Lake Erie Ecosystem Priority (LEEP)

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Lake Erie Waterkepper 18th October 2013 14:53:11
OH, Toldeo,
Please see attached document.
Michigan Farm Bureau 18th October 2013 14:41:40
MI, Lansing,
Please see attached document.
Scott Nally 18th October 2013 14:14:01
OH, Columbus,
Please see attached document.
Dennis McGrath 18th October 2013 14:05:55
MI, Lansing,
Please see attached document.
Michael E. Zeidler 18th October 2013 14:00:47
WI, Milwaukee,
Please see attached document.
Carrie Vollmer-Sanders 18th October 2013 13:58:43
IN, Angola,
Please see attached document.
Lynn Henning ECCSCM 8th October 2013 17:20:43
MI, Clayton,
This picture was taken today October 8, 2013 Cadmus Road east of M 156 headwater to the south branch of the River Raisin to Lake Erie. This is downstream of a CAFO ( Concentrated Animal Feed Operation) that double applied a field by dragline before precipitation. This facility also has had E-coli O 157 in surface and groundwater as tested by USGS
Lynn Henning 2010 Goldman Environmental Prize for North America 8th October 2013 06:28:18
MI, Clayton,
http://nocafos.org/ http://nocafos.org/violations.htm 1,091 Confirmed Violations/Discharges from CAFOs and Liquid-System Livestock Operations to Bean/Tiffin Watershed and River Raisin Watershed from 2000-2012 Table 3-1: BMPs Associated with Phosphorous (P) Sources in Agricultural Operations 1. Balance P inputs with outputs at farm or watershed scale This is not a requirement 2. Minimize P in livestock feed This is not a requirement 2. Test soil and manure to maximize P management Required only every 3 to 4 years in permitted facilities, not verified. 4. Physically treat manure to separate solids from liquid This is not a requirement Chemically treat manure to reduce P solubility (i.e., alum, fly ash, and water treatment residuals) Not required 6. Biologically treat manure (i.e., microbial enhancement) Not required 7. Calibrate fertilizer and manure spreaders This is voluntary 8. Apply proper application rates of P Sampling of manure is only done annually, no verification. 9. Use proper method for P application (i.e., broadcast, plowed in, injected, subsurface placement, or banding) Who determines proper method? 10. Carefully time P application to avoid imminent heavy rainfalls Many applications are intentionally applied just beyond the 24 hour requirement in NPDES permits and nothing for unpermitted AFOs. 11. Implement remedial management of excess P areas (spray fields and disposal sites) We have seen no remedial management in our 12 years of monitoring. 12. Compost or pelletize manures and waste products to provide alternate use Not required and may not be done properly. 13. “Mine” P from high-P soils with certain crops and grasses Not required If Dried Distillers grains are fed then it can increase the phosphorus dramatically. Local CAFO’s do feed Dried Distillers Grains http://www.ansci.cornell.edu/pdfs/pd2007feb24.pdf http://www.extension.iastate.edu/publications/ibc29.pdf http://www.amaizingddgs.com/Research/Download/Content-and-relative-bioavailability-of-P-in-DDGS-in-chicks.pdf Most applications are not applied for the crop but after the crops are harvested. Buffers are useless if there are field tile draining the field beneath the buffers. We must eliminate the practice of putting animal waste above drainage systems Sharing of properties is a large problem, with multiple applications on the same parcel of land with no accountability. Antibiotic Resistance EMU Study E-Coli O 157 Bakerlad Report Crypto and Giardia DEQ Report ( tried to attach reports) Recommendations: 1.Eliminate all animal waste applications during winter. Michigan Requires 6 months of waste storage. 2. Sampling of all waste before application not annually. (Mixing outside waste) 3. Soil Sampling annually for each crop not every three years. 4. Eliminate the application of animal waste over drainage systems. 5. Eliminate animal waste through irrigation systems. 6. No Sharing of fields or manifesting back to themselves under multiple names. 7. Limit animals and facilities in the watershed. 8. No Manifesting of waste must have enough land under the name of the facility. 9. Ground and surface water monitoring at all livestock facilities required. 10. Only enough P on the land for one year requirements for a crop. 11. Licenses for all animal waste applicators. 12. NO Voluntary compliance. 13. Enforcement 14. Eliminate subsidies and NRCS practices that cause or contribute to discharges. 15. No applications of animal waste when precipitation is predicted.
Gary Towns for Metro-West Steelheaders 7th October 2013 19:50:18
Michigan, Fowlerville,
The Metro-West Steelheaders is a fishing club with nearly 200 members. We fish in all of the lower Great Lakes and annually hold several walleye and steelhead tournaments in Lake Erie. Our members have observed a steady decline in Lake Erie water quality - especially over the past decade. We are very pleased that this is getting recognized as an important issue. In fact, the photo in the report of a boat running through algae in 2011 was the lead photograph in the May, 2013 issue of National Geographic Magazine in an article titled: Our Fertilized World. So now this Lake Erie issue has been recognized globally - and it is in our own backyard. The LEEP report presents an excellent background of the problem and provides a defined approach to dealing with the issue. The socioeconomic impacts on water users seems to have suffered from lack of data. Perhaps the long-term data set of creel census (Great Lakes Fishery Commission) could help better define what is likely diminishing use of the lake. One of the largest contributions of phosphorous has been identified as manure from farming operations and this will need significant funding to help farmers contain manure through the winter months until it can be properly applied. Manure storage units are very expensive and we will all likely have to help build them through government subsidies if we are to see them built and run properly. As with any issue with multiple sources of input a major factor is education of the public. People got mad and just weren't going to take in anymore in the early 70s - and that made news and got everyone on board to do their part. We may need this kind of a campaign again today.
Sandy Bihn & Dave Spangler 7th October 2013 17:11:31
Ohio, Toledo,
Attached
Sandy Bihn 7th October 2013 17:09:23
Ohio, Toledo,
Comments attached
David E. Welch, Director, Department of Public Utilities, City of Toledo, Ohio 7th October 2013 14:41:54
Ohio, Toledo,
The City of Toledo would like to thank the International Joint Commission (IJC) for the opportunity to comment on the draft Lake Erie Ecosystem Priority Report (LEEP). Toledo is located at the mouth of Lake Erie’s largest tributary, the Maumee River. As a result, we are affected not only by what happens in the City of Toledo, but by the entire Maumee Watershed. Although the City of Toledo has been successful in controlling local point sources as well as urban runoff, we remain impacted by non point sources throughout the entire Watershed with no ability to regulate or make improvements in the quality of water that reaches our drinking water treatment intake. As you are aware, the Maumee Watershed receives water runoff from three (3) states, so a Federal Stormwater Permitting approach is needed to effectively impact and improve the whole Watershed. The City and the surrounding communities located on the shores of Lake Erie cannot afford to continue to treat and offset the impact from those areas further up the Watershed. This is evident by our additional need of $1 million dollars for chemical costs in 2013. Immediate and large scale action to improve the current situation is critical at this point in time. We can no longer simply gather information. The current data indicates a continual increase each and every year from 1994. The shutdown of the Carroll Township’s water system, due to the increased levels of the toxin microcystin, should serve as a wake-up call to the State and Nation. Should Toledo experience a similar situation, in excess of a half million people, hospitals, and industry will be without safe drinking water with no option to flush the system of the toxin. This Region would be without safe drinking water until the concentration of microcystin could be reduced to safe levels. In conclusion, the City of Toledo strongly encourages the IJC to include a recommendation of immediate Watershed based stormwater permitting focused on non-point sources in watersheds that contribute to the Western Basin of Lake Erie.
Ohio Environmental Council 5th October 2013 20:52:25
OH, Columbus,
Attached please find the Ohio Environmental Council's written comments.
Carl and Rich Honaman 5th October 2013 19:59:27
Michigan, Sandusky,
We are Agricultural people, involved in farming and the marketing of Agricultural Supplies, therefore we are concerned about phosphorous in all the Great Lakes. We represent the gypsum industry. We believe that through active efforts to change BMP's the phosphorous content in ag runoff can be greatly reduced. The useage of gypsum will promote the water to infultrate the soil profile instead of running off the surface. Also filter strips of plants and stable soil along drainage structures can reduce the soil erosion containing both nitrates and phosphorous. We have attached information from Ohio State that talks about Gypsum and its postives for the lakes. We represent natural gypsum products from a mine located in East Central Michigan. Please look at this as a way to help the lakes and continue to produce food for a hungry world. Thank You for reading!!
Lyman Welch 5th October 2013 19:17:12
IL, Chicago,
The comments on behalf of the Alliance for the Great Lakes are contained in the attached PDF file. Should you have any questions about our comments, please do not hesitate to contact Lyman Welch, Water Quality Program Director, at 312-445-9739 or lwelch@greatlakes.org.
FLOW ("For Love of Water") James Olson & Elizabeth Kirkwood 5th October 2013 18:38:46
MI, Traverse City,
Please see attached file
Ecojustice & Environmental Defence 5th October 2013 12:57:08
Ontario, Toronto,
Attached please find the joint submission from Ecojustice and Envrionmental Defence.
Ray Stewart 5th October 2013 08:23:01
Ohio, Amherst,
The use of engineered wetlands shows promise. We need to find a way to incentivize the restoration of wetlands throughout the Maumee River Basin so that productive farmland could be taken out of production for the sake of denutrifying the waters coming off of farmland. Dr. Mitsch reported that up to 1/3 of the phosphorus load could be trapped this way. Significant!
Roberta Urbani 5th October 2013 00:11:11
Michigan, Grosse Ile,
My husband and I attended the public comment meeting at WCC. We agree with the Commission's recommendations that additional monitoring of the phosphorus loading from the Detroit River is necessary, and that additional regulations on agricultural practices, particularly in Ohio, are critical to the health of Lake Erie. As residents along the Detroit River, we would like to see a public information campaign to educate homeowners how to use healthy river practices on lawns and gardens, and about the importance of planting a buffer strip of native plants along the shoreline. Perhaps local native plant nurseries could develop an easy to plant "kit" of native plants, sort of a "buffer in a tray" that could be sold and installed easily and in large quantities. I would be happy to participate in such an effort. In a related issue, a couple months ago, after a heavy storm, we were dismayed to find condoms and tampons washed up on our shoreline on Hickory Island on Grosse Ile, the result of the inadequate CSO operation of the DWSD.
John Dinon 4th October 2013 19:34:53
OH, Toledo,
The Humane Society of the United States and its Ohio Agriculture Advisory Council commend the IJC on its diligent work to protect the Lake Erie ecosystem. We also appreciate the opportunity to provide comments to the LEEP Report. The Report does an excellent job of identifying sources of phosphorus that contribute to algal blooms and hypoxic areas in Lake Erie and recommending strategies to reduce phosphorus levels in the lake. The report will undoubtedly generate comments from experts in many disciplines. Since the HSUS's expertise is animals and animal management, we will restrict our comments to the phosphorus contribution from animal agriculture, specifically from Concentrated Animal Feeding Operations or CAFO’s. The Report correctly identifies manure as a significant source of dissolved reactive phosphorus and recommends a ban on application of manure on frozen or snow covered ground. It also recommends that governments strengthen the use of regulatory mechanisms to ensure proper nutrient management on farms and link the cost and availability of crop insurance to farm conservation practices. We agree with these recommendations. The voluntary approach to nutrient management has clearly not solved the problem of phosphorous run off from farms. In addition to these recommendations, we request that the final LEEP Report also include: 1. All permitted CAFO's must be required to have a nutrient management plan that details the ultimate disposition of all manure and other biomaterials generated by the facility. These plans must include responsibility for actions taken by entities contracted to remove manure from CAFO’s as allowed under the "Distribution & Utilization method" of manure management. 2. All CAFO's and contracted manure distributers must be required to utilize sufficient acreage of approved land for manure distribution; the quantity of this acreage to be determined by the manure output of the facility and approval of this acreage as acceptable for manure distribution to be determined by site characteristics (proximity to waterways, drainage - both natural and through tile fields, buffer zones, etc.) and by the results of mandatory soil tests on proposed distribution areas. 3. Mandatory training and certification standards for manure distribution must be required for all CAFO operators and contracted manure distributors. 4. As an alternative, CAFO's may be allowed to process manure and other biomaterials leaving the facility through a lawfully operating and governmentally approved waste water treatment plant at the CAFO’s expense. Solids (sludge) generated by this treatment must be disposed of following the same rules and procedures used for other biosolids generated by CAFO’s. 5. For items 1-4 above CAFOs must be required to document their conformance with each requirement, and to submit documents to the relevant state or provincial entity. Such entities should require that such records are accurate, complete and current, and require a certification from CAFOs as to the accuracy, completeness and timeliness of submitted records. Again, the HSUS and the Ohio Agriculture Advisory Council thank the IJC for their hard work and for the opportunity to submit comments.
Kristin Vessey 4th October 2013 17:09:12
OH, Bowling Green,
It was good to read your report, but I feel strongly that at least two issues need to be dealt with more directly: 1) Manure applications to frozen ground should be prohibited. Period. No exceptions. 2) TMDL (quoting from the EPA web site: Total Maximum Daily Load = TMDL, a calculation of maximum amount of a pollutant that a waterbody can receive and still meet water quality standards) must be calculated for the Maumee River and include nutrients, since the river is a major source of water pollution in Lake Erie. That surface water also provides the drinking water for some cities along its path. Such data are vital to corrective measures and I agree that the highest priority for remedial action should be the Maumee River watershed.
Vickie Askins 4th October 2013 15:51:49
Ohio, Cygnet,
Animal manure is one of the leading sources of the phosphorus feeding the toxic algal blooms in Lake Erie – but Ohio’s permitting agencies devised a flawed approach which circumvents the Clean Water Act in order to allow the largest producers of manure to use a huge loophole to dispose of their manure. This loophole allows untrained people to spread massive amounts of manure anywhere, anytime and at any rate they want – with absolutely no oversight. The US EPA Administrator has never approved Ohio’s phased permitting program approach for concentrated animal feeding operations (CAFOs). US EPA has also never approved any transfer of authority from the Ohio EPA to the ODA – yet the ODA has issued hundreds of CAFO permits in the past ten years that are not in compliance with the Clean Water Act. For these reasons, I helped to submit a Petition to US EPA almost two years ago requesting EPA to withdraw all CAFO permitting authority from the State of Ohio and to assume administration and enforcement of Ohio’s program. I request that you go to http://ofmpub.epa.gov/apex/wps/f?p=122:5:2346706216046::NO::P5_PETITION_ID:75 and print out our Petition and Addendums so the IJC can investigate this unlawful situation.
Great Lakes Commission 4th October 2013 15:06:40
Michigan, Ann Arbor,
The Great Lakes Commission is pleased to see that the draft LEEP report echoes many of the findings of our September 2012 Report of the GLC Phosphorus Reduction Task Force (http://www.glc.org/announce/12/pdf/FINAL_PTaskForceReport_Sept2012.pdf). The draft LEEP report and the GLC task force report both acknowledge recent science and information that shows: a) the significance of agriculture as a primary uncontrolled source of phosphorus loadings into Lake Erie; and b) that dissolved reactive phosphorus (DRP), presents unique challenges for nutrient loading and cycling that cannot be resolved by addressing total phosphorus inputs alone. In particular, the draft LEEP report and the GLC task force report both call for actions to build on this information through: • improved education and outreach; • targeting financial and technical assistance to priority watersheds; • focused efforts to address dissolved reactive phosphorus (DRP); • increased efforts on managing agricultural drainage. We further applaud the report for explicitly acknowledging the link between phosphorus loads and harmful algal blooms and recommending actions that recognize the importance of leveraging voluntary, non-voluntary/regulatory programs and call for implementing specific new approaches that include elements of both.
Judith DiNardo 4th October 2013 14:57:16
Ohio, Stow,
Recently the International Joint Commission (IJC) released their draft Lake Erie Ecosystem Priorities. The report lays out 15 recommendations that could reduce nutrient pollution flowing into Lake Erie. While many of the recommendations are very solid, they lack some of the provisions of SMART (specific, measurable, assignable, realistic, and time-bound) goals/objectives. In addition, how are the recommendations prioritized and how will they be reached? How will the IJC work with the states and province to implement these recommendations?