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Richfield Dairy Site Layout: Site Layout

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Concentrated Animal Feeding Operations (CAFO) and the Richfield Dairy

Concentrated animal feeding operations (“CAFOs”) are agricultural enterprises where animals are kept and raised in confined situations. They congregate animals, feed, manure and urine, and production operations on a small land area. Feed is brought to the animals rather than animals grazing or otherwise seeking feed in pastures, fields, or on rangeland.1

Dairy CAFOs are becoming increasingly common in Wisconsin. They can dramatically change both the environmental and social/economic landscape in a rural community.

Environmental Risks. Midwest Environmental Advocates well explained the risks that CAFOs pose to ground and surface water quality in a brief recently filed with the Wisconsin Supreme Court:
Large livestock facilities, including CAFOs,2 pose serious potential hazards which can significantly harm Wisconsin's water quality. Due to the sheer volume of manure generated on site,3 facilities containing thousands of confined animals are likely to produce agricultural point and non-point source pollution if not properly located or managed. According to the U.S. Environmental Protection Agency, agricultural runoff is the leading source of water quality impairments on surveyed lakes, rivers and streams.4 Runoff from poorly managed CAFOs results in animal waste contaminating nearby waterways with bacteria, pathogens, viruses, microbes resistant to antibiotics, and excessive levels of nutrients.5 Nitrate, a nutrient present in run-off from livestock manure, poses a significant public health risk at high levels. Human consumption of nitrates above the federal standard (by drinking nitrate-contaminated groundwater supplies) may increase the risk of cancer and birth defects.6 It is even more dangerous for children. Ingestion of nitrates by infants has been shown to lower levels of oxygen in the blood, leading to “blue-baby syndrome,” a condition of oxygen deprivation that may prove fatal.7

The devastating impacts of poorly managed or improperly sited CAFOs are well recognized in Wisconsin.8 The number of CAFOs in Wisconsin has sharply increased in the past 15 years, from 10 in 1995 to almost 160 in 2010, increasing the threat of runoff pollution to Wisconsin of lakes, river and streams.9 This concern was recently stated by both Senate Majority Leader Scott Fitzgerald and Assembly Speaker Jeff Fitzgerald, who halted construction of a large dairy operation sited within one mile of a lake in their home districts, on the basis of water quality considerations.10
Adams v. Livestock Facilities Sitting Review Board, Case No. 09-AP-608, MEA Brief, 4/29/11.

Aside from ground and water pollution, CAFOs can also pose other environmental risks, such as air pollution and odor. For example, the Wisconsin Department of Natural Resources (“DNR”) has tentatively predicted that the Richfield Dairy will emit 124 tons of ammonia per year and 10 tons of PM10 (particulate matter smaller than 10 microns). CAFOs have also been criticized for mistreating animals, relying excessively on antibiotics and hormones, and causing outbreaks of food-borne illness.11

Social and Economic Risks. CAFOs are often criticized for their impacts on farmers and rural communities. For example, a recent report on CAFOs by the nonprofit organization Food and Water Watch blamed CAFOs for reducing prices beef, poultry, and dairy farmers receive and driving small farmers out of business (though these low prices were often not passed onto the consumer).12 Small dairy farmers have also typically resented CAFOs’ practice of locking up all local rental acreage for land spreading manure, which drives up rental prices and makes it economically infeasible for small farmers to spread manure because they have to transport it longer distances.

The Food and Water Watch report additionally noted:
The earnings from locally owned and locally controlled farms generate an economic “multiplier effect” when farmers buy their supplies locally and the money stays within the community. The loss of nearly 1.4 million cattle, hog and dairy farms over the past 30 years has drained the income out of rural communities. Fewer, larger factory farms pump less money into rural communities. Several studies have reported that large-scale livestock operations were more likely than smaller livestock farms to bypass local suppliers for inputs like feed and equipment. An Iowa study found that more than two-thirds (70 percent) of smaller livestock operations bought feed locally, but only two out of five (43 percent) large-scale livestock operations bought local feed. The economic multiplier effect is much lower with large corporate-owned factory farms than with smaller independent farms.13
 Additionally, the Wisconsin Center on Investigative Journalism recently published an award-winning series called “Dairyland Diversity,” which found that as dairy herds expand in Wisconsin, farmers are increasingly relying on immigrant labor to staff CAFOs.14 The series cited a report noting that some portion of this immigrant workforce is here illegally, and that immigrants typically work for a lower wage (about $9 - $12 dollars an hour).

Despite the trend of some farms toward expansion, most dairy herds in Wisconsin remain under 200 head of cattle. Also, there are other types of dairy expansion occurring, such as rotational grazing herds or organic dairy farms.15 Thus, CAFOs are not the only dairy farm expansion model in Wisconsin at present.


About MilkSource. The Richfield Dairy is being proposed by MilkSource Holdings Inc., a corporation formed in 1979, and the newly formed Richfield Dairy, LLC.16 In recent years, MilkSource has constructed or purchased several large CAFOs across Wisconsin. According to the MilkSource website, its current sites include: Tidy View Dairy, 6,800 cows (Kaukauna, Outagamie County); Omro Dairy, 2,700 cows (Omro, Winnebago County); Rosendale Dairy, 8,000 cows (Pickett, Fond du Lac County); and Calf Source in Greenleaf (Brown County), with 7,500 calves. It has also proposed New Chester Dairy in Adams County, with 4,300 cows.

MilkSource has three partners: Jim Ostrom, John Vosters, and Todd Willer. While CAFOs have received much political support in recent years in Wisconsin, MilkSource’s expansion strategies have been somewhat controversial even among the CAFO community because it has expanded at times of historically low milk prices and has been perceived as flooding an already struggling market with large volumes of milk. The Rosendale Dairy was also highly controversial among persons who oppose CAFOs, such as family farm advocates and environmentalists, because of its unprecedented size and scope.

MilkSource’s consultant for its environmental permits is Conestoga-Rovers & Associates, an international firm whose Green Bay office frequently performs consulting work for CAFOs. Its agronomist is Polenske Agronomic Consulting. Its legal counsel is Michael Best & Friedrich, LLC, which is essentially the go-to law firm for CAFOs. That firm also represents the Dairy Business Association, a Wisconsin trade organization that has been very effective at lobbying for large livestock farms.

The Dairy. The Richfield Dairy is being proposed on about 141 acres in the Town of Richfield. According to the DNR:

The proposed dairy facility would house 4300 milking / dry cows and 250 steers for a total of 6270 animal units. Proposed facility structures include a sandbedded cross-ventilated freestall barn (416’x1232’), 80 stall milking parlor (106’x164’), livestock holding area (74’x194’), concrete feed storage pad (680’x765’), vegetated treatment area for precipitation runoff after collection of first flush (932’x348’), sweet corn silage bunker (658’x221’x12’height), HDPE lined sweet corn silage attenuation basin (23,500 sq. ft.), manure processing building (92’x210’), concrete lined separated manure solids storage area (202’x384’x12’height), animal mortality storage facility (14’x24’), covered concrete lined waste storage pond (480’x400’x28’deep), uncovered concrete lined waste storage pond (480’x250’x15’deep), commodity shed (120’x300’), shop (60’x120’), two high capacity water wells, four stormwater management ponds, Fuel Depot (24’x70’), weigh scale (12’x75’), potable water supply system, a domestic waste sewerage system and other lesser facilities.

The proposed Richfield Dairy facility would be located is the southeast corner of the intersection of 1rst Drive and Cypress Avenue. Primary access to the facility would be from 1rst Drive. Total site disturbance entails the conversion of 115 acres of existing cropland to farm buildings, production area and ancillary area. All livestock will be housed within a cross-ventilated and sand-bedded freestall barn. The combined annual estimated quantity of manure and process wastewater (including precipitation runoff) is 55.3 million gallons, plus an additional 8,552 tons of separated manure solids. Waste storage ponds (WSP #1 & #2), will have a combined design capacity of 33.2 million gallons (excluding freeboard), which represents approximately 205 days of storage for the proposed wastewater stream. The applicant owns or has agreements to land spread on 16,429 acres, with all cropland generally located within a five-mile radius of the facility.

Richfield Dairy is required to submit a high capacity well permit application to the DNR. Water usage at the facility is estimated to be about 52.5 million gallons per year, which includes 44 million gallons for animal watering /cleaning and 8.5 million gallons for evaporative cooling of the barn during hot weather. Construction of the proposed facility is tentatively scheduled to begin in March, 2012. The facility anticipates reaching the 6,270 animal unit threshold by 2013. The project cost is estimated at $35 million. The facility expects to employ ~ 40 staff with an estimated annual payroll of $1.5 million.

WI DNR, Public Notice of Intent to Issue a Wisconsin Pollutant Discharge Elimination System (WPDES) Permit No. WI-0064815-01-0.17 The DNR notice states the receiving water for any discharge are the Fordham and Little Roche Cri Creeks of the Central Wisconsin River Basin.

2 Wisconsin law defines Confined Animal Farming Operations (“CAFOs”) as facilities containing more than 1,000 animal units. See NR s. 243.03(12); Wisconsin Department of Natural Resources, Frequently Asked Questions: Concentrated Animal Feeding Operations, available at
3 In terms of scale, 1,000 cows produce as much daily waste as 18,000 humans. Large CAFOs can produce more excrement in a day than small cities treat in sewage. Wisconsin State Journal, Feb 28, 2010, “Tracking a rising tide of waste”; factory_farms/managing_manure/article_df56a7f2255-11df-90a7-001cc4c03286.html.
4 See United States Environmental Protection Agency, Protecting Water Quality from Agricultural Runoff (2005), available at
5 See Michel Greger, MD & Gowri Koneswaran, Esq, The Public Health Impacts of Concentrated Animal Feeding Operations on Local Communities, 33 Farm Community Health 11, 12 (2010).
6 Barry Estabrook, “Do Nitrates from Well Water Cause Cancer?” The Atlantic, July 8, 2010, available at
7 Id.; see also Consumer Factsheet on: NITRATES/NITRITESU.S. Envtl. Prot. Agency, available at
8 See Charles Duhigg, Health Ills Abound As Farm Runoff Fouls Wells, The New York Times, September 17,2009, available at
9 Kohler and Ridlington, “Wisconsin Lakes at Risk,” Wisconsin Environment Research and Policy Center, March 2011 (citing WDNR’s, Farms With Water Pollution Permits,,
10 May 2010), available at
11 The Fitzgeralds acknowledged, “This project would have severely affected the water quality of the Fox Lake and caused considerable damage to property owners…”; “Top GOP Lawmakers Step In to Stop Big Dairy Farm in their Home Districts,” Capitol Times, April 1, 2011,
12 Food and Water Watch, Factory Farm Nation: How America Turned its Livestock Farms into Factories (Nov. 2010), available at
13 See footnote 11.
14 See footnote 11.
1 their-hispanic-work-forces/
15 University of Wisconsin Program on Agricultural Technology Studies, Dairy Structural Change in Wisconsin, Fact Sheet No. 25 (Oct. 2007)
16 See
17 Available at
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