MSU Extension Irrigation

 Six sessions that we started back in July. It was geared up for producers and suppliers that were interested in talking about some basic aspects of irrigation, not only for field crops, but also some of the trickle in vegetables and fruit and ornamentals that are out there. So today the last session we're talking a little bit about registration and reporting, along with some energy efficiency discussions that are there. And we're going to start off in just a minute with a little bit of a review of irrigation scheduling and sort of how to end up the year. And talk a little bit about rainfall. Michigan being, Michigan and Indiana being supplemental irrigation states where about two-thirds of our water comes in the form of rainfall. Some of that comes is stored in the soil root zone system and we make use of it. And as we end up the year, It's, the question is always, how to make best use of that resource that's stored in the soil but not reduce the crops grow. We'll get there in a second. And Betsy does it  look like I should give them a few seconds longer to get in or I would say let's go ahead and get started. Okay. So my name is Lyndon Kelley, I work for Michigan State University and Purdue Extension as an irrigation educator. Today I have with us Andy LeBaron from Michigan Department, sorry MDARD,  Michigan Department of Ag. He'll help us with that. The whole acronym when he gets up here. He's going to be talking about registration, Then, Dr. Younsuk Dong. He's going to be talking about some energy efficiency issues that are there. Somewhere in between. I'm going to do a little bit of an opener about water rights and registration and Michigan and Indiana. But let's get started with a discussion of just where we got what we got for water this last week, and how we may need to finish up the season as far as irrigation. This is being recorded and we're hoping that the recordings go further than the actual number of people that join live. Remember, if you're participating live and you have questions to type those into the chat and Eric or . Or it looks like Bruce  Mackellar's with us monitoring that chat to get those questions to us. So please, questions go in the chat. If you don't get that done, have questions afterwards, our information's up several places here as we move along to get a hold of us by email or other means. And I'm trying to move to next slide. So we got a little rainfall in some areas last week. And in a lot of areas, it doesn't take much rainfall to finish up the crop. So when we look at that rainfall that came in, a quarter-inch for the majority of the irrigated area in Michigan, some places getting a half to an inch. So it really points out the variability. That's why we can't say everybody needs an inch of water this week through irrigation because some of you got it from natural rainfall and some of you didn't  depending on how things worked out in your area, and it also depends on what your crops look like for the year. If we'd said, well, what's a crop using? Well, we've went over this a couple of other times too, but we use a reference ET and that's the evapotranspiration. That's the amount of water that would leave the soil surface and the crop. The crop production factor as far as using water, so evapotranspiration and that we use as a reference number for six inch grass. That's the amount that's six inch grass would have used last week and that we use a crop coefficient on top of that. So there's several places at Michigan State University, we can have that number texted to you. We have some up here a picture of the federal site that gives us  evapotranspiration numbers by either daily or here we have weekly numbers and we have just a little over an inch for most of Michigan and Indiana from last year, really down about 50 percent from a month ago. To convert that inch to an actual crop use that you had. We use that K sub C, They are the crop coefficient. And up here we got an example of corn coming off of an MSU fact sheet that we have available. We take that reference ET we got from the last chart, times the crop coefficient. And if we think about corn, that's about half milk line, we're using about 80% or eight-tenths of the reference ET number. That brings us down to about nine tenths. So that's what you needed last week to be able to say that my crop was fed by rainfall was nine-tenths. And so you either, if you did get enough rainfall, then you subtracted. Rainfall you got from the nine-tenths and added the difference. Or we're close enough to the end, that in some cases you may have enough soil moisture reserves to be able to tap into those and that's a discussion about irrigation scheduling. And we have information available about irrigation scheduling tools and irrigation scheduling methods. A lot of corn is not using the total amount of water because of some disease issues, tar spot that we have and maybe Bruce will chime in later if we have some time about tar spot and early death that's going on, we actually see some corn being harvested because of that tar spot issue, that's there. And then soybeans, it's a little more likelihood that you'll be watering soybeans to the end, especially since we have some, some second crop soybeans that are still green. If you're soybeans are nearing yellow. 50 percent yellow is the line where we, most of us decide that it's not worth watering anymore, but we want to keep soil moisture up to 50 percent of available to the plant up to that point where the field is 50 percent yellow, lot of 50 percents there. The K sub c for soybeans, little higher, one right up to the end. So we're going to need 1.1 inches. So it's a little more likely that you would have to apply irrigation water this week to be able to keep those crops adequately watered right up to the end. So that's a review of where we're at as far as irrigation scheduling. You have any questions, please put them in the chat or , get a hold of us after the meeting and we can go from there. Next up is Dr. Younsuk Dong out of the Michigan State University Biosystems Ag Engineering. He's the state irrigation specialist and he's going to talk to us a little about irrigation energy efficiency. Alright, Well, thank you Lyndon. so those of you who are new to this irrigation webinar series, we have, we have been posting all all the previous talks on the MSU BAE irrigation website so I know Betsy  shared the link. So please check  the website to see all our previous presentations. Thanks for thanks for that. Thanks for thanks for that. Thanks for thanks for that. Thanks for thanks for that. So overall in irrigated agriculture production, your water and energy are the primary consideration. So what I'm going to talk about, not only the ways to improve energy efficiency, but also the water efficiency because, you know, the improving water use efficiency directly relate to their energy use efficiency. So here's some background information about energy in agriculture irrigation. So the energy for water pumping is the largest contribution in irrigated agriculture system. In USDA Census of Agriculture in 2018 state that the total energy expense for irrigation pump in US exceeded $2.4 billion per year. Here in Michigan in 2018, their irrigation energy expense was $21 million. The irrigation energy use, it really varies depending greatly on the climate. So in 2002 and  2012 remember those, that those years were really dry. The drought in the US caused the irrigation energy, and water use to increase by 30 percent. So what energy source do we use for irrigation? The three main energy source for irrigation system are the natural gas, diesel, and electricity. In the past, the natural gas was the leading source. So, but, but however, since 2005, the use of natural gas for  irrigation pump has been decrease. The use of electricity has become more common in US, which contributes approximately 75% of energy source for irrigation pump. The one on the primary reason why electricity bill became common source for irrigation is that electric, electric power is the least expensive energy source for irrigation. The 2018, the Census of Agriculture shows the electric, electricity energy expense for irrigation pump in US exceed 1.8 billion per year. Here in Michigan, the electricity energy expense for water pumping in 2018 was $60 million. So how can we improve and reduce, manage cost? So this is the Lyndon Kelley He prepared this slide for for this. And the first option is choosing the most cost effective energy source. Lyndon did a cost comparison for different energy source among the gasoline and diesel, the propane, or natural gas, and electricity. And this is listed from, from the high cost to low cost for each category here. But overall, what we see from here is the electricity is the most cost effective. The energy source for irrigation  water pumping. So the second, second thing we can consider is to change the the sprinkler system. changes sprinkler system. So if you have a high pressure speaker system here, consider to the change it to the low pressure sprinkler system, the USDA NRCS they estimate that this changing from high pressure to low pressure, you can save about $55 or the 770 kilowatt hour per acre annually. They estimate, uh, if, if if we change all the medium and high pressure sprinkler system in US to low pressure, it could reduce  the energy cost up to a $100 million annually. So consider if you have a high pressure sprinkler system, consider changing to the low pressure. So improving water use efficiency is directly related to improving energy efficiency. So I'm going to talk about couple things, what we can do with water use. So when you irrigate, we stress to apply an, adequate amount of irrigation to the soil. And, and make sure we only wet the root zone. And not below the root zone, which is over irrigation. And make sure we, we irrigate  large enough to minimize the number of times the wetting the crop and soil surface. Because some portion of water every time you apply, especially overhead, overhead irrigation system, some of water will be just will be just evaporated. And I like and think, oh, we talked about earlier webinar series. The more, the more frequent the wetting event, um, which, which also irrigation is one of contribution, can increase the disease pressure. So that's another consideration why we like to apply large enough but large, large applications every time you water. The lastly, apply the large application while avoiding runoff. So, so the runoff is that we really dislike to see. So in order to avoid that, first, we have to know what the soil type of your field is. So it's very important to know the soil type. And, and we have an infiltration typical value for infiltration rate in our website. So please check our website or you can just email me and I can provide the what's typically infiltration  rate values for each soil type. So the infiltration rate for finer textured soil is a lot slower than the coarse textured soil. So, so think about and consider your soil type when you apply water. The, so this is the, the EnviroWeather website, so the weather based scheduling tool is, is one of thing that you can use to determine how much water you could apply, when to apply. So the MSU EnviroWeather, program has over a 100 weather stations throughout Michigan, some in Wisconsin, as well. But every station that they provide a, a daily reference evapotranspiration values. So what this, what this means, we can use how much water lose from the field. This, there's simple equation we can, we can, we can use to calculate depending on what you're growing. So a corn soybean, they all have different crop coefficient. That they require multiply by this daily reference evaptranspiration value But, uh, you can calculate how much wire is, is losing on from your field. And you can kinda sum the weekly, daily evapotranspiration value. And then you can just refill that amount on to the field. So that's one way we can do. EnviroWeather they, they, they, they provide the text service. So the user can select to have these alerts sent by text or e-mail. And they can alert from multiple Enviro Weather stations. So if you have multiple fields from different counties or in different areas, you can set it on getting the daily evapotranspiration value from different weather stations. This tool is used that can contain the current evapotranspiration and also forecast weather forecast evapotranspiration value. So, so you can predict what's next five days, how much water will be lose. So those information is really helpful to you to schedule your irrigation on the practice. So another method is the MSU irrigation scheduling tool this is the Excel, excel version of irrigation scheduling tool. That if you are familiar with Microsoft Excel, you can use this. And it's fairly straightforward to use it. And it requires some of information like soil type, crop type, emergent stage, planing dates, and you can choose the Weather Station, MSU Weather Station, and it will automatically downloads rainfall evapotranspiration for you. And the right chart there shows. The pink line, pink dots are where your, where your your moisture level of your from your field. So this can track whether you over irrigated or, or you're at the stress level. So for example here the blue, which is full water-holding line, and the brown is the is where we like to be. Your lowest level that  we like to be at. So between the blue and the brown is what the ideal on the moisture level for your crops. So this really help you tracked on the moisture level of your field to maximize your crop production. The next, the scheduling tool, we, we use a sensor. So this why we been lately using for a lot of field in Michigan for our outreach activities. This soil moisture is basically estimate how much moisture in your soil. And it can tell you. It can help you determine how much water you could apply it to this field. And also timing. So these are just the general the the typical soil moisture sensor that we use for for our average activities. The water benefit here is the top is the graph that shows this is from, I think one of vegetable field. He apply water every morning. The blue, the green, the green line represents from within the root zone. And the brown is below the root zone. So he apply he applied irrigation same amount over time. And what we, what we saw from this field, the brown which is below the root zone. Every time you apply, it spikes. That means that the he's been putting water little much then what we he was supposed to be, what what the optimal amount. So so the bottom the graph shows green is spike because within the root zone  after irrigation, you know, the, the moisture level goes up and down below. But the below roots and the brown one is it didn't spike, it didn't respond so that this tells that he spent now he he had just the right amount for his field. So, so now we don't see over irrigation. So this is one of the example to use a sensor to improve irrigation water use efficiency. This one where we were lately working on last year and this year, using real time sensor technology to, to understand where the moisture levels then and, and help the, help the farmer is to, when to apply the irrigation. So this example we are, so we've been working on a technology called LOCOMOS, the low cost sensor technology that can automatically collect the sens, the input, the sensor data like soil condition and environmental condition and send it to the cloud server and we share the data. So in the middle there, that's the website that we've been sharing with the farmers. And the gauge there, it shows the timing. So the the MSU scheduler has the, the, the pink dot that shows up and down. So this is another way that we represent. So at this point right now, from this example, the moisture level is about 80%, so he is pretty good. But, and the right, That's how much he could apply to this field. If some for for some reason, if you have to water today because because other factors, if he could apply point about 0.6 inch of water, that will not push the water below the root zone. So that will minimize, over irrigation. But, but that's what we've been working on. And the right right there figure shows the app that the funded by MSU Innovation Center. I'm just happy that have to share with you that I just got it first version of the app, so I've been testing it. So hopefully we can share some of the prototypes in later and maybe in winter or next year. So the last thing is pressure monitoring So the pressure is very important. The promitor that shows or they can first, they can show you when the irrigation was at enough We, we installed this pressure sensor on one of the pivots. We can clearly see when the irrigation was at enough. So at the bottom chart is the y-axis, the pressure and the access date. And we can clearly see what the pressure is. The, another thing, another good information is we can Monitor,  to make sure if the pivot the pivot system it is is maintaining the right pressure, right? If it's not, then maybe there is something leaking or maybe it's somewhere on the sprinkler system. So this is good indicator and good information too. To check, to check your pivots. So this is what we done What we did this year. We used the pressure sensor we connect to the LOCOMOS and we've been getting this pressure data in real time. So, so with that, I, I, I briefly touch about some of the energy use efficiency. And, and, and I want to mention if you, if we can improve water use efficiency, I think that it has a very strong relationship with the energy use efficiency. So if you have any questions, please email me or, or you can leave it in the chat. Thank you. Great Younsuk. So that I think that puts me up next to do a little bit of background registration and reporting rules in Michigan. So now you got me in presentation. Okay. So Andy LeBaron from MDARD is going to talk in So Andy LeBaron from MDARD is going to talk in a few minutes about site-specific review system. That is the alternative you use if you can't get a registration online. I'm going to do a little bit of background real quick to do that. First slide has my phone numbers and email in case you need to get a hold of me. First thing we need to realize is that irrigation takes a lot of water. When we're looking at field crop irrigation, we'd need something around five gallons a minute per acre. That will be the capacity to put an inch on every four days, which almost keeps up with evapotranspiration, the numbers we've talked about. So a 100 acre field's going to need a 500 maker pump.   Our common 160 acre field's going to need more like a 750 gallon a minute pump to be able to have enough pumping capacity to keep up with ET. There are much smaller systems. When we look at horticultural, vegetable production, ornamental production that don't need that big a pump. A big number. or the important number here is 70 gallons a minute. If we're over 70 gallons a minute in either Michigan or Indiana, there's extra requirements that we need to meet as far as registration and reporting. When we say, well, trickle irrigation, we need less. But also in the fruit and vegetables, it's pretty common to have some frost protection available. And that takes a huge amount of water to be able to do frost protection. So we may end up in there. Before we get into registration and reporting, We do have some older rules back there we need to think about, since Michigan has been a state, we've had something that we call the riparian doctrine. This is a public trust doctrine. It's basically all the appellate level rule rulings that have happened in Michigan's courts from the inception, right around the turn of the century on, used to be 72. We're right at that number, most of them in the forties and fifties. Those appellant rather rulings or higher, are looked at is what we call a doctrine, sort of though what has been the common decision based on these things. And the important thing here is that east of the Mississippi, most of the states or all of the states are following some form of riparian doctrine. West of the Mississippi, it's first in use or the prior appropriations out there. We have a lot more lawyers that work on those things and you actually have special courts that work on water rights. And you can sell water rights just like we think about selling our oil or gas production rights here in Michigan. Riparian means next to the water in Latin. And it's important to remember that if we're talking about surface water, we have a restriction that keeps you only using the water on the land that is truly riparian next to the water. So if your deed does not have the edge of the water to it, it is a violation of that. And that would take someone that has a loss to be able to sue you in court but we've had that happen in Michigan, and it's one of the few ways that you can get an instant shut down in Michigan. Indiana follows the same rules in as far as their determinations also. When we talked about few days, a few sessions ago, we talked about planning. The important thing is to remember 70 gallons a minute. At 70 gallons a minute in Indiana, your called as significant water user. In Michigan, your called a large volume user in both states at that point you have to do registration and reporting. In Michigan. We're going to do the registration through something called the MIWWAT tool. That's where we're going next. Michigan water withdrawal assessment tool. And what we're looking for is no adverse resource impact. Indiana's using that same standard of no adverse resource impact. But it's interpreted in a different way in both states as the reporting requirement, if you have a registration, you're going to need to report, you're using more than 70 gallons a minute, you're going to need to report. We also want to mention that both states have almost identical rules in place that if you have a large volume well greater than 70 gallons a minute, and you're affecting a small well less than 70 gallons a minute, that that small well owner has the right to be made whole or for compensation to bring back his water. He cannot say you cannot use the irrigation water, but the irrigators going to have to pay the cost to make him whole to bring his water back to the quantity and quality that it was before. So there's the actual, Both states have a 1-800 a number to call. If, if you're in a position where you feel a large well, your owner has reduced your right to using that water. Indiana has a few specific laws. Actually, Indiana has more specific laws on water use. Those large quantities facilities. If you're in Indiana, you want to read through those before you start using either surface water or groundwater, and make sure that you understand that under these circumstances, the state of Indiana can reduce your water use or shut you down. So the the registration one is under code 14-25-7. It's called the Water Resource Management Act. It's been in place about 10 years longer than Michigan's had it's system in place. Michigan system came in in 2006 and through 2008 and they've gone in   sooner. They had quite a turmoil in, in the late seventies, eighties over some large farms that were using irrigation water and dried-up community wells and the homeowner wells. And that resulted in the water rights or the emergency regulation statute in Indiana. Andit put in place their groundwater conflict rules that we just seen. It also gave them the ability to shut down wells that were reducing the effectiveness or the use of municipal wells. They also have a law on surface water rights that protects like levels. And if you're within a mile and a half of a lake that has a level that is determined to be reduced because of your pumping. Can actually shut down irrigation uses. Now in Indiana, most of this is, has a warning system. Groups are, pulled together at the state level, when we get through a drought. Last time we worked on those types of issues. In 2012, there was some interest in those forming those groups in June of this year but we got enough rainfall that that's sort of what well, the discussion. All of these things in Indiana, Registration, Reporting and any of the compliance with these laws. You can talk to the Indiana DNR Water Division and Mark Basch, and Allison Mann are just excellent at helping people get registered. You have a water withdrawal greater than 70 gallons a minute or are planning one called Mark or Allison. And they will register you over the phone. They will send you the documents and they'll get you lined up to do the water use reporting. So that's about what we have on Indiana. In Michigan we started our registration system from 2006. and then further legislation in 2008. It required a permit for over 2 million gallons. Most irrigators do not have that 2 million gallons a day or of pumping capacity. And then there's also restrict an interpretation that that's a 30-day average of water use. So very, very few of our irrigators ever come close to that 2 million gallons per day per site. So we're at the point where we have to register because we're over the 70 gallons a minute, which is a 100 thousand gallons a day, but we're below the permitting requirement. Andy may talk a little bit more about permits as a way to deal with some other issues. So we need to report and register those systems. If just real quick on reporting for irrigators, we see the most common system is in acre inches. That means the producer records how many times he put on a given amount of water in a month and then totals that up. If you want to convert from acre inches to gallons, the numbers down there in the red box, that conversion number. But the reporting system will let you report and either gallons or acre inches and make sure you're looking at acre inches. Out west they talk about acre feet, a number 12 times larger. There are some industry average numbers. The only time we find that a viable system to use is in the greenhouse industry, where they know a certain amount of water is taken to grow plants to six weeks. Those types of numbers there. Real common is pump capacity times runtime. So just a simple Runtime timer on the electronic device. You have to of course read that on a monthly basis and then multiply by the capacity of that pump to get that type of number. And then flow meters are the least common system. Flow meters  may remember you need to recheck that flow meter and recalibrate each year. And you're going to need to read it at the beginning of the season and at the 30th of each month. And then take off the difference between them. They're usually accumulative systems. As far water  use reporting? Michigan has an online system that's currently being revised right now. But you will see if you have a registration, a letter come in the mail talking to you about the new reporting online system, hopefully between Thanksgiving and Christmas. In Indiana. if you filed that registration, they're going to mail you a personalized letter saying, here's your registration. Here's the amount of water use you had last year by the month. And you fill in the amount of water that you used this year. And you can then do that either right on the form and return it. Or you can go to a reporting website that they have set up and it gives you a specific link that takes you right into the reporting at your site. We need to move on to registration in Michigan. We have a standard of no adverse resource impact. We've defined that as far as that we cannot pull enough water out of the stream that we change the characteristic fish population. If we did that. The next course within the law is establishment or water user committee. We've not done that here at Michigan yet. We have not formed a water users committee. And that's probably important, especially as we lead into this site-specific review document. There is some teeth in that law, $10 thousand a day fine. And then also and that's if you knowingly cause an adverse resource impact from the large quantity of water withdrawal. And also, the Attorney General can recover the full value of the cost of any surveillance and surveillance or enforcement action by the state. So it can be very costly if you violate this rule. I'm going to quickly run through the MIWWAT basics, Most of you in the state are going to be able to get the registration through a computer tool called MIWWAT, Michigan water withdrawal assessment. It looks like this. I'll have I think the next slide up, I'll have the link to it. When you get to it, it's going to ask you, are you a new withdraw or an old withdraw. It's going to get you to the location here. I've put in that GPS location that I scoped it out with a well driller and said, Hey, this is looks like the right site to try. I'm going to open that map and I'm going to hit a little button at the top up there that says it actually changes and I can get an aerial view. There's couple of important things. You can see the boundary of your watershed. In theory, all the rainfall that, that flows through the surface or infiltrates into the ground water will end up flowing towards that stream. And so that's the Watershed Boundary That's important to know. Notice Dowagiac River here as outlined in blue. And then we put in our proposed website, route and well site. And then the website that we talked about here is for the Michigan water withdrawal assessment tool. Once I've put that in and hit the little button over here that says new withdraw. It pulls up a screen that says how much water do you want at that site? So this is a site that they're looking at, irrigating about 10 acres of vegetables with trickle irrigation and a little bit of frost protection. So he says we need 360 gallons a minute. The producer that's working there, it automatically filled in the site. When I hit the button at that location, I go in and say, Okay, in this area, I want to glacier well that meets the screen well in the gravel adn and sand underneath. And they give us some really helpful information. Some really helpful information. And this stats location box about our depth of well, I'm going to be a hair, hair deeper than most of those and this is the top of the screen. At that point. I'm going to tell them how often I'm going to pump. So I want to be able to pump the five months from May through September. I'm going to pump 24 hours a day, seven days a week. Okay. I hit the run the model, and it tells the computer to go through and do those calculations. And I get back in this location like like most of the state an automatic yes. Go through and they'll go forward. If I did not get a yes, there's a few things I could do. Let's first go through and say, well first, I can view a report. I can take that, hit that view the report button and it will tell me the specifics of what I put in. And it will also tell me I keep the wrong button. It will also tell me the amount of water that's being debited from the account. So it's like a big checking account its saying, this much of the water would have been taken from that watershed. So 66 gallons per minute is coming out of that stream. That would have went to that stream from my well. If you didn't get a yes, We were down here on the C location. We would rerun the report and we would we could either lower the well, we could move the well further from the stream or ditch  or river or lake. We can cut our pumping time within reason, remember, you are establishing the maximum amount of water that you can be using from this site. Or we may be able to trade some capacity from other registered withdrawals that we have control on. If you were originally trying a surface water withdrawal, remember that wells have a much lower impact number. Much more likely that you'll get a well than a surface withdrawal. If I have everything the way I want, I can hit register now and put in my name and it will print you. you a document with a registration number that you can take to your well driller and move forward with. Now, what we want to do is go to a different situation. So I went to a, to a stream, a watershed that I knew I would not pass in. And I filled out the same information. I just moved the location. And this is this is an area very close to Cass County and Van Buren County. And I get a fail. At that point, I got some options. We could have tried to maneuver through the system, but this this watershed is over drafted. So it's not going to be something that I can get a low enough make my impact from that well, actually low enough to get a pass. So I'm going to need to go through a site-specific review system. And that's the information that we're going to need to fill out. What happens at that point is that that site-specific review information goes to EGLE, Andy's department and he's going to deal with that in this next presentation. Right, Andy. That's right. So that's the place that we get Andy up and he tells us the site-specific review, what to go from. Is there anything they need to know that I missed in the first discussion? No, I don't think so. They covered it well, there I'm just going to expand a little bit exactly on what happens, I guess during a site specific review or what options may be available for you at that point, but no I think you hit it good there Lyndon. Ok, go for it All right. Very good. So good afternoon, everyone. I really thank you for being here. I'm I'm pretty thrilled to have this opportunity actually, you know, just to be able to provide some info straight from the horse's mouth here from Michigan's water use program. You know, honestly because where we sit we hear all kinds of false rumors and myths and misinformation that, that kinda circulates about, you know, to be honest with you in the agriculture community, in specific, we hear a lot of things that just aren't quite right and I'd love to be able to set some records straight and make sure you're getting the best information out there for you. So the first thing with that in mind, you know, the first thing I want to say is just please do feel free to call if you have any questions or concerns or whatever, you know, call me or call any of my co-workers in EGLE. If you ever have something that comes up or if you heard, you've heard something that sounds like EGLEs doing something stupid or we're awful or whatever, just just give me a call, give me a chance to either prove that wrong or if we are doing something stupid or awful, you know, maybe we can fix it. You let, let us know, just just kinda give us a chance. feel free to feel free to call anytime. If you do, I do promise you're going to get an honest,  straight answer. You know, our, our goal truthfully is really to to help you do what you want to do on your property. But at the same time, of course, making sure you don't get crossways with the law at all. Yeah, that's that's that's what our job is really. Our job is not to be the police or anything like that. As Lyndon mentioned, there's some enforcement teeth that might have come along with that. We really, really try hard not to not to go that route. I think any of you out there have ever worked with us all. You might be able to vouch for that. So yeah, we kind of are I really do see our role here is just really trying to help out property owners do what they wanna do. Um, I understand that sounds a lot like Ronald Reagan's famous nine most terrifying words of any American or whatever. But, but I can, I can promise you if if you don't think that our staff is really here to help, you either never worked with us or are you probably just have been lied to by someone? I really I really think we do a pretty good job, honestly. So so we do have to uphold the law course. That that's all that's why we're here. I guess our job is to uphold that law. We don't have any choice in that matter. We don't bend it, don't break it. We just that's just what you do is just kind of no negotiation there for the most part and tell you they say we don't bend it, but we we do our best to work our way through it, right? We certainly do. So thanks for this. . So that kinda introduced us there. And move on. Now you can what we do when a site-specific is your state specific review is required for your for your new withdrawn, which you'd like to do. Just a couple quick reminders. Some of this is a quick reiteration of what Lyndon said. But you know a registration that we keep talking about, that is just like a permit like in effect, it's it's a legal authorization to make a withdrawal, make a specified withdrawal you kinda get a registration supposed to match what you're going to do. It's a legal authorization to to do that. Any new pumps or  increased size pumps. So even if there was an old pump there, but you're increasing the size to something bigger now? Um, if the increase is 70 gallons per minute. Also, then that needs to be registered. Or if there's previously an unreported or unregistered pumps, you know, we we know those exist out there. We kind of find them every day in the course doing our work. Pretty much pumps that have just been operating, but maybe never never reported to MDARD their annual water use or never registered the withdraw. The sooner the better you know, get those things registered soon is better, hopefully we can get it in for you, get it registered in those those are also required. So we issue and deny these registrations EGLE does, based solely on stream impacts. So what's the predicted impact on nearby streams going to be from operating that withdrawal or operating that pump. That's the only criteria that we base these decisions on. So yeah, once once more, just just keep in mind, a withdrawal cannot legally be operated without a registration. So a site-specific view as is sort of the process and it's the only path to get a registration when your withdrawal doesn't pass the water withdrawal assessment tool. That's that's the that's the only next step you can take there. Um, I don't I don't like the acronym's s very much either, but but you'll commonly we heard the commonly hear these referred to as an SSR site-specific review and I may slip up today and call them that as well. Well, we talked about that when we talk about the law. So it's kind of natural that happens, but but they are required whenever that water withdrawal assessment tool. Actually, whenever a watershed, This is approaching its limit, its legal limit. And if it's doing so, the water withdrawal assessment tool is going to give you a result of a zone  C or D. Or site-specific review can also be required in zone B if you happen to be located in the the watershed of a cold transitional Stream, stream is classified as cold transitional. This four classifications, cold, cool, warm, and then this cold transitional one, the cold transitional ones, the only one that always requires a site specific view. It doesn't matter for if we're miles from an adverse resource impact line, the zone D line, it always requires a site-specific review regardless, there is no zone A in those watershed, they start out at Zone B. And so that's why sometimes you may get a Zone B result from a tool, but it'll say site-specific review is required. It's because you're located in the watershed of a of a cold transitional stream. So here's a map sort of with the current status of all watersheds in Michigan. Just like in real estate, location is kind of everything when it comes to getting your withdrawal registered, just like Lyndon showed where one spot passed, one spot doesn't it all just comes down to your location? It really comes down to what what size and type of stream do you have nearest to you? Or maybe, you know, a couple of the nearest streams are going to dictate the answer of the water withdrawal assessment tools results just kinda comes down to location there. So an SSR site-specific view is, is performed by EGLE Staff for you. What we do is pretty much just like a more sophisticated look at the withdraw and the streams in the area. More sophisticated than what the water withdrawal assessment tool can do. That's a pretty simple, basic model or what have you we do a little bit more sophisticated look at things. That's in a nutshell. That's what a site-specific review is. Not an on-site review. We're not going to show up at your door. The reason for this is the type of information that we need to do an SSR can't, can't really be collected or observed quickly or inexpensively. So we don't we don't have the funding to go out and collect any data or do much work and not much time during our site specific reviews to do that. So so it's an answer. It's such a it's a desk review, an office review, not an onsite review. It is an investigation of all the available data. You are going to run a comb through whatever is available and out there, anything that's relevant to answer that one simple question. What will be the impact on stream flow if this withdrawals operated? And the nature of the beast here is that more and more withdrawals are going to fail the water Withdrawal Assessment Tool and require site-specific view like that. The rate of that is going to increase over time. That's just, that's just how it's going to go here. That's but that's the process has been set by the legislature. So so what does EGLE do during  a site specific review once it's been requested through the through the tool through the water withdrawal assessment tool. Each review is assigned to a primary EGLE staff person. You'll get, one point of contact as your primary reviewer, all staff are trained geologists. And assuming that the request is for well, it isn't a direct intake from a lake or a stream a review by a local geology is going to be sort of the first step, the first priority in the, in the review that we do is to confirm accurate results, confirm the results of the tool. Make sure if that makes sense or not. This, this fellow here who's not actually one of our staff that you use. What he's looking at is like a shaded relief map of the surficial geology of Southwest Michigan, but but actually, you know, like a much smaller scale, site-specific data is really needed to improve their results or verify the result of the water withdrawal assessment tool. In a site specific review we need. We need a lot more  detailed information than just sort of that overall general map. So the scene here is just for demonstration, but the primary source of small scale geologic data that we have is well drilling logs that the drillers have been required to submit to the state since 1967. Most of those logs are obviously for household wells, but they do have valuable geologic information. They might vary in their, in their accuracy or, or the detail that a driller might put on those laws. But they all, even least least detailed log, will have some valuable geologic data in it. That's a requirement that they have to they have to record that and submit to the state. Been that way for a long time, The stream flow estimates for each impact the stream is also confirmed. I'm obviously there there isn't streamflow estimate in the water withdrawal assessment tool. Originally, we take a closer look to confirm that we might use any USGS, like a stream gage that continuously record stream flow. There's not very many of those out there. We would certainly use that if there's one available or any any manual instrument measurements that we take. Our staff takes while standing right in the stream. We might use those too. However, like a small number of measurements, just a few of them over time, any point in time or are kind of a very limited usefulness to us, at least in the  near term. It's not like we can run out and take a measurement and then, and then come up with a better stream for us. And that immediately it takes a long-term stream flow record to be able to to be able to make sure we've got a good one. We don't want stream flow, we don't want to base our decision based on streamflow that's so highly subject to recent rainfall and  weather patterns. Then the next step that we do each time is to, is to confirm whether the best model is being used to compute streamflow depletion. Your model is just essentially math, like a complex mathematical equation. The water withdrawal assessment tool uses one such equation. But if the local geology dictates that a different equation might be a better fit for that site. We'll we'll rerun the withdrawal during the site  specific review using an appropriate model, using a more appropriate model most of the time. The stock water withdrawal assessment tool model is the best fit for most of the geologic settings where agricultural irrigation takes place in Michigan most of time that's, that's the right one to use. Another thing we do is, is, is the water withdrawal assessment tool assumes that no water is getting back to the aquifer or to that watershed after it's been used. It, it doesn't have any return flow factored into it on its own there. So during a site-specific view, we examined how much water might be, might be returned to the aquifer to that watershed. And we credit that amount back to the to the streams account during the site-specific. We also review all prior registrations that might have been made in that watershed or the neighboring watersheds we're confirming whether they were actually installed and constructed. Confirm whether they were constructed differently than what they registered for. Make sure those match up or if they're reporting water  use that they are they're being operated, being used significantly different than than how they registered, then we will make corrections for that also after contacting that property. So to kind of sum all this up what we're doing, it's, it's, it's all quantifiable type things. You know, a site-specific review is basically an accounting audit. You were doing an audit of that watershed. The numbers all have to add up, we're making transactions in there. So so my point here is that it's really not a subjective call, judgment call that's been made by our staff or by EGLE. It's pretty much a math based, basically accounting transactions of pluses and minuses where the currency is like like when I mentioned they are the currency of gallons per minute and streamflow. Not, not dollars of course, but if there's sufficient funds meeting sufficient water in the account, withdrawal passes to a registration, and if not, then then EGLE's required by law to deny that request. So if the SSR doesn't pass, if we come up to that point where we can't can't authorize the withdrawal. Basically, you'll need to find a way to reduce your withdrawals impact on the problem stream. Or sometimes there might be more than one stream that's, that's sort of the problem that's holding to show up. There's really no other way at this point to get a registration besides figuring out a way to reduce your withdrawals impact. Some of all these options that allow for are not possible. Some of them Lyndon already covered because you do the same thing when you're using the water withdrawal assessment tool. The first one, of course, is ridiculously obvious, and I don't want to insult anyone or patronize you, but if there's any way you can reduce the pump capacity or the duration of pumping like the pumping schedule you put in. Essentially what you're trying to do is reduce the total annual amount again, that might be registered for from that. If you can reduce that impact, that can obviously help, you know. Now another, another option you can do already mentioned is that you can move that well location if you can't move that well location further from the stream of if you can go. If there's a deeper aquifer  or deeper well, option available there. Especially if there's a lower acquifer that might be confined or isolated from the surface from surface water. That, that's a tremendous help if that's available in your area. Strongly recommend that one That's obviously a more expensive well, but it can be the difference between not getting registration or a pass. Another plan that works the same as moving a well further  from the stream is if there are streams that that are in the water withdrawal assessment tool, but in reality, they're not they don't flow year round every year. We call those intermittent streams or intermittently rolling streams. We can remove those portions of the streams from the model and then recalculate. It basically just increases your distance from the actual perennial portion of the stream. This typically requires an on-site visit during the dry low flow time of the year though to see when that stream goes dry and so it's not always readily available option there. I should have also mentioned here, I don't have on a slide, but Lyndon mentioned it. A great possibility that we do successfully use sometimes. That's trading, trading existing capacity that you might have, control of. Register capacity for whatever reason, if there's a site  where you don't need as much capacity as you have currently that's already registered. You can reduce it there, take it out of service entirely for one reason or another that you've had that happen. And then you can just trade that capacity over as long as it's within that same watershed, we can trade it over towards credit, towards the new one. It is possible that this could be done even between water users, even if it's not something you control. If you happen to know that there's a withdrawal that's registered, but it's not being used anymore. You can you can you could negotiate to have that withdrawal taken out of the system and go in it's place. Obviously, it has to be all coordinated between parties. That's a possibility also . And Lyndon mentioned the permit that that is an option that that you can do. I don't highly recommend it, to be honest with you, that the same criteria to decide on a permit is the same criteria that we use for for registration. Your site specific views you can't have you can't be in zone D, You can't be likely to cause an adverse resource impact. So the only kind of benefit, I guess that a permit might get you in and why it's kinda touted out there as an available options is if it's denied you have an administrative appeal rights. You can go to like an administrative law judge. EGLE has their own administrative law judge is not an EGLE employee, I should say. We have a couple of them. I believe they're both men. They they're they're not EGLE employees. They're, they're  judges. State of Michigan judges who decide on cases that basically decide if EGLE made the right decision or not. So I'm not, I'm not saying I don't recommend it because it wants you to challenge us. I just think if we'd gotten to that point, you know, we're we're we're probably we've turned over every rock we can. We're pretty sure that this withdrawals just not likely to pass. If you have information that suggests we've come up with wrong, a bad decision there. We can accept all that all along throughout the whole process before ever having to get to a contested case and and submitting a permit application which you can't get to a contested case administrative law judge until you have a denied permit and that permit would cost you $2 thousand on top. Just to get to that point, just to get to denial, just to be able to open up that opportunity. But we can do all that work with you, very willing to work with you and all that stuff before ever getting to that point. So no one's ever done that and I honestly wouldn't recommend we can do that free of charge. Okay, so the kind of the grand, grand finale here is, is to hire a consultant to collect hydrogeologic data. I wish EGLE had money to go out and kinda do this work for us and for for the for you, for the for the folks, property owners. You know who are having trouble getting withdrawal registered. We don't have that money available. So it's on the property owner or potentially could be a group of property owners kinda in an area go in and together, to hire to collect and procure this data. That's, that's an option. The reason you might do that, the goal is, is to try to You'd only do this if it gets believe that you're going to find significantly different data or aquifer characteristics primarily that exists locally than what we have in the water withdrawal assessment tool. And on top of that, you would have to be significantly different to, to kinda move the needle and would also have to reduce the predicted impact of withdraw on stream flow. So you, in order to go ahead and do this type of work, you'd you'd obviously have to hire a sort of a specialized consultant, a qualified professional there. Then typically the primary useful data that comes from that is it is from an opera performance test, also called  aquifer pumping or aquifer pump tests. These tests provide information about the aquifer for you including kinda like basically it's how groundwater moves and how it behaves under the stress of a pumping well. What happens in the aquifer? It's very important though to understand there's, there's just no guarantee that if you collect this data that the predicted impact of streams will be reduced after, after collecting it. In fact, the data could come back showing that there's increased impact over what the water withdrawal assessment tool model and its data has predicted. This exact scenario has happened, is it's happened before unfortunately. And it's why we strongly recommend you. Please go over a plan for data collection with with us with our staff prior to prior to paying for any work to be done. We're going to give you a good honest advice basically about how likely, the  likelihood of this test or this data collection would be to be successful. We are going to tell you what we think is possible there in whether it might be a good idea or not. We'd to have this data collected, we would if it were cheaper to do. It would be wonderful. So we can have it collected all the time. We just we really do not want to be, do not want folks to go out there and spend money that doesn't end up helping in the end, it's just, we really want to avoid that situation again, those, those couple  times in the past where it where it's happened, where it didn't help them out. You know, those those folks or their consultant didn't didn't contact us beforehand. Didn't tell us what they planned on doing. Or there was even a time or two where they did, but they didn't follow the guidance. We told them this is what we need, A, B, and C, And they they didn't do that. And so the information they collected, it just wasn't useful at all for the for the decision that we had to make. So it was very unfortunate, don't want to see that ever happen again. So speaking of hiring a consultant, you know, one thing you could do is also have the option to hire a third party to do your entire site specific review. Basically, you know instead of relying on EGLE at all. These are sometimes called alternative analyses, meaning an alternative to EGLE doing the work. I think it's clear and I prefer just kinda call them third-party site-specific reviews. It kinda gets the point across clearer I guess. This option was officially made available in 2018 by by an amendment to part 327, part 327, Michigan's water withdrawal law. The law stipulated that the work had to be done by a licensed, registered, or certified professional hydro, hydrologist, hydrogeologist, or geologist actually need those three kinds of certifications. They must submit a technical report to EGLE that fully describes their data, their analysis, and their determination of hopefully not obviously not causing an adverse  resource impact. That's what the  determination had to be in order for it to be successful, have a reason for doing it. Now, this same process, similar to what I mentioned before with a permit, this really could have been done all along. We would've accepted and work with it in anytime. But the real kicker and the reason why it was put in to this amendment is that if if EGLE can't formally respond, like acceptance or denial of the determination within 20 business days,  then the withdraw gets like de facto automatic registries. So you get your passed and within within 20 days, it's very unlikely that we're not going to be able to get a, get a formal response back to you. So we're probably going to be able to review that just for the record. But this was primarily done. The amendment was was was created in response to at one time there was very long site-specific review delays that that we were having basically just due to staff shortage, for the amount of work that was coming in. At that time, maybe it would've been a struggle to get a response back to 20 days. I certainly would admit to that. But but during that period, 2015 to 2018, we were just way way behind. It was terrible time in our programs history. And yes, that amendment, as it was it it was well-intentioned, came from a good place, you know, believe me, we were we were not happy at all with the long delays that we were that we were causing we were buried and kinda really struggled with there. We are begging for help all along, not getting it help, by help I mean, asking for additional funding to hire additional staff. We didn't get it for those years. But but in the end so I say this law was was well-intentioned stuff, but in the end it was kind of it was kind of not very well thought out. It was ill-conceived, I'd say. And it really doesn't work very well. Probably because it's, because it doesn't work very well. It really hasn't been utilized. You know, there's there's actually only been one single third-party SSR ever, ever submitted. One that was valid and could be could be reviewed. It was only the one ever it had to be denied. Unfortunately, just like a regular SSR would have been denied for that. well, it was it was for a well located extremely close to a stream that had very little water left in it in its account, legally available water, I should say. The data collected in the aquifer for test and the, and the results from using a different model just simply weren't enough to overcome those obstacles. And so the the alternative analysis, the third party SSR had to be denied also.  The only one we ever got. But on the plus, staff, through that amendment process a huge win was that we got more funding to allocated to our program, to hire more staff. We did that in short order, we eliminated that large backlog of requests. Now, all almost all reviews are completed one to two weeks. Certainly, this doesn't mean that all those requests were passed, but at least we have a resolution on all those backlog of requests and new ones are being done quickly. So with that, I'll take any questions anytime now or later of course, I'm trying to run through it there quickly and we can ran over a bit. So thanks for bearing with me. Okay, Andy. Bruce, do you have any questions that came in on the chat. I'm not seeing any right at the moment but I was looking at that too. So I think we could ask a couple then,  Lyndon if you want. Go ahead. Andy. Sort of, I the unregistered initiative was a few years ago and it was designed for people that had just, it's older withdrawals that never made it into this system. Where are we at now for people that didn't get caught up but have an older withdrawal? Yeah. Okay. Yeah. So that that unreported initiative that we ran, I think it was probably 2017, 2018, 2019. I think 2018, 2019. Somewhere in that range. We we tried to advertise that to to to entice folks to to kinda step up and provide the information that shows they had these these withdrawals that had been out there in existence and operation but had never reported or egistered and that that has concluded. There will not be another similar initiative ever in the future. I will say that the the even the initiative that we ran from 2018 to 2019 was it was illegal. It was contrary to part 327 it was we weren't there was no legal ability to do that. 327 says that if you hadn't reported or registered by a certain date, it actually happens be back in 2009, April 1st of 2009. And you don't have another chance actually, April 1st, 2009 was a third chance that folks had to kinda step up and report those older withdrawals so that that one is done. I will say however, that there is an exemption, it's not really an exemption, but there's that there's a special clause in part 327 that that that would allow for the same type of thing to be done for these unreported withdrawals if it's a well, only so, surface water withdrawals? No. There's no chance to get them other than registering them through the tool if they can pass and they get registered and they  can start there, then they're getting with the fold getting with the program. After you've been registered through the water withdrawal assessment tool. But if it can't pass, there is no there is no means for surface water withdrawal to still still come  into compliance. But a but a well, a groundwater well can if they can show they can demonstrate like beyond any doubt that this well existed doesn't even really have to be in operation, just the well had to exist. By February 28th of 2006. There's a little clause in part 327 that allows that for wells only. So we can still accept basically the same program. And in this thing that we did during the initiative where you have to show the documentation to prove the wells existence, we can still do that. And we'll always be able to do that unless the law is changed for some reason. But but that's that's where we're at. Wells still can if they can be proven, surface water cannot come come in and get in compliance without passing the water withdrawal assessment tool or site-specific review. Andy you brought up surface water and we may have neglected to talk about the difference on how impacts are measured between surface water and well water. I think I said wells have a lot less impact, but I didn't describe why. Can you take a cut at that? Yeah. Yeah. Real simply, um, the the biggest reason why wells have can have a much less impact than surface water is you get to put in pumping schedule. That's actually the biggest difference is you can. You know, that if you put in surface water withdrawal, the impact of that surface water withdrawal is basically going to be instantaneous on the stream. So if it's a 500 gallon pump water from the stream instantaneously, there's 500 gallon in theory. And it's gotta be something close to that. There's, there's 500 gallons per minute less in that stream flow as soon as the pump turns on from a, so a direct surface water withdrawal from a stream that this doesn't include from a pond or or irrigation pond or lake or anything like that. It's just, just direct from a stream. So you don't get a chance to say, but I only use the pump you know obviously during the growing season and only a certain number of hours per day, days per week. You don't have that opportunity for surface water withdrawal. It's just pump capacity, straight, straight depletion based on the gallons per minute capacity of the pump. With the well, you've got the option to put in your pumping capacity, which obviously reduces the total withdrawal significantly when it's not being run 24 hours a day, every day all year long. And then and then for sure, that another big difference is just a well, it's going to be pulling water from other places, the aquifer, the water, the  groundwater resource itself. And it can be balanced by other things besides just a direct withdraw from the stream. So there's, there's kind of that function of it there too in and we can get into details if you want, but, but that certainly reduces the impact on the stream also, if you have a very shallow well that's very close to a stream, it will eventually approximate, basically just like a surface water withdrawal. Assuming that there's there's good that the geology allows for good communication between the stream and the groundwater, which many of them do. So yeah a very shallow, very close well, if you run it continuously without a schedule, it will actually kind of act just like a surface water withdrawal, but that's that's kinda explains the differences between the two. Okay. I don't see any other questions. Please chime Bruce or Betsy, if you do. But while you're on that, it seems like over the years we've had a lot of people. I'm going to use the term trade. In other words, take their remove their surface withdrawal from a ditch or a stream and trade it for a well. Can you tell us how that's done, how the math works? Yep. Yep. For sure. So the if if they've had reported that surface water withdrawals, so you know its in the system in MDARD's reporting system. And so the good on that front, that's, that really helps. That's when you're actually going to get the most credit for your withdrawal or any credit, I probably should say, um, yes. So if it was, again, let's use the example. If it was a previous 500 gallon per minute pump, surface water withdrawal from the stream. They want to switch that out and take it over to a well, we can we can trade just like we use the same terminology. We trade that capacity, that baseline capacity, that existing reported capacity, trade it straight up, basically even get a 500 gallon per minute well, that you can operate under any schedule. There's no limitations on the scheduler. What have you you get the same equivalent amount in the capacity to trade that forward towards the new withdrawal. Even if you want to have a have a well with a larger pump, in it,  a 700 gallon per minute pump in the well. You will at that point, if you trade your 500 gallon per minute example of surface water withdrawal, then you only have to register the difference that that little that 200 gallon per minute increase difference. That's the only part that needs to be registered and pass through the the water withdrawal assessment tool or site-specific review process is just the increased amount. So we just take that capacity and trade it right over one per one gallon per gallon. Andy what about the small ponds that people are irrigating that are not on streams? Is that, how does that work? I was just curious because I know it should be should be different than pumping directly out of the stream, but I'm not sure how you guys handle it. Right. We don't treat it any differently. So that this capacity trade that we actually do is not based anything on impact to the stream. So it's kind of a this is a this is a good thing for for the property owner. I'll say You're not you're not limited on only being able to trade old withdrawal for a new and on what your impact might have been in stream flow. You basically just get the full gallon per minute pump capacity traded towards a new withdrawal straight up. So even if it's from the, from the stream or if it's from a, from an irrigation pond, anything. If it's an old well that you're taking out of service. The well is aged and no longer produces like it once did, you get that original capacity or whatever capacity you had reported? to MDARD  actually, you get that capacity even if the well is not producing that any longer, you get that reported capacity from back in, in 2009, um, you get  to trade that forward. So it, it, it kinda takes out any consideration of what's the actual impact. Andy, I think has question may ban for non-contiguous ponds. That third button up there on the MIWWAT tool. We're going to have a pond that isn't connected to a surface to surface water, waters of the state.  Is that right Bruce? Yeah. I'm just thinking about some of the smaller ponds that are particularly blueberries Andy, we got a lot of high water table spots and parts of the Van Buren and Allegan Counties where they pump for limited amounts for blueberries. Just was curious what how that how that actually works in your system? Sure, Okay. Yep. Yeah, gotcha. Yep. So that third button in the water withdrawal assessment tool for that type of scenario, you know any kind of shallow pond. Basically, I guess though it can be anything man-made or even a natural lake  that's less than five acres that would that would work for that is  kind of how it kind of what that buttons there for, what that really does is it acts just like a shallow well, you get a chance to put in the depth of the pond is, I  can't remember, if we got the term like the word changed in there, it might still say, you know, what's the depth of the withdrawal or something like that. But its basically asking what's the depth of the pond? And you're putting in a withdrawal from that pond as if it were just a very wide wide well, is kinda how it works out. So you get to put in a pumping schedule. You're not limited to just using the surface water pump, surface water from the stream, just the pump capacity. You get to put in whatever kind of pumping schedule you need. And obviously being shallow like that, it's going to have a maybe a more of an impact on surface water because it's probably tied right directly to the to the water table without much clay barrier geology between sometimes,  sometimes there might be, but if it's a clay line pond or something like that, then it's only getting surface water runoff into it and not groundwater, that would be different. But the assessment tool, when you're putting it through the assessment, it's probably not going to know, not gonna be that intelligent about things, but it is just running it just like a well, a shallow well, wide hole in the ground. with a  pumping schedule that you can put through to it. And in general, we can make kind of a reasonable assumption that a well, it's reasonably similar in size is going to be better because you're going to get draw or have less impact, less say not say better necessarily, but have less impact simply because you can place it further, potentially away from the stream and also maybe pull water from a from a deeper aquifer. Is that kind of the right understanding? Yeah. Yep. I would say so. They actually like math that goes on in the  background for that shallow pond option or well, is they're identical, so there's no difference going on there. like I say, it really does treat it just like a just like a shallow well, but you're right that if a well can, can, the deeper you go, the less impact you're going to have on surface water for sure. And the pond obviously it's not going to have that mitigation factor in there just by like a geology type barrier to water movement. It's not going to have that so yeah you're right it, but it's basically just going to be the deeper option of the well, is it's what's is what's making that work better for them than a pond might. The other question I guess I  had for you real quick and then I'll stop asking all the questions, but I was curious about. So some of these watersheds are fairly sizable and you get up on a corner someplace or maybe a portion of a a field, is in one watershed versus the other. And it may have a lot of irrigation closer to that actual stream, but there's very low contribution from that flow. But if its in tight areas is there sort of a pecking order in terms of how do I want to say that in terms of like if there's applications to pull water from that, if it's a if it's a lower impact well, does that make make a higher priority for to get it through or not? I guess if you have two, they're kinda simultaneously submitted. Okay. Yeah. So I I think I understand correctly. There there there really isn't a pecking order like that. The like the function that's going on that the model that's been used. It's really just only based on distance from the well to the stream. So it doesn't really matter. It does matter a little bit and I'll explain, but doesn't really matter too much. What watershed you're in. It only matters, it mostly matters. What's your distance to the to the stream is from that well location and if there's a couple of different wells there then the same same thing applies. Distance to the streams is the primary driver of streamflow depletion prediction. And the only thing that does matter a little bit is each watershed has its own aquifer characteristics like sort of a general average number for like the aquifers  transmissivity or its conductivity and that kind of thing. That are, that are variables that go into that math equation of the model. Each watershed has its own. It's possible that when you jump across a watershed boundary, then you're going to you are going to be using different numbers at that point. Usually they're not going to vary a whole a whole lot like that. That change happens a little slower. So it's not going to, it will change things, but probably not by a huge amount to jump across a watershed boundary. But you will be using, once you do that, you use a different set of input variables for that math equation. But yeah, other than that, there's no pecking order besides first in the first chronologically, the first in time that comes in gets reviewed first and I guess has the first crack at things. If there's more than one registration or or site-specific request, an area, we work on them in the order they received. It is it is something like a little bit of a first in time, first in like an out west type water law is what Michigan has put in place now. With it, with a big caveat that we could get into if you want. But but yes so it, it's just that that's all that happens when you're kind of at those watershed boundaries. Are you, well okay, Lyndon now I'm breaking my rule here. Are you guys actually thinking then about these water user groups as a way to remediate some of those issues where you've got, where  you're in the red zone, perhaps and have trouble being able to honor requests, I guess. What's the  plan there? Right. Right. You know it I don't I don't think it's obviously none had been formed yet and we haven't like successfully utilized that feature that that water  users committee to, to resolve an issue that hasn't happened yet. I think there's good reason for that because I just well, I mean, it it just requires cooperation amongst all sorts of neighbors who may or may not be, you know, I mean, they kind of are  competitors in a way. Obviously there's still neighbors, but it's going to require some kind of shared sacrifice on, on on all the parties in order to make this work, to make room for new withdrawal, new water use that comes in later on, someone else who's been there before and operating will have to give something up. So that's obviously the the main stumbling block to why water user committees haven't  successfully been been used and haven't accomplished much yet or anything yet. I I can imagine that that there could be a scenario in the future where it, where it does happen, you know, the the idea is that it's the same thing that someone, the same process that might happen if someone does sue other water users and saying that, you know, because Michigan is a riparian rights state and we do have that reasonable use doctrine that governs here. The last person, if they go to court, the last person has just as much right as the first person did or does have. So if it goes to court. Presumably we expect that judge  is going to say everyone takes a shared sacrifice and makes room to come in under, they may say something different, I don't know. But that's kind of what the prevailing thought is, how it's going to work. And I water users committee is, is the idea is that it would do that same thing where everyone has some sort of shared sacrifice in order to make room for the additional users to come in. Just without the need of legal lawyer paying lawyers to do it, right? That's the idea behind it, to do it quicker and cheap, much cheaper obviously, but to arrive at maybe what be the same, the same eventual outcome. Because Michigan at its base, at its foundation, is a reasonable use state for using water  on your property. Administratively, the job that we have to do at EGLE is not that any longer. Once we hit the limit, we just, we're required to just say no to anybody else who comes in afterwards. Andy, I had a chance here to look at my phone and a couple of messages came in on text. One. How long is that registration good for and are they told when it's no longer good? And now okay. And the second one's who's responsible for this? And then it says landowner. So I'm not sure what that means, but can you address those two things? I'll do my best. Yeah. Yep. The for the first one for sure. Once you've received your registration, it's good for 18 months. You got a year and a half to asically construct and you can kind of think of it as a construction permit, like you've you've got that registration in hand. It's good for 18 months. We do not automatically contact people at the expiration of the 18 months, but at the same time we also or or as we're nearing it or something like that, we don't contact those folks, but we also don't automatically wipe them out. They don't they don't automatically get voided out at the 18 months either. You know, this kinda goes contrary to part 327. I said we don't break the law. We kind of bend it sometimes. We those those registrations can sit there past 18 month as long as there's no other competing registrations were not limit. We're not really interested to go in and contact those folks and have them wiped out if they happened to be lagging beyond the 18 months. So so it is possible you can go beyond that 18 months. If it happens to be in a hotly contested watershed or whatever, what I whatever I should say. Where there are other competing uses then yes, we will be in contact with folks, right at or if the 18 months is expired will be will be in contact with them around that period to say do you intend to or have you constructed on this withdrawal.  If they have, we ask for the documentation that shows that a wells been drilled or or or we don't need the documentation if they say yes, it's install and they start reporting, water use or something like that through MDARD,  then that's good enough. That's verification that that they've made good on that on that registration. So so that's kinda how we handle those. They don't automatically like just get wiped out. Um, and they can, they can, they can go past that little grace period afterwards. So the second question about who's responsible? I think yeah, if they put in the qualifier there, landowners, yes. So so the the legal obligation falls to the landowner to do all these to do all those things, to register withdrawal, to report water use, it actually falls on the actual property owner. So so not a not a lessee, not a renter on the legal liability falls to the property owner to do those things of registering, reporting water use if they if they were if they're asked well, who is responsible for this whole thing overall, it that's a longer question, but I'm not sure if that's what they meant. I think I think they were talking a little bit about the fines that came in about the time I had this slide up about the fines. Okay. So, who gets fined? Yeah. It certainly would be the property owner. So if if it's a landowner and a lessee agreement, the fine would have to come down to the to the property owner. I guess they're responsible for whatever activity takes place on their property. So that's that's where it would go, at least from obviously from from how it's directed from the state to an entity, it will go towards the property owner what happens after that is between them. Are there other questions? I don't want to drag this on. We're at 130. Betsy, we don't have anything else and on the chat. Correct. Now, I'm not seeing anything in the chat or in the Q and A. So Andy LeBaron's contact information. If you do a Water Division search, Andy LeBaron at EGLE, He'll  come right up. He answers the phone extremely well. And it gets back to people and they have much bigger staff. I can remember when Andy was the only one answering the phone. And and now there's so many names there that my memory can't hang onto them all.  So get a hold of them. Dr. Dong, thanks for being there. Talking about energy efficiency. He's available with both phone number and email along with mine at the websites or on the slides. Bruce, thanks for hanging with us today. And we'll go from there. If you have any questions, email them to one of us and we'll share them around and get the answers. Can we call it a day, and hope to see you in the future. This is the last of the webinar series, but we are just now planning and our winter,  or winter meetings. First one I have come up as in December as the Michiana Irrigation Association. And I think there's also some work going on for the Great Lakes Expo, both of which we're going to have an irrigation program in. So hope to see you there. Thanks Andy. Thank you.