Click for Copy of Federal Lawsuit filed
Summary of Facts for Phosphorus ban in Lawn Fertilizer
The most important fact of all is that 3% Phosphorus in lawn fertilizer will do the same thing as 0% but just take more time. The 3% will protect the lawns 0% has the potential to lessen the quality of the lawns in the future.
1. Nitrogen, Phosphorus, and Potassium are major turf nutrients. 27-3-3 is an example.
2. Remove one of them and you are trying to balance a three legged stool. You can do it for a while but eventually you fall over.
3. Nitrogen, Phosphorus, and Potassium are tools to grow great turf. Let us not remove a great tool from the homeowner.
4. Lawns use .22 lbs of phosphorus (P2O5) per 1000 sq. ft. every year because lawns in the residential and commercial areas of Dane County are designed to carry water away very fast. Dr. Kussow's E-mail below
5. Even on soils 2.5 times above the normal levels (excessive) of phosphorus it will take only three to five years before the lawns decline if no phosphorus is applied. Dr. Stier Lakes and Watershed Report Page 37
6. Great turf and turf buffer strips are recommended by the DNR to stop sediments and slow down water from entering our lakes.
7. The state now only does about 2000 lawn soil tests a year. People just do not take soil tests. We have over 180,000 households in Dane County alone. It takes two weeks to get the soil test results back. It takes about two hours to take the two soil tests needed and to mail them. The cost is $30 at UW extension.
8. In retail if you cannot display it, you do not carry it in inventory. In the future phosphorus fertilizer will harder to buy even if you have a soil test that shows you need it.
9. Only 50% of the lawns in Dane County are fertilized. Marginal lawns which are unfertilized lose a minimum of about one pound of soil a year per 1000 sq. ft.. This equals volume wise about one baseball/1000 sq. ft. You could lose this amount for years and never notice it. Construction sites where homes are built lose about one dump truck of soil per acre or about one tenth of inch of soil per 1000 sq. ft. (volume wise about 1/3 cubic yard or about 8 sq. ft. by 1 foot high) Lawns that are fertilized lose almost no soil and significantly less runoff water. Soil carries phosphorus.
10. In time the lawns that are not getting phosphorus will become marginal also and we will get increased sediments i. e. phosphorus into our lakes.
11. No organic fertilizers containing phosphorus can be used without a soil test including Milorganite since it has 2% phosphorus. Milorganite is classified as a lawn fertilizer by the state but the city and county are saying it is a soil amendment that is used to enhance soil structure and will not even enforce their own law. The ordinance uses the state of Wisconsin Department of Agriculture definition of what is a fertilizer in an earlier part of the ordinance. I am not quite sure how they can say Milorganite is a soil amendment. The use of organic fertilizes puts significantly more phosphorus on our lawns if the required nitrogen is used. Significantly greater potential for damaging our lakes if organic fertilizers are pushed as the correct way to fertilize lawns.
I have never fertilized my lawn and it is still green what gives. I get this all the time so perhaps the following will help.
1. First of all these calculations by the Doctors in soil and turf science try to replicate the urban conditions where water is designed to run in a relatively fast manner. Your turf may not have those conditions.
2. The second condition is that the soil as we know it, at least in our area is normally solubilizing phosphorus.
3. The problem is that the rate of solubilation (phosphorus becoming available to the turf) is enough to keep turf from dying but not enough for it to grow well.
4. The problem is when we expect turf to do a good job of stopping soil and water runoff it needs to be growing very well. The phosphorus levels can never drop below 20 parts per million in the soil. We say that amount assuming the turf has full access to 6 to 8 inches of soil and good soil structure exists.
5. This is perhaps why you have heard stories about our soils having enough phosphorus to last 100 years. Yes they do but they cannot release it fast enough for turf to grow well, just fast enough to keep it alive.
6. Nutrient uptake and availability is a very complicated process and very hard to explain to people who have not been trained in soils and nutrient uptake of plants. Perhaps that is why there is so much debate on this issue.
7. Let's just say what I have been saying all along. In the long run turf that has been growing well with the present fertilization by the homeowner will become marginal in the future with the proposed 0% phosphorus in lawn fertilizer. This will increase sediment losses and actually make our lakes worse.
28 Years and still above normal What gives??
The other thing that bugs me is that here we have in the summarized report from the Lakes and Watershed Commission on page one mind you the following statement. USGS has core samples from a lawn known not to have been fertilized for 28 years and it still had phosphorus levels above suggested growth levels (20 PPM P2O5). It is not normal. Yet No one questioned the statement. Such a claim doesn’t make much sense.
First of all someone should have asked what have the levels been doing over time. We need a starting point. Perhaps they were very high to begin with. The other thing to ask is this lawn in question like urban soils where water is constantly being forced to run over the soil to get away fast enough. It surely appears to me that someone was trying to influence others in this issue. Perhaps water ran onto this lawn so every time it rained it got fertilized.
It doesn’t take rocket science to figure out that no matter what we do phosphorus will go into our lakes. We know some of it is coming from sediment losses on marginal turf and leaching out of dead turf tissue in the spring during spring thaw. Well if this is happening how can turf go for 28 years and not be low? Well simply put it can’t, unless it was extremely high to begin with or the data collected on the lawn of 28 years is wrong.
When you let go of a ball it falls to the floor. Well when you keep taking something out each year eventually the glass gets empty. We know that even when the clippings are left the soil test decreases 2.5 PPM each year when no phosphorus is applied. 2.5 times 28 equals 70 plus the 20 required means the soil had to start at or above 90 PPM of Phosphorus. This is not the typical lawn in urban areas yet it is being used as an example. This rate of 2.5 PPM begins to slow down when the level drops below 20 PPM in the soil and turf becomes marginal. At some point below normal the rate that phosphorus becomes available in the soil matches the loss rate. When this happens turf is very marginal with large sediment losses and significantly more runoff. Beneficial soil structure is also significantly decreased.
How anyone let this slip by and put it on the first page of a summarized report to reflect normal lawns in our urban area is beyond me.
A lot of stuff you find in the Lakes and Watershed Commission Report are just statements by people. There is no collaborating research to back up the statements. It is my understanding that all statements made by the Turf and Soil scientists had other research by other people to back their statements up. It is called peer reviewed research. We need to pay more attention to what they said.
Dr. John Stier
Dept, of Horticulture, Turfgrass Extension
390 Horticulture, 1575 Linden Drive
Madison, WI 53706-1590
Dear Dr. Stier, Letter sent to him by some members of the Dane county board and his response
The Dane County Board will be considering ordinance amendments April 15, 2004 at 7:30 PM in the City County Building Second Floor regarding the amount of phosphorus that can be used in lawn fertilizers. We have heard from limnologists that phosphorus contributes to algae and lake weeds and I would assume you would agree with that statement. However, in your experience as a professor in the Department of Horticulture, Turfgrass Extension, I am interested in your views about how phosphorus is used in lawns and what consequences we may observe with a total ban on phosphorus in fertilizer.
Would you answer the following questions about this issue to help me and my constituents to understand this issue more completely? It is important to us that public policy decisions are based on the best scientific information available. I understand you and others at the UW Horticultural Department have studied this and can answer these questions.
1. Do phosphorus containing fertilizers contribute to phosphorus runoff?
2. Why do we need to have phosphorus in fertilizer when our soils are already high in phosphorus?
3. How much phosphorus runoff does turf/grass contribute to the total runoff?
To Whom it
may concern,
I have read
the 46 page report that was done on
I have 200
plus college credits with a degree in horticulture. I also have been farming here in Dane County
for many years. My summary:
Why was some of the following text left out of the summarized report by the Lakes and Watershed Commission? They seem very important and relevant. What they are saying is if we do not use phosphorus in fertilizer the lawns will be thinner. If we do anything to stop or confuse homeowners from fertilizing lawns we are in for a lot of trouble.
Page 37 by Combs "Dr. Wayne Kussow's research at the O.J. Noor Turf grass Center and other locations has shown that turf quality is best when 1 Lb of N as a regular or maintenance turf fertilizer blend ( i.e. 27-3-3 )is applied 3 or 4 times per season when soils tested in the optimum or above range in P and K.
Page 37 Kussow In my 6 years of research I was applying fertilizers to a soil testing excessive in P. My data show no relationship between the amounts of fertilizer P applied and the quantities of P in the runoff water. When I failed to apply any fertilizer for two years, the turf grass thinned out so much that the amount of runoff increased 134% and the runoff water from the unfertilized turf grass contained nearly two times as much P as in the runoff water from the fertilized turf grass. Furthermore Mr. Barten's research in the Twin Cities shows that there is no significant relationship between soil levels of P and the concentrations of P in lawn runoff water.
Stier Page
28 Scientifically -peer reviewed research shows properly applied
fertilizer does not runoff from turf. There is a possibility as shown in
recent paper that when fertilizer was applied to saturated soil conditions
followed by high levels of stimulated rainfall it did show up in the
runoff. The majority of evidence, though, in studies conducted in
Page 28 Kussow The P in fertilizer is 100% water soluble and, with a minimal amount of rain or watering quickly moves into the soil where it is absorbed on soil particles surfaces. Loss in runoff water is therefore largely by way of erosion of the soil per se in the form of sediment. Proper Lawn maintenance of lawns results in sediment losses that range from zero to a few pounds per acre.
Page 37
Stier. If established turf stops being fertilized with P, and plenty of P
exists in soil, and nothing occurs to inhibit P or P solubilization in soil,
then it could be several years ( 3 - 5 or more) before the turf starts thinning
out and runoff losses and sediment and P losses actually increase.
Page 11 by
the United States Geological Survey “there is the possibility that the ordinance
could lead to thinner, less-healthy lawns, which may lead to increased runoff
volume”
I asked
some very specific questions of Dr. Kussow.
I have included a copy of the e-mail.
It appears even with a soil test with phosphorus about 2.5 times above
the optimum and leaving the clippings it will take only 12 years before
phosphorus becomes the limiting factor.
This assumes the turf has access to the full 6 to 8 inches of soil. Most turf does not have enough of a root
system so it has only about 2 to 3 inches to work in. Based on this I would assume 6 years would be
a more realistic time frame.
It is my
understanding the UW soil test lab is doing about 2000 lawn soil tests per year
for the whole state of
One other note. A UW of Wisconsin Dean sent out
an e-mail reminding extension personnel that they could only present data, the
goal of extension is to remain unbiased in a public policy debate. This just happened to be sent out just before
the first public hearing on this matter.
That is why a significant amount of them have not voiced more opposition
to this ordinance. It is also my
understanding that the county board provides the funding for some extension
personnel and you have not funded an opening for a permanent horticulture
position in
A second
side note. The 3% allowance would mean
we do not need an organic exemption.
Most organic fertilizer is not above 3% phosphorus. Milorganite
Grass needs
.22 lbs.P2O5 (Phosphorus) per 1000 sq. feet added in a year if the clippings are left not
zero.
A Third side note. Everyone accepts the small plots that tell us on Corn, soybeans, etc. how much fertilizer they need. I wonder if everyone accepts this as gospel why do some people say the small plots Dr. Kussow uses to tell nutrient usage in turf have no relevancy. It is the same type of research.
How about a fourth. Dr Kussow is retiring this summer to the best of my knowledge. He is a tenured professor who has spent many years doing turf research. He does not need more money for research. He is just telling it like it is. I do not understand why we are not passing laws based on a science and common sense that says homeowners are not going to spend money on a soil test, the phosphorus will become the limiting factor in growth, the lawns will get thinner and more sediment and phosphorus will get into our lakes. The increase in phosphorus in the years ahead will be blamed as usual on farmers.
Edward
Knapton
608-222-2269
How do we
get people to understand that turf that is not fertilized is marginal and loses
sediment though it may look fine and look like it doesn’t lose anything.
Unfertilized lawns is where the bulk of our problem is in regards to sediment/phosphorus
issues. Minimum loss is 1 pound per 1000 sq.ft.
My thinking is, why are we requiring the people that want to take care of their
lawns (doing the most to stop sediment from getting into our lakes) to spend an
addition $30 but not requiring the people who do not fertilize their lawns to do
something. The UW recommends two soil tests one for the front and one for the
back of your lawn $15 dollars each.
Marginal lawns are causing the problem not the good turf.
How do we get everyone to
understand that good turf does not put sediment or phosphorus in our lakes.
Phosphorus is only lost from good lawns in the spring of the year during spring
runoff when the ground is frozen or saturated.
When you notice your lawn getting thin and the thatch decreasing you have
already contributed a significant amount of sediment and phosphorus to our
lakes.
This does not need to
happen. Put a minimal application of low Phosphorus fertilizer on each year.
We know exactly what is lost each year. Why can't we do just what farmers do,
put on the requirement of the crop being grown each year. It needs .22 pounds
of phosphorus each year if you leave the clippings and .55 pounds per 1000
square feet if clippings are removed.
E-mail From Dr. Kussow
At
I want to
be sure I understand your research.
Applying
Most
20 lb bags will say this covers 5000 square feet so based on this it
means .12 lbs of phosphorus per 1000. This would be applied 4 times per
year for a grand total of .48 lbs per 1000 sq feet or approximately 20 lbs of
P2O5 per acre.
Combs said that grass plants remove more than this from the soil each year
according to your work.
At the rate of fertilization suggested above, if you remove the clippings
you're using up about 0.55 lb P2O5/M (Phosphorus). But if the clippings are not removed,
you're recycling about 0.33 lb of P2O5, so the use rate is only 0.22 lb P2O5/M.
Based on the plant removing
this much and we started with a high level let's say 50 in the soil.
How long would it take before
Phosphorus was the limiting factor? At 50 ppm soil test P, you're 30 ppm
over the optimum level. Not applying fertilizer P (Phosphorus) reduces soil test P about 2.5 ppm/yr. Thus, at 50 ppm soil test P, you could go approximately 12 years
without fertilizer P.
How is it measured how much
phosphorus turf uses in a growing year? Are the clippings removed?
If the clippings stayed how much would it need? Phosphorus removal by
turf grass is determined by collecting the clippings from each mowing,
determining their dry weight and P concentration, and calculating the amount of
P removed. I think I've already answered your other question.
Am I correct in understanding
that when good turf is growing little to no phosphorus is produced in runoff water when it rains. I assume that is when many
of the studies were done. Is this correct?
The key part of your question is "good turf". If this is the case,
there is very little runoff, that runoff water contains no soil, and the amount
of P is very small. Unfortunately, when research is done by non-university
people, they're looking at some very low quality lawns and find a lot of
sediment in the runoff water. In that case, the amount of P in the runoff water
is much higher. In one well publicized
I assume there is no
quantitative research measuring how much phosphorus leaches from dead grass
plants and is carried in soil particles from good turf when it is dormant
especially from March 1 to May 1? If there is
what does it show in amounts of phosphorus is leached
per acre or thousand square feet. I collected grass from the field and
leached it with the equivalent of one inch of rain, both when it was fresh, and
the air-dried or frozen and the air-dried. The percent P in the grass that was
leached out was only 4% in the fresh tissue, but increased to nearly 30% when
frozen and dried. I then calculated the potential contribution of the grass
itself to the amount of P I was finding in runoff water. Even with only 4%
water solubility in the fresh tissue, the amount leached exceeded the amount of
P found in the runoff water from an entire growing season. The amount of P
leached from the frozen and dried grass was 2 to 3 times greater than the
amount of P I measured in runoff during the winter and early spring. By the
way, over 6 years about 80% of the P in runoff water occurred when the soil was
frozen.
When soil test recommendations
are developed do they assume normal soil structure, adequate amounts of water
and a 6 to 12 inch rooting depth for turf? When we make recommendations
based on soil tests, we have no option but to assume proper maintenance
practices and no conditions that seriously limit growth.
I have enough of a soils and
turf background to understand that even at relatively high levels phosphorus is
not readily available to plants as it is bound to soil particles especially in
our heavy clay soils. This is true, but P extractants are designed to remove
only that P that is truly plant available. Many people seem to
assume that the soil tests are unreliable in certain situations. This is not
true.
I also know that over a very
long time just like Prairies if you keep putting the clippings back you will
actually create very nice soil structure as long as you do not kill the
earthworms and like prairies had very little run off.
I think what people fail to
realize is that in all developments the water is designed to run away from the
house. We are getting a tremendous amount of water carrying phosphorus
and other nutrients especially in the spring when turf is not growing into our
storm water system. Our lawns are not designed to soak and hold all the
water falling on the property like the prairies of old did. Because of
this if we do not apply phosphorus it will run out even when the clippings are
returned. If we do not apply phosphorus the grass just will thin out
further and we will get even more phosphorus and sediment in our lakes.
How do we get this point across to our officials? I wish I had the answer to
this. You are absolutely right that the big issue is the volume of runoff in
urban areas where up to 65% consists of impervious surfaces. Lawns can help
reduce this volume if they are properly managed. After looking at a lot
of research, I'm convinced that improving the quality of lawns would reduce the
P loading of our surface waters far more than regulation of fertilizer P. But
that's a slow, educational process and politicians are under pressure to come
up with a quick fix that doesn't cost anything. Thus, they pounce on P use
regulation and convince the public that this is the answer. I challenge them to
hire someone to monitor the volumes and P concentrations of runoff water and
prove that implementation of P use regulations is effective. I'm sending you an
article I wrote on this issue. Share it with anyone you wish, but I seriously
doubt that it will do any good. There is one success story I can report to you.
After examining the issue carefully, city officials in Sturgeon Bay recently
decided not to regulate P application on lawns
God Bless
Edward Knapton
President Berry Hill Farms, Inc. DBA Americas Best Flowers Garden Center
4311 Vilas Hope Road
Cottage Grove, WI 53527
608-222-2269 Fax 608-222-1234 Cell 608-698-5627
ed@americasbestflowers.com
www.americasbestflowers.com
Also President of The Commercial Flower Growers of Wisconsin
www.cfgw.org
Further comments provided:
I just beg you to use a little common sense in this issue of phosphorus.
Farmers are spreading less and less manure. There are less and less farmers. Fertilizer has become so expensive that almost every field is tested and just enough fertilizer is put on for the crop being grown. Almost all farmers have gone to minimum tillage. Yet the lakes are getting worse.
Common sense would tell you it is because we are covering over more and more of the land with non-porous surfaces in Dane County. The Water going into our lakes has sediment in it because it does not have a chance to soak in. It just runs off a lot of weak lawns carrying sediment in the summer and phosphorus leachate in the spring when the ground is frozen.
How about if we fertilized the 50% of Lawns in Dane County that don’t get fertilized. If we required everyone to put one application of 27-3-3 on turf in the fall and limited the phosphorus to 3% we would help our lakes so much. We would see the results in one year. We could enact the law now and see results next year. The fall is the best time to fertilize because the roots are storing energy for next year.
In the spring and summer of 2005 the turf would be so much better all over Dane County that sediment and phosphorus going into the lakes would be so much less.
Now you are about to make phosphorus the limiting factor and even more lawns will be marginal with high sediment losses in the future.
You are living in some sort of utopia that does not exist here on earth. In the spring when the weather is nice a homeowner will say to himself. You know I should be putting some fertilizer on the lawn today. Perhaps I’ll run down to Farm and Fleet and pick up a bag or two. You somehow seem to think a home owner will take a soil test when his lawn looks a little down and out. I know enough about customers that they will just apply more nitrogen fertilizer without phosphorus and it will do no good since phosphorus will now have become the limiting factor. Now even more sediment which has even more phosphorus in it than the leachate in the spring will go into the lakes.
Consumers will not take a soil test and then wait two weeks for the results before they can buy the fertilizer they need. I am not sure they will spend the $30 on the tests plus shipping. You normally need two. One in the front and one in the back. It normally takes about two hours to take two good soil tests and to take or send the samples off. If I am not mistaken the extension office is closed on Saturdays and Sundays and usually closes at 4:30 PM. Most home owners could not bring it to an extension office.
One final note. I can understand cigarettes, alcohol, and gun restrictions on retailers. I am not quite sure that phosphorus is in the same league. I would simplify things and just say they cannot display Lawn fertilizer that has over 3% P2O5 or sell lawn fertilizer over 3% without a soil test. Why make the law more complicated.
Further comments and discussions:
Just a few points. I am a farm boy who has been here all my life. I am a fairly well educated farm boy with over 200 college credits with a degree in horticulture so I do know a few things about growing plants.
You have 46 pages of testimony in the Lakes and Watershed report.
My analysis. Limnologists say we are getting phosphorus into our lakes. I agree.
The turf people say phosphorus is not coming from good turf in the summer. I agree.
The turf people say phosphorus will become a limiting factor for good turf growth in time if no phosphorus is added. 3 to 5 years on high phosphorus soils if clippings are removed according to Stier I agree.
Everyone agrees that great turf is the best way to stop sediment and phosphorus from getting into our lakes.
So where the heck is all this phosphorus coming from. 50% of the turf area in Dane County is not fertilized. It allows a significant amount of sediment which carries phosphorus into our lakes. There is also phosphorus coming out of turf in the spring as it is leached out of dead turf tissue and is not allowed to soak in the frozen ground.
I am not quite sure why we want zero phosphorus. Since we already have 50% bad lawns why do you want the other 50% to become bad by limiting phosphorus.
I also think you are dreaming if you think home owners are going to pay 30 dollars for two soil tests since they need one for the back and front lawns and then wait the normal time of two weeks for the results before they buy the fertilizer.
How about a tax credit for people who fertilize their lawns. I always like carrots before we use sticks.
I also am not sure why, if we are concerned about our lakes, we are pushing organics since they will put even more phosphorus in our lakes.
Further discussions:
Just for everyone's information limnology is the scientific study of physical, chemical, meteorological, and biological conditions in fresh waters esp. of ponds and lakes.
Horticulture is the science and art of growing fruits, vegetables, flowers, and other ornamental plants. Turf and nursery plants are classified as ornamental plants and are studied at UW Madison in the Department of Horticulture. We have a world renowned turf research facility on Madison's West Side, the O. J. Noor center. The Doctors that do the research and run this facility are not in favor of this ordinance. I have Dr. Kussow's and Dr. Stier's comments posted/linked above on the web site.
Comments about Mr. Barten's power point presentation. His power point presentation. First of all he does not have a master's degree. He does not have a Doctorate Degree so I do not know why we are calling him an expert. He pushed to get 3% and 0% in Minn. His talk was the kickoff to leading the charge here for 0%.
On the handout he gave he showed Nitrogen runoff going up when phosphorus was left out. High phosphorus grows more algae but higher nitrogen in our lakes leads to more nitrogen in our ground water and more problems with our children.
The other item in the slide show was that in a golf course that stopped using phosphorus in the fertilization program. In one year and 3 months later phosphorus began to go up again in the runoff. The grass was beginning to thin out that quickly.
I wonder why we are not using all his data but just selecting out what we want to hear.
Ordinance adopted by County of Dane
God Bless
Your active enviromentalists!
Trying to make the world a little prettier everyday.
Edward and Carol Knapton