INTRODUCTION

Q. Please state your name andaddress.

A. My name is Deborah L. Allanand my address is 1575 Merrill St

SaintPaul, MN 55108-2243

Q. What is your primary work andwhat is your business address?

A. I am a Professor in theDepartment of Soil, Water and Climate at the University of Minnesota in St.Paul, Minnesota. I teach Soil and Environmental Biology, Soil Biology andFertility and conduct research focused on soils and the interaction of plantsand soils. One of my areas of focus is soil quality in alternative croppingsystems. My department address is 439 Borlaug Hall, 1991 Upper Buford Circle,St. Paul, Minnesota 55108.

Q. Who are you representing inthis proceeding?

A. In this proceeding, I amoffering my testimony on behalf of the Gardens of Eagan certified organic farmowned by Atina and Martin Diffley. Based on my knowledge of soils and theimpacts of pipeline construction on organic soils and agriculture, I amrecommending that any crude oil pipeline approved by the Minnesota PublicUtilities Commission as a result of the Minnesota Pipe Line Company (MPL)application should avoid the Gardens of Eagan organic farm. My testimony alsosupports recommendations for amendments to the Agriculture Impact Mitigation Plan(AIMP) filed by MPL. The AIMP should include specific provisions to protect andrestore organic soils and should provide compensation for production losses andscientific testing to verify the parameters of soil restoration.

Q. Please state your qualifications to render an expert opinionin this matter.

A. I received a B.A. inAnthropology from Grinnell College in Iowa in 1973, an M.A. in Anthropologyfrom the University of Pennsylvania in 1976, an M.S. in Agriculture fromCalifornia Polytechnic State University in San Luis Obispo in 1983 and a Ph.D.in Soil Science from the University of California in Riverside, California in1987.

Ibegan working at the University of Minnesota in 1987 as an Assistant Professorin the Soil Science Department, became an Associate Professor in the Departmentof Soil, Water and Climate at the U. of M. in 1993 and was appointed a FullProfessor in the Department of Soil, Water and Climate in 1999. From 2001-2005, I was the Director ofGraduate Studies for the University’s Soil Science Graduate Program.

Iam a member of many professional associations and honorary societies, includingthe American Society of Agronomy, the American Society of Plant Biologists, theInstitute for Alternative Agriculture, the Soil Science Society of America, PhiBeta Kappa, Gamma Sigma Delta (an organization supporting agriculture) andSigma Xi (a scientific research society). I have received numerous professionalawards, including recognition as Fellow of the American Society of Agronomy andFellow of the Soil Science Society in 2004.

Ihave received more than 40 grants for study and research related to plantnutrition and soil fertility. These have included grants for modeling theroot-soil interface, for improving productivity of crops, for analyzing soilcharacteristics, for development and application of soil quality indicators,for biological, social and financial monitoring to develop highly sustainablefarming systems, for developing a soil management guidebook, for assessing soilquality changes in alternative and conventional cropping systems and fordeveloping weed, pest and soil management tools for organic crop systems.

Ihave authored or co-authored approximately 45 publications in refereed journalsand proceedings and dozens of abstracts, research presentations, invitedproceedings and book chapters. Many of my publications have focused on plantroot development and biochemistry, including interactions with chemicals insoils and solutions. I have also written and presented materials relating tosoil quality assessment, soil management for sustainable agriculture, andimproving production of crops. My research presentations have addressedenvironmental effects of conventional and alternative farming and soil quality,profitability and risk of conventional and organic cropping as well as thebiology and chemistry of plant and soil systems. My curriculum vitae, providedas Gardens of Eagan (GOE) Exhibit 8 details these publications.

Q. Are you familiar with theGardens of Eagan certified organic specialty farm?

A. I know Atina and Martin Diffleythrough organic farming associations and also by the reputation of their farm.I have talked with Atina Diffley and reviewed the Organic Management Plan forthe Gardens of Eagan.

Q. What documents and materialshave you reviewed in connection with this matter?

A. In addition to the Gardens ofEagan Organic Management Plan, I reviewed the Agricultural Impact MitigationPlan (AIMP) submitted by the Minnesota Pipe Line Company (MPL) and draft suggestionsfor amending this AIMP. I reviewed the Gardens of Eagan Proposal forAlternative Route Alignment to Avoid Organic Farm and the Gardens of EaganProposal for Modification of Agricultural Impact Plan and EnvironmentalAssessment and various maps that depict pipeline route alternatives in thevicinity of the Gardens of Eagan farm.

Q. What else have you done tobecome familiar with the pipeline proposal, the AIMP and the potential impactsof the pipeline on the Gardens of Eagan organic farm?

A. I was first contacted regardingthis pipeline project by staff of the Department of Agriculture who asked forinformation about the impact of pipeline construction on organic farm soils andways to measure the restoration of soil quality. I learned from Bob Patton andMeg Monahan some of the basic information about the Minnesota Pipe Line Companyproposal and the AIMP that the Company had submitted.

Imet once with Atina Diffley and her lawyer to discuss which subjects I wouldfeel comfortable testifying to. I checked with Martin Diffley to find out whattypes of soil are present on the Gardens of Eagan farm. I consulted with mycolleague Carl Rosen, who is also a Professor in the Department of Soil, Waterand Climate at the U. of M. in St. Paul. Dr. Rosen has specific expertise invegetable production systems, and it is customary in my work to consult withand collaborate with colleagues to develop and verify expert opinions.

PURPOSE AND SCOPE

Q. Please summarize yourtestimony.

1) Organiccrop systems and, particularly organic vegetable crops are highly vulnerable tothe impacts of pipeline construction and maintenance. Constructing a crude oilpipeline on an organic vegetable farm like the Gardens of Eagan would be farmore detrimental and costly than routing the pipeline on other agriculturalland. I would strongly recommend that, if a pipeline is approved, the PublicUtilities Commission should designate a route that avoids the Gardens of Eaganorganic farm.

2) Becauseof the differences between organic and conventional farming, the AgriculturalImpact Mitigation Plan for this project should distinguish between organic andnon-organic agricultural lands and require specific practices to minimize theharm to organic soils, restore soil horizons and qualities, scientificallyverify soil restoration and provide appropriate compensation when soils andproductivity are impaired. I would recommend that the Commission require as acondition of any construction permit that the Minnesota Pipe Line Companyfollow the practices contained in the August 2006 Amended AIMP attached as GOEExhibit 5.

3) Itis clear to me from the documents I’ve reviewed that Atina and Martin Diffleyare good organic farmers and the Gardens of Eagan is a model of sound,sustainable organic practices. As many farmers struggle to make the paradigmshift to organic agriculture, I believe that a farm like Gardens of Eaganshould be protected as a model for other farmers.

Q. How is your testimony organized?

· First, I discuss the nature of soil stratification andthe differences between organic and conventional agricultural systems in termsof their reliance on soil quality. I discuss the way that this difference isheightened in vegetable cropping.

· Then, based on information in the Gardens of Eaganorganic management plan as well as recognized principles of soil science, Iexplain why the detriment to the Gardens of Eagan from the construction of acrude oil pipeline across their farm would be far greater than for conventionalagricultural land and, probably even more severe than for other organic farms.

· In addition to recommending that the Gardens of Eaganfarm be avoided, I offer some suggestions for an alternative pipeline route inthe vicinity of the Gardens of Eagan farm.

· Next, I review the Amended AIMP and explain whyspecific amendments are needed in light of what we know about the importance ofsoil quality in organic systems and the way in which soil restoration can beverified.

· Finally, I explain some of the practices documented inthe Gardens of Eagan organic management plan that demonstrate the degree ofcare and knowledge reflected in the Diffleys’ farming practices. Based on myexperience and research on sustainable agriculture systems, I offer my opinionthat this farm is a unique asset and should be protected.

Nature of Soils and Soil Quality

Q. Could you please explain someof the characteristics of soils that are pertinent to understanding the impactsof pipeline construction and maintenance?

A. To start with, it is importantto understand the differences between different layers in agricultural soil. Weoften use the words “topsoil” and “subsoil,” but these terms aren’t precise.When we talk about agricultural soils, we need to think of the horizons ofwhich soil is composed.

TheA horizon is the topmost layer of topsoil and can vary in depth—soils at theGardens of Eagan farm have A horizons that range from 8 to 18 inches deep. Thiszone is the most biologicallyactive part of the soil and is most vital to crop growth. Even within the Ahorizon, there is some stratification, with the top few inches the mostbiologically active.

TheB horizon, underneath the A horizon, contains more clays and mineral deposits,a heavier texture, more rocks and much less organic matter. On these soils itoften occurs from about 16-18 inches down to about 30-36 inches in depth. Thislayer is sometimes called the subsoil.

HorizonC is also called the regolith. It is the slightly broken up parent materialbetween the B horizon and the bedrock below. Plant roots generally do notpenetrate into this layer and there is very little organic material.

Q. How are these soil horizonsimportant in organic crop production?

A. The most important feature toremember about organic crop production is that an organic farmer relies almostentirely upon the soil’s properties for crop production. The quality of thesoil determines whether crops will be healthy and free from disease andbuilding soil quality is the primary strategy that the organic crop farmer usesto protect crops from pests and disease. The level of biological activity inthe soil is even a key determinant of nutrient cycling, whereby minerals in thesoil can be used effectively by crops. Thus plant health directly depends onthe amount and quality of biological life in the A horizon.

Forany farmer, but particularly for an organic farmer relying on soil quality forcrop production, rather than chemical inputs, soil horizons are notinterchangeable. Preserving soil horizon stratification with the mostbiologically rich soils at the surface is essential to crop health and cropproduction.

Anorganic farmer will work for many years to build the surface horizon of thesoil and especially the top few inches that are richest in organic matter. Foran organic crop farmer, the A horizon is the bank account. If that bank accountis taken away or drastically disturbed, every investment that the farmer hasmade is placed in jeopardy.

Q. How does an organic cropfarmer build up the A horizon soils, particularly the top few inches that arerichest in organic material?

A. Ittakes many years to build A horizon soil structure through planting andincorporation of cover crops, crop rotation, sheet composting, application offinished compost and other crop management to develop soil tilth, build soilnutrients, and encourage worms and other biological life in the soil.

Ifone looks at an organic management plan for a farm that uses best practices tobuild soil quality, you will see repeated plantings with vetch, soy and othercrops that are not harvested, but gently incorporated into the surface of thesoils. You will also see that more careful and labor-intensive disc andchiseling methods are used to incorporate cover crops into the soil, ratherthan plowing the crops into the soil. The shallower methods of incorporatingcover crops ensure that biological matter is preserved in the top few inches ofthe A horizon..

Q. Are there differences betweensoil quality and the reliance on soil quality in organic and conventionalagricultural systems?

A. The quality of soils on a successful organic farm is usuallyquite different from that on a conventional farm. This difference can bemeasured in terms of soil compaction, soil aggregation, organic matter content,particulate organic matter and soil microbial biomass. Generally, if tillage isjudiciously applied, amounts of both stable and active organic matter increase,along with more aggregation and microbial biomass.

Recentstudies of farms transitioning from conventional to organic crops, such as theNorth Carolina State University study reported in Agriculture, Ecosystemsand the Environment in April 2006, have demonstrated that farms making thistransition have lower yields and more vulnerability to pests in the earlieststages of the transition. As conventional inputs of synthetic fertilizers,insecticides, fungicides, and herbicides are reduced, transitional landswithout fully developed organic soils qualities have lower yields and poorercrop growth. Only when soil microbial biomass and active organic matter (whichfeeds these organisms) increase as a result of organic soil managementpractices over time do yields and crop growth increase. Soil microorganismsplay a dominant role in nutrient cycling and pest control in organic farming systems.

Q. Are certain types of cropsmore and less vulnerable to differences in soil quality?

A. Organic field crops are morevulnerable to degradation of soil quality than are conventional field crops,since they do not use synthetic fertilizers, insecticides, fungicides andherbicides to stimulate plant growth and prevent vulnerability to pests andweeds. Conventional row crops are less sensitive to stress because chemicalinputs can compensate for poorer soil conditions. Thus these crops will show less loss of health, quality andyield when soil quality is poor.

Amongorganic crops, organic vegetable growth is the most sensitive to soil quality.For example, organic sweet corn is even more vulnerable to soil qualityvariation than organic field corn. Conventional vegetable seeds are oftencoated with fungicides and pesticides when they are planted. Organic vegetableseeds, which can use none of these chemical defenses, need optimal soilconditions to germinate and grow.

Also,the quality component is so much more important in organic vegetable productionsystems than in conventional field cropping. Consumers are buying a premiumproduct which must meet their standards for appearance as well as taste andnutritional quality. On an organic vegetable farm,sub-standard soil quality produces substandard products, such as smaller earsof corn, corn not filled out to the tip, lower levels of nutrition, morecosmetic insect damage, more disease, and lower nutrient levels.

Q.What are the economic implications of the loss of soil quality on an organicvegetable farm?

A. Basedon my research on developing sustainable agriculture and my work with farmersthroughout the Midwest, I believe that the losses to an organic vegetable farmfrom diminished soil quality are of a different character and order ofmagnitude than on a conventional crop farm. To start with, the value on a peracre basis of conventional field crops is only in the range of two to threehundred dollars per acre. The average value on a per acre basis of organicvegetables is about $10,000. Atina Diffley has explained that the Garden ofEagan yields per acre range from $4,000 to $70,000, with an average of about$11,500 per acre. This is consistent with a well-run premium organic vegetablefarm in the Midwest.

However,the market for premium organic products is unforgiving. Sub-standard organic vegetable productscannot be marketed without damaging the relationships and reputations neededwith suppliers. If organic sweet corn, vegetables, melons or other crops arebelow quality standards, the crop will be a total loss.

Q. How would crude oil pipelineconstruction and maintenance affect an organic vegetable farm?

A. First,wherever digging or trenching is done, construction of a crude oil pipelinewould remove and disrupt the A horizon soils which are the organic farmer’sbank account. Even if this soil was segregated and an effort was made tophysically replace this topsoil layer, the stratification of organic soils(with the especially organic matter rich soil in the top several inches) wouldbe destroyed. Organic topsoil health could only be restored over years ofrebuilding. If soil horizons were mixed in the construction process, it is notcertain that soil quality could ever be effectively restored.

Inaddition to the area trenched by construction, compactiondue to pipeline construction would destroy organic soil fertility. Mitigationby tillage, which may be an effective strategy for a conventional crop usingchemical inputs, does not restore organic soil quality and biological life.

Whereversoil quality and biological life remained impaired, it is likely that anorganic vegetable farm would experience considerable, if not total, crop loss.

Inaddition to the area of construction, an organic vegetable farm would berequired to establish buffer areas to prevent prohibited substances fromentering onto organic fields. Due to the topography and size of vegetablefields, it is possible that entire fields of production would be lost even ifthe pipeline construction area were only a hundred or a hundred twenty-fivefeet wide.

Detriment to Gardens of Eaganand Proposed Route Alignments

Q. Do you have an opinionregarding how the Gardens of Eagan organic vegetable farm would be affected ifa crude oil pipeline was constructed across the farm in the location proposedby the Minnesota Pipe Line Company?

A. Yes. I believe that constructionof a crude oil pipeline across the Gardens of Eagan farm in the locationproposed by the Minnesota Pipe Line Company would have a highly detrimentalaffect on soil quality and biological life, organic vegetable crops, habitatand control of run-off from nearby conventional farm lands. I believe that theviability of the farm itself could be jeopardized.

Q. Could you explain some of thefactors that lead you to this conclusion?

A. According to the Gardens ofEagan Organic Management Plan (OMP), their crops are wholly organic mixedvegetables -- broccoli, cabbage, kale, cucumbers, cauliflower, peppers, squash,tomatoes and watermelon. These crops are highly sensitive to changes in soilquality and in the organic farm systems that limit pests and disease.

Asexplained in the OMP, the Gardens of Eagan vegetable crops are marketedprimarily to cooperatives in the Minneapolis/St. Paul area. This is a marketthat is highly sensitive to quality of production.

Theprimary soil type in the area proposed for the MPL crude oil pipeline is a Cylinder loam, which formed in loamyalluvium overlying sand and gravel outwash. This loam soil would be susceptible to compaction. When soil is compacted, soil pores that allowwater to pass through the soil are crushed, potentially leading to ponded wateron the field. Reduction of pore space in compacted soil also reduces the soil’scapacity to store plant available water, which can lead to early drought stresson plants. Although Cylinder loam soil is a fertilesoil suitable for agriculture, the presence of high levels of organic matterand tilth suitable for organic agriculture on the Gardens of Eagan farm wouldresult from soil building practices over time, not the inherent properties ofthe soil.

Lookingat the route map provided in GOE Exhibit 1, the proposed location of the MPLpipeline – the filed route - would interfere with the grassed and trenchedwaterway. This waterway is part of the Organic Management Plan (Modules 5 and12) and serves to prevent run-off from adjacent conventional agricultural landfrom entering organic fields. That proposed pipeline route would also destroyhabitat for birds and mammals that is critical to support beneficial insectsand control weeds and pests on the Garden of Eagan farm. In addition toconflicting with the Environmental Impact, Soil Conservation and BiodiversitySet-Aside section of the Organic Management Plan, destruction of this habitatwould undermine the Weed, Pest and Disease Management strategies in the Plan.

The proposedpipeline location would also cut across several small vegetable fields evidenton the aerial maps. In addition to the area of trenching and the constructionarea, the Gardens of Eagan would need to take an organic buffer zone around theconstruction area out of production for at least three years. Given trenching,removal of soil horizons and compaction, soil quality is likely to bedetrimentally impacted for a period of years. With the sensitivity of organicvegetables and the quality requirements of a Twin Cities co-operative market,produce grown on post-pipeline soil is unlikely to beup to shippable standards, causing a 100 percent loss of yield until the soilis brought back to pre-pipeline health and organic certification, which may notever be possible.

Ifthere is contamination from construction activities or run-off containingprohibited materials, additional organic lands will be lost to production.

In my opinion, it is likely that Gardensof Eagan would have total crop loss from several organic vegetable fields for aperiod that could be many years in duration. If the crude oil pipeline were tobe constructed where the Minnesota Pipe Line Company proposed, the viability ofthe Gardens of Eagan farm itself would be placed in jeopardy.

Q. Assuming that there iscurrently a crude oil pipeline easement across the northwest corner of theGardens of Eagan farm and that Atina and Martin Diffley tried to grow crops onthat segment of their property, but gave up after several years of poor yieldsand low quality, would that affect your opinion?

A. This information would further confirm my opinion about therisk of permanent loss of soil quality and crop production on an organicvegetable farm from pipeline construction. Although it is possible thatconstruction practices today would be less destructive than the practices usedwhen the prior pipeline was installed, an experience of trying to rebuild soilssufficiently to grow premium organic vegetables and being ultimatelyunsuccessful in that attempt would be consistent with my prediction of harm dueto pipeline construction.

Q. Would other locationsproposed for the pipeline alignment in the vicinity of the Gardens of Eaganfarm have a different level of detriment to agriculture?

A. To the extent that otherlocations for the proposed pipeline cross conventional field crop land, theywould have a far less detrimental impact to agriculture than a route acrossorganic vegetable crop lands. Conventional field crops rely less on soilquality for crop production and rely on chemical inputs such as solublefertilizers, pesticides, fungicides and herbicides to promote growth and protectcrops from pests and disease. Impacts to soils from trenching and compactionare more likely to be mitigable on conventional field crop lands, and concernsabout contamination with substances prohibited under National Organic Programregulations would be inapplicable. In addition, markets for conventional fieldcrops are less intolerant of quality variation than the value-added organicvegetable market, so crop losses are likely to be far less substantial.

Tothe extent that other locations for the proposed pipeline cross conservationreserve land, these locations would further minimize the impacts onagricultural soils and production. Conservation reserve lands are usuallyhighly eroded lands that are taken out of production or reserved due to their lowerquality for production. If erosion control practices were maintained duringpipeline construction and maintenance, location of a crude oil pipeline onthese reserve lands would further minimize harm to agricultural soils andcrops. If there is conventional agricultural land which has already been usedfor pipeline construction, this area is also likely to be of lower soil qualitythan surrounding fields. The route proposed by the Diffleys as AlignmentModification B-5 in GOE Exhibit 1 and the route identified by MPL as AlignmentsModification B-6 and B-6a in GOE Exhibits 2 and 3 would both cause less harm toagricultural soils, crops and economies than the proposed route.

Q. Do you have a recommendationas to the pipeline alignment in the vicinity of the Gardens of Eagan organicfarm?

A. I would strongly recommend tothe Public Utilities Commission that the pipeline route proposed by theMinnesota Pipe Line Company through the center of the Gardens of Eagan organicfarm be rejected. I would also recommend to the Commission that an alternativealignment be chosen that avoids the Gardens of Eagan organic vegetable fieldsentirely.

Agricultural Impact MitigationPlan Amendments

Q. Have you reviewed the Agricultural Impact Mitigation Planand the proposed Amended Agricultural Impact Mitigation Plan?

A. Yes. Initially, I was contactedby Bob Patton at the Minnesota Department of Agriculture to provide advice onhow to measure harm to organic soil quality resulting from pipelineconstruction and how to restore soil quality. I also received from the Gardensof Eagan lawyer drafts of the Amended Agricultural Impact Mitigation Plan(Amended AIMP). I made comments and proposed additional changes which have beenincorporated in the August 2006 Amended AIMP document that is attached as GOEExhibit 5. Based on myconversations with Bob Patton and my review of the drafts, it is myunderstanding that the Amended AIMP includes suggestions developed by theMinnesota Department of Agriculture, recommendations from the Gardens of Eaganand amendments based on my comments and advice.

Q. Are there any proposedamendments with which you disagree?

A. No. I have reviewed the entireAugust 2006 Amended AIMP and I support all of the proposed changes. There aresome suggested changes that are more closely related to my areas of expertise,but I am comfortable that all of the amendments suggested for the AIMP reflectprudent and reasonable protections of organic soils and organic agriculture.

Q. Are there specific amendmentsthat you would like to highlight and recommend be adopted based on yourexpertise?

A. Yes. Let me first affirm theimportance of the definitions of organic agricultural land, certificationissues and organic system planning provided in the Amended AIMP. These definitionsreflect the real differences between organic and conventional agriculture.Changing the language of the AIMP is a critical first step to develop rationalmitigation practices based on the differences between agricultural systems. Theother amendments I would like to highlight focus on preservation andrestoration of organic soils and the consequences of soil damage toproductivity.

Q. Which amendments to the AIMPwould you specifically recommend to address issues of organic soil quality?

A. I would recommend the amendmentsproposed in paragraph E in section 1 (Pipeline Depth of Cover), Paragraph E of section 2 (TopsoilStripping, Storage and Replacement) and insection 14 (Ingress and Egress)of the AIMP. These amendments are critical to prevent the loss, through erosionand removal, of organic topsoil and to ensure that soil horizons and surfacesoils are replaced. Organic crop productivity requires recreating a soilprofile similar to that which was removed, with the richness of biological lifein the top several inches of soil. For organic crops, it is insufficient toprovide that topsoil (roughly 12 to 18 inches) will be replaced withoutspecifying that soil profiles must be recreated. Also the A horizon of organicsoils are much too valuable a resource to be used for access ramps. Due to thedependence of organic crop production on the quality of A horizon soils and thecertification process, a total crop loss must be provided for until soilrestoration and certification are complete.

Theamendments in section 7 of the AIMP on Compaction, Rutting, Fertilization,Liming and Soil Restoration reflect someof my most significant recommendations in this document. First, on OrganicAgricultural Land, cost of soil restoration should include application ofcompost, soil building through cover crops, and re-mineralization inputs suchas rock phosphate.

Next,because of an organic farmer’s reliance upon soil properties for productioncapacity, it should be presumed that any compacted or rutted soils or soilsaffected by construction activities will result in damage to the futureproduction capacity of the land. It is reasonable to presume productivitylosses for ten years unless the restoration of soil quality can bescientifically established and to place the burden on the pipeline company todemonstrate when organic soil quality has been restored. The proposed tests forsoil compaction, soil aggregation, organic matter content, particulate organicmatter and microbial biomass are the tests for organic soil quality that I haverecommended.

Q. How are you recommending thatthese tests for soil quality be done?

A. The Amended AIMP reflects myopinion about how soil quality restoration should be conducted. Although somefarmers may prefer that soil quality tests match precisely withpre-construction soil quality results, I have recommended that the comparisonbe a statistical one, since there is some natural variability in results. It isnot realistic to expect that post-construction tests would be identical to priortests of soil quality.

Q. What methodology would beused to conduct these tests?

A. The appropriate methodologywould require sampling at several locations. Measurements would be made atseveral sites, including paired comparisons to adjacent conventional croplandand unfarmed land on the organic farm property to determine baseline values andtheir variation. After construction, similar measurements would be taken andstatistical tests applied.

Q. Are there other amendments tothe AIMP that you would specifically recommend in order to protect organic soilquality?

A. Yes. I believe that theamendments to section 18 of the AIMP Construction in Wet Conditions are important to maintain soil structure. The Gardens of Eagan Organic ManagementPlan is a good example of the care that organic farmers take to preventdestruction of soil structure by working in wet conditions. Soil is not workedin wet conditions or even right before rain. It is completely appropriate topresume that construction in wet conditions will result in damage to the futureproduction capability of organic lands.

Preservation of Gardens ofEagan Organic Farm

Q. In your conversations andreview of materials connected with this case, have you had a chance to form anopinion about the importance of preserving the Gardens of Eagan certifiedorganic farm?

A. Yes, I have.

Q. And what is that opinion?

A. The Gardens of Eagan organicshould be protected. It is very difficult to grow premium quality organicvegetables. That Atina and Martin Diffley can grow organic vegetables and meetthe demand of a premium market demonstrates that they have a high level ofknowledge and sophistication. Their Organic Management Plan reflects care,environmental understanding and a commitment to preserve their farm as anorganic land use in perpetuity.

Inmy experience, the transition from conventional to organic agriculture isdifficult. It requires a paradigm shift from using chemical inputs todeveloping a farm ecology. A farm like the Gardens of Eagan that not onlyprovides a role model, but mentors and teaches other farmers is an importantagricultural and cultural resource for our region. It is worth protecting.

Q. Could you summarize yourrecommendations to the Commission?

A. 1)I recommend that, if the Commission approves a pipeline project, the Commissionshould reject the route proposed by the Minnesota Pipe Line Company and selecta route for that pipeline which avoids the Gardens of Eagan organic vegetablefarm. This farm is uniquely vulnerable and is worth preserving.

2)If the Commission approves a crude oil pipeline through this process, I wouldalso recommend that the Commission require as a condition of any constructionpermit that the Minnesota Pipe Line Company follow the practices contained inthe August 2006 Amended AIMP.

Q. Does this conclude yourtestimony?

Yes.