Field Office Compliance - Assistance

Assistance ID - 125022

Farm-253 Sanderson - 312470465

1445 340TH AVE. Estherville, IA 51334

Emmet County

FO 3

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Attached Files/Reports

File Name	File Type	File Date	Note

Comments

Date	Comment	Commenter
8/12/2022	On at least two occasions, including August 9, 2022, Garrison stopped in the office to provide information about manure application at NFP sites, especially the Sanderson farm. Multiple times during these visits, Garrison stated that he was not making a complaint but that he wanted the DNR to be aware of his concerns and calculations. That said, he did call or stop multiple times in order to find out what we then did in response. In reply, I again clarified with him that he was not making an official complaint, and he agreed. I said that we are not taking any specific action (such as a complaint investigation), but we will examine the MMP and the application records when we do future inspections at NFP sites. This is our normal practice. Background: Garrison calculated application rates for the Sanderson site based on his assumptions about the facility. His information was based on an older MMP which may be out of date. He also used what he felt were the most accurate manure availability numbers and other book values, but those may not be the numbers that NFP is using in their MMP. He also assumed that that NFP was off-cycle with their planned crop rotations on certain fields that he had observed, but again, he was going by rotations listed in an older MMP. On balance, this information did not indicate to me that a violation was reasonably a possibility. It is normal for facilities to modify their MMP as the years go by, and they are not obligated to use the book values that Garrison used in his calculations. Facilities are required to keep their current plan up to date and accurate, using approved book values or actual sample results. During inspections, the DNR reviews actual application records in order to determine compliance. Garrison opined that the DNR is underfunded, and he said that he would continue to push for more effective oversight of AFOs, including new issues such as increased phosphorous transport and accumulation of copper in soil. No further action is required.	SCOTT WILSON

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