2014 Fall Newsletter - online
Dec. 19 - High E. coli count, 2,300/100mL, at Moon Lake Drain, Union Rd, immediately downstream from Hudson Dairy manure-spraying shown in the video below, Dec. 7. The manure spraying was in the SW area of the tile-drained field which carries flow underground to the neighbor's property, where it surfaces as Moon Lake Drain (Bean/Tiffin/Maumee Watershed) and crosses Union Rd 1/2 mi. downstream. Water sample was taken the morning of Dec 16 during the first rainfall (.4") after manure application. Rain continued through the day. The DEQ lab result of 2,300/100mL E. coli count is more than twice the level of Michigan's Water Standard for partial body contact. Test strips for nutrients (phosphate, ammonia) were also high, ammonia at 0.25ppm, more than twice the naturally-occuring level of 0.01-0.1 in streams.
Dec 19 - Surprise! - DEQ releases the draft CAFO General Permit (5 yr permit). No surprise - no changes in winter application practices (see p. 14 of the draft); still allowed, without incorporation, if fields ranked acceptable using the Manure Application Risk Index (based on slope, vegetated cover, etc.). Public comment period starts today, Friday, December 19, with a public hearing scheduled for January 21, 2015 (see details).
Dec 17 - DEQ update on winter application - DEQ asks CAFOs in Lake Erie, Saginaw Bay, and Macatawa Lake watersheds to (voluntarily) not apply manure this winter. Letter just provided to farm, food, faith, and environmental groups, including ECCSCM, who in March this year (see News page, scroll to March 6) requested that DEQ include a ban on winter manure application in the new CAFO General Permit. The draft Permit was due for release soon. Repeated requests from the coalition for updates were met with silence - until yesterday, when DEQ supplied this letter, apparently sent to CAFO owners in the fall. ECCSCM is pleased that DEQ acknowledges that action must be taken beyond the current Permit to protect these watersheds. However, nothing has changed in the Permit; there is still no draft 2015 CAFO Permit. ECCSCM will closely document the situation this winter, to see if this voluntary-only request is effective. Snip from the DEQ letter [our boldface]:
Dec 15 - "Dirty secrets" - DEQ dismisses researchers and citizen concerns about manure nutrients feeding Lake Erie's toxic algae, and slams ECCSCM videos of manure application as a "PR stunt." In a Detroit Free Press article today, DEQ's spokesperson isn't pleased that "a watchdog group spend its time and resources depicting regulated and approved farming practices as though they've exposed some dirty secret." Milk Source's Hudson Dairy CAFO spokesperson agrees and claims current practices are fine, "environmentally sound." Still, the dirty secret is that some current "acceptable" and "approved agricultural practices" don't protect water quality enough, don't protect Lake Erie and drinking water supplies enough, given the increase in toxic algal blooms and the devastating loss of Toledo's drinking water this summer. ECCSCM supports the International Joint Commission recommendation to ban winter application of manure and fertilizer. Ohio Farm Bureau, even, supported that ban recently. To protect Lake Erie, some Michigan agricultural practices are no longer acceptable, and must change.
Dec 7 - Milk Source's Hudson Dairy is spraying massive amounts of liquid manure, same field as Oct 13 (Waldron Rd & M-34), with dump box and tankers unloading next to a residence, VERY close to the household wellhead (circled in RED below), and directly across Waldron Rd from the Seventh Day Adventist Church and School. Tractor is draglining as far as the hose will reach; beyond that, tanker-trucks are driving across the field at the far SW end, spraying on a slope so steep the trucks can barely drive up. See video below (and others, Can the tanker get up the hill?; Pity the biota, etc. on ECCSCM's YouTube channel).
Nov 21 - Manure-contaminated wells - Door Co, Wisconsin - Public meeting scheduled next week, Dec. 2, on replacing well water after manure application Sept 8-9 contaminated well water and sickened 7 people. See recent articles on tracing the contamination (bovine) and struggles to replace residents' well water: Nov 21: article on upcoming meeting; Nov 14: article "Seven sickened by tainted wells." At a meeting of the County Soil and Water Dept on Nov. 19, many of the residents of the contaminated area "reported details of family members getting violently ill, a beloved German shepherd dying, and the many hardships associated with living in a home where you can’t drink, cook with or even bathe in the water."
Nov - Terrehaven CAFO is still not cleaned up. More than a year since DEQ filed an Administrative Consent Order (Nov 6, 2013) against Terrehaven in Adrian, production area runoff is still not contained. The Order cited Terrehaven's violations of Michigan’s water protection law and of the CAFO’s Permit, and required evaluation of storage structures. DEQ also sent a Violation Notice to Terrehaven later in Nov 2013 and again in May 2014 for contaminated runoff from the production area (see details on violations list). After all this time, containment walls around silage and stacked manure still have large gaps. Why doesn't DEQ say, "Build a wall. It's the law. Do it now."
On April 2, 2014 and again on Oct 22, aerial photos of Terrehaven production area show runoff at several locations, with pooling to low areas west of the facility, and apparent flow onto a neighbor’s property. First photo, April 2, 2014; second photo Oct 22, 2014.
Oct 22 - Bruinsma Dairy CAFO in Morenci is spraying liquid manure in 3 locations - extreme emissions, "horrible, just as bad as you can imagine," and aerosolization from a broad tank spray on Wolf Rd east of North Morenci Rd. See Stench Alerts for more photos.
Oct 18 - A Daily Telegram article today reports Milk Source will close some lagoons at both Hudson and Medina Dairy CAFOs. In the article, Milk Source also responds to the geyser of waste photo taken by ECCSCM last Sunday: "The photo was taken at the end of the application process when the hose was being cleared, said Avi Stern, communications manager for Milk Source...Once the hose-cleaning process was completed, she said, nutrients were properly integrated into the soil."
Sunday, Oct 12 - "Horrendous." Some of the worst draglining/spewing of liquid CAFO waste we've seen around here - Milk Source's Hudson Dairy is geysering waste into the air from an open-ended dragline hose. A best practice? An acceptable practice? Not for neighbors, not for soils, not for water. Rain predicted tonight, tomorrow and Tuesday. The photos show it all (see more on Stench Alerts): the spewing aerosolization, the black field, the ponding of waste.
Oct 1 - The “Land of 10,000 Lagoons” Awards will be presented by Wisconsin's Family Farm Defenders outside the World Dairy Expo in Madison, WI this afternoon. See Family Farm Defenders' Facebook page for the complete press release. Excerpts here:
Bulletin: new research on manure and water quality - from Bowling Green State University, a study that provides data for western Lake Erie watersheds on the impact of manure applied on frozen/snow-covered ground and within 12 hours before or after heavy rains. Water samples were taken at three farms, from tiles, surface drainage and drainage ditches after manure was applied, with numerous nutrient and bacteria tests performed. Among other findings, test results show that manure runoff after a heavy rain, or after application to snow-covered and/or frozen ground, increases dissolved phosphorus in the water. Dissolved phosphorus is the culprit in feeding toxic algae in western Lake Erie. From the abstract:"results support the findings of others that conclude that most nutrient and pathogen pollution occurs after large rainstorm events and after manure application on frozen ground." See full study: Horstman, Janelle, "The Effects that Liquid and Solid Cattle Manure Have on the Water Quality of Drainage Ditches in Putnam County, OH" (2014).
Sept 24 - Reports from Chicago meeting on Great Lakes water crisis: EPA Adminisgtrator Gina McCarthy announced the new Great Lakes Restoration Initiative Action Plan II, a broad effort to reduce runoff in Areas of Concern (Maumee River Watershed is one of them) and double the restoration of wetlands. Chicago mayor Rahm Emanuel hosted the meeting of Great Lakes mayors to discuss ways to protect drinking water in light of a toxic algae bloom that shut down the water system in Toledo in August. The toxic algal threat to drinking water, as detailed in a Detroit Free Press report of the meeting, is "driven largely by a phosphorus overload from agriculture runoff that is plaguing the Great Lakes, from Green Bay, Wis., to Saginaw to the western shore of Lake Erie." Toledo mayor Michael Collins asked for an executive order declaring the Maumee River a "disastrous watershed, and it truly is. I mean the agriculture runoff is incredible." Lana Pollack of the International Joint Commission noted that "environmentalists have been lobbying for years for agricultural phosphorus reductions, to no avail. But she said they may now have some new, powerful allies. 'The voices of change will be most effective,' she said, 'if they come from a public health perspective'."
Western Lake Erie CAFO Annual Manure Inputs - ECCSCM spreadsheet with total CAFO animals by facility, total CAFO manure by facility, in River Raisin and Maumee River Watersheds, Michigan and Ohio. Based on individual CAFO numbers reported in Michigan DEQ 2013 CAFO Permits and State of Ohio Livestock Environmental Permitting database. Please notify ECCSCM if you find omissions or errors, we'll be updating the spreadsheet periodically. Download 9-4-14 update here.
Sept 4 - BULLETIN: In a Wisconsin case involving high-capacity well permits at Milk Source's Richfield Dairy CAFO, Richfield, WI, a Wisconsin judge ordered that the DNR must consider the cumulative impacts of groundwater pumping when considering new high-capacity well permits. In a suit brought by WI Friends of the Central Sands and others, the court ruled that the DNR “took an unreasonably limited view of its authority” in not considering cumulative impact to ground and surface water levels, and that the public trust doctrine, statutes, and decades of court precedent required DNR to consider cumulative impacts. See Wisconsin Court order; also summary and more details at Friends of the Central Sands.
Sept 2 - worst practice: Hartland Farms CAFO draglining liquid manure in the rain.
Sunday Aug 31 - The Toledo Blade carried two front page articles on CAFO contribution to the toxic algae crisis: [our highlights]
from Stricter rules for agriculture debated - "The greatest concern, though, is how the manure is applied to area farm fields — if the fields are oversaturated by the animal waste at the wrong time. Or if it is spread on frozen fields in the winter, allowing it to flow directly into nearby ditches and streams. Pat Nicholson, who spent decades in the sewage-sludge industry as founder of N-Viro International Corp., questions how concentrated manure becomes after it has broken down in lagoons for months. 'That’s been the key to manure use forever,' Mr. Nicholson said. 'The key word is ‘soluble.’ If you put phosphorus on the land in a soluble [liquid manure] form, it all goes straight into the water."
Local CAFO info below, drawn from ECCSCM Western Lake Erie CAFO Manure database:
from Stench Alerts: weekend Aug 7-11 - "Horrendous" emissions over many square miles from Hartland Farms waste applications the last 4 days along Beecher Rd . . . Numerous reports to ECCSCM about the stench from neighbors with headaches, nausea, sore throats, burning sinuses. Many people had to close windows Thurs, Fri, Sat nights. Several people had to leave their homes. Extreme emissions continue. MDARD notified, DEQ Air Division notified, also Lenawee County Health Department.
BULLETIN, Aug 2: 'Do not drink' water advisory issued for Toledo area - Algal toxin microcystin found in samples; boiling not recommended
Last week in July - First toxic algae advisories - Maumee Bay State Park, our Maumee Watershed – from Toledo Blade article. On July 26, the Toledo/Lucas Co Health Department notified the public that tests on water near the beach at Maumee Bay State Park "showed microcystin at a concentration of 19.18 parts per billion, more than three times the threshold for safe recreational water activity." Residents are advised to avoid any "green water" in Lake Erie but also "in the lake's tributaries, such as the Maumee River, the Tiffin River [called Bean Creek in Michigan], and the Sandusky River." Microcystin is a neurotoxin "that can make people and animals sick or be fatal in large enough doses. Scientists have found in recent years it is more toxic than arsenic. Residents are advised to keep their distance in general, because microcystis puts out an aerosol that can be inhaled, especially when water is agitated."
July 28 - Note concerns today – 1) Dust Bowl, 2) spray-irrigation into neighbor's woods. 1) Major particulate emissions today, blowing from Medina Dairy field applicaton of slurry/solids on Gallup Rd field. No incorporation, no crop. Dust from manure application fields can carry fecal matter as well as large and small particulates which can aggravate asthma, reach the lungs and cause respiratory problems, other health symptoms.
NEW VIOLATION: DEQ recently cited New Flevo Dairy (NFD), Forrister Rd, Adrian, for stockpiling CAFO waste without incorporation for 7 days, a violation of the CAFO Permit. Following a complaint about the stockpiling, DEQ inspected NFD on June 27, 2014, found stockpiles in the field; NFD application records confirmed "stockpiles on the field had been present since June 19." The CAFO Permit requires incorporation of stockpiled waste within 24 hours. See photos of NFD stockpiles from June, 2014, on Stench Alerts.
July 24 - The toxin microcystin showed up yesterday in Oregon, Ohio's raw water supply which comes from western Lake Erie. The Toledo Blade reports that the water test, performed while OhioEPA Director Craig Butler was touring the plant, "had a small but detectable level of microcystin, the toxin produced by microcystis algae." The article notes, "Plant operators are not required to test for microcystin, even though scientists now place it between arsenic and dioxin in terms of its toxicity. Microcystin is capable of killing humans or at least making them sick in large doses."
CAFO waste application in Maumee Watershed - borders of states don't matter as much as watershed boundaries when it comes to Lake Erie. Michigan CAFO waste is being applied in Williams Co, Ohio; Ohio CAFO waste is being applied in Lenawee Co, Michigan these days. But here or there, these fields are all in the western Lake Erie Watershed, where excess nutrients are feeding toxic algae.
BULLETIN: July 22 - NOAA's Harmful Algae Bloom Bulletin for July 22 finds, for the first time this summer, a cyanobacteria bloom that has intensified this last week near the Maumee River. The University of Toledo has confirmed the presence of the toxic algae Mycrosystis. "Bloom patches may have developed near the Michigan coast, close to Maumee Bay..."
July 15 - Read "Bracing for Lake Erie Algae threats to drinking water," a Great Lakes Echo interview with Rick Stumpf, NOAA scientist who developed the Harmful Algal Bloom forecast for Lake Erie. The HAB forecast uses "a combination of satellite imagery, computer modeling, and water samples gathered by multiple agencies" to update the toxic algae risks to drinking water and recreation. Stumpf discusses last year's HAB following July rains that washed heavy loads of Phosphorus "from farmland along the Maumee River" into Lake Erie at Toledo. Toxins from the algae spiked to unsafe levels, causing the shutdown of one Ohio drinking water supply.
#2 - through surface runoff into catch-basins that drain to streams
July 11 - Multiple manure applications from CAFOs: New Flevo Dairy bulldozing, pushing, spreading manure stockpiles in field at the facility on Forrister. Milk Source's Hudson Dairy dragline operation shut down on M-34 at Elm Rd, just west of the City of Hudson. Today, just east of the City of Hudson, set-up for next dragline session begins, on Munson Hwy off M-34, near the start of Findlay Trail. Hudson Dairy also spray-irrigating along US-127 east of the facility, north of Donnelly Rd. Milk Source's Medina Dairy also spray-irrigating west of Ingall Hwy north of the facility.
July 10 - Hudson Dairy draglining in two locations on Elm Rd: at M-34 & Elm, several tanker trucks hauling to a dumpbox for the last three days; also on Elm Rd near Tamarack, through dragline from the facility, on the same alfalfa field as recently spray-irrigated, alfalfa now cut and chopped.
July 10 - Neighbors report "Silage has stunk for three days" from Hartland Farms. Workers at one house commented on how bad it smelled.
July 7 - More manure spray-irrigation, this time at Milk Source's Medina Dairy on Dillon Hwy. Numerous other manure applications and Stench Alerts reported to ECCSCM, including Bakerlads, Halliwill, Marvin Farms, and Hudson Dairy draglining at M-34 and Elm Rd.
REASONS TO BE CONCERNED with MANURE IRRIGATION (from Univ. of Wisconsin Extension)
CAFO air emissions: The National Air Quality Site Assessment Tool (NAQSAT) is designed for indivdual livestock operations to assess seven air emissions from their facilities – odor, dust, ammonia, hydrogen sulfide, methane, volatile organic compounds (VOCs) and nitrous oxide. "Air emissions are becoming a big concern... Livestock farmers should take the steps to better understand the pollutants emitted from their facilities," says MSU Extension. See MSU article and link to NAQSAT web tool to assess emissions by inputting species of livestock and particulars of an individual operation. An output chart recommends areas for "improvements."
NEW VIOLATION: Milk Source's Hudson Dairy cited by DEQ for applying CAFO waste on 4 days on 3 fields not listed in its Comprehensive Nutrient Management Plan, as required by the CAFO Permit. DEQ notes that "CAFO waste from Hudson Dairy had been applied to fields in Medina Dairy's CNMP without proper manifest documentation on May 23-25, and May 27, 2014." See details on the violations list and in DEQ Violation Letter.
DEQ tests show extreme E. coli contamination in Fisk Drain, Wolf Creek Watershed in Adrian Twp, June 12, 2014. In May and June, DEQ’s Surface Water Assessment Section conducted a 5-week Water Monitoring Project for E. coli in Fisk Drain at Teachout Rd, Adrian Twp (Wolf Creek/Riv Raisin Watershed), and in Medina Drain at Ingall Hwy, Medina Twp (Bean/Tiffin Watershed) — 2 sites identified as at risk in ECCSCM's 2013 water monitoring projects. DEQ's E. coli results show extreme contamination in Fisk Drain - 1,000,000 cfu/100mL on June 12, 2014; 4,814 cfu/100mL on May 14. Medina Drain was slightly above the Michigan Water Standard on June 12, at 1,249 cfu/100mL.
June 23 - ECCSCM Water Monitoring teams were sampling this morning in the Hazen Creek/South Br River Raisin Project and the Bean Creek Watershed Project. Murky discolored water at numerous sites. Data coming soon.
June 19 - Heavy rains and runoff and field tiles are a triple threat to our headwater streams flowing to Lake Erie. Contaminants can flow and Phosphorus can feed the toxic algae blooms in Lake Erie. Agricultural fields, and manure application fields at all CAFOs here, have tile risers, tile inlets, catch basins, to move excess rainwater to sub-surface tiles. Pollutants can also flow directly through these tiles to streams. This can happen even when following GAAMPs (Generally Accepted Agricultural Management Practices) or permit requirements. A recent article, headlined Forecasters predict toxic algae blooms will once again turn Lake Erie into a 'slimy putting green,' discusses NOAA's new tool for predicting harmful blooms in Lake Erie. A researcher notes: “Partly to blame for this expected algal assault are more severe storms, which wash vast amounts of phosphorous into the lake." Photo below shows the consequences of 1.5+ inches of rain on a field at Milk Source's Medina Dairy CAFO. On June 17, liquid manure was applied on this field, parts of which drain to Medina Drain, a stream on Michigan's 303(d) list of "impaired waters." The night of June 18, it poured. There's concern for this runoff draining through tile risers to sub-surface field tiles to the impaired stream - and on to Lake Erie. DEQ has been updated on the situation.
Spring Newsletter posted: Emerging health issue of manure-spraying and aerosolized pathogens; Milk Source drills 5 new high capacity wells, local concern for groundwater depletion.
MORE VIOLATIONS: DEQ Inspection of Terrehaven CAFO and fields finds multiple, ongoing violations, including stockpiling manure in fields for longer than 24 hrs – stockpiles on one field had been in place from April 21 through the day of inspection, May 7. Other violations of the Permit included not incorporating manure within 24 hrs of application; and not incorporating because of saturated ground (CAFO waste may not be applied on saturated ground). In addition, according to its own CNMP, Terrehaven does not to have six months manure storage, a requirement of all CAFOs. More details on the violations list or download DEQ CAFO Reconnaissance Inspection Letter.
LOCAL LAKE CLOSED TO SWIMMING – EXCESSIVE BACTERIA
May 24-25 Memorial Day Weekend - Neighbors reported many manure tankers on Medina Twp roads on Saturday May 24. ECCSCM confirmed the tankers were hauling, back and forth, from Milk Source's Hudson Dairy on US-127 to fields along Packard Rd/Ingall Hwy/Gallup Rd in Medina Twp. A draglining operation and manure dumpbox was set up at the edge of Gallup Rd. Manure application was taking place in fields NOT in Hudson Dairy's Comprehensive Nutrient Management Plan (CNMP), but in Medina Dairy's CNMP. It is suspected that is a violation of the CAFO’s permit. There is considerable damage to several areas of asphalt on Lime Creek Rd, and Gallup Rd, a gravel road, is now deeply-rutted, almost impassable where the heavy trucks were traveling. The Lenawee Co. Road Commission received several complaints and will be seeking reimbursement from Milk Source for road repair costs, according to the Adrian Daily Telegram.
May 10 - Milk Source set-up for draglining at Elm Rd and M-34. The green dump box is filled with liquid manure from the semi-tanker, then pumped through the "umbilical" hose, spraying manure back and forth across the field, next to neighbors, along M-34 just 1 mi. west of Hudson.
May 6 - ECCSCM begins 2014 Water Monitoring Project in Bean Creek Watershed at sites draining Milk Source facilities and fields. Some degradation of Medina Drain is already visible, with water discolored and scummy, no fish visible.
Also May 6, Milk Source is spray-irrigating manure east of the Hudson Dairy facility on US-127 and west of the facility along Elm Rd. Gusty east winds are carrying the emissions far off-site. Incredible stench for neighbors downwind. Also stench from manure application on Acker Hwy.
May 3 - Hartland Farms using big gun sprayer west of the facility on Hughes Hwy. Winds are blowing at 20mph, with gusts to 30mph – stench of silage leachate is overwhelming downwind.
May 1 - Spewing, spewing liquid manure – "isn't it lovely...," writes a driver passing by. Hoffland Farms CAFO dragline is unplugged, no applicator, no incorporation. Aerosolized fecal pollutants. Manure ponding in the field. Just unadulterated spewing!
New Violations posted: Bakerlads Farm CAFO cited for land application violations of its Permit, including spreading manure on frozen, snow-covered ground in March on a field not included in the CAFO's Comprehensive Nutrient Management Plan. The field had not been submitted for approval and public notice, as required, and not assessed using the Manure Application Risk Index, required before any application of CAFO waste to frozen or snow-covered ground. See full details and DEQ letter on Violations list.
April 24 - Multiple manure applications today; with gusty and shifting winds, many neighbors are feeling it, suffering CAFO emissions. New Flevo CAFO is draglining liquid manure in 2 locations – along Rome Rd east of Glen Hill Hwy, with 6 semi-tankers hauling back & forth; also draglining at Wilkinson and Hoddinot, both sides of the road. In Hudson Township, horrendous emissions from Hartland Farms CAFO manure application on a sloping field, drains to Bear Crk, corner of Cadmus Rd and Hughes Hwy. Neighbors downwind report eye-watering, "hair-stinking" emissions; it's really overpowering, just driving by.
April 13 - Article in Adrian Daily Telegram on 17 groups' request to DEQ to ban winter application of manure, in light of recent reports. (See March 6 below)
ECCSCM Hazen Creek/South Branch River Raisin Monitoring Project begins. Starting in April, ECCSCM will do routine monitoring at six sites northwest of Adrian – 3 sites in Hazen Creek, a major tributary of the South Branch of the River Raisin; 3 sites in the South Branch itself. We'll test for E. coli, Dissolved Oxygen, and using our new TR-7 digital meter, test for Nitrate and Nitrite, Ammonia, as well as the nutrient Phosphate, that feeds harmful algae blooms as it flows downstream and into Lake Erie.
April showers and thaw, with runoff visible from the air... aerial photos taken April 2, 2014
March 19 - warmer temperatures at last - but major melt and winter-applied manure runoff have begun. See photos below. And if you see manure runoff in your area of Michigan, please send photos to: email@example.com
Local debate over Milk Source plans: ECCSCM President Letter to Editor, Adrian Telegram 2-12-14; Commissioner Driskill (Hudson), Milk Source advocate, response 2-16-14; Telegram article, "Criticism sparks interest in dairy plan," 3-16-14.
New – Milk Source CAFO violations, manure spills in Wisconsin – details from databases of Wisconsin Deparment of Natural Resources, which oversees CAFO enforcement (see full listings in WI Manure Spills 1-1-07 to 11-22-13 and WI Enforcement Tables 2000-2013):
Winter 2014 Newsletter - just posted.
March 6 - ECCSCM and other Great Lakes groups join forces, send letter to DEQ asking Michigan to ban CAFO manure application in winter.
Bulletin: International Joint Commission - Lake Erie Ecosystem Priority Final Report released, Feb 27. This final report strengthens the Draft Report recommendation to ban application of manure – and commercial fertilizer – to frozen or snow-covered ground. See p. 9, Recommendation #10:
ECCSCM supports the prohibition of winter application of manure – in Michigan's CAFO permit (undergoing revision), in the Michigan Agricultural Environment Assurance Program (MAEAP) Standards, and in Michigan's Generally Accepted Agricultural Management Practices (GAAMPs). In late 2013, 2 important reports from the International Joint Commission and the Ohio Lake Erie Phosphorus Task Force, multi-national, multi-agency groups studying Lake Erie's excess nutrient/toxic algae crisis, both recommended that winter application of manure be banned in Lake Erie watersheds. One of the highest risk agricultural practices, manure on snow-covered or frozen ground, an impervious surface, has nowhere to go when it rains or melts except off the field and into streams. See the IJC Lake Erie Ecosystem Priority Draft Report and the Ohio Phosphorus Task Force Final Report.
CAFO waste application on snow-covered, frozen fields, all through February.