Guest post: Standing up for outstanding waters

Location of proposed hog factory has shallow groundwater that could lead to cascading pollution.




3 minute read

Deb Ryun is executive director of Wild Rivers Conservancy of the St. Croix and Namekagon.

Trade River (Greg Seitz/St. Croix 360)

Cumberland LLC has applied for a permit to build a Confined Animal Feeding Operation (CAFO) for hogs, near Trade Lake, in Burnett County, Wis. It’s estimated that this hog factory will produce about 13 million gallons of waste annually. This manure would be stored on the 38-acre hog production site, then spread on nearby farm fields.

As part of their application, Cumberland is required to identify the fields which will be used. Wisconsin law requires that CAFOs must have “adequate acreage available for the manure produced,” and severe restrictions are placed on spreading manure where groundwater is less than 24 inches below the surface. How do these requirements compare with Cumberland’s proposal?

Mapping shows that at least 30 percent of their proposed acreage for spreading manure has a water table depth of less than 12 inches, half of the required 24-inch minimum. Further, nearly 80 percent of the proposed fields have additional legal restrictions on spreading, due to proximity to important surface waters, including lakes, rivers, streams, and wetlands.

Cumberland’s application, as written, clearly does not meet legal requirements for manure disposal and should be rejected on that basis alone. However, this should not be a matter of simply tweaking the manure disposal plan and reapplying. The problem is greater than this.

A study of groundwater in Burnett County states that its overall quality is now very good and that no health risks are present. Burnett County is a very water-rich county, with more than 500 lakes, 10 rivers, and 145 miles of streams, including 66 miles classified as trout streams. The Namekagon and St. Croix Rivers, along with seven other water bodies, are listed as outstanding resource waters.

But a combination of shallow groundwater and sandy soils makes our groundwater particularly susceptible to contamination. County data show that more than 75 percent of the county has groundwater less than 20 feet below the land surface, and this groundwater exists as part of one large, continuous aquifer, much of which flows to surface water. Pollution of groundwater from application of manure in fields where the water table is near the surface could thus be disastrous, affecting not just local water but the whole St. Croix River system. This is not just a problem with one particular CAFO application; Burnett County area is geologically unsuited to CAFOs.

Since early 2019, the Wild Rivers Conservancy has been actively engaged with local efforts to stop this hog factory. We support the development of ordinances and policies at the township level in a newly developed consortium. The Conservancy is providing technical expertise related to groundwater, surface water, air pollution, manure management, topography, and other variables. The Conservancy is very much engaged in this effort and will remain so.

We have focused here on groundwater concerns, but there are also other, well-documented, negative environmental, economic, and social consequences associated with CAFOs. On a narrow, local level, no one would be happy having millions of gallons of manure stored or spread on fields near their home. But the problems with this CAFO proposal are neither narrow nor local; they are broad and regional. There are ample reasons for this project to be opposed and, ultimately, rejected.


St. Croix 360 offers commenting to support productive discussion. We don’t allow name-calling, personal attacks, or misinformation. This discussion may be heavily moderated and we reserve the right to block nonconstructive comments. Please: Be kind, give others the benefit of the doubt, read the article closely, check your assumptions, and stay curious. Thank you!

“Opinion is really the lowest form of human knowledge. It requires no accountability, no understanding. The highest form of knowledge is empathy, for it requires us to suspend our egos and live in another’s world.” – Bill Bullard

9 responses to “Guest post: Standing up for outstanding waters”

  1. peter gove Avatar
    peter gove

    Thank you, Deb Ryun and WRC for your leadership and advocacy to keep these essentially unregulated CAFO’s out of our watershed, unless their manure is treated like any other high volume biologic waste is treated by virtually any other municipal, commercial and industrial source before discharge into public surface or groundwater – on site secondary or tertiary treatment. It’s time for the CAFO industry to wake up to this absolute requirement to protect surface and groundwater, and also for those that regulate, it starting with the WI DNR, MN PCA and US EPA.

  2. Karen A Hannah Avatar
    Karen A Hannah

    How to add my voice to this discussion as a MN resident? Clearly the St. Croix is affected by governance in both states but I wonder if MN resident input is valued in fights like this one. Input?

  3. Randall Neumann Avatar
    Randall Neumann

    I just signed a survey/petition to voice my disapproval of this project

  4. Mark Hove Avatar
    Mark Hove

    Thank you for this valuable information, Deb and Greg.

  5. linda helland Avatar
    linda helland

    thank you, Deb, for a very informative objection to the proposed CAFO. how can i add my objections to any proposal? i have not seen any notice of citizen input issued by any of the regulatory agencies involved.

  6. Dunaski Avatar

    “Could lead to cascading pollution” Why don’t we just be transparent and get real! There is no “could” in hog farm pollution. That’s a given! Do the research. Factory Farming despite being inhumane and torturous is a world leader in environmental pollution! And everyone’s ok with this existing? WTF??!! All because you gotta have your bacon. Shameless

  7. Mark Peacock Avatar
    Mark Peacock

    Georgetown needs to join the townships group opposing pig factories in our area. It could be years before the DNR can or will act to offer us some protection and Polk County’s Board offers no protection for its citizens at all. “Ignore it and it will go away?” I think not. Without some effective action on our parts, things happen to us, rather than with us, and we will not like the ugly results.

  8. Valoree Dowell Avatar
    Valoree Dowell

    Where can we as individuals weigh in on this? Need some direction—names, addresses, timeframe, etc. Ty

  9. Janet Scepurek Avatar
    Janet Scepurek

    In my opinion, just look at the horrendous record of the CAFO near Emerald, WI, Blue Sky Dairy. I can’t understand why on Earth the county should give a permit to expand when they can’t even deal with their current amount of manure! In fact, while they were applying to expand I brought 20 copies of the local newspaper to the St Croix Board of Supervisors meeting with side-by-side headlines that creameries were not taking milk because of the oversupply (i.e., there’s no good reason to expand when they currently could not sell the milk) and the CAFO was not in compliance with something…I don’t remember exactly…if it was cuz they didn’t report their massive manure spill for over 3 months, as required by their permit, or they spread manure when it was raining and it ran into the ditches and killed fish. All I know is that developers will lie and say anything to get what they want and have no intention of keeping their promises. And this was after Walker severely cut the DNR staff and there was only one guy for several counties.


You may republish this article online or in print under our Creative Commons license. You may not edit or shorten the text, you must attribute the article to St. Croix 360 and you must include the author’s name in your republication.

If you have any questions, please email


Creative Commons License Attribution-ShareAlikeCreative Commons Attribution-ShareAlike
Guest post: Standing up for outstanding waters