Existing environmental issues in the area are not a basis for denying a Wisconsin Pollution Discharge Elimination System (WPDES) permit to a concentrated animal feeding operation (CAFO).

That’s among the takeaways in a five-page response from the Department of Natural Resources to issues raised at a Nov. 28 public hearing on five WPDES applications in Kewaunee County.

The hearing was a combined hearing on the proposed reissuance for Dairy Dreams, Kinnard Farms, Seidl’s Mountain View Dairy and Wakker Dairy Farm and the proposed issuance for Sandway Farms. Thursday’s response was specific to the Seidl and Wakker applications, but it addresses a number of questions and comments that covered all five operations.

Many of those concerns addressed the need to protect groundwater quality in light of continuing evidence of contamination, and several speakers called for a moratorium on expansion of dairy herds.

“The DNR does not claim that the requirements of a WPDES permit, including the requirement to develop and implement a nutrient management plan (NMP), will guarantee that water quality will not be impacted,” says the DNR document sent to people who commented or expressed an interest at the hearing. “However, the permit contains a number of requirements designed to protect groundwater. The permit also requires compliance with groundwater standards, including for land application areas.

Among the practices to protect water quality that the DNR said have been built into the WPDES permits:

• Manure or process wastewater may not be applied within 100 feet of a direct conduit to groundwater.

• Nutrient shall not be spread within 200 feet upslope of direct conduits to groundwater unless the nutrient is effectively incorporated within 48 hours

• No manure application within 100 feet of direct conduits to groundwater (sinkholes, private wells)

• No causing fecal contamination of water in a well.

• No application on fields with soils that are 60 inches thick or less over fractured bedrock when ground is frozen or where snow is present.

• No application when snow is actively melting.

• No application on areas of fields that have less than 24 inches of soil to bedrock.

• Field verification procedures include ground depth evaluations on fields with mapped shallow soils. A detailed protocol for determining bedrock depth on fields with such soils is outlined in the NMP. All fields must be evaluated before applying manure.

Read the full response here: