Lisa Anderson:

Katy Bailey and I are quoted in the press release by Midwest Environmental Advocates (MEA) and the Environmental Working Group (EWG). By following the links below, you can see the study that the two groups worked on, the press release, and some articles covering the study and related issues. The quote by me is slightly off in that it appears our well is currently contaminated. Our well was contaminated prior to 2011 when we replaced it. The “our” in the quote is a collective “our.”

New Report Finds Water Pollution Would Likely Worsen with Expansion of Animal
Feeding Operations in Northeast Wisconsin and the Central Sands

Analysis Reveals Widespread Overapplication of Manure and Commercial Fertilizer, Lack of Available Farmland for Safely Disposing of Additional Animal Waste

MADISON, WI— A new report by the Environmental Working Group (EWG) and Midwest Environmental Advocates (MEA) finds that in some areas of the state, including Kewaunee County and portions of the Central Sands, there is not enough agricultural land to safely dispose of the manure generated by animal feeding operations. The report raises concerns about the potential expansion of industrial-scale livestock operations in areas that are already grappling with drinking water pollution.

Using aerial imagery and publicly available data, EWG and MEA modeled current rates of application for commercial fertilizer and animal manure in nine Wisconsin counties. The analysis, which is the first of its kind in Wisconsin, shows that fertilizer and manure are being applied to farmland at rates that far exceed what is needed by crops growing in the surrounding area.

Nitrogen and phosphorus in manure and commercial fertilizer are essential crop nutrients, but excess nutrients caused by overapplication of manure and fertilizer can cause nitrate contamination of groundwater and pollute Wisconsin’s rivers, lakes and streams.

An Overwhelming Amount of Manure in Kewaunee County

The number of concentrated animal feeding operations, or CAFOs, in Wisconsin has dramatically increased over the past few decades. As CAFOs multiply and grow larger, they continue to pump out massive amounts of manure for disposal. The trend has been especially devastating in places like Kewaunee County, where fractured bedrock and shallow soils make groundwater vulnerable to pollution. Kinnard Farms, located in Kewaunee County, is one of the state’s largest dairy CAFOs. The farm was at the center of a landmark legal decision in July in which the Wisconsin Supreme Court affirmed the state’s authority to limit the number of animals allowed under the farm’s permit and to require the farm to monitor groundwater quality in areas where large amounts of manure are spread.

As a result of the ruling, the Wisconsin Department of Natural Resources (DNR) is now required to revisit permits for Kinnard Farms and a number of other large CAFOs. Neighbors of Kinnard Farms point to the report by EWG and MEA as evidence that the DNR must set an animal until limit that does not allow for future expansion.

“The report confirms exactly what the citizen groups have said for years—Kinnard’s current water pollution permit and nutrient management plan aren’t protecting our drinking water,” said Jodi Parins, a neighbor of Kinnard Farms. “The DNR can no longer ignore the science that shows that concentrated animal feeding operations don’t work for our water or our communities—not by watering down manure, not by capturing methane, not by flushing gray water into our streams.”

“In setting an animal unit limit for Kinnard Farms, the DNR must consider the overwhelming amount of fertilizer and manure that is already being applied to fields in the area,” said Adam Voskuil, MEA Staff Attorney and co-author of the report. “More cows would lead to more pollution—there’s just nowhere for additional manure to be safely spread.”

“Why isn’t the Wisconsin Department of Natural Resources more concerned about our health and the environments of Kewaunee and Door Counties?” said Mike Bahrke, Executive Director of the Door County Environmental Council. “CAFO manure is polluting the aquifer and contaminating wells in Kewaunee County and likely Door County. The DNR has the authority and the power, and it’s time to protect our water and our residents!”

A Drinking Water Crisis in the Central Sands

Residents of Wisconsin’s Central Sands region are equally concerned about CAFO expansion and contamination of their drinking water. The new report by EWG and MEA modeled manure and fertilizer application in Portage County and found that—as in Kewaunee County—manure and fertilizer are being applied at rates that already exceed the available agricultural fields’ crop nutrient needs. In response to the growing crisis, the DNR began developing new rules in 2019 for the application of manure and commercial fertilizer in the Central Sands and other vulnerable areas of the state. Despite strong public support, the new environmental protections faced opposition from industrial agriculture groups and their allies in the legislature, and in November, the DNR announced that it would abandon its efforts. The news that the DNR would not move forward with new groundwater protections was especially disappointing for residents of Nelsonville, where half of all private wells tested are considered unsafe due
to pollution from agricultural fertilizer and manure. The ongoing water quality crisis has led local residents to call for increased accountability and oversight of large livestock operations like Gordondale Farms, a dairy CAFO with approximately 2,000 cows. The recharge zone for the groundwater that Nelsonville relies on includes fields on which Gordondale Farms spreads manure. Like Kinnard Farms, Gordondale’s permit is now subject to modification following the Supreme Court’s July ruling. The farm’s neighbors have asked the DNR to require groundwater monitoring and to limit future expansion.

“Like other neighbors of Gordondale Farms, we’ve seen a consistent decline in the quality of our well water, said Nelsonville resident Lisa Anderson. “The EWG report confirms that what we’re asking for is both reasonable and necessary.”

Lisa Anderson

Nelsonville resident

Note: This email is being shared with most Nelsonville residents and other interested parties. The county board is not included as a whole, but feel free to share this information as you like.

Wisconsin Public Radio Story:
“Report: Too much manure and fertilizer is being spread in some areas at the expense of water quality”

Report examines 9 counties and finds overapplication of nutrients

By Danielle Kaeding

Published: 

• Wednesday, February 16, 2022, 5:10pm

By Jim McKnight, submitted Feb. 26, 2022.

A watershed moment, if you’ll pardon the pun, was reached at the last Portage County Land and Water Conservation Committee (LAWCON) meeting February 1 in Stevens Point. Responding to comments from committee members and a full room of spectators including Nelsonville residents, professional hydrologists, citizens and farmers, Chair Barry Jacowski finally admitted what years of data and testimony has established on groundwater nitrate pollution, “we all know agriculture is the problem.”

While applauding the recognition of the problem finally by the chair, it is important to note that what the data also says is that not all farming methods are harmful and certain soil types can be identified as most vulnerable. A 2021 research report by the UWSP Center for Watershed Science, recognized that the Central Sands of Portage County had “the most highly susceptible conditions for nitrate concentrations in the state” because of the combination of porous sandy soils and growing methods practiced there. By far the most negative impacts measured are found on irrigated sandy soils where monocropping with potato, corn, and vegetable row crops that rely on high levels of synthetic nitrogen applications is the norm. The permeability, or ease with which water passes through sandy subsoils, also makes it a challenge to spread large quantities of manure, even over larger surface areas, without contaminating groundwater.

Which brings us back to the LAWCON meeting, and why there was a full house. The proposal before the committee was to establish a plan for monitoring wells to be installed around the Village of Nelsonville to understand the source of nitrate contamination in private wells. A study by an independent consultant in 2019, based on lab analysis of samples from polluted wells, found the source to be agricultural. However, the committee, when presented with the study, deferred to public comments challenging the results and said more information was needed.

Frustrated, residents and groundwater activists, bolstered by the lack of any scientific data challenging initial study conclusions, asked the committee to endorse a network of monitoring wells around the Village that would produce conclusive data. That information could be used to identify specific locations and activities around the Village that are most problematic and help develop specific fixes.

For the next two years, residents supplied substantial new evidence, including quarterly sampling data sorted by location and a study confirming the likely source were fields “upstream” from Village wells based on groundwater flows. Finally, the committee approved the monitoring concept and directed staff to develop a work plan for implementing. The work plan was then put out for bids, with REI Engineering, from Wausau, awarded the contract.

At the LAWCON February meeting, their preliminary proposal, prepared by County staff and REI was presented and met with serious criticism from hydrologists, committee members and citizens in attendance. County staff and REI consultants explained quickly that this initial plan was meant to solicit comments and make improvements.

Criticisms from hydrologists with decades of experience developing monitoring plans were the most pointed. First, they said, the plan lacked specific monitoring goals from the County and suggested adding language specifying vertical and lateral measurement capabilities that would answer questions about specific sources. They suggested better locations for monitoring wells, reducing the total number of wells to save costs, but providing a more balanced picture. As an example, they pointed out that an area on the east edge of the Village with the highest consistent levels of nitrates in well water did not have a monitoring well in the current plan.

See water expert Dr. George Kraft’s critique of the REI work plan here on the blog, click link.

They also recommended sampling at multiple depths to track distance and time of travel for nitrates in groundwater flow, permitting a more precise location of sources. They said data already collected under rigorous protocols like source tracking and quarterly sampling by residents should be part of the data set and was neglected in developing the plan.

Residents and committee members also supplied their own critiques, echoing the broad consensus at the meeting that the work plan as drafted was not adequate to providing answers now on pollution sources. Staff and REI consultants agreed in principle, given the clear goals and technical improvements articulated at the meeting, and will now return to incorporating the suggestions into a second phase of the plan. All agreed that the County needs to move on to solutions, prompting the chair’s remarks noted earlier.

Regenerative Agriculture as a hopeful new farming system for cleaner groundwater

As to what solutions might look like, regenerative expert and farmer, Gabe Brown was blunt in his advice at a workshop presented by Farmers for Tomorrow on February 7 in Amherst. (see more info at: https://www.csuchico.edu/regenerativeagriculture/demos/gabe-brown.shtml) Combining his 25 year experience as a North Dakota farmer with ongoing scientific research, he presented a strong case that industrial agriculture, as typified by mono-cropping with high inputs of fertilizer and pesticides, destroys healthy soils and inhibits biological systems in soils that provide nutrients to healthy plant communities without negative consequences. Instead, regenerative agriculture stresses less mechanical disturbance, keeping soil protected with cover crops, complementary and more frequent rotations, multi-species diversity in seeding for market crops and forage as well as animal integration when possible. The results have been extremely profitable because of low input costs. Brown no longer uses fertilizer, pesticides, or fungicides, on his 6500 acres, yet gets crop yields above local averages. Harmful groundwater impacts have been reduced significantly and natural plant and animal communities restored. But above all, he says, the diversity approach makes farmers more able to withstand economic and weather cycles, leading to a better quality of life.

Now on the road 280 days a year teaching these methods, he said, “I have seen these practices work from the drought prone plains of North Dakota, to the yellow clays of Ohio and the sands of the Carolina Coast. No reason they cannot work here.”

Video: Gabe Brown discusses how Regenerative Agriculture is a solution to global challenges

(This report forwarded by Lisa Anderson). Portage County, WI has a serious problem with nitrate contamination of private water wells used by households in the rural areas subject to agribusiness activities in the “upstream” area of their groundwater. This is particularly severe in the Village of Nelsonville and the Town of New Hope areas. A group of concerned citizens has been continually pressing for some real action — that is to say, protective ordinances at County level — to strongly regulate to reduce and eliminate the nitrate contamination coming from agribusinesses in the area. This report from Dr. George Kraft, area hydrology and water quality expert, casts doubt upon the seriousness of the Land and Water Conservation Committee’s (part of Planning and Zoning Dept.) efforts to address this problem. The REI company report was presented to the County committee in an effort to show that “something is being done about this.”

January 28 2022 To:
Jen McNelly –Portage County
Steve Bradley -Portage County
Chris Holman –Portage County
Portage County Land and Water Conservation Committee

From: George J Kraft –PH, Ph.D.Subject:

REI WorkPlan would accomplish little at a large cost–improvement needed

This memorandum contains suggestions for improving the draft Groundwater Testing Work Plan submitted by REI Civil and Environmental Engineering under contract to Portage County. My comments are informed by my 40+ years of experience in hydrogeology, nitrate pollution, and monitoring network design.In brief, the REI Plan contains much competent work by a qualified contractor. But of paramount importance is this:the Work Plan, if is executed as is, will shed little light and answer few questions on the Nelsonville nitrate problem. Portage County could expend $50-$80,000 (as suggested in Option #2) and obtain little new knowledge in return.REI seems to acknowledge how little might be gained in this statement:“The placement of these [monitoring] wells will begin to assist withthe nitrate nitrate loading from private septic systems versus potential contributions from agricultural inputs.”“[W]ill begin to assist”inspires little confidence and indicates a recognition of little potential knowledge gain.1

What the County needs is a work plan that will get the job done and answer salient questions NOW rather than nibble on the edges that will kick the Nelsonville can further down the road.

Below, I suggest that the heart of the problem is a lack of well-articulated monitoring goalsand make suggestions as to what those goals might be(“A”). In “B,” I demonstrate how the proposed monitoring accomplishes little, and in “C” I suggest improvements that could help generate the knowledge that is needed to address the Nelsonville situation.Finally (D-J), I comment on other concerns and make suggestions for improvement.

Major flaw: a lack of monitoring goals

A. The work plan lacks meaningful monitoring goals.

What is Portage County trying to accomplish with monitoring?What questions is it trying to answer? Well-articulated monitoring objectives are step one in producing a good monitoring plan. Monitoring goals are completely lacking from this plan.It seems to me the responsibility for well-articulated monitoring goals belongs to the client (Portage County) and is not the fault of the consultant.I will concede that the proposal contains certain vague language that some might construe as a sort of monitoring goal, such as a Portage County goal “to develop a plan to monitor and better understand water quality…”, or a work plan goal “…to provide options through the development of a comprehensive plan to setup a groundwater monitoring well program ….”But these are not goals adequate for designing a monitoring program.

So we need well-articulated monitoring goals as a starter. Below I suggest some that reflect information “needs” previously articulated in relation to the Nelsonville nitrate problem:

1.Define nitrate concentrations and their vertical and lateral distributions in Nelsonville vicinity groundwater.

2.Define the nitrate concentrations generated by major nitrate contributing land covers in the Nelsonville vicinity.

3.Verify that improved farming practices that Gordondale suggests it is implementing might mitigate Nelsonville drinking water nitrate problems.

4.Shed light on if/how Nelsonville residents might construct new drinking water wells to obtain safe drinking water.

5.Estimate how long safe drinking water, if it exists, will last.

6.Verify previous source workon the origin of nitrate in Nelsonville wells.

7.Confirm well known groundwater flow patterns

How the plan fails

B.We need a monitoring well network (option 2)! But the proposed network will do little for advancing our understanding of the Nelsonvillesituation, and at great cost.

In the absence of well-articulated goals almost any groundwater monitoring plan might be employed. But presuming some unspoken set of goals exists, like 1-7 above, this plan mostly fails.

Most of the failure has to do with proposed monitoring well locations and the fact that wells are proposed as water table wells. What such a monitoring well network will get us is just a glimpse of what happens at the water table, but not with depth in the aquifer. The proposed network only informs well on goal 7 and only partially on goal 2 – i.e., it will inform fairly well on the groundwater quality generated in Nelsonville Village, but poorly on the other land covers.

For sake of discussion, let’s identify proposed wells in Figure 7. Those upgradient of the Village I will designate “U,” and number from NW to SE 1-4. Those downgradient of the Village I will designate “D” and also number NW to SE.

The upgradient wells, U 1,2,3 are mostly too far removed from the agricultural land cover to provide useful information on it. At best, they might give us a mix of groundwater quality resulting from woods (low nitrate) mixed with agriculture (high nitrate). Thus, a mostly failure of goal 2 when it comes to agriculture.

Frankly, if I were to bias a monitoring network to intentionally underestimate agricultural impact while attempting to appear as if I were doing something useful, this is what I would put forward.

How to fix the plan and get some much needed information

C.The problems with the plan can be fixed to make monitoring meaningful. Here’s how it could be done.

1. Move the upgradient wells to field edge to avoid a mixed-land use groundwater quality signature.

2. Monitor aquifer depth profiles that characterize whole-aquifer water quality using piezometers. I suggest a surficial screen perhaps 0-7 feet below the water table, and then 5 foot screens with 5-10 foot spacing through the remainder of the profile. THIS WOULD NOT HAVE TO BE DONE AT EVERY MONITORING LOCATION! Perhaps 1 or 2 sites each above and below gradient of Nelsonville would be
adequate.

3. Possibly two or more proposed monitoring well locations could be sacrificed as cost saving measures without substantial information loss to help compensate for piezometer costs.

4. Different monitoring technology rather than 2” cased wells could be considered as a cost-saving measure. This is common in many research settings and would work well here. NR141 specifications were written for installing monitoring wells at landfills and wastewater sites (I know because I helped write it) and are not needed in this sort of setting.

Other concerns and suggestions

Use of the word “model”

Most technical folks who would be reading this document would see the word “model” and think of a groundwater flow model, a groundwater particle track model (both such as what Andrew Aslesen of Wisconsin Rural Water did), or a full blown contaminant transport model, like that performed recently for a CAFO in the vicinity of Coloma.

What REI did is an interpolation of nitrate results. In my experience this sort of work is not called a “model,” but rather a visualization or something of that nature. I’ll concede that the REI work is a “model” of sorts, specifically, a nitrate interpolation model. It appears well and good and is useful. But I strongly suggest that this be referenced as a “nitrate interpolation model” to preclude confusion that actual contaminant transport modeling was done here.

E. Nitrate Data Interpretations

The visualizations of nitrate data are useful and seem well done. As these will likely be used by political types and others without a water quality background, I am concerned that several of the representations overdrive the data, i.e., they show interpolated nitrate concentrations where no control points exist and this will mislead others. It is traditional to “blank out” such areas or, at least show isocontour lines as dashed to indicate uncertainty. For instance, in Figure B2b, below, there is a large area with no data but inferred nitrate concentrations are shown. This should be corrected.

F. High capacity wells.

We have seen here, and in the past, including in the DNR permit process, claims that high capacity wells are potential sources of confusion in the data. But none of those who invoke this hypothesized confusion bring any evidence for it. This is a topic that I looked into at one time, and did 3-D numerical MODFLOW and MODPATH modeling to investigate. What I found was that simulated irrigation wells perturb groundwater very little in the sense that it does not substantially mix aquifer water. Most flow, I found,to such wells is horizontal until very near the irrigation well. Hence little mixing occurs. I suggest dismissing high capacity wells as a confounding factor – it’s time to show evidence or banish this unsubstantiated claim.

G. The consultant’s plan diminishes the great amount of data that has been generated for Nelsonville and disparages the laudable efforts of citizen-monitoring that has been done there.

For instance, on page 3, after acknowledging that past sampling has involved 60 of 77 known wells, the text goes on to say “there was less than 34% sample participation.” This is by most standards a HUGE amount of data and GREAT participation. It would be great participation for a government agency, and is only more noteworthy that it was largely accomplished by citizen monitoring. REI wrongly casts aspersion on citizen monitoring sampling methods and the fact that county staff monitoring is consistent with citizen monitoring. This should be corrected.

H. What’s the need for groundwater age-dating?

No monitoring goal was stated for which groundwater age-dating would address. Particularly since the proposed monitoring wells are water table wells, it’s pretty safe to assume the age in them will be months to a couple years. (I can demonstrate with a pile of data if county staff want to see it.)

I have offered the county previous work that demonstrates groundwater age distributions in a setting at a nearby study quite analogous to the Nelsonville situation. That offer is still on the table. The Aslesen work as well would provide an age date approximation.Age date techniques that were relatively cheap and common in the past (e.g., CFC, SF6) have become
less useful owing to a changing atmospheric signal. (Long story there.) Tritium-He could be the only =tool available for the potential need of this project, at the cost of about $1000 per sample.

Again, what’s the goal? Then let’s see what we can do to address it.

I. The Work Plan totally neglects a key data set – the agriculture/septage source tracking. Why?

This data set, it seems to me, is an important one for consideration in designing a monitoring plan. It is as important as all the nitrate data considered by REI. Why was it neglected? This is a major deficit in the work plan.

J. Recommendation: Skip the option 3 data loggers.

“Real time” data are not necessary. Monthly or quarterly is enough. In my experience, these things are pricey, twitchy, and need regular attention. Unless new models have more proven resilience, they are more headache than they are worth. They do not obviate a need for regular chemical analysis as they require calibration and validation.

cc. Nelsonville Groundwater Committee
Other interested parties

Footnote
1To be fair, REI includes “options” that would improve effectiveness of the monitoring plan. Without including the options and other improvements, the Plan will not be particularly informative.