Environmental Violations at Largest Retailer in US Has a $110 Million Price Tag

Wal-Mart’s staggering fine of $81 million for violations under the Clean Water Act and the Federal Insecticide, Fungicide, and Rodenticide Act is sure to get the attention of other retailers.  According to the news release by the Environmental Protection Agency, “Wal-Mart Stores Inc. pleaded guilty today in cases filed by federal prosecutors in Los Angeles and San Francisco to six counts of violating the Clean Water Act by illegally handling and disposing of hazardous materials at its retail stores across the United States. The Bentonville, Ark.-based company also pleaded guilty today in Kansas City, Mo., to violating the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) by failing to properly handle pesticides that had been returned by customers at its stores across the country.”

The release goes on to say, “As a result of the three criminal cases brought by the Justice Department, as well as a related civil case filed by the U.S. Environmental Protection Agency (EPA), Wal-Mart will pay approximately $81.6 million for its unlawful conduct. Coupled with previous actions brought by the states of California and Missouri for the same conduct, Wal-Mart will pay a combined total of more than $110 million to resolve cases alleging violations of federal and state environmental laws.”

It appears one of the biggest failings of Wal-Mart in these violation was lack of training, resulting in “hazardous wastes…either discarded improperly at the store level – including being put into municipal trash bins or, if a liquid, poured into the local sewer system.”

For more information about the Wal-Mart Case follow this link: http://www.epa.gov/enforcement/waste/cases/walmart.html

If you have questions about environmental compliance, feel free to contact Matthew Schroeder, P.E. (mschroeder@dragun.com) at 248-932-0228.

 

Vapor Intrusion Update

Vapor Intrusion Diagram: USEPA

Vapor intrusion, or Vapour intrusion (VI) if you prefer, is one of the “hot topics” in the environmental world.  While I was attending RemTec in Denver the past March, it was one of the tracks of discussion and dominated many of the conversations.

So what exactly is VI and why should you care?  I asked one of our VI experts, Dr. Khaled Chekiri, to provide some insight on VI.

What is VI, and what is the “scientific concern”?

Dr. Chekiri:  Vapor intrusion (VI) is the phenomenon by which volatile chemicals in soil or groundwater migrate from the subsurface into the air space of a building.  Understanding VI is important because of the potential impact on our health and safety.  Health concerns are considerable, because toxic chemicals often enter the bloodstream more easily through inhalation than other exposure pathways, like ingestion or dermal contact.

What are the questions or concerns surrounding VI?

Dr. Chekiri:  There are several, the main one being the confusion surrounding it.  The United States Environmental Protection Agency released the Draft VI rules in November 2002 (Draft OSWER Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soil).  Since the November 2002 release, there has been wide disparity between various regulatory bodies (state and federal) and their approach to quantify VI.  For example, requirements and procedures to investigate VI (including sampling protocols), assessment of results, and how to mitigate VI are often inconsistent and ambiguous.  Further, many in the regulated community feel that they have been kept in the relative dark regarding what they should or shouldn’t do to assess VI risks on properties they may be purchasing.

What are the new developments?

Dr. Chekiri:  In April 2013, USEPA prepared external review draft documents of two guidance documents regarding vapor intrusion:

1)  A general guidance document for all compounds:  “OSWER Final Guidance For Assessing And Mitigating The Vapor Intrusion Pathway From Subsurface Sources To Indoor Air – External Review Draft” and

2)   A guidance document focused on petroleum hydrocarbons released from underground storage tanks:  “Guidance For Addressing Petroleum Vapor Intrusion At Leaking Underground Storage Tank Sites – External Review Draft.”

The idea is that these guidance documents will help to provide some consistency for investigative, as well as mitigation, methods as it relates to VI.  Whether they provide scientifically and technically sound approaches is yet to be determined.  And if you want to weigh in on this question, the deadline for public comment is June 24, 2013.

Is there anything new in Michigan as it relates to VI?

Dr. Chekiri:  In Michigan, the “Part 201/213 Vapor Intrusion Policy and Procedure” (the Policy) was revised and updated to include comments provided by stakeholders during the May 1 to August 1, 2012, comment period.  The Policy is currently under review by senior management at the Michigan Department of Environmental Quality (DEQ) and is expected to be completed soon.  Keep your eyes peeled!  A notice will be sent out on the DEQ listserv notifying interested parties of the newly-finalized document.

What should I do in the interim?

Dr. Chekiri:  First, if you are requested to test for vapor intrusion, we would continue to caution youto very carefully consider your options before moving forward with any sampling.  The science of VI is still relatively young.  However, legal issues surrounding environmental data are more mature, and once you have analytical results, you may have certain obligations that are best discussed with legal counsel.  There are (in my opinion) better approaches to assess the potential impact of vapors than just sampling.

Second, keep a watchful eye on the regulatory developments, especially if you are buying or selling properties that may be impacted by VI.  Real or perceived impact from VI could affect transactions and obligate a new owner to response actions under due care or continuing obligation rules.

And, of course, please call us at (248) 932-0228 with any questions you may have about VI.

New Superfund Listings from the U.S. Environmental Protection Agency

On May 24, 2013, the Environmental Protection Agency (EPA) will publish a rule in the Federal Register proposing to add 9 new sites to the National Priorities List (NPL).  The EPA will also add 9 sites to the final NPL bringing the total number of sites to 1320.

New Proposed Sites

South Bend, Indiana: Beck’s Lake

Garden City, Indiana: Garden City Ground Water Plume

Indianapolis, Indiana: Keystone Corridor Ground Water Contamination

Missoula, Montana: Smurfit-Stone Mill

Oxford, North Carolina: Cristex Drum

Gastonia, North Carolina: Hemphill Road TCE

Farmington, New Hampshire: Collins & Aikman Plant (Former)

Creek County, Oklahoma: Wilcox Oil Company

Neah Bay, Washington: Makah Reservation Warmhouse Beach Dump

For more information on the new proposed sites, click here http://www.epa.gov/superfund/sites/npl/newprop.htm

New Final Sites

Macon, Georgia: Macon Naval Ordnance Plant

Martinsville, Indiana: Pike and Mulberry Streets PCE Plume

Iola, Kansas: Former United Zinc & Associated Smelters

Attleboro, Massachusetts: Walton & Lonsbury Inc.

Danvers, Massachusetts: Creese & Cook Tannery (Former)

Newark, New Jersey: Riverside Industrial Park

Woolwich Township, New Jersey: Matlack, Inc.

Harriman, Tennessee: Clinch River Corporation

Salt Lake City, Utah: 700 South 1600 East PCE Plume

For more information on the new final sites, click here http://www.epa.gov/superfund/sites/npl/newfin.htm

 

Environmental Anything v Environmental Something: Being Different

Twenty-five years ago, with a different vision about how environmental consulting should look, we opened our doors for business. We believed that science and ingenuity had a place in the market.  But, truthfully, the barriers to market entry were not very limited.  Environmental Anything would do just fine.  So, how did we start?  We didn’t put environmental in our name, we went with The Dragun Corporation.  From day one, we set out to be very different.

With an abundance of opportunities in the late 1980s, conventional wisdom suggested that if you simply follow the regulator’s requests for more work, you will have plenty of profitable work.  However, what we saw in these requests was flawed science that would not help our clients achieve their goals, and we resisted the request for more data for the sake of data.  The result: we had less short-term work, but more long-term clients.  This was different.

One of the industry limitations we recognized early was a need for more hard, scientific data that would allow for better informed decisions.  So, we tasked ourselves to write technical books and papers on our own time.  This was most certainly different.

The trend in the 1990s was to hire “any warm body,” to carry out tasks.  However, we believed that those with scientific and engineering degrees and those with a propensity to be complex problem solvers, were more suited to a long-term business model.  This was different.

And then as projects became more challenging and complex, some shied away; but we accepted the challenge.  We achieved many “firsts,” including risk-based closures and eliminating unnecessary remediation that benefited neither the environment nor the client.  This was a difference our clients appreciated.

Later, when tough economic times and shrinking market share began to reshape and test the industry, we focused on our strengths.  We were rewarded as we were engaged on challenging and consequential projects that made their way to the highest courts in North America, and another that involved aggressive negotiations with the Department of Justice.  This, too, was very different.

And today, there are global environmental challenges, leaving many with a cynical view…and so we find ourselves again taking a different view.  Because we see an abundance of opportunities and we are confident that we can, and will, find solutions – solutions based firmly on sound science and engineering principles.

In 1988, we set out to challenge the conventional wisdom and the norms of our industry.  We truly believed then, and continue to believe to this day, that there is a market for an environmental consulting company that uses science and ingenuity to find practical business solutions.  And so we remain – proudly different as we celebrate our 25^th year.

The Dragun Corporation: Established May 18, 1988

Are There NPRI Changes in The Making?

Reviewing The National Pollutant Release Inventory (NPRI) list has become increasingly important for many Ontario companies as they prepare their Toxic Substance Reduction Plans (TSRP).  As you know, your TSRP is based on your (prior year) reportable NPRI toxic substances.

If Environment Canada’s proposals are approved, the NPRI list may have some changes in the near future that may affect your future reporting.

Here is a brief overview of some of the potential NPRI changes:

Proposed Reporting Threshold Changes

• Acrylonitrile:  From 10 tonnes to 1 tonne/reporting year.

• Particulate Matter:  If the reporting threshold for any one of the three PM fractions (total PM, PM 10 or PM 2.5) is met, then all three fractions would have to be reported.

• Toluene Diisocyanates (2,6-toluene diisocyanate, 2,4-toluene diisocycanate and mixtures of 2,6-toluene diisocyanate and 2,4-toluene diisocycanate):  from 10 tonnes to 100 kg/reporting year and concentration threshold from 1% to .01% by weight.

Proposed Additions

• Part 1 Additions
  • 2,2-bis (Bromomethyl) – 1,3 propanediol
  • Glycidol
  • Methyleugenol
  • Nitromethane
  • Phenolphthalein
  • Tetrafluoroethylene
• Part 2 Additions
• • 1,6-Dinitropyrene
  • 1,8-Dinitropyrene
  • 6-Nitrochrysene
  • 4-Nitropyrene

Finally, Environment Canada is considering a change in reporting requirement for chemicals related to the oil and gas sector, and a proposal to add Naphthenic Acids (associated with oil sands).

For Ontario companies, remember the deadline for Phase II TSRP reporting is December 31, 2013.   For more information about the TSRP, see our Environmental Minute.  If you have questions about preparing your TSRP, contact Andrew Tymec (Licensed Toxic Substance Reduction Planner) atymec@dragun.com at 519-979-7300.

Water Shortages: Another Unrealized Environmental Disaster?

The drought in 2012 pushed some water supplies to dangerously-low levels and reminded us all of how deeply dependent our economy, and certainly agriculture, is on an abundance of water.

The recent drought gave rise to an increased focus on water supply, including the United Nations declaring 2013 the “International Year of Water Cooperation.”  Additionally, recent articles have surfaced that discuss future forecast of water supplies and growing populations.  Looking beyond the recent wet weather (rain and snow) that has covered much of America’s heartland, what are some of the water supply prognostications? In a word; fatalistic.

According to some sources, water is becoming an endangered resource.  The United States State Department said, “The need for fresh water will exceed the supply by 40 percent by the year 2030.”

In a March 22, 2013, article in the Washington Post, author Steve Traction writes, “The indisputable fact is that water scarcity is rapidly becoming a significant factor in the way of life in the U.S…the problem will become critical in just a decade or two…the range of effects may include…long-term restrictions on home and community water usage; significant declines in agricultural outputs as well as meat and dairy produce that require huge amounts of water for irrigation and sustenance of livestock; shortages of just about every product made using water-dependant manufacturing processes…and disruptions or complete shutdown of several critical sources of hydroelectric power.”

The author also points to dwindling water levels in Lake Mead, as well as depletion of the massive Ogallala Aquifer, which (conservatively) takes thousands of years to recharge.

More bad news on the water front:  The Christian Science Monitor (referencing a report in the journal Science) reported two years ago that that the snowpack along the Rocky Mountains is as low as it has been in the past 800 years.  But the population and demands are far greater now than they were in the 1300s and 1400s…including irrigation and power generation needs.

Water demands are growing, supplies are stressed, and our way of life is in jeopardy…

This is not the first time we have heard horrific environmental predictions.  Henry Fairfield Osborn wrote “Our Plundered Planet” in 1948 in the same year William Vogt wrote “Road to Survival.”  Both of these books issued warnings of dwindling resources, famines & over population, and an evitable fall in the standard of living.

In 1980, there was a famous bet between ecologist and doomsayer Paul Ehrlich and economist Julian Simon.  Simon offered to let anyone pick any natural resources and a future date – according to Simon, the increased population would not cause scarcity and increased prices, rather prices would fall.  Paul Ehrlich, who famously wrote “The Population Bomb” in 1968 has long warned of dwindling resources and mass famine, took Simon up on the bet.  Ehrlich picked five metals (chrome, copper, nickel, tin, and tungsten).  The future date was 1990.  Simon was right; Ehrlich paid, but he continued to forecast more ecological doom (see John Tierney, New York Times, 1990 “Betting on the Planet”).

While bad news certainly grabs headlines, business decisions need to have a more rational approach.

As it relates to water supply, all the news isn’t bad.  In a recent book, The Big Thirst: The Secret Life and Turbulent Future of Water, Charles Fishman looks at the global water issue.  Interestingly, Fishman explains that Americans use less water today than we did in 1980, not just in per-capita terms, but also in absolute terms.  Fishman notes water use in the United States peaked in 1980 at 440 billion gallons per day.  Twenty-five years later we are using less than 410 billion gallons a day even though our population increased by 70 million people.  (See “The Big Thirst.”)

Water conservation practices and new drought resistant crops have helped us get the most out of the planet’s fixed amount of water.

The past predictions of ecological doom were wrong, because, as with other environmental threats, it’s science, ingenuity, and creative minds that find solutions, while naysayers look for the next disaster.

So, should agriculture be concerned about water supply?  Yes, we cannot afford to ignore any environmental threat.  But focus on the facts and solutions rather than hysteria.  As Julian Simon said, “There’s nothing wrong with worrying about new problems, we need problems so we can come up with solutions that leave us better off than if they’d never come up in the first place.”

Hydraulic Fracturing and Communicating Environmental Risks

At first blush, it would seem that hydraulic fracturing combined with horizontal drilling technology to harvest natural gas is an environmental panacea:

• It provides abundant natural gas, which reduces the need for coal.  Using natural gas as opposed to coal reduces (among other emissions) global warming gases and NOx emissions – which, in turn, reduce eutrophication and acid rain.

• The surface footprint for drilling is reduced as more subsurface drilling is accomplished with horizontal drilling.

• And regulators from former EPA administer Lisa Jackson to state regulators have by and large offered support for the technology.

…perfect, right?  Not so much.

Why some view “fracking” as a panacea and others view it as an unacceptable risk is, perhaps, one of those environmental communication dilemmas.  Dr. Peter Sandman’s formula for environmental communication may help explain the current state of hydraulic fracturing (Risk = Hazard + Outrage).

Dr. Sandman offers a couple of other environmental risk communication thoughts to consider:

1. Are people upset about a risk because they think it’s dangerous?  If this is the case, then the solution is to convince them it’s not dangerous, or
2. Do people think it’s dangerous because they’re upset?  If this is the case, then the solution is to stop upsetting them.

Generally, it’s the latter of the two.  Obviously, this makes it that much more difficult from the standpoint of communication, because to stop upsetting them usually means ceasing your operations.

To make matters worse, technical people try to appease upset stakeholders by providing more data!  How well does that work?  Again, according to Sandman, they will resist data, and when you prove they are wrong, outrage is magnified.

Communicating environmental risks, whether it’s from hydraulic fracturing, manufacturing a widget, or farming, may well be one of the most challenging tasks for any business.  And if you think the answer is simply more data…then be prepared for more outrage.

Stakeholders (upset or otherwise) are informed daily by blogs, tweets, and various on-line communities.  And this reality will continue to pressure companies of all shapes and sizes to think seriously about how they communicate to minimize the outrage factor, not necessarily the hazard…and this is no small task!

Surprise Inspections, Activists Getting Active, and Litigation – What’s a Farmer to Do?

If you are a livestock producer in the United States, it’s time to sit up and take notice.  The Environmental Protection Agency (EPA) is using very confident language in their intent to conduct “surprise” inspections, activists are getting…active, and a recent lawsuit has the potential for an ugly precedent.

Surprise Inspections:

An article in the Midwest Producer provides details about the EPA’s intent to visit livestock agriculture facilities this spring.

According to this article, Cheryl Burdett from the U.S. EPA Water Division stated, “We are going to knock on your door and you aren’t going to know we are coming…We like to go out during wet weather.  A lot of farmers say we came out during the worst conditions.  It is planned…we want to see your facility under the worst conditions.”

Which facilities will the EPA inspect?  According to Burdett, the agency will look at several factors when deciding which producers may receive a knock on the door.  The EPA will consider aerial photographs, size of the operation, and proximity of the operation to nearby waterways.  Burdett also points out that inspections may be a result of citizen complaints.  Don’t overlook that last comment – citizen complaints are key drivers in regulatory inspections, and community relations with citizens is no small part of livestock agricultures’ business.

Activists Activity:

If you recall, in our February 20^th blog, we mentioned that the EPA was seeking comments on their national enforcement initiatives.  One of the six current initiatives is discharges from Concentrated Animal Feeding Operations (CAFOs).  The EPA posed the question in a Federal Register Notice, should these enforcement initiatives remain the same?

Some activists are providing their comments to the EPA’s Federal Register notice.   The Mississippi River Collaboration’s comments included

…Given agencies have focused on inspecting large CAFOs, there is now a great need for inspections to be done of smaller operations to determine whether they are discharging without NPDES permits (emphasis added).

We urge the EPA to maintain “Preventing Animal Waste from Contaminating Surface and Ground Water” as a national enforcement priority.  Over the last several years, our states have benefited greatly from EPA flyovers and inspections that have resulted in enforcement actions.

It is imperative that EPA turn more of its attention to regulating agricultural pollution to the full extent allowed by the federal Clean Water Act.  CAFOs are one of the most poorly regulated point source sectors in our states.

Stay tuned on the EPA’s final word on their updated environmental enforcement initiatives.

Legal Battles:

But not everyone is focused just on the Clean Water Act enforcement at livestock agriculture.  In Washington State, a dairy producer, Cow Palace LLC, is being sued by Community Association for Restoration of the Environment and Center for Food Safety, Inc.

This legal action uses The Comprehensive Environmental Response Compensation and Liability Act (CERCLA aka Superfund), the Emergency Planning and Community Right to Know Act (EPCRA) and the Resource Conservation and Recovery Act (RCRA).

The lawsuit claims the dairy violated RCRA by “open dumping” and violated mandatory notification and reporting under EPCRA and CERCLA.

The use of RCRA is of particular interest as the federal regulations for RCRA specifically state the following exemption, “The raising of animals including animal manure” (40 CFR 261.4 (b) (2) (ii)).

The complaint seeks mandatory injunctive relief requiring Cow Palace to abate and remediate and will seek the maximum civil penalties under the law requiring the dairy to pay attorneys fees and expert witness fees.

All of this said, there are at least a few thoughts that come to mind.

First, if you are not ahead of the regulatory curve, get there now.  From these stories and all other appearances, enforcement at livestock agriculture is happening and will continue to happen, perhaps with more vigor.

Second, in the instance of the Cow Palace Dairy, the complaint is suggesting that the producer had knowledge of their requirements under CERCLA and EPCRA as they point to industry group websites that educate the producers on specific reporting requirements.

Third, in consideration of the first two thoughts, make sure you have your SPCC plan completed and implemented.  If you don’t know if your plan is complete and implemented or don’t know if you need a plan – figure it out, today.

Finally, the livestock industry absolutely needs to be about being good environmental stewards, but more than that, it’s time to have a compliance plan and/or to consider how a Best Management Practices document might assist in wide spread compliance as opposed to the alternative.   Remember, compliance isn’t just about a release or potential release – it’s administrative.

One last final comment.  It’s worth restating; we are entirely in favor of environmental protection through good environmental management.  What we are not in favor of, nor do we encourage, is complying with unreasonable orders or demands from regulators that have no basis in science or regulatory justification.

As always, if you have questions or need assistance addressing an environmental issue, big or small, contact our office at 248-932-0228.

Will the EPA Remain Focused on CAFOs?

Should the Environmental Protection Agency (EPA) continue to make Concentrated Animal Feeding Operations (CAFOs) a top priority as it relates to environmental enforcement action?  That is one of the questions posed by the EPA in their January 28, 2013 Federal Register notice.

The current national enforcement initiatives (FY 2011-2013) by the EPA include 1) Municipal Infrastructure, 2) Mineral Processing, 3) New Source Review (air emissions from specific sources), 4) Air Toxics, 5) Energy Extraction, and 6) Concentrated Animal Feeding Operations, specifically, addressing animal waste discharges from large animal feeding operations.

The January 28^th notice in the Federal Register is soliciting comments on what the agency’s new enforcement initiatives (FY 2014-2016) should be.  EPA states, “The public is invited to comment on extending the current six national enforcement initiatives for the 2014-2016 cycle” (emphasis added).

For several years, the EPA has stated they are serious about enforcement at CAFOs.   On EPA’s webpage, Preventing Animal Waste from Contaminating Surface and Ground Water, the EPA provides evidence that they are more than just talk about inspection and enforcement.

Source: EPA (http://www.epa.gov/compliance/data/planning/initiatives/2011cafo.html)

As seen in the graphic provided by the EPA, cumulative inspections by the agency at CAFOs shows that large farms continued to be a priority for the agency.

Perhaps in an effort to emphasize the gravity of their focus, the EPA offers some examples of CAFO enforcement on their website.  These include a Beef Feedlot ($145,000 fine) and a racecourse classified as a CAFO for horses ($1.25 million in violations, $3 million in improvements, and $742,000 for supplemental environmental projects).

If you would like to know if there has been any enforcement action in your area, you can find this on the same webpage.  The EPA offers an interactive map of Large CAFOs and EPA CAFO Inspections and Enforcement Actions.

Do you think the EPA should continue to focus on CAFOs for enforcement?  If you would like to have your voice heard on this matter, you need to weigh in by February 27, 2013 (the end of the comment period).

Finally, as a reminder, the deadline for agriculture to comply with another environmental regulatory deadline is quickly approaching.  The deadline for development and implementation of a Spill Prevention Control and Countermeasure (SPCC) Plan is just about 3 months away.   Not sure if the SPCC applies to you?  Use this SPCC Quick Guide, or go to the National Milk Producers Federation website and use their SPCC on line tools.

If you have any questions or require assistance on an environmental issue, contact our office at 248-932-0228.

The Drought of 2012…and Preparing for the Drought of 2013?

No one knows better than farmers how unpredictable weather can be. Weather predictions, like economic predictions, are notoriously unreliable. That said, according to several reports, the drought of 2012 seems to be overstaying its welcome into 2013.

In fact, more than 60% of the contiguous United States remains in a drought as we begin 2013. And according to Fred Gesser, senior agricultural meteorologist for Planalytics, Inc., “There is a 70% probability for last year’s drought to linger into 2013.”

The impact of the current drought is being felt now. According to a report in Drovers, a small farming town in Oklahoma (Wapanucka) lost water supply completely when the spring-fed wells in the community ran dry.

The dry weather is potentially a very serious issue as farmers look toward the growing season, and as they look to maintain water needs for livestock.

With this as a backdrop, I asked Dr. Michael Sklash, our senior hydrogeologist, a few questions relating to groundwater supply and agriculture. Mike has worked on groundwater supply issues for agriculture around the world, including crop and livestock farmers in the Midwestern United States.

Is there a way to evaluate whether my aquifer is currently stressed?

Sklash: Have any of your wells run dry at any time? Has the water level in your well fallen significantly? Have you had to lower your pump intake? Have there been any changes in water quality? These are all potential indications of a stressed aquifer.

Assuming worst case scenario (a continuing drought), are there any proactive measures I can take?

Sklash: Beyond looking at the specific crop types and depending on your needs (watering crops or water for livestock), you can consider the following:
• Horizontal wells
• Deeper wells
• Capture storm water and snow melt (in a retention pond)
• Optimize irrigation
• Focus your irrigation
• Cultivate to minimize surface runoff

How should I respond when asked if my agricultural water use is negatively impacting private wells?

Sklash: This isn’t always a simple cause-effect relationship, for example:
• The wells may be in different aquifers.
• The private wells may be shallow enough to be affected directly by less rainfall recharge. Water tables typically fluctuate by a few feet in many areas in the Midwest. A drought will only make the typical annual low levels lower.
• The wells may be too far apart to have a cause-effect relationship.
• There may be other water users causing the problem.

Finally, if you are considering siting a new agricultural operation, a water supply evaluation should be a high-priority consideration early in your decision making process.

As we write this newsletter (in late January), but for a recent unseasonable storm in the eastern half of the United States, the conditions are still very dry. While we all hope for a break in the precipitation pattern, consider some of the suggestions provided above to ease the impact of the ongoing drought.

If you have questions specific to groundwater or groundwater supply, please contact Mike Sklash (msklash@dragun.com) at 248-932-0228.