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Moving Goalposts: The Challenge of Lake Erie Algal Blooms, Part 4
By: Jessy J. Sielski, MDARD - 08/09/2017

As I try to put a nice bow on this series about the Lake Erie algal blooms--and dust off my mantle for the Pulitzers that are certain to come my way--I think it's important to restate a few very important things. We've always known that Lake Erie's problems are multilayered, the contributing factors are ever-evolving, and the solutions are more elusive than anyone would like. However, there is good reason to be optimistic.

First and foremost, there is significant ownership and accountability being taken by every stakeholder involved. State and local governments, private industry, public utilities, and the agricultural community are taking steps to keep our Great Lakes one of the most valuable resources on the planet. And there has been considerable progress. Since 2008, the total phosphorous entering Lake Erie from Michigan's River Raisin has been reduced by approximately 20 percent due to non-point source reductions, while total phosphorus loads from the Detroit River have been reduced by approximately 32 percent due primarily to point source reductions.

Second, even though there is much more to learn and do, it's important to keep in mind that those working on the problem are not starting from square one. This is evidenced by the seemingly endless barrage of press releases, announcements, and promotions of new scientific discoveries, tools, resources, educational opportunities, and grant offerings--all designed to help advance what we know, what we do, and how we do it.

Last month, three of Michigan's state agencies (MDARD, DNR, DEQ) released a draft of the Domestic Action Plan for Lake Erie, which provides a framework for solving the issues that trouble Lake Erie, particularly the Western Basin. In addition to improving and expanding ongoing efforts, the plan tightens permit requirements for wastewater treatment facilities; aims to restore and improve wetlands; expands research on invasive species; supports new research on dissolved reactive phosphorus; and further supports efforts to help farmers improve their operations using the latest science and customized to their unique needs.

The word "framework" is very important because, as MDARD's Environmental Stewardship Division Director Jim Johnson emphasizes, "We've set important metrics in Michigan's Domestic Action Plan for Lake Erie--the most important of which is the 40 percent reduction in phosphorus by 2025--but our goal isn't to implement a plan and consider the job done. The goal is to fix Lake Erie. So, we've created a plan that will keep us moving in the right direction, but if we're not seeing the progress we want to see, or if new research tells us we need to adjust our course, then that's what we'll do. We need to keep moving forward based on the best information we have, but as we learn more, we need the flexibility to modify the plan or change course quickly."

There have been some criticisms of the plan, however, so let's take a moment to talk about three of the most common: 1) spreading manure on fields in winter months; 2) concentrated animal feeding operations, or CAFOs; and 3) the debate over mandatory versus voluntary management practices.

Regarding field application of manure during winter months, there is no argument. When done improperly, it has the potential to do some damage. For the non-ag people like me, here are the basics. Farm animals create waste, and there are basically two things that can be done with it. It can be stockpiled in large storage units until spring thaw, or it can be applied to the land at appropriate times throughout the winter. If the manure is applied on top of frozen ground and/or when there is snow accumulation, the manure sits on the surface until the snow melts, which washes it off the field and into the drains, rivers and lakes. And because Michigan winters are notoriously unpredictable, applying manure during the winter months can be a real...um...crapshoot.

So, given all that, it's easy to understand why many would call for an outright ban on winter spreading. Would it eliminate that specific risk? Yep. But is it feasible? Not necessarily. But to explain why, let's kill two birds with one stone and pull in the subject of CAFOs, or concentrated animal feeding operations.

Concentrated animal feeding operations permitted through the State of Michigan are farming operations that have a certain number of livestock onsite during a 12-month period (specifics on page five of this document) or an operation that has inherent risks due to various factors. Because CAFOs are typically larger than other farming operations, and because they can be categorized by a state regulation, they are often susceptible to much more public scrutiny, which is neither fair nor unfair. Everyone can choose what sticks in their own respective craws.

That said, here are some quick facts about Michigan CAFOs in the Western Lake Erie Basin tributary:

- Currently, there are 14 CAFOs in that area.

- In the past two years, four of those permitted farms have completed winter manure applications.

- There has not been a significant increase in the number of permitted CAFOs over the past five years, nor has there been a significant increase in the number of farms identified as needing to obtain a CAFO permit over the last 20 years.

"We know the public is concerned about CAFOs," Johnson said. "And those concerns aren't necessarily invalid. The size of a CAFO gives it more potential for a catastrophic event. But honestly, the size of an operation has little to do with the actual risks. When we talk about CAFOs, we need to keep in mind that they are typically in the best position to manage nutrients (manure) properly, and many of those operations are built from the ground up, using the latest technologies, information and guidelines. They also have the finances and the resources to stay ahead of the curve.

"There are about 300 CAFOs in the entire state, but there are about 23,000 livestock operations," continued Johnson. "In terms of day-to-day risks, we are more focused on the collective impact those 22,700 operations that may have a more difficult time accessing the financial and informational resources they need."

That is why, in addition to helping these smaller farming operations find financial assistance to help the implement best management practices, MDARD and numerous others are helping to create the tools needed to improve their operations.

Just last month, MDARD announced a new online tool that uses precipitation, temperature, soil moisture and landscape characteristics to show farmers when winter spreading is safe for their specific locations. The MSU EnviroImpact Tool, developed through a partnership between MDARD, Michigan State University and others, provides maps showing short-term runoff risks for daily manure application planning purposes. Farmers handling and applying livestock manure in Michigan can use this tool during any time of year to determine how risky it will be to spread manure on their fields.

It also needs to be said that a lack of a ban does not imply chaos and lawlessness. As a wise man once said, "This isn't Nam. It's farming. There are rules." Or something to that effect. And there are rules and laws for winter application of manure by both CAFO and non-CAFO operations.

Michigan's Natural Resources and Environmental Protection Act (NREPA), Act 451 of 1994 (as amended) protects the waters of the state from the release of pollutants in quantities and/or concentrations that violate established water quality standards. All farming operations must abide by Michigan's Generally Accepted Agricultural and Management Practices for Manure Management and Utilization. Winter application must go through the Manure Application Risk Index process. And an additional 35-page document regarding pollutant and wastewater discharge for Michigan CAFOs can be found at http://bit.ly/2gmOW1n.

The most important takeaways from the document are that 1) all Michigan CAFOs are required by law to have a minimum of six months of manure storage capacity to avoid spreading on frozen soil and snow, 2) they must have a comprehensive nutrient management plan, 3) they are subject to pre- and post-permit inspections and evaluations, and 4) they must keep five years of extensive documentation about everything from recorded weather patterns to land conditions at the time of application to methodology and calculations for nutrient goals--among many other things.

Policymakers are often asked why they don't just ban winter spreading, eliminate CAFOs, and make such things as no-till and riparian buffers mandatory. And if you've read the previous three installments of this blog, you can probably guess what their answers are.

First, they would say, total phosphorus in the lake is going down at a very steady rate, but the amount of dissolved reactive phosphorus is not. So, if DRP is the real problem, and we don't know what's causing it or how to stop it, what exactly would they tell farmers they must do?

"It really wouldn't be much different from telling homeowners that they can't put fertilizers and herbicides on their backyard flower or vegetable gardens unless they can prevent the dissolved reactive phosphorus from leaving the property," said Johnson. "It doesn't matter how emphatically you tell them, or how responsible they want to be. If the answers aren't available on Google and the solutions can't be purchased on Amazon, they would be in a pretty tough spot."

Second, they might point out, roughly 85 percent of the total phosphorus load entering the basin comes from the Maumee, and Ohio began implementing a ban on winter spreading in 2015. Clearly, with the issues of legacy phosphorus, invasive species, weather patterns, and all of the other things mentioned before, it's too early to tell if such a ban will have an impact.

Third, as we touched on in Part 2 of this series, some of the best management practices that were promoted so adamantly by environmentalists and governments alike are starting to show some imperfections. No-till may be contributing to DRP movement; cleaning the rain may be changing the soil; and buffers are only buffers until they inevitably become phosphorus-saturated.

And lastly, they would argue that the numbers prove that voluntary programs are working. The Michigan Agriculture Environmental Assurance Program adds, on average, an additional 38,000 acres under its nutrient management plans every year. But, they would continue, this is being done with field technicians working at maximum capacity, and whether you call the program "voluntary" or "mandatory," it will only be as successful as the resources allow.

"You can make all the rules in the world, but if the rules aren't grounded in science and you don't have the resources to enforce them, they're going to fail one way or another," said Johnson. "But when you put your available dollars and human resources into targeted research, farmer education, tools, and support--and show farmers how they can save money in the long run--not only are you more likely to get buy-in from the agricultural community, but they're going to be more willing to go that extra mile."

When I began this series, I jokingly compared my nave perspective about Lake Erie to Oscar Rogers' view of the 2008 financial crisis. ("Take it one step at a time. Identify the problem--FIX IT! Identify another problem--FIX IT! Repeat as necessary until it's all FIXED!") In reality, that actually is what's happening. Researchers are tackling dissolved reactive phosphorus. Wastewater treatment facilities are meeting or exceeding the state's new regulations. More farmers are implementing best management practices and nutrient management plans based on the best information available. And numerous universities, state agencies, and non-governmental organizations continue to advance research and develop technologies that will help farms take sustainability to the next level.

For example, there are several research projects underway that will use DNA whole genome sequencing to determine precisely what kinds of waste (human, cattle, pigs, chickens, etc.) and at what ratios are entering the rivers and lakes, as well as pinpoint the exact source(s).

Joan B. Rose, a researcher at Michigan State University and the 2016 recipient of the Stockholm Water Prize, the world's most-prestigious water award, recently gave a presentation to the Michigan Commission of Agriculture and Rural Development. She provided an overview of her ongoing research about the sources of E. coli and pathogens in 64 watersheds throughout Michigan, and one revelation was that "Pollution arising from septic system discharges [is] likely more important than [we] previously realized." Later, she said that it would be fair to extrapolate this data to the watersheds surrounding Lake Erie, and that it would be worthwhile to conduct a study to determine how much residential septic systems are contributing to the problem.

And scientists at Ohio State University and at Bowling Green State University are also using molecular analysis and stable isotope techniques to develop chemical signatures (I'm leaving this jargon in, just to share with you the kind of stuff I've had to endure these last 11 months) in order to detect where phosphorus entering Lake Erie came from: farm fields, cattle operations, sewage treatment plants or other sources.

These kinds of emerging research very well could help avoid across-the-board regulations that would hurt the people who are doing everything right.

I know I'm running short on time, space, and probably readers' patience, so I'm going to have to leave any loose ends loose, leave out reams of other information, and avoid altogether the back-and-forth arguments that some may be having with this series. But before I sign off, I want to leave you with some comments from MDARD Director Jamie Clover Adams.

"Despite all the challenges ahead, there is one absolute truth as things move forward: failure is not an option. The health of the Great Lakes is vital not only to the health of people and the ecosystem, but also to the economic strength of the state as a whole. Both the reality and the perception of Michigan's condition must be considered when addressing an issue like Lake Erie. And we'll get there, but it's going to take a little time to do it right.

This is not the kind of problem that can be fixed by applying a band-aid and then putting on another one when that falls off. It can be frustrating, but to fix a problem that has taken several decades to create, we need to think big picture and take the long view. The goalposts may keep moving, but Michigan will never stop kicking."

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