| Figuring out what to do with the vast flow of animal waste---referred to as "nutrient management" in the business---is always one of the critical concerns surrounding CAFO's. Contamination of ground water is a well-established risk, as illustrated by recent experience several counties away from Rosendale (not far from another large CAFO run by Rosendale Dairy's owner) reported on recently by the NYT. After onsite separation of solids from liquids, solid manure is usually sold as fertilizer to area farms for cash, or traded for feed crops and silage, whereas liquids are stored in "manure lagoons" and periodically sprayed onto immediately adjacent fields. That is the plan for Rosendale, but there is a wrinkle.
About 20% of the more than 13,000 acres of farm fields that Rosendale Dairy plans to spread its manure on are classified as having shallow groundwater, also called "wet soils". This means that groundwater on this land will from time to time rise above a below-surface depth of 24 inches. So, instead of staying where it's spread to be absorbed and processed by crop plants, the nutrient content of the manure will enter the ground water and travel. Travel where? It depends. If purely through soil, probably not too far horizontally. But vertically, perhaps into aquifers that feed wells, as most likely happened in the NYT story above.
But the fastest mode of travel is via the labyrinth of perforated pvc drain tiles buried in farm fields to keep them dry enough to plant, according to Wisconsin DNR Nutrient Management Specialist Andrew Craig. By design, groundwater entering these tiles flows away, and may eventually make its way into a stream or other surface water body. And if that groundwater is contaminated from the applied manure? Up goes the already-high nutrient load in that water body, as well as its downstream watershed.
There is only one way to prevent this manure from escaping wet soils: don't put any on them. This is precisely the reason that the existing DNR rules require any party wishing to spread manure on wet soils to first determine whether the ground water level is above the 24-inch depth line. If it is, then spreading is prohibited. But the only way to determine that is to dig pits or wells to see how far down the water line is. Current DNR standards recommend that these test pits be spaced closely enough that an accurate determination of the depth of ground water across a field can be made. The DNR's standard is two pits per every five acres of wet soils. Of the 13,000 acres Rosendale Dairy plans to spread manure on, 2,285 are considered wet soils. By the DNR's standards, that would dictate about 900 test pits.
Rosendale Dairy thinks all this digging and testing will cost them too much time and money, so they complained and counter-proposed an alternative plan. That plan is to dig fewer than 10% of the number of test pits in the DNR's standards. And the DNR gave them a nice break and accepted their plan. Instead of 900 pits, they only have to dig 74. But how can such sparse soil sampling yield an accurate measure of ground water depth across such a broad area? Technology!
In addition to performing 90% fewer soil tests, the other part of the "never-before-tried method" referenced above is explained in that same RCN article:
According to [written correspondence from] Conestoga-Rovers & Associates of Green Bay, an engineer working with Rosendale Dairy, the dairy has proposed a plan that could be described as a "statistical analysis" model for determining whether a field is wet. Rather than checking every field, Rosendale Dairy operators will check "representative" wet fields nearby at the same elevation.
"A total of 41 MMPs [moisture measurement points] will be installed at selected locations in the 207 fields with [wet] soils," Conestoga-Rovers wrote. "These MMPs will monitor more than 904 acres of [wet] soils area on the farm and result in a database of representative field conditions..."
The idea is that if the groundwater is not at less than 24 inches from the surface in the representative field, it will not be high at another area field at the same elevation as well.
The aim, according to Conestoga-Rovers, "is to establish permanent representative [moisture management points] in lieu of excavating soil test pits each time manure or wastewater will be land applied... Rosendale Dairy will have a statistically significant, effective database upon which to base its compliance verification that groundwater is not present within 24 inches below ground surface prior to manure and wastewater application."
The question remains, does groundwater remain at a constant depth over a given distance, or at least, will it vary in a consistent manner?
"We questioned that assumption," the DNR's Craig said.
Having questioned that, they allowed Rosendale Dairy to proceed, albeit with a requirement to dig 40 more pits to verify the statistical model. Will the DNR at least monitor the test to make sure Rosendale Dairy fully complies with this drastically reduced soil protection measure? Well, maybe, but they are not obligated to. Rosendale Dairy will self-report the results of their tests. So, a "never-before-tried method" of manure spreading, with 90% less monitoring for shallow groundwater, controlled by statistical modeling software, with Rosendale Dairy doing their own testing and reporting. What could possibly go wrong?
The safety of the groundwater and other adjacent surface bodies of water in a sizable chunk of Fond du Lac County, and possibly adjacent counties, will rely on the good faith efforts of Rosendale Dairy and its statistical model. Is there any cause for concern about this? After all, the well-spoken, telegenic lead executive for Rosendale Dairy, Jim Ostrom, states in a "Guest Opinion" published Thursday in the the Fond du Lac Reporter, that:
"When Rosendale Dairy's three partners - John Vosters, Todd Willer and I - were boys on Wisconsin dairy farms, we imagined little beyond waking early, milking, feeding and caring for cows. ...we remain committed to the dairy industry and to producing wholesome food for our nation. We are also committed to the environment and to our Wisconsin roots. We are committed to doing what is right - and taking pride in it."
That's comforting, right? On the other hand, according to a Wisconsin Public Television report from early this year, Rosendale Dairy commenced construction of the first 4,000-cow expansion of the CAFO facility in 2008, months before receiving DNR approval. This earned them a DNR Notice of Non-compliance, after several written warnings to stop work pending approval. Rosendale Dairy disregarded those DNR actions, and plowed ahead. What was the hurry? Says lead executive Ostrom:
"It's a massive investment. We've got so far over $35 million spent. We'll eventually have $70 million spent. You want to get the investment employed to pay back some of the bills soon."
Of course, Rosendale Dairy eventually got the permits they needed, just as they received this extremely lenient manure spreading approval, and will most likely soon get the green light for the final expansion to 8,000 cows (plus 500 "dry cows"). They seem to know they are dealing with a state agency that lacks the will or clout to be anything other than a speed bump for large industrial projects like this. The DNR's allocation of staff resources tells the story: in Wisconsin's Northeast Region, the DNR has only 3 enforcement staff members to cover 95 CAFO's.
The Rosendale Dairy CAFO resonates with me personally. I drive through that town every time I visit my second home located in the adjacent county to the west. I have a direct interest in the potential watershed pollution of a particular stream, Silver Creek, which begins about 10 miles southwest of this facility and meanders another 10 miles further west, eventually feeding into Green Lake, on which my house is located. Mr. Craig of the DNR could not have been more helpful in answering my questions, mailing me a disk containing Rosendale Dairy's manure spreading maps (I'll get it next week), as well as talking me through the DNR's online "Surface Water Data Viewer" software to help me determine the specific impact on Silver Creek. But his agency as a whole is no match for Rosendale Dairy, which in contrast to executive Ostrom's allusions to his pastoral, "red barn" dairy farm upbringing, is part of a sophisticated, well-financed agribusiness firm, named Milk Source Holdings, LLC.
The contrast between this industrial operation, and the small, sustainable, family farms less than 30 minutes away, that I recently profiled here and here is quite jarring. There is a fork in the road heading to two very different food futures. I'm committed to the fork that heads towards these small farms.
If you are looking for holiday/end-of-the-year donating opportunities, you might consider Midwest Environmental Advocates, who have been representing the local citizens organization opposing the Rosendale Dairy, People Empowered to Protect the Land (PEPL) of Rosendale. If you check out MEA's site, you'll see how much important work they are doing.
Cross-posted at Great Lakes Real Food |
