A review of the NRCS Custom Soil Resource Report resulted in Mark Madison concluding that “the Custom Soil Resource Report was created for the specific area of Kauai that includes the proposed dairy operation and is much more detailed than the general information presented in the Plan. Yellow highlights was added to emphasize data that are in direct conflict with the Plan’s claims that soils are suitable for an intensive confined animal feeding operation and animal waste disposal with land application and irrigation of effluent. The proposed dairy operation is situated on soils that are very limiting for land application of animal waste. An intensive waste management program of 699 cows on this site should not be allowed. A waste management program on this site will likely result in contamination of ground water that is extracted by community wells within the aquifer, recharged by the farm. Surface runoff from this site will contain manure contaminants that will be conveyed to streams, wetlands and coastal waters.”