April 23, 2010 is the deadline for comments to the DNR on their proposed General Permits for CAFOs. Please send them an email opposing General Permits as this would affect all and every CAFO application in the state. The industry is pushing hard for this. Thanks, Edie Ehlert, CSP Coordinator

General Clean Water Act Permits for factory dairies in Wisconsin will streamline the process for the Concentrated Animal Feeding Operation (CAFO) industry by reducing citizen input on applications and making Wisconsin an even more attractive target to factory farms.

General Permits (GP) would limit essential public Input

• Public comments on new and expanding CAFO permits will be limited to the Nutrient Management Plans (NMP), not the entire CAFO application.
• Because all dairy CAFOs under 5720 animal units will receive coverage under this single permit and its generic Environmental Assessment (EA), citizens will not get to comment on or influence permit terms or request an EA for new dairies on an individual basis.

General Permits would make it impossible for DNR to protect unique regional resources

• The GP would impose identical setback distances between manure application fields and waterways, tile inlets, ditches, and wells for every large dairy CAFO, everywhere in the state, regardless of regional water quality issues.
• Unique features DNR's general permit fails to protect include karst geology, DNR-designated impaired, outstanding, and exceptional waterways, and areas with scarce or vulnerable ground water

General Permits serve only the CAFO industry, promoted by the Dairy Business Association.

• The DNR's role is to protect the environment for the people of the state, not to work to promote factory farms, but fast-tracking approval of factory farms ignores this responsibility.
• The General Permit came out of a Memorandum of Understanding (MOU) between the DNR, the Dairy Business Association and the Dept. of Ag, Trade, and Consumer Protection. To restore credibility and fulfill its mission to the people of Wisconsin, DNR should draft a Citizens MOU and base its CAFO regulations on that document, not on a backroom deal with polluters.

Fees need to be greatly increased through the legislature to cover the real costs of CAFO applications.

• DNR has stated that it will not finalize the General Permits unless the legislature approves more funding for CAFO inspections and enforcement – DNR must continue to demand this funding.
• The industry is not paying its way. We, the citizens are paying, and the DNR is massively underfunded for the job. General Permits will only make it easier for CAFOs to pollute without fear of enforcement actions by the DNR, unless permits fees increase dramatically.

DNR claims General Permits will give more staff time for compliance inspections.

• Since the DNR is already failing to enforce compliance, weakening the process is not likely to increase protection of our communities.
• DNR has provided no information on the resources it believes fast-tracking new CAFOs will free up. More likely, the influx of new CAFOs will strain DNR resources even further

Written Comments to:
Gordon Stevenson, DNR Bureau of Watershed Management
PO Box 7921, Madison, WI 53707-7921
DNRWTLARGECAFO@wisconsin.gov DNRWTSMMEDCAFO@wisconsin.gov Go to www.dnr.state.wi.us/runoff/ag/permits.htm for DNR information.