City of Ashland has requested a detailed Environmental Impact Statement (EIS) from the Wisconsin Department of Natural Resources.
The letter by Mayor Debra S. Lewis requesting the EIS is dated last Friday and comes as sentiment against the proposed Concentrated Agricultural Feeding Operation (CAFO) has rapidly grown in Bayfield and Ashland counties in far-northern Wisconsin.
Lewis' letter is reproduced below:
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February 27, 2015
Ms. Cathy L. Stepp,
Secretary
Wisconsin Department of Natural Resources
P.O. Box 7921
Madison, WI 53707-7921
Via email: DNRSecretary@wisconsin.gov
Re: Badgerwood, LLC Hog Facility Reicks View Farm CAFO
Dear Ms. Stepp:
I write as the Mayor of the City of Ashland to respectfully request, in the strongest possible of terms, that the Wisconsin Department of Natural Resources require an Environmental Impact Statement (EIS) before taking any action to permit the operation of the proposed Badgerwood, LLC Hog Facility, also known as the Reicks View Farm Concentrated Animal Feeding Operation (CAFO) in the Town of Eileen, Bayfield County. While the CAFO would be located outside of the City of Ashland, some of the CAFO's greatest impacts would fall directly on the City of Ashland, due primarily to the location of the proposed CAFO near the headwaters of Fish Creek, and to Ashland's location, just seven or so miles east, at the mouth of Fish Creek, where Fish Creek enters Lake Superior's Chequamegon Bay.
I understand that the types of permits required for the CAFO to operate have generally been excepted by Natural Resources rule from EIS requirements, either as a "minor action" or as an "equivalent analysis action." However, I believe that the Badgerwood CAFO is of such magnitude and complexity that the DNR should exercise its discretion under NR 150.20(4), Wis. Admin. Code, to follow EIS procedures. Virtually every factor listed in NR 150.20(4)(b) points to the appropriateness of an EIS in this case.
The Ashland City Council recently passed, unanimously, a resolution calling on the Bayfield County Board to exercise its authority to adopt more stringent standards than contained in ATCP 51 to regulate CAFOs. In issuing the call, the City Council cited its concerns for safe drinking water, beach safety, tourism, and public health factors. I am confident that if the timing of the DNR's decision on an EIS for the project allowed it, the Ashland City Council would take similar action specifically to request that an EIS be required. As it stands now, the City's resolution directed to Bayfield County does state our policy on the matter and as such should be considered as a factor under NR 150.20 (4)(b)(2), that the "project may be in conflict with local . . . environmental policies."
The City of Ashland has the following specific questions which can only be answered by the careful preparation of an EIS :
l . What would the Badgerwood CAFO's environmental impact be on the City of Ashland's drinking water?
2. What would the Badgerwood CAFO's environmental impact be on the Chequamegon Bay fishery?
3. What would the Badgerwood CAFO's environmental impact be on the City of Ashland's swimming beaches?
4. What would the Badgerwood CAFO's environmental impact be on odors in and near the City of Ashland?
5. What would the Badgerwood CAFO's environmental impact be on small-scale farming near the City of Ashland?
6. What would the Badgerwood CAFO's environmental impact be on tourism in the City of Ashland?
I will briefly address each of these points so that you can understand why I am asking these questions. Clearly, at this point we all have more questions than answers, which is why an EIS is so important.
1. What would the Badgerwood CAFO's environmental impact be on the City of Ashland's drinking water?
The City of Ashland obtains one hundred percent of its drinking water from one intake pipe in Chequamegon Bay. The City's Utility Supervisor has advised the City Council that extensive algal blooms could greatly interfere with our intake and treatment of drinking water, requiring increased back-flushing of the system to unclog it, reducing efficiency, and raising costs. Installation of a second intake pipe would be a multi-million dollar project and is unaffordable for the City.
Chequamegon Bay has no algal blooms of any significance now. Our concern is that the CAFO will add nutrients to the Lake resulting in such blooms. We do not know how water circulation patterns in the Bay would affect our water intake were blooms to occur.
2. What would the Badgerwood CAFO's environmental impact be on the Chequamegon Bay fishery?
Ashland has a vibrant sport fishery on its doorstep in Chequamegon Bay. Summer and winter, visitors and locals alike find their way onto the Lake, contributing to our quality of life and the Ashland economy at the same time. Eutrophication, de-oxygenation, and fish die-offs would be devastating to this aspect of our lives and our economy. We are aware that CAFO's are thought to be responsible for eutrophication in other locales, and we are extremely concerned that it could happen here, too.
3. What would the Badgerwood CAFO's environmental impact be on the City of Ashland's swimming beaches?
Ashland's primary swimming beach is adjacent to the Fish Creek estuary and less than one mile from its primary mouth. The water is clear and clean and because it is shallow, ideal for young children. Algal blooms resulting from excessive nutrient loading from the CAFO could ruin this resource, as could infectious agents from pig waste.
4. What would the Badgerwood CAFO's environmental impact be on odors in and near the City of Ashland?
Ashland is a city of over 8,200 inhabitants. The prevailing west-to-east winds leave the City downwind from the CAFO and the fields where it intends to spread manure. Ashland is not an Iowa farm town where the smell of pig manure might be expected. Ashland is a lakeshore town where people come to breathe deeply of the fresh, invigorating air. We need to know if the millions of gallons of pig manure being collected and spread just a few miles upwind of us will detract from our fresh-air resource.
5. What would the Badgerwood CAFO's environmental impact be on small-scale farming near the City of Ashland?
Small-scale, sustainable agriculture is a thriving and growing sector of our local economy. Awareness and selectivity of what we eat in Ashland is on the rise and becoming part of our local "brand." The Chequamegon Food Cooperative just completed a major enlargement, fueled in part by a booming interest in eating healthy and local foods. The Co-op in turn provides support for local farmers through a number of innovative programs. People in Ashland like pork just as much as the next guy — which is why small-scale, local, sustainable, family hog farms such as Maple Hill, just outside Washburn, and Angel Acres, just outside Ashland, are very busy. The risk of importing swine disease from Iowa and thus destroying existing local farms is of serious concern to those of us who see sustainable agriculture as a key component in our economy.
6. What would the Badgerwood CAFO's environmental impact be on tourism in the City of Ashland?
By many measures, our area is the poorest in the state of Wisconsin. Our greatest source of wealth is our clean air and clean water. Without those assets we have nothing special to offer the visitor. The tourist coming "up north" wants to feel that he or she is going someplace special and pristine.
Many of us who live in Ashland have had the experience of standing by the shore of Chequamegon Bay, perhaps while on an evening walk or bike-ride, seeing a car or minivan pull up, maybe with license plates from South Carolina or California, and watching the driver and passengers get out, stretch, inhale a deep breath of Lake Superior air, and marvel at the blue water laid out before them. Often there is a smile; sometimes there is a look of amazement, and if there are children usually there is a race to the water's edge. Whatever it is, we know that the first experience of standing beside the largest freshwater lake in the world will stick with that person for a long time. Our nightmare: that same car pulls up, the driver steps out, takes a deep breath and chokes on the pig-manure scented air, and then has to tell her children to stay out of the algae and scum-laden water lapping on our beach.
The DNR needs to thoroughly assess the risk of this scenario coming about. The only way to do so is to perform a full EIS. The future of our lives as we know them in Ashland may well depend on the information that can only be developed through the EIS process.
Debra S. Lewis Mayor
cc:
Duane Popple
1300 W. Clairemont Avenue
Eau Claire, WI 54701
Via email: duane.popple@wisconsin.gov
CAFO Intake Specialist
WT/3
Wisconsin DNR
P.O. Box 715
Madison, WI 53707-7155
Via email: Tyler.Dix@wisconsin.gov
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