There is a lot to watch as WDNR plows ahead with the development of Targeted Performance Standards for Nitrogen in NR 151.  Although proposed rule language is not yet available the proverbial "writing is on the wall" as to where this is headed.  1. There is nothing "targeted" about the application, just look at the maps. 2. This will (big surprise) disproportionately impact CAFOs since the implementation tool is via NMPs (and CAFOs are by far the advanced adopters). 3. The fall application restrictions will create more of a "land war" and increased truck traffic and distance (talk about carbon emissions!).  4. The UW economic impact analysis better include significant costs for increased storage! 5. Does anyone else think its a bad idea to shift nutrient applications mostly to pre-plant springtime when saturated conditions and freeze thaw is at its worst!  Surface waters be damned, we're just focused on groundwater in this rulemaking.  Insert eye-roll emoji here!