Diligence, communication make the foundation

MAUSTON, Wis. — Preparing for a concentrated animal feeding operation inspection does not have to be intimidating said farmers and CAFO specialists at a workshop held by the University of Wisconsin-Madison Division of Extension and the Wisconsin Department of Natural Resources, Feb. 11 in Mauston.

“I think it should be something you’re welcoming and not looking at them as adversaries,” said dairy farmer Randy Schmidt. “You need to work with them because they are part of your business, whether you think so or not.”

Schmidt and his family operate a 3,800-cow dairy farm in southwest Richland County. The farm obtained its first CAFO permit in 2016. Schmidt said the farm is preparing to host a re-certification inspection later this year.

“You know the things they don’t want to see,” Schmidt said. “They don’t want to see seepage or things like that. Repair the little things you see that need to be repaired. Make sure you have your record in place. You want things to look right, the things that are all traceable back to water you want to be good. Everything is an open book.”

Dr. Jim Mlsna and his family milk between 800-900 cows on their Vernon County farm near Hillsboro. Mlsna’s farm is on its third permit.

“I am always the one who takes care of the inspections on our farm,” Mlsna said. “I find it’s easier to be more honest, to say, ‘Hey, this is what we did, this is what we’ve been doing, what we’re trying to do.’ I would expect the same from our DNR reps that come to the farm, too, to treat us with a little respect and common sense.”

Being proactive is an important part of operating a large-scale dairy farm, Schmidt said.

“It’s important to keep an open dialogue, open lines of communication,” Schmidt said. “We all know things are going to go wrong, sometimes. The DNR has always maintained to me that if I have a problem, they want to hear it from me first, rather than having someone calling it in, so be diligent on your response time.”

DNR CAFO compliance and enforcement coordinator James Salscheider explained there are two different types of production site inspections: comprehensive and partial.

Comprehensive inspections are planned well in advance and encompass all facilities covered under the permit in question, including satellite sites. A comprehensive inspection will look at all areas of the production site and include a records review, where DNR staff will look over all records required to be kept for the permit.

Salscheider said a partial inspection can be related to engineering, to ensure compliance of scheduled upgrade construction. A partial inspection can also be related to enforcement, Salscheider said, and can include wet weather inspections, which can be short-notice inspections.

“Inspections typically look great during dry weather, but we want to see your production site when it’s the most stressed,” Salscheider said.

Salscheider said comprehensive inspections are scheduled throughout the permit term. The first inspection is for a first-time permittee planning to expand above 1,000 animal units.

“That initial inspection of the production site is a good opportunity for the DNR to get to know you and your production facilities,” Salscheider said. “We’ll see how the logistics are run, look at reviewable facilities that will require engineering evaluations.”

The next comprehensive inspection takes place midway through the permit term and is typically done during the second year of the permit, Salscheider said.

“That mid-term inspection is kind of like a check-up or physical of the site,” Salscheider said. “We’ll make sure all of the reviewable facilities are being maintained and you’re keeping up on the record-keeping requirements.”

The most comprehensive site inspection that staff conduct is the permit reissuance inspection, which takes place one year prior to the expiration of the current permit.

“The reissuance inspection is a really in-depth review of record,” Salscheider said. “We’ll make sure you’re in total compliance of your permit, so we can move forward with the reissuance process.”

During the inspection, Salscheider said CAFO specialists will be looking at all areas of the farm identified as production areas.

“We’ll look at your manure storage facilities, solid and liquid,” Salscheider said. “We’ll take a look at your raw materials storage facilities, feed and bedding. We’ll look at barnyards, feed lots, calf hutch areas. We’ll take a look at your runoff control systems for those facilities; storm water conveyance systems; mortality management systems; and manure and processed wastewater transfer systems. We’ll also look at ancillary service areas identified as areas of the production site that are adjacent to the production area but not intended for manure convey or handling, processed wastewater handling.”

Some of the common issues found with waste storage facilities include erosion of earthen and clay-lined facilities and cracking of concrete facilities; seeping of water in and out of the facilities; excessive broadleaf and wood vegetation; and evidence of animal burrowing. Salscheider said specialists will be looking for permit markers denoting the margin of safety and the maximum operating level for the waste storage and will ask the farmer about this.

The most common issues found in feed storage areas include cracked and missing concrete on pads and bunker walls, allowing seepage through both walls and floors, along with perimeter tile blowouts, Salscheider said.

“It’s important to fix these areas when they are small,” Salscheider said. “They could quickly get to a size that requires plans and specs to be submitted for approval prior to fixing.”

Mlsna and Schmidt agreed continual vigilance makes inspection preparation and compliance easier.

“We try to keep things cleaned up and take care of things that we know are going to be points of concern,” Mlsna said. “We don’t like confrontation and we don’t like to have any interactions with the DNR that we don’t create.”

Schmidt said strict compliance with his permit aids his family in presenting a good face to the public. His farm’s location is 40 miles from Madison, on Highway 15, with two neighboring nature conservancies.

“My goal is to always have something green growing on the farm almost every day of the year,” Schmidt said. “We’re diligent about getting cover crops on. We work to be transparent. … My dad always told me to leave it better than you found it, and that you’ll spend your lifetime building your reputation, but you can lose it in 10 minutes. Your actions will always speak louder than your words.”