A Watershed Moment. Lake Huron rolls, Superior sings In the rooms of her ice-water mansion. Old Michigan steams like a young man's dreams The islands and bays are for sportsmen. And farther below Lake Ontario Takes in what Lake Erie can send her. In The Wreck of the Edmund Fitzgerald1, Gordon Lightfoot sings the words to a geography lesson about the Great Lakes Basin, which is part of the St. Lawrence Watershed. This watershed includes parts of 11 American states and six Canadian provinces. The Great Lakes hold one-fifth of the world’s, and 95% of the United States’, fresh water supply. At its heart lies one state – Michigan, whose Great Lakes coastline of 3,288 miles2, is more than any other state’s except Alaska. What happens to Michigan’s surface water impacts this entire system. Michigan is truly The Great Lakes State.

Figure 1. St. Lawrence Drainage Basin, including the Great Lakes Drainage Basin3

In 2015, The Less = More Coalition published Follow the Manure: Factory Farms and the Lake Erie Algal Crisis, which targeted the role that Concentrated Animal Feeding Operations (CAFOs), or factory farms, and the manure they produce, play in contributing dissolved phosphorus to Lake Erie’s toxic algae problems. _________________________ 1

The Wreck of the Edmund Fitzgerald. Lightfoot, G. Summer Dreams. Eastern Sound Studios. December, 1975. Great Lakes Facts and Figures, Great Lakes Information Network http://www.greatlakes.net/lakes/ref/lakefact.html, updated March 13, 2017. 3 http://www.infrastructure.gc.ca/images/great-lakes-grands-lacs_basin-bassinx390_eng.jpg 2

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Follow the Manure, with its interactive maps, continued the work begun by Less = More’s 2013 report, Restoring the Balance to Michigan’s Farming Landscape, and showed the extent to which Federal subsidies fund these facilities in the Western Lake Erie Watershed. In many cases, these taxpayer dollars continue to fund the bad actors and ineffective agricultural practices, with disastrous effects in Lake Erie and throughout the Great Lakes Basin. In 2017, we find ourselves at a watershed moment. Millions of dollars are being spent on various efforts to keep phosphorus from entering the surface waters of the Great Lakes in the form of additional subsidies through partnerships between the U.S. Dept. of Agriculture (USDA) and the U.S. Environmental Protection Agency (EPA). In addition, the USDA through the Farm Bill continues to subsidize commodity crop production which feeds these livestock, crop insurance, and conservation and EQIP pollution remediation/prevention programs. But, using the River Raisin, one of Lake Erie’s tributaries, as an example, much work remains. While the level of total phosphorus in the Raisin has declined greatly over the years, the amount of dissolved phosphorus (which is the subset of total phosphorus that actually “feeds” the toxic algae) has almost doubled since the 1990’s.4 So, unless efforts are better targeted, it is just a matter of time before another toxic mass floats into another municipal water intake somewhere in the Great Lakes. Where will it happen next? In this 2017 Appendix to The Less = More Coalition’s Follow the Manure project, called A Watershed Moment, we turned our attention to Michigan and its 272 National Pollutant Discharge Elimination System (NPDES)-permitted CAFOs. These farms meet the EPA standards for a large CAFO5, which in addition to animal numbers housed, must confine their animals for 45 days or more in a 12-month period, and no crops, vegetation, forage growth, or post-harvest residue are sustained in the normal growing season in the lot or facility. If they meet these criteria, they must obtain an NPDES CAFO permit, administered by the State of Michigan’s Department of Environmental Quality (MDEQ) on behalf of the U.S. Environmental Protection Agency (USEPA). For this project, we tracked the main sites of factory farms (but not their satellite locations and feeder farms) under Michigan’s General CAFO permit, as well as the Individual CAFO and No-Potential-to Discharge CAFO permits. Subsidies and violations were tracked according to the site itself, which may have had several owners over the years; those owners and all the names that subsidies and violations were received under, combined, are shown with that site. We did not track the processing facilities with CAFO permits, nor did we track the medium and small facilities that are not required to obtain permits. We also did not track the farms where animals are pastured, not confined. As of December 31, 2016, Michigan’s 272 permitted factory farms confined 20,640,837 animals that produced 3,348,566,912 gallons of CAFO waste6. These farms housed 311,553 _______________________ 4Ferner Calls Phosphorus Reductions Misleading.

Henry, T. The Blade, Toledo, OH. October 2, 2015. https://www.epa.gov/sites/production/files/2015-08/documents/sector_table.pdf 6 Defined in Michigan’s NPDES CAFO permit application, “CAFO waste” includes, but is not limited to, process wastewater, manure, production area waste, silage leachate and runoff, and contaminated runoff. 5

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dairy cows and heifers; 43,327 beef cattle and veal calves; 637,934 hogs; 18,898,149 chickens, and 749,874 turkeys. About 79.5% of this waste was produced by dairy cows and heifers, and 2.5% came from beef cattle and veal calves. About 1.5% came from chickens (egg-layers, pullets, broilers) and less than .5% came from turkeys. Approximately 8% came from swine, and the remaining 8% was produced by farms that housed a combination of categories. Unlike human waste, CAFO waste is not treated. The vast majority of this untreated animal sewage is stored in giant Figure 4. CAFO manure lagoons, Bean Creek/Maumee watershed. Photo: ECCSCM/Sierra Club/Lighthawk open cesspits called lagoons, or under slatted barn floors, to which millions of gallons of clean groundwater are added, until it can be applied as liquid fertilizer on farm fields. The Southeast Lake Michigan Watershed (St. Joseph, Black-Macatawa, Kalamazoo, Upper Grand, Maple, Lower Grand, and Thornapple Rivers) is home to the most factory farms (149), the most CAFO waste produced (1.8 billion gallons), the most subsidies received ($59 million), and the most environmental enforcement actions by the State (388). Of special concern is the Saginaw Bay – Lake Huron area, where there are a very high number of these farms in a relatively small area. The most manure was produced by CAFOs in Huron County at nearly 402 million gallons, about 12% of the total produced in the State. The factory farms in Allegan County received the most subsidies (around $14 million) and earned the most environmental enforcement actions by the State at 255. Concentrated animal feeding operations in Michigan’s 4th Congressional District received the most subsidies, $26,928,362. By district, these farms also produced the most manure and waste at 1,022,563,988 gallons in 2016. This district includes all of Clare, Clinton, Gladwin, Gratiot, Isabella, Mecosta, Midland, Missaukee, Ogemaw, Osceola, Roscommon, Shiawassee, and Wexford counties, and portions of Montcalm and Saginaw counties. The factory farms in Michigan’s 6th Congressional District amassed the most environmental enforcement actions by the State of Michigan through 2016, at 263. This district includes Allegan, Berrien, Cass, Kalamazoo, St. Joseph, and Van Buren Counties. In total, Michigan’s factory farms received $103,861,110 in a combination of Federal subsidies (listed above) from 1995-2014, and were cited for 644 environmental enforcement actions by the State (through Dec. 31, 2016). The large interactive map, A Watershed Moment, includes layers that allow the user to explore the facility locations by watershed and by Congressional district, the species housed and the number of livestock, the CAFO waste produced, the subsidies granted, and the environmental citations given for violations of their 3

NPDES permits for things like discharges of CAFO waste to the waters of the State. The sortable data table from which these maps were made is linked. Since the 1970’s, tremendous efforts have been made to clean up the polluted Great Lakes and their tributaries. But these lakes are now again at risk. Over 400,000 people in northwest Ohio and southeastern Michigan lost access to their drinking water for several days in August, 2014, when the City of Toledo’s water treatment plant intake was closed due to an outbreak of cyanobacteria-produced microcystin in Lake Erie. Scientists and other experts had been watching these toxic algae outbreaks in The Great Lakes Basin for several years. In fact, the Figure 2. NASA Satellite, Great Lakes, 20117 record year for these outbreaks before that was 20118, where these bright green outbreaks could be seen not only in Lake Erie, but also in Lake St. Clair, Saginaw Bay in Lake Huron, and even in Lake Michigan on NASA satellite maps. If we could have looked more closely, we would also have seen them in some of Michigan’s inland lakes, most notably Lake Macatawa in Holland. In Lake Erie, experts attribute the phosphorus runoff that is the limiting nutrient in these algal blooms to many sources, including construction activities, stormwater runoff, combined sewer overflow discharges, lawn and garden fertilizers, tree leaves, pet waste, faulty septic systems, climate change, quagga and zebra mussels, and agricultural practices such as increased tile drainage of farmland, no-till (a conservation practice that can stratify phosphorus in the top few inches of soil), fertilizer application rates, and more.

Figure 3. Wolf Creek, City of Adrian drinking water source, Raisin Watershed, CAFO manure application on snow. Photo: ECCSCM

_________________________________ 7 Harmful Algae Blooms Plague Lake Erie Again. Borre, L. Water Currents, National Geographic Voices. April 24, 2013. 8 Ibid

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Mainly, according to these same experts, it comes from agriculture, and manure from livestock operations plays a big part9, 10. Saginaw Bay, Lake St. Clair, and even Lake Macatawa suffer similar problems from cyanobacteria-produced microcystin. In recognition of CAFO manure and the problems caused by its application on snow and frozen ground, the MDEQ sent a letter to all MI NPDES CAFO permit holders in October, 2014, in the Western Lake Erie, Saginaw Bay, and Macatawa watersheds asking them to “avoid land application on snow and frozen ground, if at all possible.”11 Cladaphora, a true algae which is also “fed” by excess nutrients such as phosphorus, and bacteria, adds to the problem in Saginaw Bay and Lake St. Clair. Progress was made in Michigan during 2016 with the addition of its open waters of Lake Erie to the EPA 303(d) Impaired Waters list for phosphorus. But Environmentally Concerned Citizens of South Central Michigan’s orthophosphate test results in a lake downstream from two CAFOs (dairy and swine) and where CAFO manure is applied continue to show excessive orthophosphate levels, and DNA tests taken of bacteria in the lake have all showed the presence of cattle DNA, and some contained swine DNA.12 Despite all of this subsidy money which is generally used for programs designed to combat sediment and erosion, instead of dissolved phosphorus that flows wherever the water goes, ECCSCM’s edge-of-field test results where manure is applied continue to show excessive levels of orthophosphate. Our recommendations from 2015’s Follow the Manure project still stand, which are: 

Stop giving shrinking federal taxpayer dollars for conservation practices to polluting CAFOs.  Change the phosphorus soil test requirements. Phosphorus soil test 

requirements need to be set to allow no more than 40 ppm (Bray P1) from manure and chemical fertilizer.

Ban application of CAFO waste on frozen or snow-covered ground.

Figure 5. January manure application, Bean Creek/Maumee Watershed. Photo: ECCSCM/Sierra Club/Lighthawk

__________________________ 9 What is causing the harmful algal blooms in Lake Erie?

King, K., Smith, D., and Williams, M. Journal of Soil and Water Conservation, March/April 2015. Vol. 70, No. 2. 10 A Balanced Diet for Lake Erie: Reducing Phosphorus Loadings and Harmful Algal Blooms. International Joint Commission. February, 2014. 11 Letter, MDEQ staff to NPDES CAFO permit holders, October, 2014. 12 Environmentally Concerned Citizens of South Central Michigan http://nocafos.org

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

Require soil and edge-of-field water testing before a facility receives Environmental Quality Incentives Program subsidies and after they are implemented to determine their effectiveness.  Develop practices that address the role of subsurface tile drainage systems in agricultural runoff, especially where liquid manure is applied.  Develop a comprehensive policy based on the best and most current data across state lines. The Great Lakes Basin and the entire St. Lawrence River Watershed know no political boundaries. It is one system.

As with the previous Less = More Coalition projects, we continue to hope that this effort inspires further inquiry, as well as serious deliberation about how taxpayer money is spent to address this environmental crisis. Toxic algae isn’t just a Lake Erie problem. It’s found in Michigan’s Great Lakes, and it’s getting worse. It’s now even in Michigan’s smallest inland lakes. And according to the IJC, 80% of Lake Erie’s total annual inflow comes through the St. Clair River, from Lakes Michigan, Superior, and Huron.13 It’s an entire ecosystem. Just like it says in the song.

__________________________ 13 A Balanced Diet for Lake Erie.

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Credits: This project was prepared by Environmentally Concerned Citizens of South Central Michigan, The Socially Responsible Agricultural Project, and University of Michigan-Dearborn student James Campbell on behalf of the members of Less=More, a diverse coalition of organizations seeking to create a fair playing field for sustainable farms in Michigan. Special thanks goes to Environmentally Concerned Citizens of South Central Michigan for its comprehensive data on CAFOs in Lenawee and Hillsdale Counties. Less=More Steering Committee members include: Center for Food Safety, Crane Dance Farm, LLC, East Lansing Food Coop, Environmentally Concerned Citizens of South Central Michigan, Food & Water Watch, Greater Grand Rapids Food Systems Council, Groundswell Farm, Humane Society of the United States, Michigan Voices for Good Food Policy, Michigan Young Farmers Coalition, Sierra Club Michigan Chapter and The Socially Responsible Agricultural Project.

Sources: This project is only as robust as the data it is based on, and there is reason to believe that not all instances of CAFO pollution that come to the attention of agency regulators are officially recorded, nor were all CAFO permit records viewable to the public, in the MDEQ MIWaters database at the time the records were searched. The project authors and the members of the Less = More Coalition make no guarantee of accuracy and are not responsible for any errors. Farm Data including violations: MDEQ MIWaters database. Profiles; 2015 CAFO Annual Reports, due Apr. 1, 2016; 2015/2016 manure production reports; 2015/2016 NPDES CAFO new applications and permit renewal applications; 2015/2016 Comprehensive Nutrient Management Plans (CNMPs) https://miwaters.deq.state.mi.us/miwaters/#/external/home NPDES Permit Inventory as of November, 2016: http://www.michigan.gov/deq/0,4561,7135-3313_72753-10780--,00.html Subsidies: Environmental Working Group’s Farm Subsidy Database https://farm.ewg.org/?_ga=1.70764243.250448904.1489451193 Freedom of Information Act Requests to MDEQ Water Resources Division staff dated 7.1.2016, 7.7.2016, 7.10.2016, 1.20.2017, 1.22.2017 Environmentally Concerned Citizens of South Central Michigan http://nocafos.org

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