The Department of Agriculture, Trade and Consumer Protection (DATCP) is responsible for promulgating nutrient management rules in Wisconsin per 92.05 (3) (k). Wis. Stats. These rules include development and dissemination of agricultural technical standards within the state to abate non-point source water pollution. Wisconsin is transitioning from the nitrogen-based nutrient management technical standard, to the revised phosphorus (P)-based USDA Natural Resources Conservation Service (NRCS) Technical Standard 590, Nutrient Management. The P-based 590 standard is required for Confined Animal Feeding Operations (CAFOs), federal Environmental Quality Incentive Program (EQIP), and the Dept. of Natural Resource’s (DNR) nutrient management performance standard. According to ATCP 50 Wis. Admin. Code, after 2005, when DATCP incorporates the P-based nutrient management standard into ATCP 50 (~2006), a farmer “shall” have a nutrient management plan for mechanically applied nutrients if at least 70% cost sharing is offered by local conservation agencies. A qualified planner shall approve the farmer’s nutrient management plan; have soil tests from a DATCP certified soil testing laboratory; comply with University of Wisconsin nutrient recommendations; and maintain tolerable soil loss levels for each field. DATCP estimates that 9 million acres of cropland will require P-based nutrient management plans at a cost of $28 per acre or $252,000,000 beginning in 2004. If Wisconsin implements nutrient management in 15 years, the annual cost will be $16,800,000 each year to meet the cost share requirement.