Crawford Stewardship Project

CSP Request to DNR for Environmental Impact Statement on Roth CAFO

Robert Rohland
Department of Natural Resources
Black River Falls, WI

Dear Mr. Rohland:

Crawford Stewardship Project would like to raise concerns about the DNR acceptance of the Roth Feeder Pig Operation NMP as complete. We are further respectfully requesting that in addition to the Environmental Assessment currently being done by the Department an Environmental Impact Statement be considered.

The primary concerns identified by our experts remain:

Too little land for too much manure: Many fields are already too high in phosphorus. Less than 200 acres for the manure from 1,700 animal units are high by all industry standards for manure applications. Terrain is steep: Run off from surface applied manure is of grave concern. The adjoining Boydtown Creek and Wisconsin River are rated as exceptional, outstanding and/or impaired resource waters of the state, warranting additional restrictions. Major heavy rain events are becoming routine in the area due to shifts in weather patterns. To allow a facility of this type to locate so near to these resources without careful study is to risk irreversible damage.
Karst Geology: We recognize that our area’s fractured geology can result in high vulnerability to contamination of our ground water. The geology of the land needs to be thoroughly scrutinized by an independent soil scientist and hydro-geologist before a facility with storage capacity of millions of gallons of liquid waste is located in the area.
Neighbor Health: Safe drinking water is the right of our citizens. We are asking the DNR to protect our drinking water. Once polluted, our confined aquifer may be impossible to cleanse. Parts of the Roth farm are located in the atrazine prohibition area along the Wisconsin River known to be more susceptible to groundwater contamination. A well immediately down plume of the Roth Feeder Pig operation is already testing over the limit for nitrates.
Engineering: NR 243 clearly states that the DNR will pre-approve engineering design of a facility before construction, but to our knowledge this was not done. Engineering inspections during construction appear to have been inadequate as well. Therefore the public has no assurance the facility does not present the added threat of engineering failure to the environmental concerns listed above.

Due to these vulnerabilities and concerns, we are requesting that a full EIS be done on this application.

Respectfully Submitted

Jennifer Nelson, Board Chair
Crawford Stewardship Project

			Crawford Stewardship Project works to protect the environment of Crawford County from threats such as those posed by concentrated animal feeding operations (CAFOs) and to promote sustainable land use, local control of natural resources, and environmental justice. Crawford Stewardship Project is a nonprofit organization. Donations are tax deductible. Support CSP Send a check to: Crawford Stewardship Project P.O. Box 284 Gays Mills, WI 54631 csp.county@gmail.com
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	Ongoing Projects Sand Mining Crawford County CAFOs Water Quality and CAFO Monitoring Karst Geology Sustain Rural Wisconsin Network-SRWN Livestock Siting Law & State CAFO Permitting Crawford Stewardship Project is grateful for the generous support of the Wisconsin Community Fund. Order your Driftless Wisconsin poster today! "CAFOs are only profitable because so much of the cost and damage is externalized onto the environment, neighbors and wildlife. The monitoring, supervision, clean-up, restitution, fines are not happening, thus the true cost of CAFOs never find the way onto the balance books." Talking point from the CAFO Conference.	CSP Request to DNR for Environmental Impact Statement on Roth CAFO Robert Rohland Department of Natural Resources Black River Falls, WI Dear Mr. Rohland: Crawford Stewardship Project would like to raise concerns about the DNR acceptance of the Roth Feeder Pig Operation NMP as complete. We are further respectfully requesting that in addition to the Environmental Assessment currently being done by the Department an Environmental Impact Statement be considered. The primary concerns identified by our experts remain: Too little land for too much manure: Many fields are already too high in phosphorus. Less than 200 acres for the manure from 1,700 animal units are high by all industry standards for manure applications. Terrain is steep: Run off from surface applied manure is of grave concern. The adjoining Boydtown Creek and Wisconsin River are rated as exceptional, outstanding and/or impaired resource waters of the state, warranting additional restrictions. Major heavy rain events are becoming routine in the area due to shifts in weather patterns. To allow a facility of this type to locate so near to these resources without careful study is to risk irreversible damage. Karst Geology: We recognize that our area’s fractured geology can result in high vulnerability to contamination of our ground water. The geology of the land needs to be thoroughly scrutinized by an independent soil scientist and hydro-geologist before a facility with storage capacity of millions of gallons of liquid waste is located in the area. Neighbor Health: Safe drinking water is the right of our citizens. We are asking the DNR to protect our drinking water. Once polluted, our confined aquifer may be impossible to cleanse. Parts of the Roth farm are located in the atrazine prohibition area along the Wisconsin River known to be more susceptible to groundwater contamination. A well immediately down plume of the Roth Feeder Pig operation is already testing over the limit for nitrates. Engineering: NR 243 clearly states that the DNR will pre-approve engineering design of a facility before construction, but to our knowledge this was not done. Engineering inspections during construction appear to have been inadequate as well. Therefore the public has no assurance the facility does not present the added threat of engineering failure to the environmental concerns listed above. Due to these vulnerabilities and concerns, we are requesting that a full EIS be done on this application. Respectfully Submitted Jennifer Nelson, Board Chair Crawford Stewardship Project