December 7, 2021
Michigan Department of Agriculture and Rural Development
Pesticide and Plant Pest Management Division
Lansing, MI 48909
Re: MABA Support of Proposed Regulation 634
I am writing on behalf of the Michigan Agri-Business Association (MABA), a Michigan-based nonprofit
trade association representing more than 300 companies and organizations involved in the success of
agriculture in our state. MABA strongly supports proposed regulation 634 by the Michigan Department of
Agriculture and Rural Development (MDARD), related to commercial fertilizer sales in Michigan. This
proposed rule set benefits our state government and the agriculture industry by creating a more efficient
and streamlined process for reporting fertilizer tonnage.
Currently, companies selling commercial fertilizer in Michigan are required to report tonnage of sales
twice each year, in January and July. Completing two tonnage reports annually – when one report would
achieve the same objective – adds complexity and cost for businesses. Proposed regulation 634
streamlines this process by moving from a biennial system to an annual tonnage reporting system. The
regulation will greatly reduce the burden on both the businesses that file these reports and MDARD staff
who are responsible for processing and auditing them.
Our Association has encouraged the Department to promulgate these common-sense rule changes and we
appreciate the time and effort the Department has put into drafting the updated rules. We support the
regulation as proposed. Please feel free to contact me with any questions.
Michigan Agri-Business Association