INTRODUCTION

Q. Please state your name and address.

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

Saint Paul, MN 55108-2243

Q. What is your primary work and what is your business address?

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

Q. Who are you representing in this proceeding?

A. In this proceeding, I am offering my testimony on behalf of the Gardens of Eagan certified organic farm owned by Atina and Martin Diffley. Based on my knowledge of soils and the impacts of pipeline construction on organic soils and agriculture, I am recommending that any crude oil pipeline approved by the Minnesota Public Utilities Commission as a result of the Minnesota Pipe Line Company (MPL) application should avoid the Gardens of Eagan organic farm. My testimony also supports recommendations for amendments to the Agriculture Impact Mitigation Plan (AIMP) filed by MPL. The AIMP should include specific provisions to protect and restore organic soils and should provide compensation for production losses and scientific testing to verify the parameters of soil restoration.

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

A. I received a B.A. in Anthropology from Grinnell College in Iowa in 1973, an M.A. in Anthropology from the University of Pennsylvania in 1976, an M.S. in Agriculture from California Polytechnic State University in San Luis Obispo in 1983 and a Ph.D. in Soil Science from the University of California in Riverside, California in 1987.

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

I am a member of many professional associations and honorary societies, including the American Society of Agronomy, the American Society of Plant Biologists, the Institute for Alternative Agriculture, the Soil Science Society of America, Phi Beta Kappa, Gamma Sigma Delta (an organization supporting agriculture) and Sigma Xi (a scientific research society). I have received numerous professional awards, including recognition as Fellow of the American Society of Agronomy and Fellow of the Soil Science Society in 2004.

I have received more than 40 grants for study and research related to plant nutrition and soil fertility. These have included grants for modeling the root-soil interface, for improving productivity of crops, for analyzing soil characteristics, for development and application of soil quality indicators, for biological, social and financial monitoring to develop highly sustainable farming systems, for developing a soil management guidebook, for assessing soil quality changes in alternative and conventional cropping systems and for developing weed, pest and soil management tools for organic crop systems.

I have authored or co-authored approximately 45 publications in refereed journals and proceedings and dozens of abstracts, research presentations, invited proceedings and book chapters. Many of my publications have focused on plant root development and biochemistry, including interactions with chemicals in soils and solutions. I have also written and presented materials relating to soil quality assessment, soil management for sustainable agriculture, and improving production of crops. My research presentations have addressed environmental effects of conventional and alternative farming and soil quality, profitability and risk of conventional and organic cropping as well as the biology and chemistry of plant and soil systems. My curriculum vitae, provided as Gardens of Eagan (GOE) Exhibit 8 details these publications.

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

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

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

A. In addition to the Gardens of Eagan Organic Management Plan, I reviewed the Agricultural Impact Mitigation Plan (AIMP) submitted by the Minnesota Pipe Line Company (MPL) and draft suggestions for amending this AIMP. I reviewed the Gardens of Eagan Proposal for Alternative Route Alignment to Avoid Organic Farm and the Gardens of Eagan Proposal for Modification of Agricultural Impact Plan and Environmental Assessment and various maps that depict pipeline route alternatives in the vicinity of the Gardens of Eagan farm.

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

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

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

PURPOSE AND SCOPE

Q. Please summarize your testimony.

1) Organic crop systems and, particularly organic vegetable crops are highly vulnerable to the impacts of pipeline construction and maintenance. Constructing a crude oil pipeline on an organic vegetable farm like the Gardens of Eagan would be far more detrimental and costly than routing the pipeline on other agricultural land. I would strongly recommend that, if a pipeline is approved, the Public Utilities Commission should designate a route that avoids the Gardens of Eagan organic farm.

2) Because of the differences between organic and conventional farming, the Agricultural Impact Mitigation Plan for this project should distinguish between organic and non-organic agricultural lands and require specific practices to minimize the harm to organic soils, restore soil horizons and qualities, scientifically verify soil restoration and provide appropriate compensation when soils and productivity are impaired. I would recommend that the Commission require as a condition of any construction permit that the Minnesota Pipe Line Company follow the practices contained in the August 2006 Amended AIMP attached as GOE Exhibit 5.

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

Q. How is your testimony organized?

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

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

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

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

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

Nature of Soils and Soil Quality

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

A. To start with, it is important to understand the differences between different layers in agricultural soil. We often 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 of which soil is composed.

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

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

Horizon C is also called the regolith. It is the slightly broken up parent material between the B horizon and the bedrock below. Plant roots generally do not penetrate into this layer and there is very little organic material.

Q. How are these soil horizons important in organic crop production?

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

For any farmer, but particularly for an organic farmer relying on soil quality for crop production, rather than chemical inputs, soil horizons are not interchangeable. Preserving soil horizon stratification with the most biologically rich soils at the surface is essential to crop health and crop production.

An organic farmer will work for many years to build the surface horizon of the soil and especially the top few inches that are richest in organic matter. For an organic crop farmer, the A horizon is the bank account. If that bank account is taken away or drastically disturbed, every investment that the farmer has made is placed in jeopardy.

Q. How does an organic crop farmer build up the A horizon soils, particularly the top few inches that are richest in organic material?

A. It takes many years to build A horizon soil structure through planting and incorporation of cover crops, crop rotation, sheet composting, application of finished compost and other crop management to develop soil tilth, build soil nutrients, and encourage worms and other biological life in the soil.

If one looks at an organic management plan for a farm that uses best practices to build soil quality, you will see repeated plantings with vetch, soy and other crops that are not harvested, but gently incorporated into the surface of the soils. You will also see that more careful and labor-intensive disc and chiseling methods are used to incorporate cover crops into the soil, rather than plowing the crops into the soil. The shallower methods of incorporating cover crops ensure that biological matter is preserved in the top few inches of the A horizon..

Q. Are there differences between soil quality and the reliance on soil quality in organic and conventional agricultural systems?

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

Recent studies of farms transitioning from conventional to organic crops, such as the North Carolina State University study reported in Agriculture, Ecosystems and the Environment in April 2006, have demonstrated that farms making this transition have lower yields and more vulnerability to pests in the earliest stages of the transition. As conventional inputs of synthetic fertilizers, insecticides, fungicides, and herbicides are reduced, transitional lands without fully developed organic soils qualities have lower yields and poorer crop growth. Only when soil microbial biomass and active organic matter (which feeds these organisms) increase as a result of organic soil management practices over time do yields and crop growth increase. Soil microorganisms play a dominant role in nutrient cycling and pest control in organic farming systems.

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

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

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

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

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

A. Based on my research on developing sustainable agriculture and my work with farmers throughout the Midwest, I believe that the losses to an organic vegetable farm from diminished soil quality are of a different character and order of magnitude than on a conventional crop farm. To start with, the value on a per acre basis of conventional field crops is only in the range of two to three hundred dollars per acre. The average value on a per acre basis of organic vegetables is about $10,000. Atina Diffley has explained that the Garden of Eagan 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 vegetable farm in the Midwest.

However, the market for premium organic products is unforgiving. Sub-standard organic vegetable products cannot be marketed without damaging the relationships and reputations needed with suppliers. If organic sweet corn, vegetables, melons or other crops are below quality standards, the crop will be a total loss.

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

A. First, wherever digging or trenching is done, construction of a crude oil pipeline would remove and disrupt the A horizon soils which are the organic farmer’s bank account. Even if this soil was segregated and an effort was made to physically replace this topsoil layer, the stratification of organic soils (with the especially organic matter rich soil in the top several inches) would be destroyed. Organic topsoil health could only be restored over years of rebuilding. If soil horizons were mixed in the construction process, it is not certain that soil quality could ever be effectively restored.

In addition to the area trenched by construction, compaction due to pipeline construction would destroy organic soil fertility. Mitigation by tillage, which may be an effective strategy for a conventional crop using chemical inputs, does not restore organic soil quality and biological life.

Wherever soil quality and biological life remained impaired, it is likely that an organic vegetable farm would experience considerable, if not total, crop loss.

In addition to the area of construction, an organic vegetable farm would be required to establish buffer areas to prevent prohibited substances from entering onto organic fields. Due to the topography and size of vegetable fields, it is possible that entire fields of production would be lost even if the pipeline construction area were only a hundred or a hundred twenty-five feet wide.

Detriment to Gardens of Eagan and Proposed Route Alignments

Q. Do you have an opinion regarding how the Gardens of Eagan organic vegetable farm would be affected if a crude oil pipeline was constructed across the farm in the location proposed by the Minnesota Pipe Line Company?

A. Yes. I believe that construction of a crude oil pipeline across the Gardens of Eagan farm in the location proposed by the Minnesota Pipe Line Company would have a highly detrimental affect on soil quality and biological life, organic vegetable crops, habitat and control of run-off from nearby conventional farm lands. I believe that the viability of the farm itself could be jeopardized.

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

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

As explained in the OMP, the Gardens of Eagan vegetable crops are marketed primarily to cooperatives in the Minneapolis/St. Paul area. This is a market that is highly sensitive to quality of production.

The primary soil type in the area proposed for the MPL crude oil pipeline is a Cylinder loam, which formed in loamy alluvium overlying sand and gravel outwash. This loam soil would be susceptible to compaction. When soil is compacted, soil pores that allow water to pass through the soil are crushed, potentially leading to ponded water on the field. Reduction of pore space in compacted soil also reduces the soil’s capacity to store plant available water, which can lead to early drought stress on plants. Although Cylinder loam soil is a fertile soil suitable for agriculture, the presence of high levels of organic matter and tilth suitable for organic agriculture on the Gardens of Eagan farm would result from soil building practices over time, not the inherent properties of the soil.

Looking at the route map provided in GOE Exhibit 1, the proposed location of the MPL pipeline – the filed route - would interfere with the grassed and trenched waterway. This waterway is part of the Organic Management Plan (Modules 5 and 12) and serves to prevent run-off from adjacent conventional agricultural land from entering organic fields. That proposed pipeline route would also destroy habitat for birds and mammals that is critical to support beneficial insects and control weeds and pests on the Garden of Eagan farm. In addition to conflicting with the Environmental Impact, Soil Conservation and Biodiversity Set-Aside section of the Organic Management Plan, destruction of this habitat would undermine the Weed, Pest and Disease Management strategies in the Plan.

The proposed pipeline location would also cut across several small vegetable fields evident on the aerial maps. In addition to the area of trenching and the construction area, the Gardens of Eagan would need to take an organic buffer zone around the construction area out of production for at least three years. Given trenching, removal of soil horizons and compaction, soil quality is likely to be detrimentally impacted for a period of years. With the sensitivity of organic vegetables and the quality requirements of a Twin Cities co-operative market, produce grown on post-pipeline soil is unlikely to be up to shippable standards, causing a 100 percent loss of yield until the soil is brought back to pre-pipeline health and organic certification, which may not ever be possible.

If there is contamination from construction activities or run-off containing prohibited materials, additional organic lands will be lost to production.

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

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

A. This information would further confirm my opinion about the risk of permanent loss of soil quality and crop production on an organic vegetable farm from pipeline construction. Although it is possible that construction practices today would be less destructive than the practices used when the prior pipeline was installed, an experience of trying to rebuild soils sufficiently to grow premium organic vegetables and being ultimately unsuccessful in that attempt would be consistent with my prediction of harm due to pipeline construction.

Q. Would other locations proposed for the pipeline alignment in the vicinity of the Gardens of Eagan farm have a different level of detriment to agriculture?

A. To the extent that other locations for the proposed pipeline cross conventional field crop land, they would have a far less detrimental impact to agriculture than a route across organic vegetable crop lands. Conventional field crops rely less on soil quality for crop production and rely on chemical inputs such as soluble fertilizers, pesticides, fungicides and herbicides to promote growth and protect crops from pests and disease. Impacts to soils from trenching and compaction are more likely to be mitigable on conventional field crop lands, and concerns about contamination with substances prohibited under National Organic Program regulations would be inapplicable. In addition, markets for conventional field crops are less intolerant of quality variation than the value-added organic vegetable market, so crop losses are likely to be far less substantial.

To the extent that other locations for the proposed pipeline cross conservation reserve land, these locations would further minimize the impacts on agricultural soils and production. Conservation reserve lands are usually highly eroded lands that are taken out of production or reserved due to their lower quality for production. If erosion control practices were maintained during pipeline construction and maintenance, location of a crude oil pipeline on these reserve lands would further minimize harm to agricultural soils and crops. If there is conventional agricultural land which has already been used for pipeline construction, this area is also likely to be of lower soil quality than surrounding fields. The route proposed by the Diffleys as Alignment Modification B-5 in GOE Exhibit 1 and the route identified by MPL as Alignments Modification B-6 and B-6a in GOE Exhibits 2 and 3 would both cause less harm to agricultural soils, crops and economies than the proposed route.

Q. Do you have a recommendation as to the pipeline alignment in the vicinity of the Gardens of Eagan organic farm?

A. I would strongly recommend to the Public Utilities Commission that the pipeline route proposed by the Minnesota Pipe Line Company through the center of the Gardens of Eagan organic farm be rejected. I would also recommend to the Commission that an alternative alignment be chosen that avoids the Gardens of Eagan organic vegetable fields entirely.

Agricultural Impact Mitigation Plan Amendments

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

A. Yes. Initially, I was contacted by Bob Patton at the Minnesota Department of Agriculture to provide advice on how to measure harm to organic soil quality resulting from pipeline construction and how to restore soil quality. I also received from the Gardens of Eagan lawyer drafts of the Amended Agricultural Impact Mitigation Plan (Amended AIMP). I made comments and proposed additional changes which have been incorporated in the August 2006 Amended AIMP document that is attached as GOE Exhibit 5. Based on my conversations with Bob Patton and my review of the drafts, it is my understanding that the Amended AIMP includes suggestions developed by the Minnesota Department of Agriculture, recommendations from the Gardens of Eagan and amendments based on my comments and advice.

Q. Are there any proposed amendments with which you disagree?

A. No. I have reviewed the entire August 2006 Amended AIMP and I support all of the proposed changes. There are some 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 reflect prudent and reasonable protections of organic soils and organic agriculture.

Q. Are there specific amendments that you would like to highlight and recommend be adopted based on your expertise?

A. Yes. Let me first affirm the importance of the definitions of organic agricultural land, certification issues and organic system planning provided in the Amended AIMP. These definitions reflect the real differences between organic and conventional agriculture. Changing the language of the AIMP is a critical first step to develop rational mitigation practices based on the differences between agricultural systems. The other amendments I would like to highlight focus on preservation and restoration of organic soils and the consequences of soil damage to productivity.

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

A. I would recommend the amendments proposed in paragraph E in section 1 (Pipeline Depth of Cover), Paragraph E of section 2 (Topsoil Stripping, Storage and Replacement) and in section 14 (Ingress and Egress) of the AIMP. These amendments are critical to prevent the loss, through erosion and removal, of organic topsoil and to ensure that soil horizons and surface soils are replaced. Organic crop productivity requires recreating a soil profile similar to that which was removed, with the richness of biological life in the top several inches of soil. For organic crops, it is insufficient to provide that topsoil (roughly 12 to 18 inches) will be replaced without specifying that soil profiles must be recreated. Also the A horizon of organic soils are much too valuable a resource to be used for access ramps. Due to the dependence of organic crop production on the quality of A horizon soils and the certification process, a total crop loss must be provided for until soil restoration and certification are complete.

The amendments in section 7 of the AIMP on Compaction, Rutting, Fertilization, Liming and Soil Restoration reflect some of my most significant recommendations in this document. First, on Organic Agricultural Land, cost of soil restoration should include application of compost, soil building through cover crops, and re-mineralization inputs such as rock phosphate.

Next, because of an organic farmer’s reliance upon soil properties for production capacity, it should be presumed that any compacted or rutted soils or soils affected by construction activities will result in damage to the future production capacity of the land. It is reasonable to presume productivity losses for ten years unless the restoration of soil quality can be scientifically established and to place the burden on the pipeline company to demonstrate when organic soil quality has been restored. The proposed tests for soil compaction, soil aggregation, organic matter content, particulate organic matter and microbial biomass are the tests for organic soil quality that I have recommended.

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

A. The Amended AIMP reflects my opinion about how soil quality restoration should be conducted. Although some farmers may prefer that soil quality tests match precisely with pre-construction soil quality results, I have recommended that the comparison be a statistical one, since there is some natural variability in results. It is not realistic to expect that post-construction tests would be identical to prior tests of soil quality.

Q. What methodology would be used to conduct these tests?

A. The appropriate methodology would require sampling at several locations. Measurements would be made at several sites, including paired comparisons to adjacent conventional cropland and unfarmed land on the organic farm property to determine baseline values and their variation. After construction, similar measurements would be taken and statistical tests applied.

Q. Are there other amendments to the AIMP that you would specifically recommend in order to protect organic soil quality?

A. Yes. I believe that the amendments to section 18 of the AIMP Construction in Wet Conditions are important to maintain soil structure. The Gardens of Eagan Organic Management Plan is a good example of the care that organic farmers take to prevent destruction of soil structure by working in wet conditions. Soil is not worked in wet conditions or even right before rain. It is completely appropriate to presume that construction in wet conditions will result in damage to the future production capability of organic lands.

Preservation of Gardens of Eagan Organic Farm

Q. In your conversations and review of materials connected with this case, have you had a chance to form an opinion about the importance of preserving the Gardens of Eagan certified organic farm?

A. Yes, I have.

Q. And what is that opinion?

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

In my experience, the transition from conventional to organic agriculture is difficult. It requires a paradigm shift from using chemical inputs to developing a farm ecology. A farm like the Gardens of Eagan that not only provides a role model, but mentors and teaches other farmers is an important agricultural and cultural resource for our region. It is worth protecting.

Q. Could you summarize your recommendations to the Commission?

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

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

Q. Does this conclude your testimony?

Yes.