Roth feeder pig environmental concerns and need for an EIS

Dr. Byron Shaw
Emeritus Prof Soil and Water Resources UWSP

For the following reasons I feel there should be an environmental impact statement performed on the potential impacts of the Roth farm before any WPDES permit is issued to this facility.

1. All of the farm land drains to either exceptional resource waters (ERW), outstanding resource waters (ORW) or Clean Water Act section 303 (d) listed impaired waters. State and Federal law prohibits the discharge of new pollutants to waters already impaired by those pollutants, and also prohibits any lowering of water quality in ORWs or ERWs. The DNR must rigorously examine the potential impacts to these designated waters from manure discharge and assess the need for additional protections in any WPDES permit for the Roth farm.
2. The Roth farm plans to put the waste water from 1500 + animal units onto less than 195 acres of land 26 of which are unavailable for manure due to greater than 200ppm soil test P this leaves 169 acres for manure disposal not counting waterways that need to be excluded. This gives a land to animal unit ratio of .11 acres per animal unit. Even the Dept of Ag Trade and Consumer Protection recommends 1.0 acres per animal unit in their Work Sheet 3 for livestock Siting
3. In addition to hog manure there is a herd of 95 cows that are fed on some of the fields during the winter months. Some of these fields are already overloaded with phosphorus. And subject to runoff to the Wisconsin River during snowmelt and spring rains.
4. None of the manure used on this farm is incorporated making surface water contamination from runoff highly likely.
5. The only way this operation can fit within the NRCS 590 standard is with the very low manure analysis values obtained over the last year. These values are far below average values for hog manure and with proper sampling are likely to show much higher values in the future making it impossible to meet even the liberal 590 or DNR 243 standard.
6. There are also unrealistically high yield values used in the nutrient management plan to justify the high manure application rates. Even if these yields are achieved, it further indicates a level of fertility management that will result in both surface and groundwater pollution. Setting yield goals higher than county averages for the soils involved should not be acceptable on soils already having excessive phosphorus concentrations and on the steep slopes that occur on most of this farm.
7. All of the fields on this farm drain to ravines and or well defined waterways assuring that during runoff events there will be significant nutrient, bacteria and solids loss to the receiving streams. Not all of these areas of concentrated flow are mapped and shown to have the proper manure spreading restrictions.
8. All of the fields on this farm are well drained making then susceptible to nitrate leaching. Even though they are not listed on the NRCS list of soils with high leaching potential. Nitrate concentrations down gradient of these soil types often exceeding the health standard. This is further reason to only fertilize for crop yields that are averages for the soil types present.
9. In addition to the well drained nature of the soils there is the potential for Karst features on some of the hill top soils. This makes for an additional likelihood of nitrate and bacteria leaching into the underlying limestone aquifer. The Dubuque soils that occur on the ridge top fields are all described as having less than 60 inches of soil over weathered limestone bedrock. According to the the Northeast Wisconsin Karst Task Force report this would put these soils into the extreme category for relative vulnerability to contamination. For this category of soils the report recommends less than 6000 gallons per year of manure application with no more than 3000 per application. They also recommend immediate incorporation of manure after application.
10. The 590 standard allows for adding an additional 20% nitrogen over University recommendation when manure or alfalfa credits are the only source of nitrogen. This is not justified if water quality is a concern and assures that on average there will be a 20% over application of nitrogen. This further guarantees groundwater contamination as it only requires leaching of 11 pounds of nitrate nitrogen to reach the 10 mg/l nitrate standard in an area with 5 inches of annual groundwater recharge which is a reasonable number for the soils and topography found on this farm.
11. The overall level of nutrient management, high density of animals to land area, steep slopes, already overloaded soils with phosphorus, proximity to protected surface water resources, proximity to vulnerable groundwater and unrealistically low manure values all make it highly likely that significant water resource problems will occur if this facility is permitted as proposed.
12. As DNR is required to prevent further pollution of ORW, ERW and 303b listed waters there is a definite need for a detailed EIS before this facility would be permitted.
13. I have attached a copy of a Critique of the 590 Standard that further outlines the probability of water resource standard violations even if the 590 standard is met.