Crawford Stewardship Project

July 13 Letter to Terence Kafka, DNR

Comments on the proposed Richfield Dairy CAFO, owned by Milksource, WPDES Permit # 0064815-01-0

On behalf of the 900 supporters of Crawford Stewardship Project, I am registering our opposition to granting a permit to the Richfield Dairy CAFO due to issues listed below:

•   Inadequate assessment of soils: Sandy soils of the region are vulnerable to allowing water pollutants easy transfer. Soil sampling should be required annually to assure that over application of manure does not occur.

•   Water quality concerns: Already 24% of the area wells are high in nitrates. Additional overload of nitrates to groundwater through run-off and application of liquid manure to fields could harm neighboring wells. Further, the WPDES proposed permit does not ensure there will be no discharge of manure from land spreading to surface waters. We are asking for no discharge allowance.

The permit should not allow application of manure on fields with a phosphorus index more than 1. Ranges from 3-6 is likely to cause phosphorus pollution to surface waters. In addition, other fertilizer application rates need to be included in the NMP or there is a risk of over application of nutrients. The permit and NMP identify water courses on fields inadequately, thus proper buffer zones are not identified that are needed to keep pollutants from entering the surface waters.

•   Monitoring needed: Given the vulnerabilities listed above, the DNR should set up monitoring of discharges where run-off from fields occur. This is supported by Wis.State.s.283-55(1).

In conclusion, Crawford Stewardship Project opposes this application. The risk to community health is great given the water quality concerns alone.

As stated repeatedly, most of us rural residents appreciate and support farming vigorously. We support sustainable farming that exists in concert with other diverse economic rural ventures. Milksource will have 5 CAFO dairies in the state with this application. The profits will go to the few owners while modest family farmers continue to be driven out of business.

Respectfully submitted,

Edie Ehlert,
Crawford Stewardship Project Coordinator

			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.	July 13 Letter to Terence Kafka, DNR Comments on the proposed Richfield Dairy CAFO, owned by Milksource, WPDES Permit # 0064815-01-0 On behalf of the 900 supporters of Crawford Stewardship Project, I am registering our opposition to granting a permit to the Richfield Dairy CAFO due to issues listed below: • Inadequate assessment of soils: Sandy soils of the region are vulnerable to allowing water pollutants easy transfer. Soil sampling should be required annually to assure that over application of manure does not occur. • Water quality concerns: Already 24% of the area wells are high in nitrates. Additional overload of nitrates to groundwater through run-off and application of liquid manure to fields could harm neighboring wells. Further, the WPDES proposed permit does not ensure there will be no discharge of manure from land spreading to surface waters. We are asking for no discharge allowance. The permit should not allow application of manure on fields with a phosphorus index more than 1. Ranges from 3-6 is likely to cause phosphorus pollution to surface waters. In addition, other fertilizer application rates need to be included in the NMP or there is a risk of over application of nutrients. The permit and NMP identify water courses on fields inadequately, thus proper buffer zones are not identified that are needed to keep pollutants from entering the surface waters. • Monitoring needed: Given the vulnerabilities listed above, the DNR should set up monitoring of discharges where run-off from fields occur. This is supported by Wis.State.s.283-55(1). In conclusion, Crawford Stewardship Project opposes this application. The risk to community health is great given the water quality concerns alone. As stated repeatedly, most of us rural residents appreciate and support farming vigorously. We support sustainable farming that exists in concert with other diverse economic rural ventures. Milksource will have 5 CAFO dairies in the state with this application. The profits will go to the few owners while modest family farmers continue to be driven out of business. Respectfully submitted, Edie Ehlert, Crawford Stewardship Project Coordinator