MADISON, WI— A new report by the Environmental Working Group (EWG) and Midwest Environmental  Advocates (MEA) finds that in some areas of the state, including Kewaunee County and portions of the  Central Sands, there is not enough agricultural land to safely dispose of the manure generated by animal  feeding operations. The report raises concerns about the potential expansion of industrial-scale livestock  operations in areas that are already grappling with drinking water pollution. 

Using aerial imagery and publicly available data, EWG and MEA modeled current rates of application for  commercial fertilizer and animal manure in nine Wisconsin counties. The analysis, which is the first of its  kind in Wisconsin, shows that fertilizer and manure are being applied to farmland at rates that far exceed  what is needed by crops growing in the surrounding area. 

Nitrogen and phosphorus in manure and commercial fertilizer are essential crop nutrients, but excess  nutrients caused by overapplication of manure and fertilizer can cause nitrate contamination of  groundwater and pollute Wisconsin’s rivers, lakes and streams. 

An Overwhelming Amount of Manure in Kewaunee County 

The number of concentrated animal feeding operations, or CAFOs, in Wisconsin has dramatically increased  over the past few decades. As CAFOs multiply and grow larger, they continue to pump out massive amounts  of manure for disposal. The trend has been especially devastating in places like Kewaunee County, where  fractured bedrock and shallow soils make groundwater vulnerable to pollution. 

Kinnard Farms, located in Kewaunee County, is one of the state’s largest dairy CAFOs. The farm was at the  center of a landmark legal decision in July in which the Wisconsin Supreme Court affirmed the state’s  authority to limit the number of animals allowed under the farm’s permit and to require the farm to  monitor groundwater quality in areas where large amounts of manure are spread.

As a result of the ruling, the Wisconsin Department of Natural Resources (DNR) is now required to revisit  permits for Kinnard Farms and a number of other large CAFOs. Neighbors of Kinnard Farms point to the report by EWG and MEA as evidence that the DNR must set an animal until limit that does not allow for  future expansion.  

“The report confirms exactly what the citizen groups have said for years—Kinnard’s current water pollution  permit and nutrient management plan aren’t protecting our drinking water,” said Jodi Parins, a neighbor of  Kinnard Farms. “The DNR can no longer ignore the science that shows that concentrated animal feeding  operations don’t work for our water or our communities—not by watering down manure, not by capturing  methane, not by flushing gray water into our streams.”  

“In setting an animal unit limit for Kinnard Farms, the DNR must consider the overwhelming amount of  fertilizer and manure that is already being applied to fields in the area,” said Adam Voskuil, MEA Staff  Attorney and co-author of the report. “More cows would lead to more pollution—there’s just nowhere for  additional manure to be safely spread.” 

“Why isn’t the Wisconsin Department of Natural Resources more concerned about our health and the  environments of Kewaunee and Door Counties?” said Mike Bahrke, Executive Director of the Door County  Environmental Council. “CAFO manure is polluting the aquifer and contaminating wells in Kewaunee  County and likely Door County. The DNR has the authority and the power, and it’s time to protect our water  and our residents!” 

A Drinking Water Crisis in the Central Sands 

Residents of Wisconsin’s Central Sands region are equally concerned about CAFO expansion and contamination of their drinking water. The new report by EWG and MEA modeled manure and fertilizer  application in Portage County and found that—as in Kewaunee County—manure and fertilizer are being  applied at rates that already exceed the available agricultural fields’ crop nutrient needs.  

In response to the growing crisis, the DNR began developing new rules in 2019 for the application of  manure and commercial fertilizer in the Central Sands and other vulnerable areas of the state. Despite  strong public support, the new environmental protections faced opposition from industrial agriculture  groups and their allies in the legislature, and in November, the DNR announced that it would abandon its  efforts.  

The news that the DNR would not move forward with new groundwater protections was especially  disappointing for residents of Nelsonville, where half of all private wells tested are considered unsafe due  to pollution from agricultural fertilizer and manure. The ongoing water quality crisis has led local residents to call for increased accountability and oversight of large livestock operations like Gordondale Farms, a dairy CAFO with approximately 2,000 cows. The recharge zone for the groundwater that Nelsonville relies  on includes fields on which Gordondale Farms spreads manure. Like Kinnard Farms, Gordondale’s permit is  now subject to modification following the Supreme Court’s July ruling. The farm’s neighbors have asked the  DNR to require groundwater monitoring and to limit future expansion. 

“Like other neighbors of Gordondale Farms, we’ve seen a consistent decline in the quality of our well water,  said Nelsonville resident Lisa Anderson. “The EWG report confirms that what we’re asking for is both  reasonable and necessary.”

“This report shows that water quality in the Nelsonville area won’t improve on its own,” said local resident Katy Bailey. “We’re counting on the DNR to use its authority to protect our drinking water.” 

A Void of Important Information 

While the report provides a clearer picture of agriculture practices in those areas, it also reveals a critical  lack of publicly available data that hinders the ability of state and local officials to take meaningful action to  address agricultural pollution. For example, there is a lack of publicly available data on county-level  commercial fertilizer sales and application in Wisconsin. Likewise, there is relatively little publicly available  information regarding the location and size of unpermitted livestock operations and the amount of manure  they produce. 

Moreover, county conservationists and local conservation departments are underfunded and understaffed, making it challenging to oversee agricultural operations and understand the effects that animal waste and  non-point source pollution have on the land and water. As the volume of manure increases, it becomes even more difficult to track and regulate. 

“Our report highlights how the failure of Wisconsin regulators to monitor and manage the vast amounts of  manure and fertilizer being applied to fields in these nine counties limits their ability to protect residents,”  said Sarah Porter, Geospatial Director at Environmental Working Group and lead author of the report

“A comprehensive assessment of the capacity of Wisconsin’s rural landscape to handle its manure and  fertilizer load is long overdue,” said MEA Senior Staff Attorney Andrea Gelatt. “That assessment must drive  decisions about whether to allow CAFO expansion or to set reasonable limits on expansion so that families  in rural Wisconsin can have the clean water they deserve.” 

Midwest Environmental Advocates is a nonprofit law center that combines the power of law with the  resolve of communities facing environmental injustice to secure and protect the rights of all people to  healthy water, land, and air. Learn more at or

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