ILLINOIS POLLUTION CONTROL BOARD
March
28,
1972
In the matter of
PLANT NUTRIENTS
)
R 71-15
Opinion of the Board
(by
Mr.
Aldrich)
Plant nutrients are relative newcomers
to the growing list of
environmental
concerns.
Illinois
is
an appropriate
state in
which
to examine
the role of nutrients because
it has
in recent
years
led
all states
in the application of major plant nutrients
(nitrogen, phosphorus,
potassium).
The Pollution Control Board
in May,
1971, approved proposals for public hearings on the
application of fertilizers,
animal wastes,
and sewage sludge and on
controlled access of livestock to streams.
The purposes of the
hearings were to determine:
1.
Whether plant nutrients are creating pollution problems by
reaching surface or underground waters
in excessive amounts.
2.
The present state
of knowledge on the extent to which
fertilizers and animal manure contribute to pollution problems.
3.
Whether
steps can be taken
to correct pollution problems in
the event that problems
are identified and agricultural
practices are
found to be important contributors.
Two
approaches were to be considered:
a)
adoption of rules and
regulations,
and h)
reliance upon needed research, education
and voluntary changes
in practices.
4.
The impact
of alternative courses of action both on the
environment and on food supply and costs.
5.
The administrative feasibility of rules
and regulations.
When
the proposals were distributed
for hearing purposes, no decision
had been made
that regulations would be adopted.
The testimony developed by more than
80 witnesses
in ten public hearings
combined with extensive exhibits produced
a comprehensive record of
available information on the status and trends of nitrates
and phosphates
in streams,
the
role of crop production practices
in determining the
plant nutrient content of surface waters
and the environmental and
economic consequences of alternative practices.
But it also revealed
major deficiencies
in available information on which to base our
decision in the matter of plant nutrients.
4
—
127
NITROGEN
Harmeson reported an increase in nitrate content of surface waters
since extensive records began in 1945
(Nov.
3,
pp.
157-170).
The
magnitude of
the increase
is difficult to assess because continuous
long-term records at the same sampling sites are
lacking.
In some
streams the Water Quality Standard of
10 mg/l nitrate nitrogen
(45 mg/l nitrate),
R 71—14,
is frequently violated especially
in
east—central Illinois.
Sources of excess nitrates in streams
are
well known but
the magnitude of the contribution of each is unknown.
Increases
in fertilizer nitrogen and in the acreage
of row crops are
the most likely contributors.
Dr.
Kohl described
a technique
(Dec.
10,
pp.
23-41) which he claimed could iaentify the nitrate in water which
traced directly to fertilizer.
The methodology was challenged by
TVA scientists Edwards
(Dec.
10,
pp.
207-214)
and Hauck
(Dec.
10,
pp.
233—262).
The experts could not resolve the controversy even
after extended debate and
a subsequent conference.
Nor does the
record demonstrate any alternative to commercial fertilizer that would
provide adequate food without an equal potential for exporting nitrates
to surface and groundwater.
None of the expert witnesses could
say
whether the substitution o~livestock and human wastes or of nitrogen-
fixing legumes
for fertilizer nitrogen would reduce the amount of
nitrates that
leach through or run off
the soil.
The record clearly supports the conclusion that within
a given
set
of supporting cultural practices,
the greater the amount of nitrogen
applied the greater the potential for loss
to ground and surface
waters
(Nov.
3,
p.
52).
But farmers who produce the highest yields
and apply the highest rates of nitrogen may produce
a unit of crop
with
less potentially leachable nitrate than farmers who produce
average yields.
Surveys reveal that recent increases
in nitrogen con-
sumption in Illinois,
and for the entire Cornbelt, are due
to higher
rates being applied on previously underfertilized fields.
The pro-
portion of fields that receive more than 150 pounds per acre has
decreased in recent years.
Several witnesses questioned the credibility of
10 mg/l nitrate
nitrogen
(45 mg/l nitrate)
as
a suitable standard
for public drinking
and food processing water.
The present standard is intended mainly
for the protection of infants against possible methernoglobinemia
(blue baby syndrome).
Testimony
in the record supplemented by the
exhibits
is confusing and inconclusive.
The record shows that methemo-
globinemia is almost non-existent
in Illinois,
only one case having
been confirmed in Illinois in the past ten years and it was from a
private well.
Dr.
Gelperin reported
a relationship between nitrate
in drinking water and methemoglobin
in pregnant women and infants but
found no observable effects during the study period
(Aug.
4,
pp. 121-
123),
Numerous examples
are cited
in the record where
the standard
is exceeded in farm wells by a factor of
two to ten times with no known
health effects among humans
or livestock,
As was pointed out by
Dr.
Kohl,
this does not constitute proof of no harmful effect,
but
it raises questions on the status of the standard.
The nitrate
4
—
128
standard of 10 mg/l nitrate nitrogen
for public drinking
and food
processing water is not new.
it was
a part of SWB-l4 adopted in 1967
and was included in the
U.
S. Public Health Standards as early as
1962.
The question raised
is not whether low nitrate
is desirable but
whether the present standard is justified by an analysis of the
benefits and
costs of achieving
it.
High nitrate content is some farm wells
is,
according
to the
record,
not traceable
to nitrogen fertilizer but rather to septic systems or
animal wastes and appears to be most common
in the Illinoia~
glaciation area of southern and western Illinois.
The productivity of Illinois soils is an irreplaceable resource.
About
40 percent of the nitrogen and organic matter have been lost
from
the surface soil as
a result of farming.
We recognize that
the
preservation of soil productivity
is an important environmental goal
but
the record does not establish the role of nitrogen fertilizer in
achieving
it.
Commoner asked us to adopt
the
regulations on which
the
hearings were based though he did not feel
that this would reduce the
nitrogen content of waters.
It would in his view be
a step in the
right direction.
He maintained that Illinois agriculture was
“out of
balance”
and that nitrogen fertilizer aggravated
the situation.
He
proposed a return to more reliance on organic sources and
less on
fertilizer.
His views are contrary to those of many soil scientists.
Furthermore
a 40
decline
in soil nitrogen and organic matter occurred
before the widespread use of nitrogen fertilizer.
In any event we
prefer to await additional information as indicated below, before imposing
any limitations
on fertilizer use.
Even though many farmers testified
that present practices met the proposed standard,
to regulate it would
limit future increases and we do not have adequate cost—benefit infor-
mation to justify that result at the present time.
Swanson reported that regulations
that reduce the amount of nitrogen
fertilizer applied
for corn in Illinois would reduce the income of
Illinois farmers but would have little effect on food prices.
If
restrictions were imposed throughout
the cornbelt,
the burden would
shift from farmers to consumers in the form of higher food prices
(Ex.
19).
Many farmers testified that because of their intimate and continuing
contact with the environment,
they have
a special sense of stewardship.
They alleged that this in combination with the fact that plant nutrients
are valuable production factors which are costly to replace, serve
as
a substantial deterrent
to excessive or misapplication of fertilizer.
They maintained that,
if research identifies problems resulting
from.
fertilizer practices, education programs and economic considerations
will be adequate to protect the environmental interests
of society.
But what may not be excessive from the farmer point of view may be
too
much for
the good of society for his calculation do not include possible
adverse effects downstream.
Based on the record we
feel that research
on the optimum economic rates of applied nitrogen is extensive
(Aug.
3,
pp.
24-30;
Ex.
19,
p.
5)
but deficient in the relationship of rate
to
the nitrate content of waters which receives the drainage from cropland.
4
—
129
We conclude
that the water quality standards for nitrate nitrogen are
presently being vidlated
in certain streams of the
state
and that the
potential nitrate problem will grow as the demand for food increases.
The record has not demonstrated
that health effects have resulted,
Deficiencies
in available knowledge on the credibility of the nitrate
standard, on
the contributions of various nitrogen sources
to nitrates in
water,
on the effectiveness of possible control measures
and on
undesirable
side effects on the environment from alternative practices
convince us that
at. this time we should make provision for more inform-
ation
on which to decide
the
issue rather than to promulgate regulations
of
unpredictable
effectiveness
and
side
effects~
Accordingly
we
shall
ask
the
Institute
for Environmental Quality to
give
high priority
to obtaining information on nitrates which will provide
a basis
for
early
reconsideration
of
the
matter,
Specifically
we
request
the
Institute
to
develop
an
implementation
plan
for
achieving
the
standard
of
10
mg/I
nitrate
nitrogen
in
public
drinking
and
food
processing
water
or,
if
Institute
studies
show
that
the
cos~
to
achieve
compliance
are not justified by
the
benefits,
to
propose
a revision,
Perhaps additional research will be required
in
stream sampling,
in conriec~tionwith applications
of fertilizer,
animal
and human wastes,
in groundwater hydrology,
and in
cropping
systems
before an implementation plan can be developed.
We suggest that
the
Institute also
consider
the
technical
feasibility
and
economic
reason-
ableness of removing nitrates
from public drinking
and food processing
water in case
a choice becomes necessary at
a future date between
nitrate removal versus major adjustments
in food production practices
in order to reduce the sources
of nitrates.
Specific suggestions
for
needed agricultural research are
list.ed
in
a supplemental opinion by
Board Member,
Mr.
Aldrich.
The position of the Federal EPA appears
to be in basic agreement with
our decision as indicated
in testimony introduced
into our record:
“The development of fertilizer application management plans
will require full evaluation of
the nutrient availability
and retention capability
of various soil
types in particular
agricultural areas.
The capability of existing programs,
such as those of the
Ti,
S. Department
of Agriculture
and
State and local Agricultural Agencies should be brought
to
bear
toward developing the essential information
for complete
watersheds
and soil structure types
at an early date.
Start-
ing now with available information,
guidelines for fertilizer
application, including optimum and maximum recommended rates
should be developed.
The voluntary use of the guidelines
in
the fertilizer program for individual farms should be encouraged.
Effective use must
be made of the available educational and
technical assistance programs
at the Federal,
State,
and local
levels”
(Ex.
72,
p.
10).
4
—
130
PHOSPHORUS
Based on
this
record
and
the
record in R 70-8 (Effluent Standards),
R
70—12
(Des
Plaines
Water
Quality),
R
71-10
(Phosphorus
in
Detergents
and
other
Cleaning
Products),
and
R
*7l_14
and
R
71-20
(Water
Quality
Standards)
,
we
do
not
now
propose
to
regulate
the
time
and
rate
of
applications
of
phosphorus
in
fertilizers.
Phosphorus
has
bean
shown
to
be
a
serious
water
contaminant in
the
Fox
River
as
well
as in
Lake
Michigan
and
other
still
waters,
but
not
in
flowing
streams
generally.
Nor
has
the
evidence
stressed
the
contribution
of
fertilizer
runoff
in
these
Illinois
waters
subject
to
serious phosphorus problems.
In
this
connection
it
should
be
understood
that
phosphorus
in
land
runoff
is
not
to
be
ecuated
to,phosphorus
in
fertilizers.
it
also
includes
phosphorus
contributed
by
decaying grass,
leaves
and
other
vegetation
and
erosion
from
both
non—farm
and
farm
areas
and
live-
stock
wastes.
Based
upon
expert
testimony
by
Dr.
Ralph
Evans,
Head
of
the
Water
Quality
Section
of
the
State
Water
Survey
we
stated
in
the
Board
Opinion
in
R
71-10:
“The
effect
of
nutrients
on
flowing
midwestern
streams has been negligible
and there
is no substantive evidence
supporting the view that. phosphorus
in these streams is
a major water
quality degradent.”
The behavior of phosphorus fertilizer when applied to the
soil is
well known.
Illinois soils
have retention capacities for phosphorus
far
in
excess
of
the
amounts
applied
in
fertilizer.
Hence
phosphorus
in tile drainage effluent is little affected by fertilizer applications.
According to Dr. Nelson
(Ex.
29(e),Table
4), about one percent of
surface—applied phosphorus was carried in solution in surface runoff
from
a
relatively
steep
slope
following
heavy
rainfall.
An
additional
amount
was
carried
off
in
association
with eroded soil particles.
In
future
hearings
we
expect
to
take
a closer look
at erosion as
a source
of
phosphorus.
From
1962
to 1970 while use
of
fertilizer
phosphorus
in
Illinois
tripled,
data
from
the
Illinois
State
Water
Survey
show
the
following:
—the
average
annual concentration of filterable phosphorus in
the
Illinois
River
at
Peoria
was
constant except for excursions
above
the
average
in
1963
and
1964.
-neither filterable nor total phosphorus increased in the
Kaskaskia River at Shelbyville.
-filterable phosphorus did not increase in representative small
streams (Embarrass River, Elkhorn,
Seven Mile and Wolf Creeks).
From this record and from others involving phosphorus we believe
that research is needed on the
relative
availability
to aquatic plants
of
phosphorus
that
is
in
solution,
in
organic
matter,
or
adsorbed
on
soil particles.
4—
131
Though we have decided that regulations
on phosphorus fertilizers
should not be imposed at this
time we must register our concern for
prudent use of fertilizer in order
to conserve finite reserves of
phosphorus
in economically recoverable form for future use.
A highly
productive
soil is
a relatively good place
to store reserves provided
erosion
is controlled.
But erosion
is not completely controlled.
Furthermore
there
is an inexorable slow chemical transformation to
relatively less plant-available
forms.
FENCING LIVESTOCK FROM STREAMS
The hearing record on the fencing of livestock out of streams except
for reasonable access
for drinking or crossing
is singularly one—sided.
No one testified as
to the need for such
a regulation.
Several farmers
testified at each of the nine hearings where
an opportunity was afforded
to
the effect that the proposal was unnecessary, unworkable, uneconomic
and perhaps environmentally undesirable.
Livestock in and near streams which may at some point be used for
public drinking or food processing water
is esthetically unpleasant.
Furthermore,
the Water Quality Criteria book
(U.
S. Department of
Interior)
lists leptospiro~isas
a disease hazard from livestock urine
in streams.
Dr.
Hanson, College of Veterinary Medicine, University
of
Illinois, reports
that there are several serotypes,
some carried
primarily by wild animals, others by swine,
cattle and dogs.
The
disease
is common among domestic livestock and can be contracted by
humans from swimming in infected waters.
Since all streams eventually reach waters that are used for public
drinking or food processing water,
a fencing requirement y~ouldapply
to all streams.
Animals, wild or domesticated,
in and near streams
are nothing new.
When massive herds
of buffalo roamed the Illinois
prairies,
the condition of some streams must have been incredibly bad,
Farmers maintained that as long
as the number of livestock did not
exceed the carrying capacity of the pasturage,
the assimilative
capacity of the stream would not be exceeded.
The
issue,
therefore,
more appropriately belongs in the hearings on livestock wastes where
the matter of wastes
from large concentrations of livestock will be
considered.
Fencing streams
is very costly.
Fences will be repeatedly
torn out
by high water.
Fencing will reduce the control of noxious weeds.
The high cost of fencing would make uneconomical
the utilization of
large acreages of rough
land for grazing,
the only use to which it
is suited.
As
a consequence,
farmers would likely increase their
acreages of cropland
as.a
means
of compensating for their lost
income.
This would lead to additional floods and erosion which would
be more environmentally undesirable than grazing along or crossing
streams.
We conclude
that at this time we should not require fencing of
grazing
livestock
from
streams.
The
matter
will
be
further
examined
in
the
livestock
waste
hearings
in
order
to
assure
that
the
runoff
from
feedlots
and
other
livestock
concentrations
does
not
pollute
surface
waters.
The
matter
of
leptospirosis
was
not
covered
in
the
record.
It
merits
further
attention
and
is
being
pursued
with
the
Director
of
the
State
Department
of
Public
Health
and
the
Department
of
Veterinary
Pathology
and
Hygiene,
University
of
Illinois.
SLUDGE
The
proposal
relating
to
sewage
sludge
and
effluent
was
intended
to
limit
the
application
of
available
nitrogen
to
the
same
level
as
in
fertilizer.
Since
we
have
not
adopted
a.
limit
on
nitrogen
rate,
we
are
not
suggesting
a
regulation
on
sewage
sludge.
Adequate
safeguards
can
be
developed
by
the
Environmental
Protection
Agency
in
connection
with
site
approval
augmented
by
surveillance
after
the
sewage
material
application
is
in
progress.
Board
Member
Mr.
Aldrich
has
prepared
a
Supplemental
Opinion
in
much
greater
detail
on
the
sections
on
nitrogen
and
phosphorus.
I, Christan L. Moffett,
Clerk of the Pollution Co trol Board,
ce tify
that the Board adopted the above Opinion this~
‘day of
,
1972
by a vote of 5-0.