Commenting on WPDES permits

One way to protect yourself from a livestock factory operation is to influence the content of WPDES permits issued by the DNR. Every concentrated animal feeding operation (CAFO) must obtain a permit from the DNR.

The DNR includes a series of prohibitions in each permit. These prohibitions include:

• no discharge from the facility, except in a 25 year 24 hour rainfall event or chronic or catastrophic rainfall event;no manure storage in a water quality management area, which includes…;
• no manure spreading within 200 feet of a stream or conduit to groundwater unless the manure is incorporated within 72 hours. See NRCS Standard 590.

The DNR also includes various conditions in each permit, including:

• the requirement to prepare a Nutrient Management Plan that considers the soil conditions and nutrient needs of the crops, and spread manure in accordance with that plan;the requirement to analyze manure nutrient content, take soil samples every four years, and keep daily manure spreading logs;the requirement to construct and maintain all manure storage facilities to minimize leakage and spills, in accordance with NRCS Standard 313; and
• the requirement to install runoff controls at each part of the facility to prevent discharges.

The DNR has a lot of discretion to include additional permit requirements if necessary to protect water quality. These include requirements to:

• spread manure according to the phosphorous needs of crops, rather than the nitrogen needs, where manure spreading may cause pollution by runoff;require core sampling of the soil in an earthen lined manure storage pit if critical groundwater, geologic, or construction conditions warrant;install of groundwater monitoring wells if critical groundwater, geologic, or construction conditions warrant; and
• any other additional requirements necessary to achieve water quality standards for nearby waters.

You are entitled to receive notice of draft permits and review them to ensure they comply with state and federal law. To get on the mailing list, contact:

Keri Behm, DNR-Madison
behmk@dnr.state.wi.us
608-266-3291

Contact MEA for technical assistance in drafting comments on WPDES permits for new and expanding industrial-scale operations. For more information, contact advocates@midwestadvocates.org or at 608-251-5047.