COLOMA – Friends of the Central Sands (“FOCS”), a non-profit organization dedicated to promoting natural resource stewardship in Wisconsin’s Central Sands, filed a lawsuit today along with a request for a Contested Case hearing relating to the recent approval of high capacity wells, a WPDES Permit (Wisconsin Pollution Discharge Elimination System), and an environmental assessment for Richfield Dairy, a proposed CAFO (concentrated animal feeding operation) in Adams County. FOCS, along with Family Farm Defenders and several local residents and property owners, filed these documents in Dane County Circuit Court and with the DNR.
“We all value the work of the men and women in the DNR. However it is troubling that while the DNR acknowledged some of our concerns and imposed some permit conditions, many holes remain in these approvals that could seriously jeopardize water resources in the Central Sands,” said local property owner Bob Clarke.
On Thursday, November 3, the DNR issued Richfield Dairy a high-capacity well permit and approved the WPDES permit for wastewater discharges, including manure-spreading, and a modified approval of the dairy’s plans and specifications. These modifications were not made with sufficient public input or review and remain a significant area of concern.
The high-capacity well permit approval caps the dairy’s annual water withdrawals at 131 million gallons, yet evidence was submitted to the DNR that a lower amount of annual withdrawal—52 million gallons—would lower lake levels by an average of 2 inches per year and would reduce stream flows by 5%. The DNR stated that it did not view these reductions as a “significant adverse environmental impact.” While recognizing and agreeing with the impact based on 52 million gallons, the DNR actually approved an amount 2.5 times that amount. There are world class trout streams that would be impacted by this as well. Additional research has shown that pumping at the rate of 131 million gallons per year will reduce stream volumes in some sections by 10% or more.
“At the least, the DNR should have done a more complete environmental review resulting in a comprehensive Environmental Impact Statement. Instead they feel that the Environmental Assessment was adequate,” said part time resident Bill Vance. “That DNR would disregard scientific evidence of drawdown in an already over-taxed aquifer is very disturbing, and bodes very poorly for water resources in our region.”
FOCS is also highly alarmed that the WPDES permit does not appear to contain a limit on the number of animals at the site; in fact, in one document, the DNR explicitly states it is “not limiting the size of Richfield Dairy via the WPDES permit.”
Said local resident Terry Tinkle, “Richfield Dairy has been presenting this as a 4,300 cow dairy. But now it looks like the dairy can expand whenever the mood strikes it. How can the public be assured it won’t expand to the point it harms our precious water resources?”
“These factory farms do not represent what is the best for Wisconsin. By their very size and nature they cause great economic harm to the family farm and the communities they supposedly support,” said John Peck of Family Farm Defenders.
Local organic farmer Russ Brown added: “We must stop the ‘business at all costs’ mindset permeating this process. There has to be a balance.”
FOCS is also concerned that Richfield Dairy’s manure spreading operations will pollute the regional groundwater, especially in light of DNR’s recognition that local soils are at higher-risk for transmitting groundwater contamination. This spreading will be allowed to occur with little if any oversight. And, while FOCS was glad to see the dairy is required to install groundwater monitoring wells at its production site, there appear to be no consequences in the WPDES permit for violations of groundwater quality standards.
FOCS continues to play a role to ensure the stewardship of the natural environment in the Central Sands and is currently involved in other activities such as the development of a ground water coalition in the Central Sands and supporting the efforts of Sustain Rural Wisconsin Network, a statewide coalition of individuals and organizations dedicated to preserving the environment while maintaining the health and economic vitality of rural communities. “We have important work to do protecting our natural world and opposing the Richfield Dairy is critical in accomplishing this mission,” said Bob Clarke. “We will continue as long as necessary.”