Miscalculations

Among the dozen or so flaws with the Supreme Beef NMP (nutrient management plan), we believe that DNR is allowing a gross underestimation of the annual amount of nitrogen (N) and phosphorous (P) nutrients that must by Iowa law be disposed of on crop fields at agronomic rates.  To say that there is something fishy with DNR’s acceptance of the producers estimates is an understatement.  It smells of corruption and political hackery.

Cows poop.  We know how much they poop.  By law the nutrient content of cattle manure produced in a facility is to be calculated by using published values of pounds of N and P produced per cow per year, multiplied by the number of cows.  Simple.  Too simple, so obviously a loophole had to be included.  For new facilities,  estimates can be obtained by using measured nutrient concentrations and volumes from a similar facility.  One that stores and handles the manure in the same manner as the new facility proposes.

But let’s be clear.  There are a range of possible storage and handling scenarios where concentrations and volumes might be different, but within that range of scenarios, the product of concentration x volume will initially be similar.  Cows just poop.  They don’t know or care how their manure is handled or stored.

What Supreme Beef has done to produce their estimate of annual N&P nutrients from the proposed 11,600 cattle, is to claim very low N&P concentration values from a “similar facility” where the manure has been stored in diluted form.  We know that because the moisture content is listed in the test results as almost 98%.  These low concentration numbers are then multiplied by the daily volume values from standard tables corresponding to undiluted manure – manure “as excreted” with a moisture content of 92%.  This chicanery results in an under estimate of annual N&P nutrient production by a factor of times 4 to times 6. 

We have explained this to the DNR reviewers in great detail.  Sure there are technical issues that make it a bit more complicated than I’ve presented.  But DNR’s response has not been rational. It has been an Orwellian mix of red herrings mixed in with meaningless word salad.  They cannot admit we are right, because the flaw is fatal, and we believe staff have been told that the NMP must be approved… regardless.