•In the practice of spray irrigation of manure, aerosolized lagoon waste is reduced into smaller particulate droplets, which are easily ingested and inhaled by humans and animals.
• Manure has over 160 different known pathogens, viruses and bacteria, and includes barn cleaners and their chemical make-up, antibiotics, hormones and may contain municipal and/or industrial wastes.
• All lagoon wastes should be incorporated into the ground immediately to diminish the risks from these wastes, and the pathogens and diseases they may contain.
• Becky Larson of UW Madison stated, “that transmission of pathogens through airborne routes is unknown and controversial”. Becky also stated that several meteorological factors complicate the practice of spray irrigation of manure including wind, humidity, temperature, and precipitation.
• Mark Borchardt USDA-ARS Institute for the Environmentally Integrated Dairy Management Study revealed that the “bulk of pathogens reside in the liquid portion of manure”, the portion that would be spray irrigated.
Borchardt also stated that there are three forms of transmission of pathogens: Fomites, which are solid surfaces; and through our water and our food. These are three areas of great concern and run the risk of contamination from this practice due to the reality of drift.
• All parties seem to be in agreement that there is just too much that we simply “don’t know” about this practice and more research must be done addressing the potential health and environmental risks associated with the practice of spray irrigating manure.
• Spray irrigation of manure will expose citizens to heightened ammonias and hydrogen sulfide fumes and stench that could continue for the duration of 10 continuous hours, a day, at a time. We also fear that the industry will use this form of disposal for as many as eight months out of the year, if weather cooperates, and will extend our spreading season, and in turn, our exposure.
• Uninformed citizens and individuals in the spray vicinity risk exposure unknowingly by simply being outdoors and doing normal, recreational activities.
• DATCAP has extolled the virtues of “spoon-feeding crops”, less “road traffic and damages”, and “less soil compaction”, with this practice.
DATCAP also wanted to call this type of application of manure, “Precision application of ‘nutrients’”. This terminology was discussed by the state manure workgroup where it was stated that there is “absolutely nothing precision about this practice, and that it should not be called precision anything”.
Precision, as described in the dictionary states: precise; definite-exactness; correctness of arrangement or adjustment. This is not, nor can this practice be applied with unequivocal precision. It is impossible even under the best of controlled conditions.
Fugitive emissions, emissions that cannot be captured or controlled, are one of the greatest threats for this form of manure disposal.
The DNR has stated, “Measurable drift will be defined as feeling droplets hit ones skin or visually seeing droplets on a pick-up truck windshield”. [Permit language in DNR documents May 2013].
Devastated residents living near operations that are currently doing this practice have written letters and spoken publically, revealing the problems posed by this practice, which include residues, stench, flies, plunging home values, and over-all diminishing quality of life issues.
• More research has come out on superbugs, antibiotic resistant diseases, and pathogens such as MRSA , which travels through air-borne routes. More and more studies are being revealed indicating air as a transport for many diseases.
Children, the elderly, immune-suppressed individuals, asthma and COPD patients will be greatly affected including persons with pulmonary/heart issues.
Children will be tremendously impacted as they have a greater number of rapid respirations per minute than adults, and tend to mouth breathe. They would have the greatest exposure due to their size and inability to detoxify as readily as an adult. These youngest and most vulnerable citizens represent our future and deserve our FULL protection.
• Crops as tall as 8 feet high would be considered for the practice of spray irrigation of manure increasing drift possibilities and increased exposure possibilities to residents. This is not a widely accepted practice in our state of Wisconsin, with only 10 farms currently using spray irrigation of manure. In other states, such as North Carolina, a ban currently prohibits any new permits on this practice.
• Research needs to be professional. State of the art weather stations and other professional means must be used in all aspects of research. These demands must be made and adhered to, and must be on site at the farm locale.
• Safeguards for the citizenry and environment must be paramount. Wisconsin Administrative Code 214.21 pertaining to permanent in-ground monitoring systems must be kept in place unconditionally. Wisconsin Administrative Code, 214.14, requiring a separation of five feet from groundwater and bedrock under spray irrigation systems must also be upheld unconditionally, without any discussions to reduce this distancing.
• Maximum wind speeds must be set, with automatic shut-offs when those speeds are obtained.
• There should be computer monitoring of all mechanical systems, to reduce risks due to mechanical failure.
Please reread Wisconsin state toxicologist Robert Thiboldeaux’s Memo from February 17, 2011, relating to “Public Health Setbacks for manure spray irrigation”. http://datcp.wi.gov/uploads/About/pdf/DHSMemo.p
Drift is a reality. Currently in Wisconsin grape growers are suffering the results, and loss of grapes, and profits, due to the drift of herbicides. Lawsuits are ensuing in response to this problem. Drift, when it leaves one property is trespassing on another landowner’s rights. An article ran in the Green Bay Gazette, business section on 9-21-2013 .
Current set backs from homes is 500 feet. These setbacks can be reduced to 250 feet, with landowner permission. There are no current setbacks for roadway areas or property lines.
• There is no differentiating between different irrigation equipment, and its effects on drift.
• Air emissions are not taken into consideration and are not regulated at all. Research shows heightened emissions with this form of manure disposal.
• Permits are currently not written with standards that guarantee enforcement.
• Health Departments, such as the Kewaunee Health Department, state, “At this time, the local health department will be looking to the Wisconsin Department of Natural Resources for guidance on the use of spray irrigation” of manure. [April 8, 2013]