Industrial strength agriculture weakens this community

Let’s suppose that a new industry wants to set up shop in Kewaunee County with the intent to pollute the environment by producing more waste than product; lower property values by dumping its toxic waste over more than half of the county; and degrade the social and economic fabric of the community by creating an environment that repels new businesses and tourists and offends those who call this home.  Oh, by the way, they want the government to pay them to assure profitability. What are the odds that industry could even get off the ground? Then why do we allow the industrial agriculture industry the opportunity to do business here?

Last week Channel 5, WFRV TV, aired a report on the proposed 13 million gallon manure storage pit planned for construction by Pagel’s Ponderosa Dairy west of Kewaunee on County Rd. F. The photo below shows its location and scale. On one hand you like to see factory farms take responsible action for adequate manure storage capacity. On the other hand, by placing the pit as close as 200 feet to existing homes you have to wonder WHY? Such arrogance only fuels the growing disgust and anger by rural residents toward CAFOs. Furthermore, when decisions are made that allow only a few to profit at the expense of so many others, you wonder how the permitting process could have gotten this far.

Many Kewaunee County businesses stay profitable by providing good products, good services and good value. Successful businesses also contribute positively to community development. It’s increasingly difficult to find value in the products marketed by huge dairy CAFOs. Government subsidies provide a monetary cushion that allows CAFOs to continue doing business. Plus they are expanding at an alarming rate and scale. CAFOs are ruining the quality of the environment, the quality of life and denying people an opportunity to profit from their investments in land and houses by driving down property values.

Kewaunee Cares encourages you to let your state law makers, the Department of Natural Resources, and local government know that Kewaunee County is not a designated dumping ground for industrial agriculture. It’s time for us to demand responsible action from our county’s largest industry and our governing bodies.

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4 Comments

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4 responses to “Industrial strength agriculture weakens this community

  1. Harriet

    Thank you again and again Kewaunee Cares!!
    This is truly an environmental travesty of sustainable agriculture and appears to be beyond control…Plutocracy at its zenith!!
    Will our local and state governments ever assume some form of responsibility?? What about the citizens (taxpayers)…when will they stir from their slumber? ( I hope soon before we have an environmental disaster)!
    Well said and again many many thanks for “airing” what is happening in our own back yards!

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  2. The letter below was presented to the WDNR (who in their own ways are doing nothing to adequatelty/properly deal with the impacts of these huge CAFOs). The WDNR process for approving these pits is conatined within the water pollutant discharge policies, and they wash their hands of the requirements they should have to deal with the air quality, land quality, health and safety of residents, traffic safety, property values, and quality of life for residents by stating that the permit process does not give to the department the authority to address such issues. While absolving themselves of dealing with this emotionally charged issue of negligence and inadequate rules, regulations, standards, and guidelines, they’re openly admitting that as a department, they do NOT function as a whole to adequately protect all aspects of the lands, waters, air, and citizens of the state, by relying on outdated and inadequate permitting procedures. What is in place today, does NOT protect the citizens from these CAFOs, Pagel’s Ponderosa accounting for nearly 10,000 head of cattle, and over 54 million gallons (proposed) of liquid manure storage – 13M+ gallons at a location over 3 miles from his farm….

    We are writing to publicly object without question that we are opposed to the 13,139,290 gallon, 6.5+ acre finished area, liquid fecal manure satellite storage pit proposed by John Pagel on County Highway F, three miles away from the source of his waste production and storage problem of the factory farm! We are not opposed to sustainable and manageable farming, but the inadequate handling of waste problems with ill-conceived proposed satellite facilities.

    We the concerned citizens have compiled this long letter of objection and have outlined overall general concerns, some specific concerns, and conditional approval issues which must be addressed by the WDNR and owner.

    We question the validity of the Site Assessment in the proposed design documentation, and owner’s selection of this location along with the approval by the WDNR. We feel that the design criteria utilized for this proposed pit is outdated and does not adequately address facilities of this size, nor adequately protect the private residences or public lands of the state with respect to air and water quality. We feel that due to the age and condition of the existing pit, the previous impacts to the environment of constant discharges and spreading operation mishaps associated with the area of the proposed pit, and the potential impact on the concentrated residents of the area and public recreational property users nearby, and the management and consequences with the Kewaunee River Watershed and Lake Michigan, that the proposal should be treated with caution and the highest scrutiny given prior to approval. In this proposal, we feel an additional burden of proof ought to be placed on the owner and source of the excess manure, as to why this location is feasible, appropriate, or even manageable. Specific evaluation should be made comparing the proposed new pit at this satellite location versus a new storage (or expansion of storage) at the source property location of the manure. Due to impacts to the Kewaunee River, State of WI lands, private landowners, and general public, the WDNR should require specific site assessment comparisons/alternatives and an undeniable conclusion that this location is a better and more suitable alternative than expanding or installing new storage at the source location at Pagel Ponderosa farm. A satellite pit should not be considered without detailed analysis and justification why expanding the existing storage at the source location is not feasible. As we will point out throughout this letter of objection there are numerous issues associated with a 13+ million gallon pit at this proposed satellite location. These issues include but are not limited to, the proposed location brings into question the ability to adequately protect the State of WI lands and waters, and the proposed location impacts a high concentration of residents and public at this location versus the existing status quo associated with storage at the source farm location (and a long list of personal issues to follow). If after this location is deemed, without a doubt the best solution to the liquid manure storage problem, then additional conditions must be placed on the approved permit or the citizens and public will not be adequately protected against the reduction in air and water quality, as well as an overall reduction in the quality of living.

    The owner’s proposal outlines a site assessment that references three main reasons for selecting this site – soil type, size requirements, and proximity to existing fields.

    The selection of this site based on soil conditions is baseless because the soil conditions from the proposed site to the owner’s farm are virtually unchanged. Throughout Kewaunee County and specifically along this ridge area there is a predominant distribution of clay soils without bedrock. This area of similarity includes the source farm location. By simply expanding or increasing capacity at the farm source location where 40.9 million gallons of capacity already exist, there is little change to the existing conditions/issues.

    The statement in the site assessment portion of the proposal to utilize this location based on proximity to existing lands is baseless because the owner’s property at the farm source location could accommodate this storage. Furthermore, the owned property is a small portion of the owner’s overall property, and the rental properties adjacent to the owned properties are not long term binding agreements which would warrant a necessity to locate this satellite storage pit near them. [13.1M gallons of 54M gallons total capacity = 24%. Total properties as noted in the permit application are 3620 acres, 24% of total property would equal 869 acres. This satellite location does not account for 24% of the total property, nor is it a justification that this 13.1M gallon addition should be selected due to “proximity to fields”.] Locating the liquid manure storage at the source farm is fundamental farming operation that is being ignored with this huge satellite pit proposal. This is not to mention the increased operating costs associated with tankers to be utilized to truck the manure to the satellite pit from the Pagel farm, and hoses and tanks needed to transport again to spreading operation areas elsewhere. Given the proposal, the manure will have to be tanked to the satellite pit, dumped in, and then pumped back out to a tanker to be spread at a later date at a different location. How can these increased operating costs alone make the proposed location viable? [More than 2000 tankers will be required to fill a 13M gallon pit]

    Any statement regarding selection of this location based on size requirements is completely baseless. The owner has more than adequate land available for additional storage at the farm source location. And the selection of this site based on size requirements must make no humane consideration to other private residences. The proposal places this satellite facility less than 300 feet from private wells, 200 feet from residences, and 50 feet from yards and outbuildings. By comparison, the existing pits at the source farm location are not this close to the owner’s home.

    Another consideration associated with choosing this satellite location for the proposal was that there is an existing pit onsite. This existing pit has sat idle for an extended period of time, has not been maintained, may not have been properly monitored or self-reported, was not built according to any recent standards or inspections, and according to local residents it no longer holds liquid anyway as it often sits dry by the end of summer (even after “this years heavy rainfall” as noted in the owner’s proposal with unsubstantial claims as to why additional waste storage is necessary). Logistically, this proposal appears like it is being considered a modification to the existing permit held by the manure producer.
    Is the existing storage pit included in the existing permit?
    Do the permit requirements vary for expansion of existing pits versus full approval of completely new pits?
    What are the regulations and requirements associated with satellite pits (3 miles from the source location)?
    How does the permit process differ?
    How many satellite pits are approved throughout the state of WI, of what capacity, and with what contingencies?

    We question the handling of the permit as an “expansion of an existing storage area” because the existing pit was built and constructed without adequate documentation and regulations. To treat the creation of a new storage facility which will be roughly 15-20x larger than the existing, undocumented and uncontrolled facility is simply not acceptable. Furthermore, the existing pit has been idle for an extended period of time and it is unknown whether the required monitoring, testing, and reporting have been performed. With respect to the area in question, the owner’s land and rentals, there have been past performance problems, and continue to be problems with the application of liquid manure. The spreading of liquid manure and subsequent runoff issues in very low moisture and even dry conditions continually create problems for all the nearby residents. How can it be reasonably expected that problems associated with storing 13.1M gallons at this location can be adequately controlled?

    In October 2010 in the area of the existing pit, a manure spreading operation led to a spill that impacted the waters of the Kewaunee River, lands of the State of WI, a Kewaunee County Park, and private landowners. [This event was presented via PowerPoint Presentation to the WDNR in a manner that intended to make light of the situation with humor. We have a number of issues with the response, reporting, and remedial actions associated with that spill]. On a consistent basis during fall spreading operations (once again in October 2011) residents report problems with runoff and discharge of liquid manure in the area of Birchwood Rd. These areas contain tile lines and surface waterways that offer multiple routes to the Kewaunee River and threaten the surrounding air, land, and water quality, as well as personnel safety concerns of the residents for their wells, health, and quality of life. The existing storage pit should not be considered an appropriately constructed or managed facility suitable to be considered for “expansion”. The functionality and design of the existing pit is questionable at best. This existing pit appears to be abandon as of now which is a relief because it is not up to any reasonable standard design. Based on the proposed plan and the existing storage, this new storage appears to be approximately 18x the capacity of the existing pit, and with the previous problems of the area, such an increase in volume cannot be tolerated! We remind you that the proposed design for this new satellite facility indicates that no automatic monitoring will be installed. The WDNR should not accept any risk of an undetected leak at this location that has already proven to impact the Kewaunee River. The October 2010 spill was identified via the southern route across the Swintosky-Ratajczak-Kewaunee County property (see attached aerial map), and an attempt was made to alleviate the spill and stop entry into the Kewaunee River at Ransom Moore Lane. The northern route across Kopacz-Pelishek-State of WI property was not identified until much later in the day after manure had already reached the river and been reported by fisheries staff. Efforts to block this route only included placing sand along the surface waterway at the Kopacz/Pelishek property boundary. No effort was made to control a tile line under the surface waterway which outlets into a surface waterway on the Pelishek/State of WI land with direct route into the Kewaunee River. The northern route provided a path north of the fisheries facility for manure to runoff into the river during the fall salmon and trout harvest. The southern route discharges into the Kewaunee River just south of the fishery. These waters are protected and precious fish habitat which is highly utilized for public recreation fishing and general enjoyment.

    Based on previous events, if this storage facility is expanded in size and another discharge occurs, we feel that protection of the lands and waters of the Kewaunee River Watershed and local residents can be adequately controlled due to the combination of the multiple spill discharge routes along with increased volume of manure.

    The previous events, issues, actions, and subsequent discharges into the Kewaunee River are cause to doubt the ability to control future events as well as fulfill the goals of the WDNR Water Division Monitoring Strategy, the goals of the WDNR to protect the lands and waters of Wisconsin, and the ability of the owner to adequately respond to, monitor, and report waste problems. Approving the expansion to the storage pit capacity only creates further concern for immediate residents and members of the public. While these concerns so far are associated with the enforcement, performance, and consequences of the WDNR and permit holder to maintain overall goals of the state to protect the environment, we have yet to fully touch on the personal property concerns of the local landowners, or the impact to public recreational property users.

    To summarize the proposal, this new “to be expanded pit” is…
    Miles from the source property
    Near more homes and private lands than the source property
    Impact on more personal wells
    Air quality issues impacting more families, a restaurant, and public recreation land
    Impact on more families and traffic due to transport of the manure
    Decreased property values in an already depressed real estate market
    Nearer multiple direct discharge routes into the Kewaunee River and Lake Michigan
    To operate in an agitated manner that will lead to reduced air quality
    To be filled and emptied via tanker trucks
    In the past, trucking at the intersection of Birchwood Rd and Cty F has been dangerous.
    25+ children live and play in the immediate area
    Birchwood Rd includes a Deaf Child area
    Tankers travel the routes at high rates of speed and cut corners sharply

    The requirement to place a liquid manure storage facility no closer than 250’ from private wells must be scrutinized! We are requesting a 1000’ setback from private wells due to the size of this facility. When the 250’ regulation was enacted, it did not consider nor address storage facilities of this size and magnitude. Based on information of the past, it is estimated that this facility is larger than any facility at the time the 250’ regulation was put in place. Therefore we request a proportional setback relative to the total increased capacity (approximately 4x greater). The 250’ setback from wells is a MINIMUM requirement for facilities greater than 300,000 cu ft. Residents at this proposed location now will have to worry about groundwater quality impacts from the Kewaunee Landfill in addition to this proposed pit.

    Table 2 from the NRCS Waste Storage Facility Code 313 defines minimum criteria for larger storage facilities and farms as being greater than 300,000 cubic feet capacity. 13.1M gallons equates to 1,756,467 cubic feet – 5.85 times larger than what is considered in the Code Table! This criteria published in 2005 is outdated and does not adequately address the monstrous operations, facilities, and waste products of these mega factory farms. Since the table and code establishes criteria as minimum requirements (i.e. greater than or equal to 250’ separation to wells, greater than or equal to 5’ thick clay side liners, etc.) it is not without reason to require much more robust design parameters to protect the private residents of this area who live more than 3 miles from the source farm from this potentially disastrous satellite storage facility. [Note that despite the proposal outlining 13,139,290 gallon capacity (1,756,467 cu ft), the physical capacity per the site plan and sections equates to 2,666,496 cu ft (19,946,775 gallons). Only if “operating levels” are relied upon and controlled will the stated 13.1M gallon capacity be maintained.]

    The overall devastating reduction in air quality associated with an agitated 13,139,290 gallon storage facility cannot be tolerated for a satellite pit 3 miles from a source farm! The population density is greater in this proposed area than at the source farm (where the air quality is already horrible based on herd size and existing facilities). These private properties and public recreational lands are downwind (east) and downhill of the proposed satellite site, with the river valley approximately 100’ lower elevation. The intensity of the denser odor infused air has been proven to accumulate and linger in the lower elevations. The State of WI Besadny Hunting grounds are downwind and downhill (thousands of pheasants are stocked here each fall and this property is a key small game, turkey, and deer hunting area). The Kewaunee County Parks, Winter Park and Bruemmer Park Zoo, are downwind and downhill. State of WI snowmobile trail corridor passes through the river valley and within a half mile of the satellite pit. The Kewaunee River is a highly active recreational fishing area downstream of the discharge routes, and downwind and downhill of the facility. The concentrated population centers (residentially zoned) of the unincorporated towns of Birchwood and Footbridge are downwind and downhill of the facility. We insist that you study and report on the impacts this facility will have on the Kewaunee County Air Quality Standards (and Kewaunee County’s continued inclusion on state air quality watch lists). Everyone we talk to are expressing concerns with greatly diminished air quality in this denser private residence and public recreational area.

    Additional permit conditions must be set forth if this proposal is still deemed acceptable, given the great deal of public concern. While we partially agree with the conditional items listed in the WNDR permit response dated 10/18/2011, we are also requesting that additional requirements and conditions are met for this proposal.
    1) 1000’ setback from private wells of residential dwellings, protecting citizens otherwise unaffected by the Ponderosa farm three miles away. If a 250’ minimum setback is required from a facility with 300,000 cubic feet capacity, a much greater setback is necessary from this 1,738,000 cubic foot facility.
    2) Install a 6’ thick clay liner plus geomembrane liner which would be similar to the county landfill construction in the same area, and more adequately address the enormous capacity and weight of this facility. At minimum install a 5’ thick clay liner per NRCS Code 313 Table 2.
    3) Install a geotextile membrane cover at least 2.4mm thick, and maintain cover from April through October. Due to the concentration of private residences so near this satellite facility, and concentrated area of public recreation, all odor control measures should be enacted.
    4) Install and maintain mature cedar trees along the berm to reduce line of sight of this “eyesore”, and airborne odor. Installation to be designed per NRCS Technical Guide Standard 380.
    5) Additional solid separation and reduction to less than 2% solids. Since the ponderosa farm uses the solids for animal bedding anyway, additional separation is not without benefit of just reducing odor.
    6) Install and maintain active and alarmed monitoring systems. As noted, a leak of this huge facility would be completely devastating to the residents’ wells, property, lands and waters of the state. The effort to combat and clean the spill would be immense. Constant monitoring, early detection, and immediate response are a must for a satellite facility of this capacity.
    7) The owner of this proposed satellite pit should pay for testing of the wells prior to installation, and on a periodic basis to ensure contamination is not occurring via leakage. Testing of samples shall be sent to a laboratory of the residents’ choice. The design criteria for clay liners admittedly accounts for leakage, and with the proximity to so many private wells, contamination monitoring is a must.
    8) Limiting of tanker truck operations to normal working hours, 7am to 7pm due to the concentration of private residences and concern for general traffic safety. Additional consideration for school bus traffic hours of operation due to the concentration of children in the area and concerns for their safety.

    A specific concern we want to have addressed is the increased tanker traffic at this proposed satellite storage location.
    What road route will be used for tanker trucks?
    Note: if a tanker holds 5700 gallons, it will take 2281 tankers to fill the 13M gallon pit.
    Are the tanker truck operators licensed?
    Are the employees of the farm authorized to perform such work in the state of WI?
    Are the tanker trucks registered for operation on the proposed roads?
    Are the roads GVWR going to be exceeded?
    What impact to road conditions will the increased traffic have?
    Who can we contact to report spills?
    How will the owner clean up spills on the roads?
    Are grants and subsidies being used to pay for the increased operating costs of transporting this manure 3 miles away?

    The township of West Kewaunee ordinances and mission contain a focus on preserving prime farmland. This structure in total will cover over seven acres of prime farmland when finished grade and access driveways are included. Despite this facility not requiring strict adherence to zoning ordinances associated with buildings, it does not uphold the mission of West Kewaunee to preserve prime farmland.

    In summary, simply put, the increased amount of excessive manure stored in the proposed satellite location has a potential to impact far more residents’ homes, wells, and lives than a pit at the source location due to the concentration of residents. An increase in storage has a much higher potential for detrimental consequences to the Kewaunee River / Lake Michigan Watershed area due to existing configuration of the farmland drainage. Public recreational uses are highly concentrated in the area, bringing air quality concerns to the front of the minds of the users. Considering these issues in conjunction with the previous spill and consequences of a potential spill, we are opposed to construction of the proposed facility.

    It is sickening to know that this proposed satellite facility is being proposed in the first place, and extremely disheartening that the permit is being revised, or even considered for approval without proper input from the affected residents, increased requirements/conditions, and updated design criteria that would adequately address the huge capacity of this satellite pit. How and what will it take to come to a conclusion based upon reason and logic, that this satellite liquid manure storage pit, three miles away from the source of the problem, with the capability of holding 13.1M gallons of liquid feces, is not at all acceptable or even logical? John Pagel should be building this new storage at the source of the problem, where existing storage is already located, land is available, soil conditions are essentially the same, no additional transportation will be required, the site can be monitored for leaks (along with the existing storage), contamination impact already exists, an emergency response can be far more effective than responding to a satellite location, and all the impacts/issues associated with a liquid storage facility and any consequences already exist BECAUSE THERE IS ALREADY EXISTING STORAGE ONSITE. At a minimum he should have to prove without a doubt that this satellite site is better than his existing site – the reasons outlined in the proposal are baseless as noted throughout this letter. (And tread lightly, if the existing source location at the ponderosa farm is not adequate for this new 13.1M gallon capacity, how can the existing 40.9M gallon capacity be seen as adequate?)

    The immediately impacted residents in the area have not been notified by the owner nor WDNR of this proposal in any manner other than the public WDNR posting of the permit modification in the Green Bay Press Gazette. That posting contained no details relative to the shear size of this facility. The general public, even the residents directly across the street from the proposal, have not been adequately informed, engaged, or allowed an adequate opportunity to fully express all their concerns with this proposal that just does not make sense. We have scrambled over the past 28 days to accumulate the details of the pit and impacts to the community. Why have the residents and public not been more informed of such a huge facility? What is it that the residents need to do in order to be heard and have a voice in this issue? With the monstrous sizes of facilities associated with these megafarms, communication and public input must be considered vital to the approval process. Additional media attention is definitely warranted. Additional legal action may be necessary. With assistance from the Midwest Environmental Advocacy Group, and local political parties, we plan to bring more attention to this proposal. While discussions and actions are ongoing, we question what it will take to bring further scrutiny and evaluation to this baseless and detrimental proposal now when we need it most? What will it take to revisit the design criteria for these huge facilities to adequately address the “new megafarm” practices? The surrounding private landowners can shut down access to snowmobile trails, stage protests, boycott, require additional safeguards and restrictions on the storage facility, involve the media, bring political opposition, etc, but with what true impact? What will it take to enact stricter regulations and requirements, perform additional studies on these huge facilities, and simply see that a proposal such as this for a huge satellite facility makes little sense?

    The city of Green Bay and surrounding communities whose drinking water comes from Lake Michigan also need to be made aware of this huge storage facility at a location which has produced runoff that drained into the Kewaunee River in the past and impacted the waters of Lake Michigan. The clockwise current in Lake Michigan will direct any discharge via the Kewaunee River watershed, north to the water supply intake facility. The beaches, waters of Lake Michigan, and drinking water for dozens of communities are all in jeopardy with this proposed expansion, not even considering the numerous other huge liquid manure storage facilities on the lakeshore.

    Statutes, ordinances, and regulations are currently inadequate. They do not address the huge capacities and discharge capabilities of these mega factory farms. The impact on human health, air quality, water quality, and land quality is our utmost concern and must be made top priority of the WDNR. Even conditions placed on the approval simply address the adverse symptoms, not truly fixing the cause of the problem. Additional studies associated with the vast sizes of the factory farms are required. Additional rules, requirements, regulations are all needed NOW in regards to how the waste products are controlled and their impacts to the public of this state!

    Sincerely,

    Concerned citizens of the town of Birchwood, county of Kewaunee, state of Wisconsin, and the United States of America

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  3. Tim,
    Your letter illustrates the frustration felt all over this state on this issue. It’s a huge problem that deserves more than a cursory review and fast track approval. Keep us informed on progress and developments. You have our support.

    Kewaunee Cares

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  4. Harriet

    Tim,
    Very well spoken….right on.
    All the citizens of Kewaunee Co. should take heed…your property values will
    all be impacted, but guess what, your taxes will keep creeping upward anyway and your tax dollars will even pay for road repair if and when the super fecal wagons start rolling and break up the highways! Also remember NIMBY, Not In My Backyard can quickly become a reverse NIMBY, Now In My Back Yard!
    Keep up the good fight!
    Harriet

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