration, etc.

***Compliance with program requirements***

This experiment relates to EPA's Environmental Innovation Strategy in
several ways. First, it borrows from ERP experiences in other states
(supported by EPA) as well as innovative approaches to animal
agriculture environmental improvement being used in other states and in
Minnesota, in partnership with producer associations and various rural
governmental and non-governmental organizations. Second, the project
deals with a priority environmental issue for Minnesota and EPA:
restoring the environmental quality of impaired surface water and
preventing future impairments. Third, the project demonstrates a focus
on results by improving water quality using new environmental tools
(self-certifications, farm management systems, and statistical
assessment of sub-sector performance) and partnerships to obtain water
quality protection sooner than could be obtained with conventional
regulatory tools and current resources.

1.  The proposed project demonstrates an innovation used in other states
    and supported by EPA (ERP), but applies it in an experimental sense
    to a sector where it has not yet been deployed. As such, MPCA will
    be researching the applicability of ERP in this new area, gathering
    data on metrics for environmental improvement, compliance, and
    resource efficiency, applying this learning to other feedlot and
    (eventually) economic sectors, and disseminating the results of the
    experiment via web and reports to citizens, state and national
    agencies, and NGOs.

2.  The focus of the project proposal is on techniques for preventing
    surface and ground water contamination at the source. However, to
    the extent a "whole farm" or integrated management approach can be
    expressed in the program materials and promoted in the field by
    staff and partners, this project will be multi-media. MPCA expects
    to leverage environmental management systems (EMS)-like approaches
    (including auditing) already being used by producers or promoted by
    their associations.

3.  Target priority environmental issues -- Measures will look at
    producers moved to environmental improvement sooner than expected
    with existing alternatives, and encouraged improvement in impacts
    and farm management systems beyond the primary (and priority) area
    of water quality protection. To the extent that the project develops
    as an alternative or supplement to the existing interim permitting
    process (the existing state permitting minimum for non-CAFOs), the
    project will constitute an innovation in permitting that the feedlot
    program will be able to integrate and carry forward.

4.  Likely improvement in results from project implementation -

-   Differ from current methods -- MPCA expects that participating
    feedlots will self-audit for compliance and adopt environmental
    improvement techniques for more areas of the farmstead sooner than
    under a conventional inspection program. In addition, the producer
    association should be motivated to promote the ERP program more
    effectively than MPCA can on its own.

-   Build on "lessons learned" -- Clearly, MPCA is adopting a process
    used and evolved successfully in other states. We also will be
    building on the work of producer associations and public/private
    pilots in Minnesota and other farm states, leveraging quality
    assurance programs, Farm Bill audit incentives, and
    EMS/auditing-based approaches promoted by producer associations.

-   Quantifiable environmental improvements -- self-corrections for
    compliance, feed and supplement BMPs, soil-tested nutrients levels,
    nutrient management plans, energy use reduced, water conserved,
    amounts composted, riparian buffers installed, drain tile inlets
    capped, etc. These measures will be developed further in the first
    phases of the project.

-   Improved administrative efficiency -- MPCA and delegated counties
    fully expect to have their existing level of effort leveraged (at
    least by a factor of two, although this research will verify this
    assumption) by producer associations and participating producers in
    the course of the project. The resource savings would escalate as
    the pilot is extended to other feedlot sectors.

-   Costs and efficiency improvements for producers -- On a quicker
    basis than otherwise possible, participating producers should
    realize energy and water use cost reductions, soil loss, nutrient
    supplement reductions for animals and feed crops, and so on, and the
    net present value of completing compliance and environmental
    improvements sooner as opposed to in the future.

5.  Measuring improvement and accountability

-   Information on the project will be made available through reports,
    web pages, conferences, and trainings. All project participant
    performance data will be available to surrounding communities via
    the web page and local distribution.

-   Timeline for achievable results --MPCA plans to begin work in August
    2004, with baseline inspections complete in October 2005. Follow-up
    inspections, results analysis, and plans for extension to other
    sectors would be complete by December 2006.

-   Goals for environmental improvement -- Mentioned in QAPP in more
    detail.

-   Indicators of environmental improvement -- Mentioned elsewhere in
    more detail, although final measures will depend on the result of
    stakeholder discussions and what aspects of operations participating
    producers will agree to measure.

-   Baseline measurements -- Stakeholder discussions will set compliance
    and performance goals; subsequent inspections will measure status
    against those compliance and performance goals and practices.
    Baseline inspections will be complete in October 2005.

-   Plan, timeline, and commitment for project evaluation -- Agreed-upon
    goals and measures will receive baseline and follow-up data by fall
    2006, at which point final analysis of the project will take place,
    draft conclusions discussed with stakeholders including EPA, and
    final results distributed by December 2006.

-   Results expected within one to three years and how measured --
    Mentioned elsewhere in more detail.

-   Long-term results (three years plus) -- These are difficult to
    project at this point, but if the results of the experiment warrant
    expansion into other feedlot sectors, than similar results could be
    expected based on species-specific goals and measures, and the size
    and readiness of those other sectors.

6.  Transferring Innovation

-   MPCA will use its feedlot database to assimilate all data gathered
    as a result of the project, will demonstrate that database to
    interested jurisdictions, and will make performance and project data
    available through public distribution.

-   MPCA expects eventual widespread participation with the ERP
    approach, across feedlot sectors. Also, we believe other farm states
    with numerous animal agriculture operations will find the experience
    useful.

-   The feedlot ERP project will fundamentally change how MPCA and
    counties approach feedlot compliance, and more importantly,
    identification and targeting of resources towards under-performing
    sectors or locations. Feedlot ERP can be deployed to support
    priority TMDLs, as well. Finally, MPCA expects that this initial use
    of ERP within the agency and the state will diffuse to other sectors
    in manufacturing and commerce.

-   MPCA (on behalf of participating counties) will commit to provide
    consultation and mentoring to other States wishing to adopt a
    feedlot ERP approach.

***[Budget Summary]{.underline}***

**[\[Financial information redacted\]]{.mark}**