Daley Farms in southeastern Winona County Minnesota in Groundwater Province 3 wants to expand is dairy operation to expand to nearly 6,000 animal units of their feedlot and asked the Winona County Board of Adjustments for a variance from the county’s 1,500 animal unit limit. The Winona County Board of Adjustments denied the variance on February 21, 2019 after multiple comments and community input Daley Farms has appealed the denial to the Winona district court. MNWOO submitted comments as below because MNWOO is concerned for the increased pollution of the sensitive Karst groundwater and the surface water affecting your water wells.
On behalf of the Minnesota Well Owners Organization (MNWOO), we submit the following comments on the Daley Farms feedlot expansion. We respectfully request that the Board of Adjustment deny the variance for Daley Farms. We agree with the determination of the staff report of Winona County Planning and Environmental Services Department that the petitioner does not meet criteria (1), (3), (4) (6) and (7). We disagree with the staff report on criterion (5) which states “The variance will not alter the essential character of the locality nor substantially impair property values, or the public health, safety, or welfare in the vicinity.”
Our comments will address the serious and extensive water quality problems for all water resources in the area of the proposed expansion. We conclude that there is not an area within the State of Minnesota that has more polluted water resources than that part of western Winona County situated for the feedlot expansion. We believe that this feedlot expansion will exacerbate the ongoing impairment of trout streams destroying remaining aquatic life and habitat, and intensify the poisoning of both private and public drinking water supplies creating an acute public health crisis.
Current Documented Contamination of Water Resources in the Area of the Daley Farms Confined Dairy Feedlot
Utica, Bethany, and Lewiston, the three municipalities closest to the Daley Farms, have elevated nitrate contamination between 3 and 10 mg/L in their public water systems. Nearly 75% of all nitrogen contamination comes from row crop production from growing corn and soybeans (see https://www.pca.state.mn.us/sites/default/files/wq-s1-80.pdf). In addition, these public water systems have concentrations of one of more of the following commonly detected herbicides used on row crops in the area: acetochlor and its metabolites, alachlor and its metabolites, metolachlor and its metabolites, and atrazine and its metabolites. See:
Utica Township and the surrounding areas have some of the highest nitrate contamination in private wells and the highest occurrences of private wells above the Health Risk Limit (HRL) of 10 mg/L (see table below). Nearly half of the wells tested the area of Daley Farms in 2016 by the Minnesota Department of Agriculture are currently above the HRL. The nitrate HRL was promulgated to protect the most vulnerable part of our population – expecting mothers and babies under 6 months old. In addition, these private wells have concentrations of one of more of the following commonly detected herbicides used on row crops in the area: acetochlor and its metabolites, alachlor and its metabolites, metolachlor and its metabolites, and atrazine and its metabolites.
The South Fork of the Whitewater River (SFWW) is the sub-watershed of the Whitewater River that Daley Farms proposed expansion is located. The SFWW is currently impaired for total suspended solids/turbidity, nitrates, fecal coliform bacteria, stressful temperatures, and degraded habitat (see map below). The Daley Farms row cropping land use in the SFWW contribute to these impairments through soil, nutrient, and pesticide loss from fields where manure and commercial fertilizer and pesticides are applied. In addition, bacteria from manure applied to row crop fields pollute the SFWW.
On July 28, 2015 a major fish killed occurred on the SFWW. The Minnesota Department of Natural Resources estimated that 10,000 fish were killed and 6.5 miles of stream were poisoned killing nearly all aquatic life. Although State agencies could not determine the exact cause of the fish kill, recent applications of fungicides on corn, excessive application of manure and copper sulfate used as hoof treatment on cows were highlighted as possible causes. See:
Unified Fish Kill Response and https://www.twincities.com/2016/01/16/dave-orrick-the-troublingmystery-
Based on the Winona Geologic Atlas, this area of western Winona County where the proposed expansion and the vast majority of the fields that would receive the manure have the following physical characteristics:
- Shallow depth to bedrock;
- Very high sinkhole probability;
- Highest susceptibility to pollution from any land use activities.
This information has been known since 1984 when the first version of the Winona Geologic Atlas was published. In the proceeding 35 years, we have increased the number of annual cropping acres, increased the rate at which we apply commercial nitrogen fertilizer and manure, and increased the number of animal units producing the manure in western Winona County. The documented water quality impairments in the South Branch of the Whitewater and the extensive and serious contamination of Prairie du Chien-Jordan aquifer in western Winona County have resulted from past and current land use activities. In 1989, Minnesota passed the Groundwater Protect Act with the stated goal “…that groundwater be maintained in its natural condition, free from any degradation caused by human activities…” We simply have not met this goal with the existing regulatory safeguards and best management practices.
In sum, the current agricultural land use practices of the Daley Farms and their neighbors are causing significant groundwater and surface water contamination. The contamination of municipal and private drinking water supplies surrounding the Daley Farms are a threat to human health in the area. The steams flowing from this area are contaminated with bacteria, pesticides, sediment, and nutrients. These pollutants are causing long-term degradation of aquatic health and occasionally reach high enough levels to wipe out all the aquatic life in a stream. The cumulative evidence of existing water quality problems in the immediate vicinity of the Daley Farm operation are extensive and pose serious public health threats to the surrounding private and public wells. Therefore MNWOO requests that the Winona County Board of Adjustment deny the variance.
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