Appendix B

Letter from Dr. Ron Sheffield to Owyhee County

Planning and Zoning Administrator Mary Huff, July 18,
2007
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Universityof Idaho
College ofAgrlculturaf and Life Sciences
Bio.lo.gicaland Agricultural Engineering
Twin Falls Research and Extensio.n Center
P.O.'Bo.x1827 '
Twin Falls, Idaho. 83303-1827 U.S.A
Telepho.ne: 208-736-3625 .
Cell: 208-308-5194
Fax: 208-736-0843
Web );ite: http://\wNI.agls.uidaho.edu!bae!
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July 18, 20.07

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Mary Huff
Administratar
Owyhee Caun~ Planning & Zaning
Post Office Bax 128
Murphy .•Idaho. 83650

Ms Huff,

I am writing yau in respanse to. yaur affice's request an June 28, 2007, far my review af the
prapased Nutrient Management Plan (NMP) for DeRutter Dairy's expansian. It is my
un'derstanding that the dairy currently has a capacity af 4000 milking caws, 600 dry caws, and
5000 heifers, and is prapasing to. expand to. 6000 milking cows, 1200 dry cows, and J200 heifers.
The praposed NMP was develaped via the Idaho. 1:Plan,and lacks several details concerning the ..
aperatian af the dairy's manure handling system :and activities related to. mitigating patential
adars. Specifically, my cancerns and recommendatians are listed belaw.

'1. Phosphorus Excretion. The manure generatian values used in the NMP are based an
'/991 manure generatian values adapted by the USDA-NRCS. Several advances in
animal genetics, dairy management; and feedin~1strategies have taken place since the
late 80's; the time in which the studies were canducted to. generate the 1991 values.
Subsequently, the American Saciety af Agricultural and Biological Engineers and the
Assaciatian far Prafessianal Animal Scientists developed new a manure generatian
standard (ASAE 384.2 MAR2005) that was adopted in 2005. Specifically, the standard
raises the estimated phaspharus excretian for a mature 1400 Ib dairy caw from 0.21 Ibs
P20s/cow/day to 0.39 Ibs P20s/caw/day, nearly doubling the amount af excreted
phaspharus per day. The use afthe 1991 excretian values is in accardance with state
rules. Hawever, given the current accepted science, the praposed NMP creates a false
sense of security far the praducer that the mana!~ement af phasphorus, thraugh fallowing
the NMP, will accur with aut excessive build-up af sail phosphorus in the soil, wilen in
reality, that will likely occur because anly half af the excreted manure phaspharus has'
been accaunted for in the NMP. A capy afASAE 384.2 MAR2005 is attached for yaur
reference.

2. Compost Management. The NMP states that the vacuumed manure from the freestal/
barns will be managed via the compast system. The NMP daes nat address haw the
collected manure slurry (approximate moisture content of 88%) wi!! be dried and or
incorparated into compost windraws. Additianally, the NMP daes not mentian the use at
carban material such as straw, wood chips or shavings, or mint waste to. adjust the
carbon to. nitrogen ratio. (C:N) af the campast windraws to. ensure praper camposting.

~X~riCLII tLiraI [. Life SCI en_c_e_s ._~

To enrich educatron through dh'ersity the Universiij' o~ Idailo is an equal opoortunity/affirmatlve action employer and "ducation institution.
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Additionally, the' plan does not specify how much of the produced compost will be utilized
for freestall bedding and how much will be exported off the farm ...

3. Slurry Evaporation Area. The use of an area to evaporate vacuumed slurry dUring
·.warm periods of the year is currently used on the farm and is not mentioned in the NMP..
Vacuumed manure is applied to the ground in shallow depths (-114 inch) toaHow the
water in the material to evaporate, thus reducing thevolume and moisture content of the.,
material that will be scraped from the ground and managed as a solid .. This practice is;
effective in reducing the volume of manure. and generating a more manageable dry
product, but occurs at the expense of odors, volatized ammonia, and potentia! fly
production. This practice should be avoided,
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4. High Groundwater Nitrates. The January 8, 2007 Siting Team report indicates that
groundwater concentrations for nitrate are greatBr than the state standard of 10 mg/L,
and are increasing. H is my understanding, through discussions with the site, that it has
participated in a joint DEQ and ISDA monitoring program for at least the past 4 years.
The NMP fails to provide any plans to reduye soi/nitrate levels on the farm, even if there
may hBve been pre-existing conditions. To address soil nitrates in this part of Owyhee
County will require additional mariagement on behalf of DeRutter Dairy as well as other
farmers in the vicinity.

5. Flies. The Siting Teanl report states that the farm has developed an integrated pest
management plan; however it is not referenced in the NMP. Several commercial
companies are available in the Treasure Valley to provide fly control services for large
dairies. Control should be conducted on the entire facility, including the manure
separation and Gomposting areas, in addition to 'feed storage and livestock production
areas. 0.-1;

If you have any questions, please feel free to call me at 208-736-3625.

In service to all Idahoans,

Dr. Ron Sheffield

Assistant Professor and Waste Management Engineer

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