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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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Crawford Stewardship Project is grateful for the generous support of the Wisconsin Community Fund. 
"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.
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Sustain Rural Wisconsin Network Letter to DATCP May 12, 2010To the DATCP Board of Directors: The undersigned organizations and individuals write to urge you to take swift and firm action with regards to the Wisconsin Livestock Facilities Siting Law and Rule. As you know, DATCP Staff conducted a series of “listening sessions” around the state to receive public input on the agency’s review of the Siting Rule, and has since prepared a “Four Year Evaluation Report” of the Rule, dated April 28, 2010. We appreciate the Department’s efforts to collect and analyze the public comments and to provide direction to the DATCP Board as it considers next steps. While the Four Year Evaluation Report is, on the whole, a balanced and comprehensive review of the Livestock Siting program, it is important for the Board to understand the full ramifications of this program on rural communities around Wisconsin. State law requires that DATCP “review rules promulgated under [the Siting Law] at least once every four years” and that the DATCP Secretary “appoint a committee of experts to advise the department on . . . the review of rules.” While the Siting Law does not require DATCP to actually revise the Rule through a formal rulemaking process, the citizens of Wisconsin have voiced their overwhelming sentiment that there are multiple changes needed to the Rule and that substantial revisions are necessary. A. The Citizens of Wisconsin Have Voiced their Concerns: Changes to the Rule are Needed Although we know that many of you attended the public listening sessions, we call the Board’s attention to some of the most compelling written comments received from Wisconsin citizens as part of this process:
B. The Underlying Policies of the Livestock Siting Law and Rule Must be Addressed by the DATCP Board While DATCP staff and proponents of the Siting Rule have emphasized that the current four-year review should be limited to the effectiveness of the substantive standards of the Siting Rule, we urge the Board to use this opportunity to delve into the underlying policy implications of the law itself. Only now, with four years’ worth experience to analyze, is the Board fully equipped to provide much-needed policy direction to DATCP staff and the Legislature. The Siting Law has reduced the environmental protections available to communities around the state. The law actually required local governments with pre-existing standards arguably more protective than the Siting Rule to review and either weaken its local ordinance or justify its requirements based on “reasonable and scientifically defensible findings of fact . . . that clearly show that the requirement is necessary to protect public health or safety.” Unfortunately, neither “environmental protection” nor “protection of public welfare” are goals of the Siting Law or are acceptable grounds for more stringent local standards. Additionally, the Siting Law did not create uniform state standards; most communities in Wisconsin still have no standards in place for livestock siting or expansion. These underscore fundamental flaws with the Siting Law itself: a truly protective and uniform state-wide siting program would apply automatically to all communities and would be rigorously implemented and enforced by DATCP. Such a program would prevent the “race to the bottom” that we have already seen where new CAFOs specifically target Towns or Counties without a Siting Ordinance in place. 2) The Siting Law creates a nearly-impossible burden for enacting more stringent local standards It is telling that, to our knowledge, not one local government has successfully enacted more protective local siting standards under the Siting Law. There is a lesson to be learned in the experiences of the Town of Lamartine, in Fond du Lac County. The Town has attempted for several years to work constructively with DATCP staff to develop a local zoning ordinance that meets the strict limits of the Siting Law while serving the needs of the community to promote sustainable agriculture and reduce land use conflicts. After numerous reviews by DATCP staff of various revisions to the proposed zoning ordinance, the Town has yet to reach a satisfactory outcome. We encourage the Board to contact Town officials to learn more from their experience. Although many concerned citizens recognize that the major flaws in the livestock siting program stem from the statutory language in Wis. Stat. 93.90, it is widely understood that a degree of interim relief for rural communities and neighbors of large livestock facilities can come in the form of revisions to the Siting Rule. As DATCP staff have documented, “The majority of comments [received during the Listening Sessions or public comment period] specific to the rule requested some level of adjustment.” In conclusion, we respectfully request the DATCP Board to take the following specific actions:
Respectfully submitted by the following Wisconsin Organizations and citizens:
Wisconsin Citizens
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