Citizen Group brings Concerns on the Wauzeka Hog Operation to the DNR
February 15, 2012
A Notice of Non-compliance (NON) order was issued by the Wisconsin Department of Natural Resources (DNR) to the Roth Feeder Pig operation in Wauzeka Township in Crawford County on February 3, 2012. According to the NON, the Roth operation has failed to submit a completed Annual Report due January 31, 2012. The NON reflects some of the concerns brought to the DNR by Christa Westerberg, lawyer with McGillivray, Westerberg, & Bender, LLC, on behalf of Crawford Stewardship Project (CSP) in a letter sent January 17, 2012. This is the second time Mr. Roth has been issued an NON, the first was in March 2011, after CSP brought a series of concerns to the DNR. Since the February 3, 2012 NON was issued, Mr. Roth has sent documents to the DNR that likely address some of the requirements listed in the NON. Other issues addressed by the DNR in the Feb 2012 NON include:
Requirement to submit a complete and up to date Nutrient Management Plan (NMP) by March 31, 2012 using “updates normally required” as past updates have used “various tools and non-standard forms”.
DNR granted another extension on the old earthen lagoon abandonment plan to 6/30/2012 with actual abandonment completion due date of 6/30/2013.
Crawford Stewardship Project has reviewed the Roth NMP over the past year. Results have shown significant concerns, which include missing required documentations and inconsistencies. While an NMP update is required annually, one was not submitted in 2010. The 2011 NMP uses different numbering of the fields used for spreading than the 2009 plan, making tracking individual field soil health difficult, plus field maps were not submitted for 2011, nor were all required checklists for NRCS 590 and NR 243 standards submitted each year. Despite these tracking difficulties CSP was able to review five of the larger fields, noting that organic levels have dropped significantly in these fields, phosphorus levels have increased in two of five fields, and potassium levels have dropped.
The original WPDES (water discharge permit) issued by the DNR on May 1, 2010, required abandonment of the old earthen lagoons at the operation to be completed by December 2011. “We are highly concerned that each failure to meet requirements results in additional time extensions from the DNR,” comments Edie Ehlert, Crawford Stewardship Project Coordinator. “We have requested that the DNR require Mr. Roth to apply for a modified WPDES permit for extensions over 120 days as required by law so as to include the public in the process.”
The Roth Feeder Pig Operation has about .15 acres (15 hundredths of an acre) per animal unit of land to spread manure, while conservative industry standards call for a minimum of 1 acre per animal unit. During the original Roth permit process, citizens expressed concerns summarized by Dr. Byron Shaw, Emeritus Professor of Soil and Water Resources, UWSP, “The overall level of nutrient management, high density of animals to the land area, steep slopes, already overloaded soils with phosphorus, proximity to protected surface water resources, proximity to vulnerable groundwater and unrealistically low manure values all make it highly likely that significant water resource problems will occur if this facility is permitted as proposed.”
“Why does it take legal review and letters of concern from Crawford Stewardship Project to bring review and action from the DNR?” asks CSP board member Ellen Brooks. “We see a large new building being built onsite to replace old, smaller buildings, and we wonder if an expansion is being planned,” reflects neighbor Fred Hausler.
Meanwhile, area citizens continue to monitor the water quality around the CAFO, concerned that little monitoring from the DNR and field health issues bring greater concern for water quality deterioration over time.