Press Release

November 12, 2025

ELPC, MEA Urge WI DNR to Deny Permit as Written to CAFO Seeking to Double its Livestock

Concerns focus on water pollution and past permit non-compliance

Madison, WI. – Today, the Environmental Law & Policy Center (ELPC) and Midwest Environmental Advocates (MEA) submitted comments to the Wisconsin Department of Natural Resources (DNR) outlining serious concerns related to a draft permit for Gilbert Farms, a concentrated animal feeding operation (CAFO) located in Door County. The draft permit would enable Gilbert Farms to more than double the number of livestock on its property, thereby endangering its neighbors and Door County’s waters with pollution from the significant increase in animal waste production.

The draft permit would allow Gilbert Farms to apply over 21 million gallons of nutrient- and bacteria-laden manure on land in an area that is highly susceptible to groundwater contamination due to shallow depth to bedrock. What’s more, Gilbert Farms has a well-documented history of flouting the rules––both the permitting rules for CAFOs, as well as manure application rules for Silurian bedrock in Door County–– violations for which the DNR has failed to take any enforcement action.

The comments submitted today by ELPC and MEA were based on legal, hydrogeologic, and agronomic analyses of the draft permit. The organizations are urging the DNR to make changes that strengthen the draft permit, including:

• Refer the CAFO’s past non-compliance violations to the Department of Justice for enforcement;
• Require the CAFO to use GPS-assisted technology when spreading manure and process wastewater;
• Require a more robust network of groundwater monitoring, including at landspreading fields.

“From a legal and scientific perspective, this permit contains a lot of problems, and it will almost certainly lead to more pollution,” said Katie Garvey, Senior Attorney at ELPC. “On a more basic level, granting this CAFO permission to massively expand its operations without holding it accountable for past noncompliance just defies common sense and fairness.”

“We share local residents’ concerns about this proposed expansion, and we are asking the DNR to do more to hold Gilbert Farms accountable,” said Adam Voskuil, Senior Staff Attorney at MEA. “Without additional modifications, the proposed permit puts the community’s water resources and the health of local residents at risk.”