1. Notice & record gaps. The corrected public notice and available record contain material discrepancies or unresolved questions concerning animal classification, legal description, NPDES status, application completeness, engineering review, and the basis for DWEE's preliminary intent to approve.
2. Groundwater protection. The permit record does not adequately demonstrate protection of groundwater, surface water, streams, wetlands, and the Niobrara watershed from pit seepage, structural failure, spills, stormwater runoff, and overapplication.
3. Hydrogeologic data. The record does not provide sufficient site-specific hydrogeologic information to demonstrate required separation from seasonal high groundwater or adequate protection of nearby domestic, livestock, and irrigation wells.
4. Enforceable safeguards. The proposed permit does not clearly establish enforceable baseline sampling, groundwater monitoring, leak detection, construction-quality assurance, inspection, public reporting, emergency-response, and corrective-action requirements.
5. Nutrient Management Plan. The Nutrient Management Plan leaves unresolved questions about land control, usable acreage, soil and manure testing, crop and yield assumptions, nitrogen credits, phosphorus buildup, application rates and timing, setbacks, and contingency acreage.
6. Mortality management and catastrophic loss. The record does not adequately demonstrate that routine composting, emergency mortality handling, and catastrophic-loss disposal can be conducted at this site without contaminating groundwater or surface water, and does not establish enforceable siting, capacity, monitoring, emergency-response, and contingency requirements.