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Public input on ‘Sensitive Areas’ scope statement due by Friday, Dec. 6
Karst Geology
KARST GEOLOGY is a fractured bedrock that allows for contaminants from the surface to penetrate into groundwater. This attribute is made more sever when the bedrock is overlain by shallow layers of soil.

DRIFTLESS - At their upcoming meeting on Tuesday, Dec. 10, the Wisconsin Natural Resources Board (NRB) will act on whether or not to approve the scope statement for development of ‘Sensitive Areas’ revisions to the state’s Runoff Management rule NR 151. 

The rule, if developed, would “establish agricultural nonpoint source performance standards targeted to abate pollution of nitrate in areas of the state with highly permeable soils which are susceptible to groundwater contamination (sensitive areas) for the purpose of achieving compliance with the nitrate groundwater standards.” 

Some believe that the fractured sandstone geology underlying counties in western Wisconsin such as Crawford, Vernon and Richland counties should be covered by such rules. They believe that our fractured bedrock makes our drinking water exceedingly vulnerable to contamination.

Citizen testimony and written comments to the NRB on the agenda item is welcome. The meeting will take place at Room G09, State Natural Resources Building (GEF 2), 101 South Webster Street, Madison. 

The public’s options to offer input are as follows: to testify in-person or submit written comments, NRB Liaison Laurie Ross will require receipt of your request to testify and/or your written comment by 11 a.m. on Friday, December 6, 2019.

Laurie Ross can be reached at 608-267-7420 or by email at

NRB meetings are now webcast live. To watch, go to the webcast archive at and click on this month’s meeting. After each meeting, the webcast will be permanently available on demand.

Process to date

So far, despite a press conference held in Watertown, on August 1 with Governor Evers and representatives of DATCP, DNR and DHS, to announce the initiative, the process has bogged down in waiting for the NRB to approve the statement of scope for the process.

At their October meeting, the NRB required that three public hearings about the scope statement be held in November. Those three hearings were held at the Hancock Research Station, just south of Stevens Point; at Blackhawk Technical College in Janesville; and at the Fond du Lac campus of UW-Oshkosh.

WDNR provided the Independent-Scout the 164 pages of written (as opposed to in-person) testimony provided about whether the NRB should approve the scope statement.

Written testimony

There were a total of 92 written comments submitted that came from every corner of the state. One of those came from Clean Wisconsin, and contained 356 signatures. Of the 92 written comments submitted, six were in opposition to the NRB’s approval of WT 19-19, and 86 were in support of NRB approval.

In a memo dated December 3, DNR Secretary Designee Preston Cole shared a general summary of the comments received from the three public hearings held in November. The comments were drafted by DNR staff Brian Weigel and Ann Kipper. The summary was as follows:

• Nitrate contamination  is widespread in Wisconsin, affecting tens of thousands of wells.

• Something must be done about nitrate contamination.

• Nitrate groundwater contamnination is significant in the central sand region.

• Other areas of the state also have high nitrate concentrations  in groundwater and should also be considered as sensitive, particularly the southwestern  portion of the state.

• The department should look at both areas of high levels of nitrates in groundwater aud areas with highly susceptible soils.

• The department has not identified the specific waterbody or area that the proposed rule would apply to.

• Existing rules are not working in some geologic areas.

• The department has not documented substantial  implementation of existing rules to justify the need for a targeted standard.

• Many producers are following nutrient management plans and other cropland conservation practices.

• The scope statement was developed without input from the agriculture industry.

• Nitrate pollution is linked to significant health issues.

• Consider a broader range of factors affecting nitrates in groundwater than just soil permeability.

• Wisconsin citizens should have clean drinking water.

Wrtitten comments supporting the scope statement were submitted from: Platteville, Rolling Ground (2), Colby, Steuben (3), Milwaukee (3), Madison (7), Hartland, Saxon, Eau Claire (3), Neshkoro, Cable, LaCrosse, Downsville, Rice Lake, Pardeeville, Siren, Green Lake (4), Markesan (2), New Lisbon, Neenah (2), Hayward, Appleton, Princeton, Neillsville, Amherst Junction, Somerset, Kewaunee, Brandon, Stevens Point (2), Nekoosa, Suamico, New Glarus, Green Bay (3), Gresham, Ripon (5), Viola, Wautoma, Soldiers Grove, Wauzeka, Cross Plains, Deerbrook, Oconomowoc, Algoma, Chilton, Lincoln County, Sparta, Rhinelander, Chippewa Falls, Ferryville, Oshkosh, Pickett, and Gays Mills. There were also submission supporting approval of the scope statement from Cincinnati, OH (2); Tinley Park, IL; Marine on St. Croix, MN; and the University of Nebraska-Lincoln. There was a group submission from: Clean Wisconsin, Wisconsin Conservation Voters, River Alliance of Wisconsin, Wisconsin Wildlife Federation, Wisconsin Lakes, and Midwest Environmental Advocates.

Opposing written testimony came from Ladysmith, Waterloo, Reedsville, Fall River, Seymour, and a group submission from: Farm Bureau, Dairy Business Alliance, WPA, Wisconsin Potato Growers, Wisconsin Cattlemen’s Association, Wisconsin Dairy Alliance, WAPAC, WMC, Wisconsin Soybean Alliance, and the Wisconsin Corn Growers Association. 

There is still time if you want to add your voice to this process – you can attend the NRB’s meeting in-person to deliver spoken testimony or provide written testimony via e-mail.