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.  
Chuck Lippstreu  
Michigan Agri-Business Association