• A thoughtful re-assessment of the rules (especially manure management) can result in significant improvements for the agricultural community as well as our surface and groundwater resources.
  
  
• The standard, as written with regards to distance from navigable lakes and streams, application rates, and slope do not adequately minimize the risk of nutrient delivery to our surface or groundwater.
  
  
• We fully support a strong and viable agricultural community, but recognize that the face of agriculture is changing toward larger operations generating more waste
  
  
• As profitability is leading to farm expansions, DATCP will play an essential role in steering behavior away from practices which pose a risk to the environment and toward a new constructive model of how farms manage manure.
  
  
• Any farms covered under proposed ATCP 51 (locally regulated new and expanding farms over 500 animal units) should be required to have adequate storage (6 months) and prohibited from spreading liquid manure on frozen and snow covered ground.

Amrhein also wrote that calls for complete prohibition of winter spreading of manure can too easily by dismissed as "knee jerk" and will not be effective.

The DNR has only recently started systematically recording data on fish kills, including those caused by manure-related incidents. Thirty fish kills were reported to DNR in 2004 and causes have been established in about half of the cases. Of the known causes, manure-related incidents were determined to be the cause of six fish kills, and suspected in a seventh fish kill.

Stevenson said weather patterns that in recent years have brought mild winter weather with periodic warm-ups and rain, increasing the risk of manure applied to frozen fields running off into lakes and rivers.

More farmers are managing manure as a liquid rather than a solid without building the storage they need to avoid applying during times of the year when the risk of runoff is high, Stevenson said. The liquid form more easily runs off.

"Twenty years ago, the typical dairy farm had 40-60 cows, had a lot of bedding and solid manure," Stevenson said. "It was harder to displace. Today, more conventional dairying uses a lot of flush water. It’s cheaper and easier to pump than to spread as a solid."

Stevenson said when you combine the liquid manure with the "freeze and thaw" patterns of recent winters, "you have problems."

"We had a couple days of 50 degrees this winter, and the phones here were ringing off the hooks," Stevenson said.

Most of the manure-related incidents in 2004 and so far in 2005 are caused by smaller farms, those not required to get a water quality permit that spells out standards for how the operation will handle, store and spread manure.

Of the more than 40,000 livestock operations in Wisconsin, 131 are required under current federal rules to have such a water quality permit because they have more than 1,000 animal units. An animal unit reflects the amount of waste generated, and equals 1,000 beef cattle, 710 dairy cows, 200,000 broiler chickens or 2,500 pigs.

Almost all of the sources contacted for this column agreed that a cooperative effort between agriculture and conservationists is needed to address the problem.

Stevenson said farmers are "really not villains" in the runoff problem, and added that there are economic and cultural factors that contribute to it. In most cases, the problems are not caused by any intentional misapplication of the manure, he added.

"DATCP, other state agencies, the agricultural and agribusiness community, and environmental groups should all work together to arrive at approaches to help avoid these situations in the future," Amrhein wrote in his open e-mail.

"Challenge them to think outside the box – toward treating agricultural waste in the same vein as human waste – to suggest innovative approaches that provide an economically viable alternative to spreading manure on land during unfavorable conditions."