GOLDEN SANDS DAIRY LLC
PROPOSED IRRIGATION MANAGEMENT PLAN

Golden Sands Dairy LLC (GSD) has planned for the option of applying manure via center pivots; however, such applications will not be made upon startup of the dairy farm. When irrigated manure applications are incorporated into the farm’s regular management plan, the farm will follow the practices described in this document.

This document is intended to describe management practices, nutrient applications and rates related only to center pivot applications of manure and process wastewater. All other practices, applications and rates will be dictated by the NMP narrative, in accordance with NR 243.

System Description

The irrigation systems the farm will use for applying liquid manure are those machines with a relative proximity to the dairy that are supplied by an underground pipeline, above ground hoses or both. The systems at GSD will be modeled after the systems in place at the Central Sands Dairy.

The irrigation system used at GSD will likely include a drop tube with a Nelson Rotator with a trash buster body and Brown (potato) plate. This provides very uniform distribution as well as facilitates easy maintenance and cleaning. All applications from this equipment will take place approximately 8 feet from the ground surface. It is impractical to deliver from a lower height because the canopy of some crops exceed this height. Most of the irrigation equipment will be nozzled between 800 and 1000 gallons per minute and run at pressures from 30-45 psi. All of the irrigation systems will likely be equipped with computer panels to allow for remote operation and monitoring and precise applications. This coupled with a telemetry package allows the farm to operate and monitor the equipment from virtually anywhere. Information from these panels downloads via the internet to the farm office, operator stations and employee smart phones. If a problem occurs with the irrigation equipment, employees can shut these units down or switch to a default control from anywhere.

End gun controls as well as optional valves will allow GSD to control individual sprinklers whether it is for adjustment or changes needed due to weather factors and system position.

Calibration of nozzle outputs are all pre-calculated and engineered by the factory. The farm will conduct annual fall test pumping of irrigation water to provide information on system performance as well as indicators of poor sprinkler performance. If performance is determined to be sub-par, it can be repaired, or new equipment packages can be installed to update the system.

The land base in proximity to the dairy is made up of primarily two soil types also with very little to no slope. The uniformity in soil, slope and fields makes even more beneficial the uniform application of nutrients. At the rates GSD will apply manure, runoff from these fields will not be an issue. We believe the very low p index on these fields, coupled with the practices employed by GSD make this an enviable NMP by many industry professionals.

Application through center pivots will allow smaller applications of nutrients throughout the season which increases flexibility to apply as the crop needs and to appropriately manage varying field and weather conditions. Another benefit is an ability to apply less manure in the fall because a diverse cropping rotation allows for applications in every month of the growing season.

Practices to Comply with NR 243.14(5)

·  CRITERIA FOR SITE LOCATION NR 214.14

500 ft setback from a private residence will be followed

·  DESIGN AND CONSTRUCTION

Consistent with NR 243 and 214, applications will be monitored to prevent ponding and runoff from application site

Consistent with NR 214.14, Table 1, maximum volume per load cycle @ .65 inches

Consistent with NR 214.14, Table 1, maximum intensity of application of 1 inch per hour

Drop nozzles will be used to minimize wind drift

·  APPLICATION LIMITATIONS

Applications made by GSD will be for the purpose of supplying nutrients to field and vegetable crops that are harvested annually

All nutrient applications will be consistent with the approved WPDES Permit and NRCS 590 nutrient application guidelines

Consistent with NR 214.14(3), daily hydraulic application rate will not exceed 10,000 gal per acre per day

·  APPLICATION MONITORING REQUIREMENTS

All manure applied by center pivot irrigation will be sampled according to WPDES permit conditions

In addition to WPDES permit conditions, GSD will conduct additional manure testing on a field specific basis at the time of application to monitor nutrient concentrations of applied liquid

In addition to WPDES permit conditions, Petiole sampling and crop tissue analyses will also be used to monitor nutrient concentration and crop needs

NR 243 and NRCS 590 require soil samples be taken on five acre grids once every four years; GSD will conduct these soil samples annually to more closely monitor field and soil conditions.

·  SOIL INVESTIGATION REQUIREMENTS NR 214.20

Detailed NRCS soil maps are provided for all fields utilizing center pivot irrigation of manure and processed waste water.

590 Field Data Report and Snap-Plus soil sample reports are provided for all fields that will use center pivot irrigation of manure and process waste water.

Soil series information provided for corresponding field soil types

Field specific Cation Exchange Capacity data will be collected by Wysocki Produce Farm Inc. as a part of its current and historic field soil samples. The Snap-Plus cropping sequence for crop years through 2019 provides crop specific UW based fertilizer recommendations.

Soil nitrate tests do not exist for the fields utilizing center pivot applications of manure and processed waste water. University of Wisconsin Publication A3634 – Nitrogen Management on Sandy Soil - does not recommend nitrate testing of Plainfield Sand and Friendship Sand because the soil nitrate content changes rapidly on sand.

Center pivot irrigation equipment vendor information provides hydraulic data and hardware descriptions for individual center pivot.

Well construction Reports – Form 3300-77A – will be provided. These reports will provide individual center pivot information on: location, well type, construction method, geology, static water levels, and pump GPM.

·  GROUNDWATER MONITORING REQUIREMENTS NR 214.21

Pursuant to NR 214.21, WDNR may require groundwater monitoring, depending on the type and strength of the manure, the volume of discharge, the type of land treatment system, the rate of discharge to the system and site characteristics. In addition, WDNR may waive any requirement to install monitoring wells based on a number of factors, including: whether the system is operated at nutrient and hydraulic rates which do not exceed the agronomic needs of the cover crop, whether the geology, soils and proposed hydraulic loading rate indicate that groundwater contamination is unlikely, the ratio of groundwater flow velocity to the hydraulic application rate and the density of the waste material.

Based on all of the best management practices identified throughout this document, and additional information provided below, groundwater monitoring at GSD application sites is not necessary.

Regardless, GSD has proposed a site-wide groundwater monitoring program that will be implemented 8 months before any manure is applied via center pivot.

·  MANAGEMENT PLAN FOR SETBACK AREAS/FIELDS

GSD will not apply manure or process wastewater within a 500 foot setback to residences. (Maps and field listing included). GSD will utilize traditional application methods and solid or commercial applications within these setback areas.

Options for traditional manure application on these restricted fields will include drag hose and airway bar applications, and possible surface applications with tanker trucks for liquid manure. Solid manure applications can be made to these fields as described in the NMP narrative. Commercial fertilizer applications will also be made to these fields in the absence of manure nutrients.

Summary of Best Management Practices to be Followed at GSD

·  GSD will follow the phosphorus based nutrient management planning as required by NR 243 and NRCS 590. Irrigation applications will not exceed the WPDES limitations for volume, nitrogen or phosphorus.

·  GSD will use anaerobic digestion of manure liquids to reduce pathogens

·  GSD will not apply irrigated manure to field areas within 500 foot setback restrictions, and will instead apply to these fields via traditional application methods. This BMP will help avoid conflicts with neighboring private residences.

·  GSD will have the ability to remotely monitor and shut off sprinkler nozzles and end guns of the center pivots if needed to avoid off-site movement of nutrients.

·  All manure application requirements of WPDES Permit will be followed to protect surface and ground water.

·  All application rates will be conducted in accordance with crop needs and SNAP-Plus recommendations.

·  GSD will wait a minimum of 5 days between specific field applications.

·  Field specific manure sampling will more accurately monitor nutrient loads.

·  Plant tissue testing will monitor nutrient needs of crops through the growing season.

·  GSD will sample soil on fields on an annual basis to monitor nutrient levels.

·  GSD will monitor weather conditions at application fields to avoid off site drift. (See Appendix A)

·  No ponding or runoff will be allowed.

·  Manure applications by GSD personnel and recently purchased equipment will allow for better control of the manure application in a timely manner.

·  Additional practices to minimize leaching potential of nutrients

a.  Pivot irrigation allows better management to shorten the window between application and cover crop planting or actively growing cover crops

b.  GSD will work to apply the majority of manure to actively growing crops.

c.  GSD will reduce fall nitrogen per acre applications to exceed requirements of the NMP. (Appendix A)

d.  Where appropriate, GSD will dilute manure liquids with irrigation water to facilitate incorporation of nutrients into the soil organic matter and facilitate nutrient tie up.

e.  Oats, or another cover crop, will be applied as a temporary cover crop to fields with spring manure if crop planting will be delayed.

f.  Pivot irrigation allows fall applications to growing cover crops, including alfalfa, to facilitate nutrient tie-up and further reduce leaching potential.

g.  GSD will utilize split applications for fall applied manure. (See Sec 8 - Appendix A)

GSD is confident that the conditional requirements of the WPDES Permit and the significant management practices listed and described above will help protect the ground water of the area and will minimize the risks associated with pivot irrigation while maximizing GSD’s implementation of sustainable agricultural practices.

Page 2