IEC Comments on Supreme Beef Manure Management Plan

The Iowa DNR hosted a virtual meeting Monday, March 1 to hear public comments on a  proposed Nutrient Management Plan for an expansion of the Supreme Beef, LLC cattle feedlot operation. Supreme Beef, LLC is proposing to expand its facility on the former Walz Energy site in Giard Township of Clayton County. In October, DNR approved the operation for up to 2,700 head of cattle. The new proposal is for 11,600 total head. 

Michael Schmidt, Staff Attorney for the Iowa Environmental Council, shared the following during the meeting: 

"We have several significant concerns about the NMP: it proposes over-application of manure, makes unfounded assumptions regarding manure nutrient content, does not list conservation practices, and will pose a threat to water quality in the region.

First, regarding over-application of manure, some of the soil phosphorus index calculations are incorrect. This is important because soil with a phosphorus index greater than 5 cannot receive manure (65.17(17)(f)). The calculation of the phosphorus index depends on accurately identifying the erosiveness of soil, based on soil type. Because the critical soil types were incorrectly identified, the index was inaccurate. Several proposed fields cannot receive manure application and the ability to expand depends on having those fields.

Second, the NMP assumes manure nutrient concentrations that are inconsistent with DNR tables and guidance from independent research. The NMP cites manure testing from a beef processing facility as the basis for its assumption. It is not clear from the NMP where the manure in the test came from, why it deviates significantly from all other guidance, or why that concentration would be more accurate.

Third, the Iowa Administrative Code requires listing conservation practices in the NMP to control pollutant runoff. (65.112(8)(e)(7)). The NMP made assumptions about conservation practices without identifying them. That does not meet the requirements of the rule.

Finally, the DNR has authority to evaluate open feedlots “with respect to potential adverse impacts on natural resources or the environment.” (65.103(5)) This site poses risks to water quality. Bloody Run Creek is an OIW and cold-water trout stream, on karst terrain, so excess nitrogen and phosphorus could cause significant harm to aquatic life. Beyond the sheer volume of manure produced, many of the proposed land application fields are distant from the facility – as far as 30 miles away – and it does not make economic sense to transport manure that far, especially with the claimed nutrient content. That means manure might be over-applied closer to the facility because landowners will refuse to pay for transport to more distant fields. DNR identified 19 feedlots within 8 miles of Supreme Beef, so expanding Supreme Beef to become such a large feedlot increases the cumulative risk of nutrient pollution.

Each of these deficiencies independently provides a basis for DNR to disapprove the application because it does not comply with the requirements of the Iowa Administrative Code. IEC urges the DNR to disapprove the NMP. We will submit written comments detailing our objections."

The DNR will accept written comments until 4:30 p.m. on Monday, March 8, 2021. IEC will submit written comments, asking the DNR not approve the NMP because: 

• The proposed expansion poses high risks to water quality. The open feedlot would be the largest in the region, on karst terrain that is highly susceptible to conveying water pollution. 
• The open feedlot is in the watershed of an Outstanding Iowa Water – any overflows from the manure storage basin or manure applied to adjacent land could reach Bloody Run Creek. 
• The Nutrient Management Plan assumes very low concentrations of nitrogen and phosphorus in the manure without justification. DNR’s standard figures of total nitrogen and phosphorus in manure are four to six times higher. If the concentration of nutrients is in fact diluted, more volume needs to be accounted for in the NMP. 

You are encouraged to share your concerns with the DNR by sending comments to kelli.book@dnr.iowa.gov by 4:30 p.m. on Monday, March 8.  

UPDATE: IEC submitted written comments on March 8. View those comments. 

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