Comment Submitted by Norman Arendt

I have several clients that are feed mills and also am performing all hazards mitigation planning throughout southern Minnesota and Northern Wisconsin. One thing I find in common is the total lack of computer skills among farmers and feed mill operators. In many areas Internet is evren non-existant. Some of the mills date back to the 1930's and are operated by sons of sons of farmers that never attended anything other than high school and maybe a trade school for a short period of time. Many mills are operated by omnly one or two individuals. In some mills farmers will mix and load their own supplies. The proposed regulations are not realistic in terms of the skills and operating processes at many mills. Unless the government is not only going to provide computers but also training at their facilities the rules will not be followed. Further to then claim that you will fine them per day for failure to follow the rules will just put many farmers and feed/fertilizer mills out of business. They are not operating on that type of margin to either buy the necessary equipment or provide the training off site to use it. The larger modern farms, usually corporate farms, and the larger modern feed/fertilizer mills have the staff and computer skills to follow the rules, but the one size fits all will not work with family farms and feed mills unless you are intentionally trying to drive them out of business and rules such as this will. Agriculture operates on a very slim margin with many farms in debt to survive. Further if you wish for the farms and mills to use less explosive potential products some one will have to provide the education to them so that they change. I am sure that with the knowledge they would change to AN alternatives if they are equal to or less than in total cost. Total cost you have to look at amount per acre and number of applications to justify the cost savings. Many farms in both Southern Minnesota and Northern Wisconsin use propane as fuel for heat and do not have cell phones. Many family farms are just as large as the corporate farms but with less resources. I realize that AN in certain mixtures and whether it is coated or uncoated determines the explosive potential. Many farmers do not care about this and some have not even heard about this aspect of AN. Another issue is how AN gets to the Midwest farmers and mills. Most comes up the Mississippi on uncovered barges where 15% loss is considered excellent. The first issue you should address is this transport of AN to the mills. Any change in transport increases costs which in turn has a pyramiding affect all the way to the consumer of the agricultural products. I would think that you would address propane useage and anhydrous ammonia just as you would AN.