Kinnard  CAFO Comments

January 19, 2022

Attention Tyler Dix:

Kinnard Farms is already larger than it was when groundwater in the area was so contaminated that a “massive regulatory failure” was declared by a judge in 2014. Groundwater issues are far from resolved in the area, so it appears gravely irresponsible to allow them to nearly double the size of their operation, if they so choose, as long as they can prove that their manure lagoons can handle the volume. How did local groundwater quality (for which we have much better information than almost anywhere else in the state) and drinking water goals impact the DNR’s animal unit cap? These should have been the primary considerations, as the DNR is the body entrusted to keep our water safe, clean, and abundant. All animal unit caps should be primarily based on water quality and quantity considerations, not a farm’s capacity to store and spread manure. Unless and until this is the case, any animal unit cap is simply an arbitrary number. 

We were pleased to see that groundwater monitoring will be required for more than just the production facility. This is an important step forward, and will provide more important information. However, I would posit that there is already sufficient information about the groundwater quality in the area that the DNR should be ready to immediately act in light of issues. There needs to be a holistic plan for addressing these landscape-scale issues, and while Kewaunee County and eastern Wisconsin have more rules and regulations on this front than most of the state, implementation has been painfully slow, positive results have yet to be seen, and residents continue to struggle with contamination at alarming levels.

Crawford Stewardship Project is based in southwest Wisconsin, and has over a decade of experience closely monitoring our local CAFO, Roth Feeder Pig, and studying the sensitive karst hydrogeology of our area. We have closely followed the developments in eastern Wisconsin, with hopes that the actions taken there will soon translate into similar or more stringent protections for our area. We urge that action be taken before we are in a groundwater health crisis like Kewaunee County, but as rule after rule fails to move forward at the state level, the county continues to abdicate responsibility, and our local CAFO is slated to be permitted to expand exponentially, we are quickly losing faith that significant preventative action will be taken in time. Our supporters have lost patience and are desperate for solutions. We hope to be able to work with the DNR and other state agencies to proactively address these issues in a collaborative, inclusive, and science-based manner. 

Please recognize that this permit will set precedent for many future permits, and that it is of critical importance to make sure a high bar is set for water quality and quantity protection, or we will continue to live with unacceptable conditions in much of our rural water for generations to come. 

Thank you for considering our comments.

Forest Jahnke
Program Coordinator
Crawford Stewardship Project
fjahnke@crawfordstewardship.org