Crawford Stewardship Project works to protect the environment of Crawford County and neighboring regions from threats of polluting and extractive industries, to promote sustainable land use, environmental justice, and local control of natural resources

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


Crawford Stewardship Project is grateful for the generous support of RESIST, Inc. RESIST funds and supports grassroots groups organizing on the frontlines of the peace, economic, social, and environmental justice movements.

“We abuse land because we regard it as a commodity belonging to us. When we see land as a community to which we belong, we may begin to use it with love and respect.” ~Aldo Leopold, A Sand County Almanac

"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.

“A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise.”
~Aldo Leopold, 1948. A Sand County Almanac.

DNR General Permit Proposal for CAFOs

April 22, 2010

Gordon Stevenson
Copies to>,

DNR Bureau of Watershed Management

Dear Mr. Stevenson,

Crawford Stewardship Project is registering our opposition to the DNR proposed General Permitting process for CAFOs. We presented our abbreviated concerns at the public hearing in Viroqua. We thank the agency for the opportunity to register our opinion on this issue.

Our extensive experience in Crawford County with the CAFO process confirms the need for greater scrutiny of applications, requirements that all DNR rules and laws are strictly followed, and enforcement of violations beyond the stepped "enforcement" of sending letters to the violators.

A General Permit is a step in the wrong direction to address these concerns and will instead streamline the process to bring more CAFOs to our state. Public input would be reduced as we could only comment on the nutrient management plans, not the entire applications. Environmental assessments would no long be required for CAFOs under 5720 animal units, thus treating everywhere in the state as the same. We believe that unique issues such as karst geology, water quality and quantity, and distances from impaired, outstanding, and exceptional waterways require individual scrutiny. Watersheds with already high livestock density need to be protected more carefully as well.

A General Permit serves the interests of industrialized agricultural, supported by the industry's lobbying organization, the Dairy Business Association (DBA) among others, at the expense of the well being of rural communities. The DNR has signed a Memorandum of Understanding (MOU) with DBA, which as citizens of rural Wisconsin, we find to be in conflict with the health and long term bright future of the citizens and environment of Wisconsin. We would like to see the DNR return to its mission to protect the environment and put aside the General Permit scheme as well as the MOU with the DBA. We support instead, an MOU with the citizens of this state, to formulate a plan to strengthen CAFO permits, as well as inspection and enforcement of laws pertaining to existing factory farms.

The General Permit will not protect our water quality from CAFO pollution. Phosphorus allowance on many fields can be as high of a p-index of 6, which means the potential for phosphorus runoff to surface water is "high." DNR should limit manure application to fields with a p-index of 2 or lower in order to protect surface water and meet federal clean water standards.

Nutrient management plans (NMPs) under the General Permit would continue the practice of allowing CAFOs to apply 15% more nutrients than actual crop yield averages, because the NRCS 590 standard permit this. This practice defies both science and common sense, and virtually guarantees excess nutrients will find their way into surface and ground water over time.

There is a need for higher fees for CAFOs, to cover all expenses incurred by the agencies involved in the application process. Municipalities are paying their share and CAFOs should be charged likewise. Taxpayers are bearing the brunt of the costs of a private enterprise that is both unwelcome and a health hazard to our rural communities.

Our experience in Crawford County reveals clearly a WPDES permitting process that is seriously flawed. To further streamline the process will only make it worse for our rural community. The lack of enforcement, the acceptance of all CAFO applications, and the lack of agency monitoring of our waters shows the need for strengthening of all aspects of CAFO applications.

Respectfully Submitted,

Edie Ehlert,
Crawford Stewardship Project Coordinator

Crawford Stewardship Project Board: Ellen Brooks, Chair; Lamar Janes, Treasurer; Gloria Derksen, Secretary; Maggie Jones, Rob Horwich, and Jane Holzhauer

Crawford Stewardship Project is a 501(c)3 non-profit organization registered in the state of Wisconsin