George Meyer, Secretary 
State of Wisconsin
Department of Natural Resources
PO Box 7921
Madison, WI  53707-7921
 

Dear Secretary Meyer,

I am writing on behalf of Citizens for Responsible Development, a Dunn County Wisconsin environmental group.

Our group has been involved for the past year as opponents to the Primegg Farms project of Primera Foods.  As you know, this egg laying and egg breaking operation  proposed for Wheeler would be Wisconsin’s largest industrial agricultural facility in its own right; Primera has now expanded the scope of the project to include additional potential sites with additional facilities near Clear Lake and Augusta and is in the process of applying for various permits from your agency.

We believe that under Chapter NR 150 the Primegg project clearly requires both an environmental assessment and an environmental impact statement.

We are specifically concerned about toxic air emissions, dust, ammonia discharges to the Hay River, increased industrial waste water from the Cameron WWTF discharged to the Red Cedar River, increased phosphorus loading in the Red Cedar Basin, expansion of the Wheeler WWTF, potential nitrate contamination of ground water, the ability of the WDNR to effectively regulate an enterprise of this magnitude, and Primera’s abysmal environmental record in Illinois.

Recent regulatory and court decisions in Minnesota concerning feedlot operations raise additional disturbing questions:

•  The Hancock decision required the MPCA to consider the cumulative effects of large feeding operations when making decisions about an EIS.
•  The MPCA staff also recommended a full EIS for an expansion at Golden Oval Eggs.  Golden Oval has a relationship with Primera.  The request for an EIS was based upon staff concerns over toxic air emissions, endocrine disrupters, and endotoxins.

We are deeply troubled by the vague and evasive answers provided by Primera.  More troubling still are the answers provided by Primera which are in conflict with the facts of this application as recorded in the voluminous records from the past year’s testimony.  Our organization would like to request an additional 90 days to submit detailed questions and provide additional information for the environmental assessment.

Please consider this a formal request from The Citizens for Responsible Development for the following:

 1.  That the record for the environmental assessment be held open for at least an additional 90 days to allow a response to information already submitted by Primera and that an additional period of time be allowed for responses to future submissions by Primera.

 2.  The agency will require a full environmental impact statement from Primera for each of its proposed laying hen, egg breaking operations.

Regards,
 
Mark Warner
E5847 1170 Avenue
Wheeler, WI 54772