News Archives
(From the present back to the first CAFO construction in 1997 and first CAFO violations)

See full list of CAFO Violations - 1,117 confirmed by the Michigan DEQ


Summer Newsletter just posted here: Toledo water crisis and CAFO connection - how runoff from here reaches Lake Erie; & new CAFO violations.

New 2014 Western Lake Erie CAFO Annual Manure Inputs - ECCSCM spreadsheet with total CAFO animals by facility, total CAFO manure by facility, in River Raisin and Maumee River Watersheds, Michigan and Ohio. Based on individual CAFO numbers reported in Michigan DEQ 2013 CAFO Permits and State of Ohio Livestock Environmental Permitting database. Please notify ECCSCM if you find omissions or errors, we'll be updating the spreadsheet periodically. Updated Aug 13. Download here.
Total CAFO Animals
(all species) in western Lake Erie Watersheds = 12,803,065
Total CAFO Annual Manure (liquids and solids) in western Lake Erie Watersheds = 5,018,056,506 lbs

Local CAFO info below, drawn from ECCSCM Western Lake Erie CAFO Manure database:

CAFO animals, waste totals* for our area in Michigan (Hillsdale, Lenawee Counties)

34,633 animals, mostly cows
producing each year
163,827,000 gals. of liquid waste
stored in 56 waste "lagoons," pits, ponds
and also producing
143,600,000 lbs. of solid waste

Dairy cows produce more than 20 times the waste a human produces
Waste from CAFO cows here = untreated waste of a city of 600,000 people = Boston!

* when Milk Source reaches permitted capacity soon. Source for CAFO data: DEQ 2013 CAFO Permits for these CAFOs:
Bakerlads Farms, Bleich Dairy, Bruinsma Dairy, Halliwill Farms, Hartland Farms, Hoffland Dairy, Milk Source/Camden Dairy, Milk Source/Hudson Dairy, Milk Source/Medina Dairy, New Flevo Dairy, State Line Farms, Terrehaven Farms, White Farms.

from Stench Alerts: weekend Aug 7-11 - "Horrendous" emissions over many square miles from Hartland Farms waste applications the last 4 days along Beecher Rd . . . Numerous reports to ECCSCM about the stench from neighbors with headaches, nausea, sore throats, burning sinuses. Many people had to close windows Thurs, Fri, Sat nights. Several people had to leave their homes. Extreme emissions continue. MDARD notified, DEQ Air Division notified, also Lenawee County Health Department.

BULLETIN, Aug 2: 'Do not drink' water advisory issued for Toledo area - Algal toxin microcystin found in samples; boiling not recommended
From the Toledo Blade: The City of Toledo issued a warning early Saturday morning, advising residents not to drink the city’s water...Chemists testing water at Collins Park plant found two sample readings for microcystin that exceeded the recommended “do not drink” standard of one microgram per liter...Before 8 a.m., grocery and convenience stores across the area were out of water. The city‘‍s plant provides treatment services to an area of approximately 400,000 people across 100 square miles.

Last week in July - First toxic algae advisories - Maumee Bay State Park, our Maumee Watershed – from Toledo Blade article. On July 26, the Toledo/Lucas Co Health Department notified the public that tests on water near the beach at Maumee Bay State Park "showed microcystin at a concentration of 19.18 parts per billion, more than three times the threshold for safe recreational water activity." Residents are advised to avoid any "green water" in Lake Erie but also "in the lake's tributaries, such as the Maumee River, the Tiffin River [called Bean Creek in Michigan], and the Sandusky River." Microcystin is a neurotoxin "that can make people and animals sick or be fatal in large enough doses. Scientists have found in recent years it is more toxic than arsenic. Residents are advised to keep their distance in general, because microcystis puts out an aerosol that can be inhaled, especially when water is agitated."

July 28 - Note concerns today – 1) Dust Bowl, 2) spray-irrigation into neighbor's woods. 1) Major particulate emissions today, blowing from Medina Dairy field applicaton of slurry/solids on Gallup Rd field. No incorporation, no crop. Dust from manure application fields can carry fecal matter as well as large and small particulates which can aggravate asthma, reach the lungs and cause respiratory problems, other health symptoms.
dust bowl
7-28-14 - Gallup Rd dust, particulate emissions from Medina Dairy waste application.

Also today, July 28, Medina Dairy is spray-irrigating southeast of the facility on Ingall Hwy, with end-spray from the travel irrigator shooting into the trees of a neighbor's woods.
7-28-14 - Milk Source's Medina Dairy end-sprayer hitting a neighbor's woodlot, trees, Ingall Hwy.

NEW VIOLATION: DEQ recently cited New Flevo Dairy (NFD), Forrister Rd, Adrian, for stockpiling CAFO waste without incorporation for 7 days, a violation of the CAFO Permit. Following a complaint about the stockpiling, DEQ inspected NFD on June 27, 2014, found stockpiles in the field; NFD application records confirmed "stockpiles on the field had been present since June 19." The CAFO Permit requires incorporation of stockpiled waste within 24 hours. See photos of NFD stockpiles from June, 2014, on Stench Alerts.
See NFD Violation Letter.

July 24 - The toxin microcystin showed up yesterday in Oregon, Ohio's raw water supply which comes from western Lake Erie. The Toledo Blade reports that the water test, performed while OhioEPA Director Craig Butler was touring the plant, "had a small but detectable level of microcystin, the toxin produced by microcystis algae." The article notes, "Plant operators are not required to test for microcystin, even though scientists now place it between arsenic and dioxin in terms of its toxicity. Microcystin is capable of killing humans or at least making them sick in large doses."

CAFO waste application in Maumee Watershed - borders of states don't matter as much as watershed boundaries when it comes to Lake Erie. Michigan CAFO waste is being applied in Williams Co, Ohio; Ohio CAFO waste is being applied in Lenawee Co, Michigan these days. But here or there, these fields are all in the western Lake Erie Watershed, where excess nutrients are feeding toxic algae.
HDOhio oakMI lensign
7-24-14 - (left) Michigan CAFO waste to Ohio (Hudson Dairy, Hudson, MI, draglining in Williams Co, OH); (right) Ohio's Oakshade CAFO, Lyons, OH, draglined yesterday in Lenawee Co, MI. Both locations are in western Lake Erie Watershed.
See Stench Alerts for other CAFO waste applications in westerm Lake Erie Watersheds of Michigan.

BULLETIN: July 22 - NOAA's Harmful Algae Bloom Bulletin for July 22 finds, for the first time this summer, a cyanobacteria bloom that has intensified this last week near the Maumee River. The University of Toledo has confirmed the presence of the toxic algae Mycrosystis. "Bloom patches may have developed near the Michigan coast, close to Maumee Bay..."

July 15 - Read "Bracing for Lake Erie Algae threats to drinking water," a Great Lakes Echo interview with Rick Stumpf, NOAA scientist who developed the Harmful Algal Bloom forecast for Lake Erie. The HAB forecast uses "a combination of satellite imagery, computer modeling, and water samples gathered by multiple agencies" to update the toxic algae risks to drinking water and recreation. Stumpf discusses last year's HAB following July rains that washed heavy loads of Phosphorus "from farmland along the Maumee River" into Lake Erie at Toledo. Toxins from the algae spiked to unsafe levels, causing the shutdown of one Ohio drinking water supply.

Examples from here: how excess Phosphorus from agricultural fields flows to streams — and to Lake Erie where it feeds toxic algae.
#1 - through sub-surface field tiles that drain to streams
wallace Medinasource
Wallace Cr, River Raisin Watershed, with multiple tile outlets; and (right) Medina Dr, point of origin, Bean Cr Watershed, with multiple tile outlets

#2 - through surface runoff into catch-basins that drain to streams
MDrunoff Dilloncatchbasin catch
Field at Medina Dairy on Dillon Hwy 6-19-14, and the same field 7-16-14, showing catch-basin that drains runoff to Bean Cr Watershed; close-up of catch basin

July 11 - Multiple manure applications from CAFOs: New Flevo Dairy bulldozing, pushing, spreading manure stockpiles in field at the facility on Forrister. Milk Source's Hudson Dairy dragline operation shut down on M-34 at Elm Rd, just west of the City of Hudson. Today, just east of the City of Hudson, set-up for next dragline session begins, on Munson Hwy off M-34, near the start of Findlay Trail. Hudson Dairy also spray-irrigating along US-127 east of the facility, north of Donnelly Rd. Milk Source's Medina Dairy also spray-irrigating west of Ingall Hwy north of the facility.
7-11-14 - New Flevo Dairy/NFD bulldozing manure stockpiles on field at the facility, Forrister Rd.

Munson munson drag
7-11-14 - Hudson Dairy, Munson Hwy just off M-34 - the usual dragline set-up, RR car-style dump box, multiple tankers filling it; dragline in operation

7-11-14 - Hudson Dairy spray-irrigating CAFO waste across from facility on US-127, north of Donnelly Rd

July 10 - Hudson Dairy draglining in two locations on Elm Rd: at M-34 & Elm, several tanker trucks hauling to a dumpbox for the last three days; also on Elm Rd near Tamarack, through dragline from the facility, on the same alfalfa field as recently spray-irrigated, alfalfa now cut and chopped.
elm34 elmfield
7-10-14 - Hudson Dairy dumpbox, tanker and dragline reel; and draglined field at Elm & M-34.

7-10-14 - Hudson Dairy draglining from the facility on cut alfalfa field, Elm at Tamarack

July 10 - Neighbors report "Silage has stunk for three days" from Hartland Farms. Workers at one house commented on how bad it smelled.
7-10-14 - Hartland Farms is also spreading solids, swaths through the alfalfa field at Dowling Hwy & Cadmus Rd.

July 7 - More manure spray-irrigation, this time at Milk Source's Medina Dairy on Dillon Hwy. Numerous other manure applications and Stench Alerts reported to ECCSCM, including Bakerlads, Halliwill, Marvin Farms, and Hudson Dairy draglining at M-34 and Elm Rd.
medina1 medina2
7-7-14 - manure irrigation along Dillon Hwy at Medina Dairy CAFO.

REASONS TO BE CONCERNED with MANURE IRRIGATION (from Univ. of Wisconsin Extension)
• The full extent of health and quality of life risks are unknown and potentially severe.
• Health concerns that aerosol spray drift from manure irrigation could carry pathogens, particulates, antibiotics, endocrine disruptors, cleaning compounds, toxic gases (hydrogen sulfide and ammonia), and ‘super bacteria’ including LA-MRSA. Concerns that contaminants could affect the general population and especially those with compromised immune systems and elderly; concerns that those negative health effects could be magnified because aerosols penetrate lungs and carry toxins to the bloodstream more directly than if ingested.
• Quality of life concerns, reinforced by reports from people who have complained of worsening respiratory health, poor air quality, increased airborne particulates, odor, and contamination of their property as a result of nearby manure irrigation.
• The potential for contamination of surface water and wells from irrigation application, especially in areas where access to groundwater is more direct such as in sandy soil or karst. There are concerns about runoff from precipitation events after manure irrigation application.
• Groundwater quantity concerns that manure irrigation might use excessive amounts of groundwater resources and may draw down wells.
• There are concerns that existing and future setbacks will be inadequate to protect neighbors, surface waterways, and crops in nearby fields.
• There are concerns that monitoring implementation of manure irrigation practices would be difficult and impractical.

CAFO air emissions: The National Air Quality Site Assessment Tool (NAQSAT) is designed for indivdual livestock operations to assess seven air emissions from their facilities odor, dust, ammonia, hydrogen sulfide, methane, volatile organic compounds (VOCs) and nitrous oxide. "Air emissions are becoming a big concern... Livestock farmers should take the steps to better understand the pollutants emitted from their facilities," says MSU Extension. See MSU article and link to NAQSAT web tool to assess emissions by inputting species of livestock and particulars of an individual operation. An output chart recommends areas for "improvements."

NEW VIOLATION: Milk Source's Hudson Dairy cited by DEQ for applying CAFO waste on 4 days on 3 fields not listed in its Comprehensive Nutrient Management Plan, as required by the CAFO Permit. DEQ notes that "CAFO waste from Hudson Dairy had been applied to fields in Medina Dairy's CNMP without proper manifest documentation on May 23-25, and May 27, 2014." See details on the violations list and in DEQ Violation Letter.

DEQ tests show extreme E. coli contamination in Fisk Drain, Wolf Creek Watershed in Adrian Twp, June 12, 2014. In May and June, DEQ’s Surface Water Assessment Section conducted a 5-week Water Monitoring Project for E. coli in Fisk Drain at Teachout Rd, Adrian Twp (Wolf Creek/Riv Raisin Watershed), and in Medina Drain at Ingall Hwy, Medina Twp (Bean/Tiffin Watershed) — 2 sites identified as at risk in ECCSCM's 2013 water monitoring projects. DEQ's E. coli results show extreme contamination in Fisk Drain - 1,000,000 cfu/100mL on June 12, 2014; 4,814 cfu/100mL on May 14. Medina Drain was slightly above the Michigan Water Standard on June 12, at 1,249 cfu/100mL.
See DEQ data for both sites, all samples.

June 23 - ECCSCM Water Monitoring teams were sampling this morning in the Hazen Creek/South Br River Raisin Project and the Bean Creek Watershed Project. Murky discolored water at numerous sites. Data coming soon.
floydhudsondr wallace
6-23-14 - Floyd Hudson Drain, trib of South Br River Raisin, Skinner Hwy; on right: Wallace Creek, tributary of Hazen Cr, Forrister Rd.

June 20 - A water sample taken in Medina Drain at Ingall Hwy on June 19 had an E. coli count "greater than" 2,419/100mL (tested at DEQ-certified Adrian Water Treatment Plant; 2,419 is the maximum bacteria count possible using the lab's IDEXX process). Michigan’s Water Standard is 1,000/100mL or less for partial body contact.

June 19 - Heavy rains and runoff and field tiles are a triple threat to our headwater streams flowing to Lake Erie. Contaminants can flow and Phosphorus can feed the toxic algae blooms in Lake Erie. Agricultural fields, and manure application fields at all CAFOs here, have tile risers, tile inlets, catch basins, to move excess rainwater to sub-surface tiles. Pollutants can also flow directly through these tiles to streams. This can happen even when following GAAMPs (Generally Accepted Agricultural Management Practices) or permit requirements. A recent article, headlined Forecasters predict toxic algae blooms will once again turn Lake Erie into a 'slimy putting green,' discusses NOAA's new tool for predicting harmful blooms in Lake Erie. A researcher notes: “Partly to blame for this expected algal assault are more severe storms, which wash vast amounts of phosphorous into the lake." Photo below shows the consequences of 1.5+ inches of rain on a field at Milk Source's Medina Dairy CAFO. On June 17, liquid manure was applied on this field, parts of which drain to Medina Drain, a stream on Michigan's 303(d) list of "impaired waters." The night of June 18, it poured. There's concern for this runoff draining through tile risers to sub-surface field tiles to the impaired stream - and on to Lake Erie. DEQ has been updated on the situation.
6-19-14 - Medina Dairy runoff from heavy rain, Dillon Hwy.

Spring Newsletter posted: Emerging health issue of manure-spraying and aerosolized pathogens; Milk Source drills 5 new high capacity wells, local concern for groundwater depletion.

MORE VIOLATIONS: DEQ Inspection of Terrehaven CAFO and fields finds multiple, ongoing violations, including stockpiling manure in fields for longer than 24 hrs – stockpiles on one field had been in place from April 21 through the day of inspection, May 7. Other violations of the Permit included not incorporating manure within 24 hrs of application; and not incorporating because of saturated ground (CAFO waste may not be applied on saturated ground). In addition, according to its own CNMP, Terrehaven does not to have six months manure storage, a requirement of all CAFOs. More details on the violations list or download DEQ CAFO Reconnaissance Inspection Letter.

May 2014 - E. coli and toxic microcystin advisories are already posted for 12 beaches in Ohio, according to the Toledo Blade, including a swimming advisory for excess bacteria in Lake Harrison, just over the border in Fulton Co. The Ohio health department posts swim advisories when E. coli bacteria levels are high enough to make people sick. Children, the elderly, and people with weakened immune systems are particularly advised against swimming in those conditions. Toxic algae advisories are again posted in Grand Lake St. Mary's, where the risks have been so great in recent years that limits were put on manure application in the watershed. Near the end of April, levels of the algal toxin microcystin in Grand Lake St. Mary's were higher than 25 parts per billion, more than four times the state’s safety threshold of 6 parts per billion. Officials recently warned that indicators point to a potentially serious harmful algae bloom in Lake Erie this summer.

May 24-25 Memorial Day Weekend - Neighbors reported many manure tankers on Medina Twp roads on Saturday May 24. ECCSCM confirmed the tankers were hauling, back and forth, from Milk Source's Hudson Dairy on US-127 to fields along Packard Rd/Ingall Hwy/Gallup Rd in Medina Twp. A draglining operation and manure dumpbox was set up at the edge of Gallup Rd. Manure application was taking place in fields NOT in Hudson Dairy's Comprehensive Nutrient Management Plan (CNMP), but in Medina Dairy's CNMP. It is suspected that is a violation of the CAFO’s permit. There is considerable damage to several areas of asphalt on Lime Creek Rd, and Gallup Rd, a gravel road, is now deeply-rutted, almost impassable where the heavy trucks were traveling. The Lenawee Co. Road Commission received several complaints and will be seeking reimbursement from Milk Source for road repair costs, according to the Adrian Daily Telegram.
gallup rd
5-24-14 - Four manure tankers, Gallup Rd, two of them backed up to the manure dump box.

5-24-14 - Hudson Dairy manure tanker on Gallup Rd, Medina Twp.

torn up
5-24-14 - One of Gallup Rd sand-rutted areas.

May 10 - Milk Source set-up for draglining at Elm Rd and M-34. The green dump box is filled with liquid manure from the semi-tanker, then pumped through the "umbilical" hose, spraying manure back and forth across the field, next to neighbors, along M-34 just 1 mi. west of Hudson.

May 6 - ECCSCM begins 2014 Water Monitoring Project in Bean Creek Watershed at sites draining Milk Source facilities and fields. Some degradation of Medina Drain is already visible, with water discolored and scummy, no fish visible.
medina down medina up
5-6-14 - Medina Drain downstream at culvert (left), and upstream (right).

Also May 6, Milk Source is spray-irrigating manure east of the Hudson Dairy facility on US-127 and west of the facility along Elm Rd. Gusty east winds are carrying the emissions far off-site. Incredible stench for neighbors downwind. Also stench from manure application on Acker Hwy.

5-6-14 - Milk Source manure spraying from irrigator near Elm Rd neighbors.

May 3 - Hartland Farms using big gun sprayer west of the facility on Hughes Hwy. Winds are blowing at 20mph, with gusts to 30mph – stench of silage leachate is overwhelming downwind.
5-3-14 - Hartland gun-spraying sialge leachate west of facility on Hughes Hwy.

May 1 - Spewing, spewing liquid manure – "isn't it lovely...," writes a driver passing by. Hoffland Farms CAFO dragline is unplugged, no applicator, no incorporation. Aerosolized fecal pollutants. Manure ponding in the field. Just unadulterated spewing!
dragspray pondingcafo
All photos May 1, 2014, Hoffland CAFO

New Violations posted: Bakerlads Farm CAFO cited for land application violations of its Permit, including spreading manure on frozen, snow-covered ground in March on a field not included in the CAFO's Comprehensive Nutrient Management Plan. The field had not been submitted for approval and public notice, as required, and not assessed using the Manure Application Risk Index, required before any application of CAFO waste to frozen or snow-covered ground. See full details and DEQ letter on Violations list.

April 24 - Multiple manure applications today; with gusty and shifting winds, many neighbors are feeling it, suffering CAFO emissions. New Flevo CAFO is draglining liquid manure in 2 locations – along Rome Rd east of Glen Hill Hwy, with 6 semi-tankers hauling back & forth; also draglining at Wilkinson and Hoddinot, both sides of the road. In Hudson Township, horrendous emissions from Hartland Farms CAFO manure application on a sloping field, drains to Bear Crk, corner of Cadmus Rd and Hughes Hwy. Neighbors downwind report eye-watering, "hair-stinking" emissions; it's really overpowering, just driving by.
hartland1 hartland2 hartland3
April 24, 2014 - Fierce emissions from this Hartland Farms manure application, Cadmus & Hughes.

ECCSCM and other Great Lakes groups ask Michigan to ban CAFO manure application in winter. See article in Adrian Daily Telegram.

ECCSCM Hazen Creek/South Branch River Raisin Monitoring Project begins. Starting in April, ECCSCM will do routine monitoring at six sites northwest of Adrian – 3 sites in Hazen Creek, a major tributary of the South Branch of the River Raisin; 3 sites in the South Branch itself. We'll test for E. coli, Dissolved Oxygen, and using our new TR-7 digital meter, test for Nitrate and Nitrite, Ammonia, as well as the nutrient Phosphate, that feeds harmful algae blooms as it flows downstream and into Lake Erie.

April showers and thaw, with runoff visible from the air... aerial photos taken April 2, 2014
All waters in these photos flow to Lake Erie – Bleich, Medina Milk Source, and 5 other CAFOs are in Bean/Tiffin Watershed which flows to Maumee River;
Terrehaven and 5 other CAFOs are in River Raisin Watershed. See watershed map and CAFO locations.

overview pitsl
4-2-14 - runoff, overland flow around Bleich CAFO on US-127; close-up of manure pits

4-2-14 - concern about seepage below the pits at Bleich

4-2-14 - arrays of manure pits, stormwater flowing at Medina Milk Source CAFO, Dillon Hwy

4-2-14 - aerial photo of runoff from back and from the front of Terrehaven CAFO barns in field behind the main facility. This area drains to Wolf Creek.

4-2-14 - aerial photo of runoff from Terrehaven CAFO to the west, and to the east to Pine View Dr residential area.

March 19 - warmer temperatures at last - but major melt and winter-applied manure runoff have begun. See photos below. And if you see manure runoff in your area of Michigan, please send photos to:

Local debate over Milk Source plans: ECCSCM President Letter to Editor, Adrian Telegram 2-12-14; Commissioner Driskill (Hudson), Milk Source advocate, response 2-16-14; Telegram article, "Criticism sparks interest in dairy plan," 3-16-14.

March 11 - manure runoff from Terrehaven CAFO reaches neighbor's property:
runoff 1 runoff 2

New Milk Source CAFO violations, manure spills in Wisconsin – details from databases of Wisconsin Deparment of Natural Resources, which oversees CAFO enforcement (see full listings in WI Manure Spills 1-1-07 to 11-22-13 and WI Enforcement Tables 2000-2013):
• Tidy View Dairy - Jan 6, 2007 - "Liquid manure was pouring out of broken drain tile line into tributary of Apple Creek - Drain tile was traced back to dairy."
• Tidy View Dairy - Sept 14, 2009 - "Truck hauling manure for Tidy View Dairy lost control & went into south side ditch causing the truck to spill ~6,000 gal of manure..."
• Tidy View Dairy - Sept 15, 2010 - Notice of Noncompliance, unapproved land application sites.
• Rosendale Dairy - Nov 12, 2008 - Notice of Violation, construction without permit.
• Rosendale Dairy - July 29, 2009 - Notice of Noncompliance, landspreading noncompliance.
• Rosendale Dairy - Nov 13, 2009 - "During manure application, manure line broke, spilling manure into road ditch. Manure line was run through culvert... & broke on east side of the road."
• Also: [redacted] Milk Source Dairy - Feb, 2004 - FDA Violation - "On February 11 and 25, 2004, an investigator from the Food and Drug Administration (FDA) conducted an investigation into two illegal tissue residues in dairy cows sold for slaughter as human food by [redacted]. That investigation included a review of your firm’s involvement with the aforementioned residues. The investigation revealed serious deviations from the regulations for Extralabel Drug Use in Animals, Title 21, Code of Federal Regulations." (FDA letter to James Ostrom, Pres, Milk Source)

Coming Soon - Milk Source - What to Expect?
“In our business model, it is essential to grow” - Jim Ostrom, Milk Source (AgWeb, Jan. 8, 2014)

(If Vreba-Hoff’s 6,000 cows/40 million gallons of manure were too much for our headwater streams - 2 streams are still listed as “impaired” because of manure discharges - what will happen with numbers like these?)

Milk Source - Animal totals: 60,300
Tidy View Dairy, Kaukauna, WI – 6,800
Omro Dairy, Omro, WI - 2,700
*Rosendale Dairy, Pickett, WI - 8,400
New Chester Dairy, Grand Marsh, WI - 8,400
Richfield Dairy, under construction - (4,300 to start)
Calf Source, De Pere, WI - 9,000
Heifer Source Feedlot, Liberal, KS - 25,000
*At Rosendale, more than five miles of pipe is being laid to pump manure to distant fields
(all numbers from AgWeb article about Milk Source, named "Innovative Dairy Farmers")

Why Worry?
• concerns about headwater streams, originating on Milk Source property at both Hudson (US-127) and Medina (Dillon Rd) operations.
• concerns about groundwater - Note: Dec. 2013 Court ruling in a lawsuit brought by Friends of the Central Sands and others concerned about groundwater depletion from high-capacity wells proposed at Milk Source's Richfield Dairy and about an incomplete Environmental Assessment of groundwater impact performed by the DNR: the Wisconsin Court of Appeals ruled that the Environmental Assessment had failed to consider the “potential cumulative effects” of the wells and ordered the DNR to re-assess the impact the dairy’s wells may have on the environment.

Winter 2014 Newsletter - just posted.
Highlights: 6 Great Lakes states ban CAFO waste on frozen or snow-covered fields. When will Michigan stop it?
Do you know where your milk comes from? How to track the source.

Bulletin: International Joint Commission - Lake Erie Ecosystem Priority Final Report released, Feb 27. This final report strengthens the Draft Report recommendation to ban application of manure – and commercial fertilizer – to frozen or snow-covered ground. See p. 9, Recommendation #10:
"The Governments of Ontario, Michigan, Indiana, Ohio, Pennsylvania and New York should ban the application of manure, biosolids and commercial
fertilizers containing phosphorus from agricultural operations on frozen ground or ground covered by snow for lands that drain to Lake Erie.

ECCSCM supports the prohibition of winter application of manure – in Michigan's CAFO permit (undergoing revision), in the Michigan Agricultural Environment Assurance Program (MAEAP) Standards, and in Michigan's Generally Accepted Agricultural Management Practices (GAAMPs). In late 2013, 2 important reports from the International Joint Commission and the Ohio Lake Erie Phosphorus Task Force, multi-national, multi-agency groups studying Lake Erie's excess nutrient/toxic algae crisis, both recommended that winter application of manure be banned in Lake Erie watersheds. One of the highest risk agricultural practices, manure on snow-covered or frozen ground, an impervious surface, has nowhere to go when it rains or melts except off the field and into streams. See the IJC Lake Erie Ecosystem Priority Draft Report and the Ohio Phosphorus Task Force Final Report.

CAFO waste application on snow-covered, frozen fields, all through February.
3-1-14 - Warner manure on snow-covered fields, Pentecost Hwy. (close-up, below)



2-25-14 - Warner manure on snow-covered fields, Pentecost Hwy.

2-20-14 - sudden warm-up, rain on Bakerlads CAFO manure application, Cadmus Rd

2-20-14 - rain falling on Hartland Farms CAFO manure on snow-covered, frozen fields, Cadmus Rd

black manure
1-17-14 - Hartland Farms CAFO manure on snow, on slope.

Dec 30 - yep, no change in winter application of manure. With no consideration of neighbors at the holidays, no consideration of the goopy ground, freezing up fast with temps dropping fast, 17º this morning, Bakerlads is applying liquid manure along Cadmus Rd east of Morey.

Nov 26 - Fall Newsletter just posted. Highlights: Medina Drain photos THEN (scum, creepy colors) and NOW(clear); Wolf Creek, Adrian-area CAFOs & Terrehaven violations.

BULLETIN: 7 Violations - Terrehaven CAFO, Wolf Cr Hwy near Adrian, was cited for multiple violations, including contaminated runoff from the feed storage and barns flowing into an undocumented “temporary holding pond,”contaminated runoff from the production area flowing “east toward an open field” and “west toward an open field, and eventually to a small pond,” clean stormwater from several buildings contaminated with production area waste. Woody vegetation was growing on the berms of the wastewater lagoon, which "can compromise the integrity of the lagoon liner by root penetration.”
(details from DEQ Violation Notice of Nov. 8, 2013. See more information on our Violations list)
terrehaven1 terrehaven2
8-29-13 - Terrehaven with waste heaped, seeping, and (close-up, photo taken from opposite angle) flowing into a black manure pool.

Nov 23 - See results and total data from ECCSCM's 3 Water Monitoring Projects for 2013: Wolf Creek Watershed (River Raisin Watershed), and Medina Drain, Lime Lake Inlet (Bean/Tiffin Watershed). Medina Drain, in particular, shows recovery since the Vreba-Hoff shutdown. Below, see video of minnows in Medina Drain, Sept. 2013. But what will happen when Milk Source LLC moves in with 3,000+ cows in Spring 2014?

Oct 4, 2013 - Health risks to neighbors from Hartland Farms heavy manure application and emissions – see report sent to MDARD and DEQ by local Registered Nurse. Hydrogen Sulfide levels reached 1.2ppm (1,200ppb) in a neighbor's home. The neighbor at this residence is ill, receiving radiation treatments, and on Oct 5 was taken by ambulance to hospital with "extreme stress in breathing." New Mexico, New York, and Kentucky have 1-hour air standards for Hydrogen Sulfide of 10 ppb. This is 1,200 ppb inside a residence! The World Health Organization recommends exposure no higher than 10.6ppb over a 24-hr period. Where can neighbors go to breathe safe air? If not in their own homes?
outside inside
Lower number shows Hydrogen Sulfide level on 10-4-13 at 0.7ppm (700ppb) next to Hartland Farms manure field; on 10-7-13, Hydrogen Sulfide reaches 1.2ppm (1,200ppb) inside a neighbor's house.

Sept 4 - See news clip on WTOL-Toledo, on the MilkSource purchse, including an interview with ECCSCM President John Klein on community and environmental concerns.

Aug 31 — SOLD: ex-Vreba-Hoff CAFOs sold to MilkSource of Wisconsin. See more details.

Just posted:
Summer 2013 Newsletter, with articles on Hydrogen Sulfide emissions, Wisconsin mega-CAFO on track to purchase ex-Vreba-Hoff facilities here.

Aug 9 - serious Hydrogen Sulfide (H2S) emissions from Hartland Farms manure application, Beecher Rd & Henning Hwy. The new Drager 2000 H2S meter registered 1.0 ppm (= 1,000 ppb) this afternoon, far above the 1-hour air standard in 13 states. Michigan has no air standard for H2S. New Mexico, New York, and Kentucky have 1-hour air standards of 10 ppb. This is 1,000 ppb! 100 times worse.
Aug 9 - Drager meter near Hartland Farms manure spraying; top number 19.1 is percent Oxygen; second number 1.0 is H2S parts per million.

stench ADVISORY: Aug 1 – Lime Lake area residents, Medina Twp residents near Dillon Hwy: with the imminent sale, apparently within weeks, of ex-Vreba-Hoff CAFOs to MilkSource, a Wisconsin CAFO, consider doing baseline well water tests of your drinking water. If massive applications of liquid manure resume, baseline tests are important, should there be manure discharges or spills. ECCSCM is testing Lime Lake Inlet this summer for baseline data. (See July entry below).

Free water sample bottles with mailer for the Dept. of Environmental Quality Lab are available from your County Health Department or from ECCSCM. Click here for DEQ lab tests and fees. An E. coli test and nitrate test (included in Automated Partial Chemistry test) are especially important.

FIND THE CAFOS IN YOUR AREA – Click on this Food & Water Watch map
cafo mpa


Open Letter to potential buyers of ex-Vreba-Hoff/Southern Michigan Dairies CAFOs

July - ECCSCM water monitoring team is testing Lime Lake Inlet, a stream already impaired and now threatened again, and more seriously, if the ex-Vreba-Hoff facility on US-127 is sold and manure application resumes in this watershed. We're testing 4 times this summer for E. coli, Nitrates and Nitrites, Phosphate, Ammonia.
July 29, 2013 – two of ECCSCM water test sites on Lime Lake Inlet, at Lime Lake Rd and at Tamarack Rd

2013 Spring NewsletterHighlights: Taxpayer subsidies to CAFOs and livestock facilities in our area; FBI investigates Vreba-Hoff's Willy van Bakel, and more...

May 11 - Hoffland Farms is spraying fields adjacent to Lake Hudson, on Lake Hudson State Recreation Area public land. Who said yes, it makes sense to spray liquid manure across from a public beach? Who said yes, it makes sense to let manure emissions drive campers from a state campground? Who said, let hikers and anglers hold their noses?
2spray sign
May 11, 2013 - Lake Hudson State Recreation Area, a dumping ground – the lake lies behind those trees. Hoffland Farms is spraying and stinking the public's air.

May 11, 2013 - Hoffland Farms liquid manure is ponding in the fields next to Lake Hudson.

April 27 – A water-quality team from Illinois Citizens for Clean Air & Water came to Hudson to train ECCSCM on the use of new water monitoring equipment, including hand-held digital meters for testing phosphate, nitrate, ammonia, etc. and in-stream equipment that samples for numerous pharmaceuticals and antibiotics.
test2 test3

4-27-13 ECCSCM water monitoring training with Northern Illinois University team

April – it's raining cow pies (from Terrehaven CAFO manure hauler) on cars and Wolf Creek Hwy, Adrian. For drivers following, it's off to the car wash, again. These spatter and smear, but at least they're not the liquid slurry that takes 2 runs through the car wash.

early March, 2013 – Ground is still snow-covered, but thaw has begun. CAFOs are back in the fields spraying manure. These conditions pose extreme risk for runoff and pollution of streams in many locations.
3-6-13 Warner manure application on slope, Pentecost Hwy, Franklin Twp
3-6-13 More Warner manure on Pentecost
3-5-13 Hartland Farms manure runoff, along Beecher Rd east of Dowling

Check your calendar – March 21, 2013 at 7 p.m. – Panel Discussion: Less = More: Restoring the Balance to Our Food System
B119 Wells Hall, Michigan State University, East Lansing, MI
Free and open to the public
See full details of program and speakers, including Dan Imhoff, author of Food Fight and CAFO: The Tragedy of Industrial Animal Factories; Dr. Gail Hansen, Staff Veterinarian, Pew Campaign on Human Health and Industrial Farming; Lynn Henning, Sierra Club CAFO Water Sentinel and Goldman Environmental Prize winner, and others.

Help level the playing field for our farmers


Sign the Petition to Stop Factory Farms!


ECCSCM joins new Michigan initiative: Less = More
support for factory farms means a MORE sustainable Michigan!

Help rein in taxpayer subsidies to factory farms and instead support clean, locally owned and operated livestock farmers. Michigan State conservationist Garry Lee decides how Michigan prioritizes taxpayer dollars that come to the state through the Farm Bill. This year, he can either choose to fund subsidies for polluting factory farms or instead support clean, locally owned, sustainable farms. Over the coming months Less = More will be hosting events across the state to make help Michigan make the right choice.
Learn more at
Read the Less = More white paper on current CAFO subsidies in Michigan – a vision for Restoring the Balance to Michigan's Farming Landscape.



2013 Winter Newsletter now online – print copies will be mailed next week
latest sale of former Vreba-Hoff CAFOs apparently falls through!
E.coli contamination in stretches of River Raisin; CAFO violations in River Raisin Watershed, last 5 yrs.
• grants for River Raisin/western Lake Erie basin water protection project to DEQ and MDARD

January 2013 - Extensive water testing equipment has arrived! ECCSCM recently received both hand-held and in-stream equipment capable of testing for a range of pollutants near CAFOs. Hand-held meters will test for water quality indicators such as nitrates, phosphate, ammonia, etc. with follow-up E. coli and fecal coliform tests if indicated. Other equipment will sample for multiple pharmaceuticals and antibiotics, with analysis by labs using EPA-approved methods. ECCSCM will receive training on the use of all equipment and begin testing as soon as weather permits.

Open Letter to potential buyers of ex-Vreba-Hoff/Southern Michigan Dairies CAFOs

Claims of CAFO Operators – True or False?
CAFO operators often claim: 1) if they have good intentions and enough land for application, liquid manure won’t contaminate streams; 2) if they follow their CAFO permit, liquid manure won’t contaminate streams.
(Answer: FALSE and FALSE)
Fact: all CAFOs here have been cited for manure discharges to streams. Having good intentions – as most here do – has not solved the pollution problem. Having plenty of acreage has not solved the pollution problem. Following the practices allowed in the CAFO permit has not solved the pollution problem.
Why? Because liquid manure on tiled fields is the problem. All fields here are tiled, so liquid manure like rain drains to the tiles and contamination flows to streams.
FOR CAFOs, THE ONLY WAY TO PROTECT STREAMS: 1) use a drier waste system, a pasture-based system with winter composting; or 2) install a municipal-grade wastewater system, so the liquid applied to land would not impair water quality.


See ECCSCM Monitoring Projects for 2013 – Air, water, DNA testing...

Update: November: another possible buyer for the ex-Vreba-Hoff facilities has appeared on the scene, with a purchase option in place. There is no indication on the part of the buyer of any willingness to monitor the impaired streams that originate on the CAFO properties. Consequently, ECCSCM is gearing up for water testing at several sites before animals fill the barns. We'll do baseline testing and follow up as soon as manure application begins. These facilities have the problem of being the ONLY source of contaminants in two of the impaired streams, at several locations. There's no upstream. Medina Drain and Durfee Creek, 2 of the impaired streams, originate on the Dillon Rd property. In addition, Lime Creek (the stretch called Lime Lake Inlet), is also impaired and drains major fields at the US-127 facility and flows directly into Lime Lake. More details on the monitoring projects will be posted soon.

Nov 12 - foul water discharging from Bakerlads manure field after rains last night. This water flows to the South Branch of the River Raisin – and on to Lake Erie. Contaminants and excess nutrients in agricultural runoff have been the major contributor to Lake Erie's toxic algae blooms and dead zone. See Nov 7-8 Stench Alerts for Bakerlads stockpiling details.

Fall 2012 ECCSCM Newsletter
NW Adrian area – new ag concerns for neighbors, water quality. One CAFO and several large livestock operations lie upstream from Lake Adrian, the City of Adrian's drinking water supply... Also, in July, Sale of 3 Vreba-Hoff facilities to Wisconsin buyers falls through!...and USDA study in Bean Creek Watershed shows risks of corn silage for water quality.

July 5 - SMD said in May, there was "no excuse" for draglines in waterbodies. But once again, SMD manure contractors have placed a dragline in the culvert of a waterbody, Covell Drain where it crosses Canandaigua Rd. Hoffland Farms manure spill at the lagoon, at tile riser leading to Rice Lake Drain.
covell hoffland1 hofflan2
Covell Drain culvert (left) with SMD dragline, 7-5-12; manure spill (right) at Hoffland Farms lagoon, pooling at tile riser leading to Rice Lake Drain.

May 12 - SMD cited for 2 discharges of liquid manure to surface waters. See Violations page for details.

May 3 - SMD dragline has been moved from Bean and its tributary on Medina Rd around the corner to the same tributary on Acker Hwy, where it's in the water, a fold in the line. Draglining application is along Munson Hwy. Along the way, the line is not only in the tributary but also on the Acker roadway itself and in the stormwater culvert at the US-127 facility.
Ackerwestside foldAcker
5-3-12 - Dragline in water of tributary to Bean Creek, Acker Hwy (west side culvert; east side with fold)

roadAcker storm
5-3-12 - SMD's dragline on the road surface of Acker Hwy (left); and in the water at the stormwater culvert, US-127 (right)

May 1 - 7:00pm - SMD dragline breaks! Liquid manure flows down ditch.

break fix
5-1-12 - break in dragline along Donnelly Rd and "fix" that wasn't, with straps. See black water (below).

May 1, 2012 - SMD is draglining again, the dragline placed across Bean Creek. The manure-inflated dragline is lying in the water of a tributary of Bean Creek, see photo below, and somewhere out of sight, also crossing Bean Creek itself, a natural stream, with the Michigan Nature Association Powell Sanctuary just 1 1/2 mi. downstream. In 12 years here, we have NEVER seen draglines in streams. DEQ says this is not their "jurisdiction." Think of the risks – to fish, freshwater mussels (several threatened species), drinking water sources downstream. How can this be legal? Could you stretch a pipe with septic waste across a stream, even temporarily? Given the extreme risk, should this be an "acceptable" agricultural practice?
kink other drag
5-1-12 - At the tributary culvert, the drag line hose has a kink (left). Some liquid must be getting through or the hose would blow up; on the other side of the culvert (middle) the line is fully inflated, lying in the water, and pumping on towards Bean Creek. (On right) applicator pumps liquid manure on the field through those tentacles.

weekend of April 28-29, Southern Michigan Dairies is draglining along Ridgeville Rd, with black water flowing through County Drains to Toad Creek. DEQ has not responded. See details, photos of manure-filled draglines along US-127, across several fields.
4-29-12 - scum on Toad Creek/Blanchard Joint County Drain, downstream from SMD draglining.

3 Hudson-area CAFOs - SHUT DOWN!
All cows are gone. Front gates are padlocked. The three former Vreba-Hoff dairies - taken over last fall by Rabo Agri-finance Bank and its subsidiary Southern Michigan Dairies - are completely shut down.
Out back, out of sight, millions of gallons of liquid manure...
Spring manure spraying in gear once again - neighbors suffer...
Michigan ag contributes $71.3 billion to economy? - NONSENSE!
You hear the number - $71.3 billion! - touted by Farm Bureau over and over, you hear it at every ag meeting, in press releases, picked up by politicians in bombast about Michigan agriculture.
A gigantic number! And, as it turns out, an imaginary number.
The real number? $2.73 billion. Still a fine number. Just 30X smaller.
Bless Bridge Magazine for some serious scrutiny and honest analysis of federal GDP data, showing...

January - Southern Michigan Dairies is fined $24,500 for violating its deadline for closure of the failed concrete manure lagoon at SMD 1. The lagoon was properly closed on Dec 27, 2011, 56 days past the deadline. The fine must be paid within 30 days of receipt of the DEQ Letter sent to Mark Fischels, Pres., Southern Michigan Dairies, Rabo Agrifinance, Ames, Iowa, on Jan 5, 2012.

Jan 5 - DEQ announces Public Hearing for Southern Michigan Dairies CAFO permits for Feb 1 in Hudson. See links below to the DEQ draft permits and SMD applications. Also see article with general information and details on the permits in our Winter Newsletter.

Please attend this hearing and comment. Let DEQ know your concerns. Or email your comments to Mike Bitondo, DEQ:

Wednesday, Feb. 1, 2012
7:00 p.m. to 9:00 p.m.
Hudson Middle/High School Cafeteria
771 North Maple Grove Avenue
Hudson, Michigan 49247

SMD 1 draft permit and application form.
SMD 2 draft permit and application form.

Jan 3 - Bakerlads CAFO field sprayed black with liquid manure, immediately upslope from the South Branch of the River Raisin (banks visible lower right). Thaw is predicted for later this week.
1-3-12 – Black manure field sloping to South Branch River Raisin, east of Morey Hwy between Beecher and Cadmus Rds.


See New Year's Eve video of bulldozed houses, closed SMD barns.
Dec 28 - Is Southern Michigan Dairies closing down its facilities? SMD 1 and 3 were emptied of animals last fall. SMD 2 along US-127 has emptied one barn. A cow hauler is sitting at the north end of the facility. The house across US-127 has been bulldozed down. The house and barns across from the SMD 1 facility on Dillon have also been dozed into a heap.

December 14 - Press Release

Groups Call on State of Michigan to Shake Up Agriculture Practices

East Lansing, MI – A diverse group of faith, farming, conservation, community and food organizations today called on the Michigan Agriculture Commission to reassess and revamp some of the state’s most controversial livestock farming practices. The seventeen organizations called for a complete reassessment of the Michigan Department of Agriculture and Rural Development’s Generally Accepted Agriculture Management Practices, or GAAMPs regarding use of liquid livestock wastes and concentration of facilities. The organizations specifically ask the state officials to give “due consideration” of impacts of these practices on agricultural communities and the environment, as well as on individual operations.

Janet Kauffman, spokeswoman for Environmentally Concerned Citizens of South Central Michigan, presented a letter from the organizations to the Commission at their meeting today. Kauffman said "the big picture shows big impact and real harm -- to neighbors, to watersheds, and to the Great Lakes. To stop pollution downwind and downstream, agricultural practices can't just be for one farm anymore. We need to add it all up and find practices that protect whole communities, and whole watersheds."

According to the letter, the voluntary GAAMPs for liquid manure and facility concentration have lagged far behind the scientific documentation of the negative impacts of this waste on public health, natural resources and the well-being of communities. By law the GAAMPs are updated every year, however updates are usually minimal and has not addressed the rapid growth of intensive livestock practices. The introduction of liquid manure systems and the application of the liquid manure onto fields with subsurface tiles, and rapid expansion and the concentration of large facilities has been linked to water pollution downstream, including in the Great Lakes. Pathogens, including E. coli, Cryptosporidium, and Giardia are commonly found in ditches that drain the farms into streams and lakes.

Lyman Welch, Water Quality Program Manager, Alliance for the Great Lakes, explained the significance of cumulative impacts, “Agricultural runoff threatens our Great Lakes with algal blooms that harm the lakes’ health, and the economy of the region through lost tourism and lost recreational use. Michigan’s agricultural practices must be updated to help prevent nutrient runoff from harming the Great Lakes.”

“Thirty years is a significant length of time, time to reassess practices for effectiveness,” said Rita Chapman, Sierra Club Clean Water Program Manager, “to make sure they still result in clean water and air, and healthy sustainable agricultural communities. It’s time to look ahead to agricultural practices that all can live with.”

In addition to ECCSCM, Sierra Club and the Alliance for the Great Lakes, the letter presented to the Commission today was signed by the following organizations:

- Adrian Dominican Sisters, Program for Justice Peace, and Corporate Responsibility
- Clean Water Action
- Clinton River Watershed Council
- Food and Water Watch
- Great Grand Rapids Food Systems Council
- Izaak Walton League of America, Dwight Lydell Chapter
- Lone Tree Council
- Michigan Environmental Council
- Michigan Farmers Union
- Michigan Trout Unlimited
- National Wildlife Federation
- Program of Environmental Studies/Geology, Alma College
- Society for Protecting Environmental Assets
- Western Lake Erie Waterkeepers

Nov 28 - Lagoons at SMD 2 along US-127 appear very full.

Winner 2010 Goldman Environmental Prize
as featured in Ophra Winfrey's O magazine

Lynn Henning, CAFO Water Sentinel for Sierra Club, and member of ECCSCM Board of Directors, is the 2010 winner of the Goldman Environmental Prize for North America. The Goldman prize is granted to only 6 activists world-wide. Lynn was awarded for her work to protect natural resources from CAFO pollution. She was presented the award in San Francisco on April 19 and spoke in Washington, D. C. on Earth Day weekend. See article in the Adrian Daily Telegram.

Lynn's Sierra Club Water Sentinel monitoring has led to numerous CAFO violations in our area, documented by the DEQ.
Lynn Henning

Aug 15 - SMD manure discharge into Medina Drain, tributary of Bean Creek. Details from DEQ email 8/15/11: "Friday afternoon there was a break at the pivot of the irrigation sprayer in the corn field west of Ingall Hwy. An unknown amount of liquid reached the beginning of the N Medina Drain. They immediately dammed up the drain at three separate points downstream, including at the field, downstream of Ingall Hwy and at the farthest point where any of the liquid reached downstream of Ingall. They called us late Fri morning and we were down there to observe that afternoon. They contained and pumped liquid throughout Friday and Saturday and either applied the liquid to approved fields or placed it back in lagoons. By Saturday night most of the work was done. Sunday they did some final flushing of the drain using clean water with contracted trucks from Leas Farms. The trucks were triple rinsed and filled with clean water for the flushing. Downstream of the flushing the water was again pumped out and field applied. Once the flushing was complete we approved the removal of the temporary dams and all is complete to our satisfaction at this point."

weekend of Aug 12-14 - Southern Michigan Dairies incident: A neighbor reported to ECCSCM that SMD tankers were hauling and discharging liquid into the North Medina Drain, Ingalll Hwy, beginning on Fri Aug 12, and continuing all weekend. North Medina Drain is a tributary of Bean Creek. ECCSCM photos on Sunday Aug 14 show a tanker dumping water directly into the Drain. A tractor with pump and another semi are in the field near a center-pivot irrigation system near the head of Medina Drain. Did manure discharge to Medina Drain? No report from DEQ yet on that.

Sunday, Aug 14 - tanker discharging water into North Medina Drain, Ingall Hwy; tractor with pump and another semi in the field near head of North Medina Drain.

early June 2011 - fields are finally drying, lagoons are very full. Millions of gallons of manure will soon be sprayed in our watersheds, all draining to Lake Erie, already contaminated with excess nurients.
Lagoons at Hartland Farms, 6-4-11

April 25, 2011 - with some CAFO lagoons nearly full and rain in the forecast every day this week, manure is being hauled to other locations. Over the long Easter weekend, manure tankers were rolling from Hartland Farms to Bakerlads, from Southern Michigan Dairy 2 to SMD 3.

March 2, 2011 - DEQ and Michigan Attorney General's Office files an Administrative Consent Order with Southern Michigan Dairies, the subsidiary of Rabo Agrifinance which took over the 3 Vreba-Hoff CAFOs in November, 2010. The ACO requires SMD to pay $100,000 as partial payment of Vreba-Hoff fines owed, requires SMD to empty and close the satellite lagoon on Packard Rd by Sept. 30, 2011, as well as close the failed concrete lagoon at SMD 1 (formerly V-H 1). The ACO also requires notification if any potential buyer is "involved with Wilhemus van Bakel personally or any of his business entities, including but not limited to: Vreba-Hoff Dairy, LLC; Vreba-Hoff Holding, LLC; Vreba-Hoff Dairy Development; the Van Bakel Group, or Nova Lait, LLC. The DEQ reserves the right to leave whole the Judgment Liens...should SMD transfer Dairies I, II, or III a van Bakel or Vreba-Hoff affiliated entity." See the full ACO document.

February 2011 Newsletter

Superbugs – an important national public health issue, including a recent editorial, "The High Cost of Cheap Meat," in the New York Times, June 2, 2011. Also, read the full EMU study, “Antibiotic Resistance, Gene Transfer, and Water Quality Patterns Observed in Waterways near CAFO Farms and Wastewater Treatment Facilities,” which used data from water tests in our watersheds. EMU researchers found multi-drug resistant bacteria in water near CAFOs here: “Our results indicate that CAFO farms not only impair traditional measures of water quality but may also increase the prevalence of multi-drug-resistant bacteria in natural waters.”

Feb 10, 2011 - Is Rabo/Southern Michigan Dairies selling former Vreba-Hoff equipment, tractors? See the trucks loading up at the facility on US-127 on our ECCSCM's YouTube channel.

Feb 2011 - Manure application on snow and frozen ground continues, at great risk to our headwater streams of Lake Erie. See article in this month's Newsletter about other states that prohibit this practice; and see it happening now, as usual, in Michigan.


ECCSCM October Newsletter

Nov 2010 – Bank takes over Vreba-Hoff facilities. According to an article in the Adrian Telegram Nov 18, Rabo Agrifinance "has taken over ownership of the Vreba-Hoff Dairy facilities near Hudson following negotiations to avoid foreclosure on a $55 million loan. Rabo Agrifinance Inc. had ownership of the Vreba-Hoff properties transferred on Nov. 12 to one of its business entities, Southern Michigan Dairies LLC. The bank has been running Vreba-Hoff I and II and the Waldron Dairy since then." By mid-November, V-H 1 and Waldron Dairies were shut down, all cows and operations consolidated at V-H 1 facility on US-127.

Video: Nov 3, 2010 – several fields in Hudson Township are sprayed black with liquid manure, before predicted rainfall. This practice often leads to contaminated water in field drain tiles, which pour into streams. Awful stench filled the car. Neighbors downwind are suffering today.

Oct 2010 – Foreclosure action against Vreba-Hoff
After a decade of violations, of trial and error and mismanagement of waste, of manure discharges and impaired streams, it's possible that Vreba-Hoff dairy CAFOs in Hudson will be shutting down soon.
The mortgage company Rabo Agrifinance has filed a foreclosure action to recover a $55 million debt and to foreclose on real estate mortgages and personal property. See Adrian Daily Telegram article. Rabo Agrifinance filed for foreclosure after the state of Michigan put a $580,000 lien on Vreba-Hoff properties in Lenawee and Hillsdale Counties. The Michigan court ruled earlier this month that Vreba-Hoff had failed to pay back fines and violated manure treatment standards agreed to in a previous court order.
Two Rabo lawsuits
Rabo lists a $14.4 million loan against Waldron Dairy, Vreba-Hoff 1, Vreba-Hoff 2, and in Ohio, Blue Stream, Wild Cat and Williams Dairy Farm, as well as another $2 million loan against Waldron, Blue Stream, Wild Cat and Williams Dairies. More loans cover farmland, cattle and other personal property, including equipment.
A hearing on the foreclosures was scheduled for Oct 19 in federal district court, Grand Rapids, but has been temporarily postponed.
State of Michigan lawsuit – injunction in place
In the ongoing Michigan Department of Natural Resources and Environment (DNRE) lawsuit against Vreba-Hoff, the 30th Circuit Court on Oct 18 issued an injunction ordering Vreba-Hoff to “immediately cease irrigating effluent in violation of treatment standards.” Vreba-Hoff was also ordered to keep manure pits at proper levels. Since Vreba-Hoff has violated its own treatment standards for years, the facilities may well have to reduce cow numbers to control manure levels in lagoons.
Early in October, the court filed a $580,000 lien against Vreba-Hoff’s two CAFOs in Lenawee and Hillsdale counties after the court found that Vreba-Hoff failed to pay back fines and violated the manure treatment standards, with more than 700 violations over many days in 2008-2009 for irrigating polluted wastewater.
Groundwater Concerns
In court, groundwater concerns were also addressed. Vreba-Hoff’s recent hydro-geologic study to determine if groundwater contamination was present was characterized as “inadequate” by the state of Michigan’s lawyer. The state is concerned that with all their financial problems Vreba-Hoff will not re-do the study and will not install the groundwater monitoring wells that were required.

October 2010 - Judge finds Vreba-Hoff in violation of previous Orders; decision on de-populating dairy herd coming soon. Adrian Daily Telegram reports, "A court decision that could decide whether the two Vreba-Hoff dairies near Hudson remain open could be handed down as soon as an Oct. 18 hearing in Ingham County. Michigan Department of Natural Resources and Environment is asking a judge to order a reduction of 600 cows a month until the dairies meet standards set in permits for their manure treatment systems." (see full article)

August - Bridgewater Dairy buys Chesterfield (now called Oakshade Dairy) out of foreclosure. Chesterfield left over 20 million gallons of manure in pits, according to the Bridgewater website.

August - Vreba-Hoff misses Aug 23 deadline for payment of past fines. Also, court hearing on the new lawsuit (see July, below) scheduled for September 20.

July - Sturgis Journal reports Vreba-Hoff's business arm, Midwest Ag Investments, has filed for Chapter 11 bankruptcy. The Journal article quotes Peter van der Vegt, director of business development for Vreba-Hoff, asserting, "the bankruptcy is an opportunity for Midwest Ag Investments LLC to protect its assets, and the bankruptcy is a part of its restructuring plan."

July 19 - New Court Action against Vreba-Hoff - Michigan's Department of Natural Resources and Environment (DNRE) files a new Amended Complaint against Vreba-Hoff with the 30th Circuit Court citing numerous, continuing violations – liquid waste still doesn't meet treatment standards; Vreba-Hoff has not had a certified operator of its treatment system since April 2009; Vreba-Hoff continues unauthorized dumping of waste in the satellite lagoon on Packard Rd, an illegal groundwater discharge. DNRE requests the court to order "depopulation of the dairy operation" if treatment standards are not met. DNRE also asks the Court to order Vreba-Hoff to hire a certified operator for the "Earthmentor" system immediately, to enjoin Vreba-Hoff to stop hauling waste to the satellite lagoon and, as ordered previously, to close the lagoon down.
See DNRE Fact Sheet on the current state of Michigan's lawsuit against Vreba-Hoff.
See the full DNRE Amended Complaint.
Marchlagoon Maylagoon 2Maylagoon
Vreba-Hoff’s “satellite” lagoon on Packard Rd noted in the new Court Action – (left) March 19, not shut down, well after March 8 deadline; (middle) May 19, still there, filling up with unauthorized Vreba-Hoff dumping; (right) May 30, photo from far side, showing gap bulldozed shut and hauler dumping manure, foaming at the corner.

May 11 - after heavy rains, massive runoff from Hoffland manure application sites. Manure draglines are still in place in the fields along Tomer Rd.



May 6 – Hoffland CAFO draglining at Wheeler and Haley Rds; also applying along Tomer Road, with liquid waste ponding on already saturated ground. Draglining pumps liquid manure direct from lagoons through hoses to the field.

5-6-2010 - wheel tracks full of Hoffland liquid manure

April 23-24 - strong emissions from Hartland Farms manure application – before predicted rainfall of 1" – along Cadmus Rd east of Hughes; Bakerlads also spraying along Cadmus west of Morey Hwy.
4-24-2010 – Bakerlads black manure field along Cadmus Rd, in rain

March - With warmer days and thaw, winter application of manure runs off fields. On March 3, blackwater from Bakerlads field tile flows to South Branch of the River Raisin.
runoff blackwater
3-3-10, black manure at far end of Bakerlads field runs off and reaches tile system; blackwater flows from tile into South Branch of the River Raisin


Dec 14 - DEQ files new lawsuit against Vreba-Hoff 4th lawsuit in 5 years – see DEQ press release
DEQ has filed a new lawsuit against Vreba-Hoff, alleging hundreds of new permit violations. “Once again we find ourselves having to ask the court to enforce the numerous agreements that Vreba-Hoff has failed to live up to, and enough is enough,” said DEQ Director Steve Chester. Vreba-Hoff is prohibited from irrigating treated effluent unless it meets certain concentration-based limits. Despite failing to achieve those limits, Vreba-Hoff irrigated waste at multiple locations over 128 days during the summer and fall of both 2008 and 2009.

Dec 13 - runoff from field application of Bakerlads manure leads to foamy discharge at Plank Rd, South Branch of the River Raisin.
South Branch RR
12-13-09 – foamy discharge from Bakerlads manure field, South Branch of the River Raisin.
Dissolved Oxygen level tested at 2.2 mg/L, well below fish-kill level.

Aug 11 - Bulletin: another apparent manure discharge from Chesterfield Dairy, this time in Michigan. A neighbor reports that Chesterfield "had to bring two tankers to suck out a major manure runoff at the corner of Mulberry Road and the Sand Creek Highway. Chesterfield has been spraying manure ... all day and the rain washed the manure into the nearby creek...I believe the DEQ has been called already, the police, the health department, the road commission, the MDA, probably other agencies." Another neighbor writes, "AS DUSK APPROACHED THE STILLNESS CAME WITH IT. THERE HAS BEEN NON STOP LIQUID MANURE SPRAYED, THIS IS THE THIRD WEEK IN ALL OF 120 ACRES. IT FINALLY RAINED SO HARD THAT MANURE RAN OFF THIS ROLLING GROUND INTO THE DITCH, WHICH DUMPS INTO THE NILE WITHIN 40 YRDS. CHESTERFIELD DAIRY BARRICADED A CULVERT WITH A BLOWN UP BLADDER BALL 2 HRS.LATER. HUGE VACUUMS ARE SUCKING OUT THE POOL THAT IS BUILDING UP. STILL PUDDLES OF WATER THAT LAY AROUND THE DITCH SMELL LIKE MANURE TOO. NOW EVERYONE IS GONE THE DITCH IS FILLING UP AGAIN IT LOOKS AND SMELLS HORRENDOUS NOW ITS JUST LYING THERE NO ONE AROUND TO SUCK IT OUT MY 9 YR OLD COULDN'T TAKE THE SMELL ANY MORE AND THREW UP. WE WENT HOME DON'T KNOW WHAT TO DO."

Aug 4 - Blackwater in North Medina Drain, immediately downstream from Vreba-Hoff 1 fields. ECCSCM called DEQ Emergency hotline as possible discharge. At Vreba-Hoff 2 on US-127, field tile south of the facility is running gray water.
blackwater tile
blackwater from North Medina Drain at Vreba-Hoff 1, 8-4-09; graywater from field tile along US-127 at Vreba-Hoff 2, 8-4-09

July 16 -At 10 p.m., emergency responders report a manure discharge from Chesterfield Dairy, Lyons, OH just east of Morenci, to Little Bear Creek, a tributary of the River Raisin. Pollution Incident Report says "the creek is running black from the manure." On Friday, July 17 at least 3 mi. of the stream are still black with manure, the stream edges lined with dead fish.
fish kill
fish kill in Little Bear Creek, from Chesterfield manure discharge, 7-17-09

June 24 - The Michigan Supreme Court ruled that the public has the right to know what CAFOs do with their millions and millions of gallons of manure. CAFOs' Comprehensive Nutrient Management Plans (CNMPs) will now be submitted with their pollution control NPDES permits and will be available to the public, following a Sierra Club suit that argued the same information is required and is public in all other industrial and manufacturing NPDES permits.

June 24 - ECCSCM sampling for ammonia at 5 stream sites near Vreba-Hoff spray-irrigation finds 6ppm–highest level of Hach test strip–at EVERY SITE. Ambient freshwater ammonia levels are typically less than 0.1 ppm. Ammonia levels above 1 ppm can be toxic to some fish.

May 18 - Vreba-Hoff paid its $223,500 fine (see April 16 below); Vreba-Hoff still owes $180,000 in fines, due when the EarthMentor "treatment" system is certified as operating as designed. Vreba-Hoff says it's working fine, but ... why haven't they got the certification

May - Livestock found to be the main source of E. coli in Lake Huron. After years of arguments over where the disease-carrying bacteria come from -- humans, livestock or wildlife -- DNA "fingerprinting" says human sewage is only a tiny fraction of the problem. Manure from cattle and pigs far outweighs human sewage as the source of E. coli pollution in Lake Huron, says a new Canadian study, published in the March issue of the Canadian Journal of Microbiology. See article in Ottawa Citizen (May 5, 2009) or read the abstract or full scientific study, "(REP)-(PCR) analysis of Escherichia coli isolates from recreational waters of southeastern Lake Huron" in the March issue of Canadian Journal of Microbiology.

April 16 - Vreba-Hoff orderd by 30th Circuit Court to pay $223,500 in fines no later than May 18 (see entry Feb. 3 below -- Vreba-Hoff's motion for "relief" was dismissed by Judge James R. Giddings.

April 13 - Leonidas, St. Joseph County - Vreba-Hoff-developed Bustorf Dairy permit is being appealed by Society for Protecting Environmental Assets. DEQ initially denied a permit for the proposed 2260-cow dairy, then granted the permit in March. See article in Kalamazoo Gazette.

Feb 3 - update on ongoing Vreba-Hoff lawsuit: Michigan Attorney General files a motion in 30th Circuit Court for Summary Disposition, asking the court to rule that Vreba-Hoff's undisputed fines are "due and owing immediately" to the State of Michigan. Vreba-Hoff had requested "relief" from paying its $400,000+ fines until it could add more cows to produce more income. The Attorney General's brief concludes: "Perhaps what is most ironic about Vreba-Hoff's objection and requested relief is the fact that the reason for the lawsuit in the first place was because of Vreba-Hoff's inability to properly treat or otherwise control the vast amount of agricultural waste generated by over 6,000 cows. Rather than reduce or eliminate the source of the waste, Vreba-Hoff is requesting to add even more cows, with the 'hope' that the treatment system (which has failed to meet the agreed upon standards) will somehow work as originally represented sometime in the future...MDEQ has no confidence in Vreba-Hoff's projections or abilities, and merely asks compliance with the negotiated agreements." (Brief in Support of Motion for Summary Judgment, MDEQ vs. Vreba-Hoff Dairy LLC, 30th Circuit Court, Feb 3, 2009)

Feb/Mar issue of Mother Earth News publishes article on "The Hidden Link Between Factory Farms and Human Illness." This article provides links to numerous recent studies on health issues, focusing especially on antibiotic-resistant bacteria in factory-farmed meats.


Dec 31, 2008 - last year's tally of offenses, degradation: 65 violations and unlawful discharges from CAFOs in our area during 2008. (See details of these violations)

Nov 6 - Mediator recommends Vreba-Hoff fiines of $223,500 for multiple violations of the 30th Circuit Court's Interim Order. The Dispute Resolution Facilitator (DRF) established by the Interim Order notes that the Order required Vreba-Hoff to construct a partial-treatment system for animal wastes, and pay $180,000 in penalties for previous violations when the "Defendant [Vreba-Hoff] presents an engineer's certification that the Earth Mentor System is operating as designed...Defendant has not presented the certification." Total fines owed by Vreba-Hoff are now $403,500. The DRF Report cites at least 10 violations, some continuing for many days, including: overflow of a manure pit (Sept. 7, 2007), discharging to Medina Drain; 3 other illegal discharges to streams; failure to remove cows as required when waste storage was insufficient; lack of freeboard marking; missed deadlines for construction of the treatment building and sand separation devices; missed deadline for operation of treatment cells at both Vreba-Hoff 1 and 2 facilities in Hudson.
--Report and Recommendations of Dispute Resolution Facilitator to the 30th Judicial Circuit Court, Ingham County (November 6, 2008)

Oct 29 - CAFOs fined $213,000 for road damage by Lenawee County Road Commission, 2004-2008 -- including $178,000 in fines against Vreba-Hoff for damage to Dillon Hwy and Packard Rd. New Flevo CAFO paid $35,000 for damage to Forrister Rd.

Oct 14 - Wayne Pacelle, president and CEO of The Humane Society on Oprah Winfrey show with agribusiness reps on California's Prop. 2. which would abolish confinement of farm animals in extreme conditions -- no room to turn around or stretch their legs or wings. See NYTimes editorial, Oct. 9 (link below).

Oct 9 - New York Times editorial supports California's Propostion 2, the California Prevention of Farm Animal Cruelty Act.

Sept 24 - MDA cites Agri-Flite Services, a crop dusting company, with violations of state and federal pesticide laws after spraying July 30 of Headline Fungicide on Hartland Farms cornfield drifted onto neighbors' property. Several residents became ill, and MDA testing found the active ingredient of Headline, pyraclostrobin, on the residents' property and crop fields. MDA "has initiated the appropriate enforcement action with Agri-Flite Services."

Sept 24 - Government Report Links Factory Farms to Harmful Air Emissions, Water Pollution - A Government Accountability Office (GAO) study released
today says that large factory farms, known as Concentrated Animal Feeding Operations (CAFOs), can emit dangerous levels of airborne and waterborne pollutants. Rep. John Dingell of Michigan said, “This GAO study confirms that the Bush Administration’s plan to exempt industrial sized animal feeding operations from emissions reporting requirements is nothing more than a favor to Big Agribusiness at the expense of the public health and communities living near these facilities.” See full report.

Sept 10 - Concerned about the water usage at proposed Vreba-Hoff dairy in Ogden Twp, Lenawee Co. Commissioners unanimously backed a well protection resolution asking the Legislature to expand existing laws that govern high-capacity wells. Limited groundwater supplies in southeast Lenawee County leave homeowners vulnerable if a dairy or other large water user moves in. Commissioners passed a resolution two years ago asking the state for a moratorium on permitting new dairies. See full article in Adrian Daily Telegram.

July 7 - After 3 years and repeated air pollution violations, State Line Farms in Morenci will shut down its swine barns at Ridgeville Rd, removing all animals by Nov. 9, and pay $28,000 in fines, under a Consent Order negotiated with Michigan's DEQ. Consent Order and details are posted for 30-day public comment.

June 30 - For the first time, the Michigan DEQ denies a proposed NPDES permit for a CAFO. Bustorf Dairy in St. Joseph County was denied a permit after very strong testimony by the township, local businesses and residents, Republicans for Environmental Protection, and the Huron Potawatomi Tribe that demonstrated “considerable disagreement on the validity of the assertions made by the applicant” regarding social and economic benefits to the community. See DEQ decision and Kalamazoo Gazette article.

May 22 - Pulic hearing in Hudson on Waldron, Vreba-Hoff permits was packed with neighbors, downstream residents, telling their stories of CAFO pollution, asking DEQ to deny NPDES permits to both CAFOs. See Adrian Telegram article. Written comments can be emailed until May 29 to Mike Bitondo, DEQ:
Several speakers described horrendous emissions from Chesterfield Dairy, Lyons, OH, which continues, since early April to dump and spray waste in Michigan fields.

HUDSON MIDDLE SCHOOL AUDITORIUM -- 771 North Maple Grove Avenue, Hudson, MI
The hearings are for public comment -- PLEASE COME AND SPEAK, OR HAND IN WRITTEN COMMENTS. Waldron Dairy (formerly Mericam, at Camden & Meridian Rds) is owned by Vreba-Hoff and plans major expansion. More liquid manure on tile-drained fields, more pits.
Both hearings will be held on the same evening, Waldron hearing first, then Vreba-Hoff. DEQ notes that the hearings are "an opportunity for the public to be heard, DEQ does not comment or answer questions. The hearing is recorded and DEQ will prepare a written response to comments. All comments will be considered but only comments applicable to the permit will receive a written response."
See public notice and more details, including links to draft permits for Waldron, for Vreba-Hoff.
Or email Mike Bitondo, DEQ, for details:

week of April 14 - neighbors report Chesterfield Dairy in Lyons, OH (which receives Vreba-Hoff manure) is transporting manure back to Michigan, spraying in Seneca Twp. Numerous complaints from residents to ECCSCM and local officials.

March 27 -DEQ cites Hartland Farms and Bakerlads for illegal discharges of manure (see March 3 below).

March 12 - For 7 months, Vreba-Hoff has violated repeated DEQ orders to immediately close a manure storage structure that failed and overflowed last summer (ordered Aug 24, 2007, Sept 17, 2007, Jan 22, 2008, and again March 12, 2008). When will they comply? This manure lagoon lies adjacent to the source of a tributary of Bean Creek -- the tributary was added to Michigan's impaired water list in 2004, after repeated manure discharges by Vreba-Hoff. Think of the consequences as Lake Erie headwaters are polluted, year after year.

March 7 - Hoosiers for Sustainable Agriculture serves Notice of Intent to Sue the US Fish & Wildlife Service and Vreba-Hoff CAFO for failure to protect a rare colony of Mitchell's Satry butterfly, one of the rarest species in the world. See full press release. The Notice sets forth violations of the federal Endangered Species Act resulting from Vreba-Hoff’s plan to build “Toll-Tail Dairy, LLC” next to the fragile Pigeon River habitat. Mitchell’s Satyr lives only in a rare type of fen, at only 2 small locations in Indiana and only 13 small locations in Michigan. Under the Endangered Species Act, when proposed development threatens a listed species, the FWS has a duty to ensure that a Habitat Conservation Plan is prepared and approved before construction begins. However, in this instance FWS refused to exercise its duty even though the planned Toll-Tail Dairy will likely extinguish the Pigeon River colony of Mitchell’s Satyr. Ironically, the FWS website lists “livestock production” as one of the top threats to Mitchell’s Satyr.

March 10 - DEQ cites Waldron Dairy (Vreba-Hoff owned) for multiple violations, including 2 illegal discharges of manure to Bean Creek Watershed after application of wastes to frozen and snow-covered ground.

March 3 - rain started late morning. Almost immediately, Hartland Farms manure was discharging to Bear Creek from Hughes Hwy application last week, Bakerlads manure was discharging to South Branch of the River Raisin from Cadmus & Morey application yesterday, road is flooded, and Bakerlads are still spreading, in the rain.

3-3-08 Bakerlads waste running off the manure-black field to Cadmus Rd, drains to S.Branch River Raisin

Feb 13-18 - Waldron Dairy sprays manure black on snow fields along Ridgeville Rd before thaw and predicted rain. Runoff from these fields will flow to Lime Creek.

Waldron Dairy spraying manure 2-13-08, Ridgeville Rd; runoff and ponding two days later, 2-15-08
"When a chronic polluter spreads thousands of gallons of liquid manure on snow covered frozen ground 3 days before a predicted thaw and rain when is it a criminal violation? We had a high on 2/17 of 48 degrees and .62" of rain according to the Weather Underground for Adrian. And once again it was before a holiday weekend."

Feb 7 - major flooding in northern Ohio, southern Michigan after snow thaw and heavy rains. Near Lyons, OH, manure application on frozen, flooded ground, just east of CR-M and CR-13.

Jan 28, 2008 - Waldron Dairy CAFO spray-applying liquid manure on frozen ground, as temps warm and rain starts to fall, violating every recommended "guideline" for good ag practices. Only outcome possible: contaminated liquid will flow to tile-inlets and pollute Bean Creek tributaries.

1-28-08, Waldron Dairy spraying manure, black field just before rain, at Burt & Seeley Rds.

Jan 22 - DEQ orders Vreba-Hoff "to cease the discharge immediately" from a tile at South Medina Drain, first noticed discharging in October, 2007.

Dec 3 - Vreba-Hoff fined $8,000 for dam safety violations under a Consent Agreement with DEQ's Land and Water Management Division, after construction of four waste lagoons/dams at the dairy facilities without required dam permits.

Nov 21, day before Thanksgiving - Bakerlads Farms/MSU Center of Excellence discharges waste to South Branch of the River Raisin after surface application of slurry/solids for several days with no incorporation, no crop in field. Blissfield and Deerfield get their drinking water downstream.

11-21-07 - Bakerlads manure runoff, ponding

Oct 26 - DEQ cites Vreba-Hoff for numerous violations of its Interim Consent Order, including land application of wastes to fields without sufficient phosphorus data; land application of contaminated sand bedding, bypassing sand separation requirement; improper composting -- "the current practice of simply piling solids and later land applying certainly does not meet the industry standards for composting"; removal of check dams, failure of silt fencing, expired construction storm water permit; failure to transport off-site the waste of "excess" cows at the dairy operations.
DEQ Notice Letter (October 26, 2007)

October- pits and more pits at Vreba-Hoff. That's the solution to industrial dairy waste? Watch the farmland disappear.  These are "farms"? Looks like mountaintop removal mining. These sites are the origins of 3 streams, the headwaters of Lake Erie. (see more pit & "compost" photos)

10-31-07 Vreba-Hoff 1 (left) and Vreba-Hoff 2 (right).

Oct 17 - penalties mount for Vreba-Hoff --$164,000 owed as of Oct 17, with 2 ongoing violations--1) storage structure levels are not yet marked as required; 2) untreated manure is stored in settling basins of "treatment" system.  Each of these violations carries a stipulated penalty of $500/day, "which is continuing to accrue." (DEQ letter to Vreba-Hoff, Oct. 17, 2007).

Sept 26 - Attorney General's office orders Vreba-Hoff to pay $141,500 in penalties for multiple violations over the last two months; also orders removal of 350 cows.

Sept 13 - DEQ notes "Vreba-Hoff has allowed conditions to further deteriorate to the point the Dairy Operations now pose a grave threat to public health and the environment." (see pdf of full DEQ letter)

Sept 13-ECCSCM applauds MSU's pasture-based dairy initiative. MSU develops pasture-based dairy and markets for pasture-based products (see press release). With a $3.5 million grant, MSU will convert the conventional dairy operation at Kellogg Biological Station to a pasture-based program over the next two years. "A 120-cow milking herd will be maintained on an intensively managed rotational grazing system and on a replicated plot-based pasture system. A portion of the milk produced at KBS will be used for production of cheese at the MSU Dairy Plant."  The grant also will fund "work to develop an improved supply chain – processing, distribution and marketing programs – for pasture-raised animals."

Sept 9- Vreba-Hoff manure lagoon overflows at Vreba-Hoff 1, discharges manure into South Medina Drain. DEQ water tests find E. coli levels at 370,000/100ml in the headwaters of South Medina Drain; 2 days later, E. coli is still greater than 10,000/100 ml. On Sept 10, DEQ finds concrete lagoon still over freeboard; DEQ orders Vreba-Hoff "to take actions to prevent further discharges from this structure." DEQ finds the CAFO is "1,687,000 gal. over freeboard capacity in their storage structures."  DEQ also notes, "They have not removed cows from the facility as required by the CO [Consent Order] if they go over freeboard."

Aug 24 - DEQ notes "a grave situation" at Vreba-Hoff facilities: "The situation at Vreba-Hoff's two Hudson-area dairies appears to have deteriorated substantially this week." On Aug 23, a concrete storage structure failed at V-H 1, leading to an illegal groundwater discharge. In the last month, DEQ cited Vreba-Hoff for more than 15 violations, including 3 illegal discharges to South Medina Drain and to Durfee Creek Extension, multiple freeboard violations, failure to meet required deadlines, etc. (See complete list of July/August violations cited by DEQ)

weekend Aug 24-26 - Vreba-Hoff hauling tanker after tanker of manure from Hudson through Morenci to Chesterfield Dairy in Lyons, OH, after rains put lagoons at risk for overflow.  Vreba-Hoff STILL hasn't got its manure situation under control; it's almost a year of overful, near-overflow conditions. Routine rain is an "emergency" situation? See State Line Observer article, Aug. 29: "A lot of manure passed through Morenci over the weekend as Vreba-Hoff Dairy sent dozens of tanker loads to a storage lagoon east of town..."

June 7, 2007 - At last! Court orders Vreba-Hoff to pay $180,000 in fines for violations, orders volume limitations on waste and construction of new waste treatment system, prohibits new barns for 10 years.  (see DEQ press release;Ingham County Interim Court Order;Settlement Agreement) After years of pollution, the bad news is: the new "treatment" will not function until next year, if then; and the old "treatment" doesn't work.  Which means neighbors and streams will suffer Vreba-Hoff business as usual -- pollution for many many more months.

May 18 - Durfee Creek, a stream on Michigan's 303(d) list of impaired waters, is still foul and blackish-red, a month after manure discharges from Vreba-Hoff. The stream still has slim to non-existent buffers, and today--brush removal ! by the Lenawee County Drain Commission.  How can this stream recover, with continuing abuse and degradation? In its Notice Letter citing multiple discharges over several days, DEQ noted the pivot irrigator "travels through a low wet area where irrigation of waste easily flows into the creek." The letter also noted the stream "was very dark in color and had a strong agricultural waste odor...Several areas of obvious overland flow and erosion from the irrigated field to the creek were noted. Very little to no vegetated buffer exists along the creek."  (DEQ Notice Letter to Vreba-Hoff, April 11, 2007)
5-18-07 --(left) Durfee Creek, black water, at Dillon Hwy;and (right) the thin green line is Durfee Creek's pitiful buffer, with heaps of back-hoe-ripped shrubs from Drain Commission "brush removal" -- there's that much less rootedness to hold soils and stop manure flows to this impaired waterway.

May 4 - Vreba-Hoff Crisis-- 8 months of overfull, overflowing lagoons, unlawful discharges, and still no action from the court on Vreba-Hoff violations.  Aerial photos on May 4 show the north lagoon at Vreba-Hoff on US-127 overflowing into adjacent calf hutch area. Other photos show overfull lagoons at both facilities.
Vreba-Hoff north lagoon, US-127, overflowing, 5-4-07   close-up, manure water flowing into calf hutches

April 20 - Len. Co. Road Commission asks Vreba-Hoff to pay $177,000 for road damage. "The cost of repairing three miles of gravel roads that Vreba-Hoff Dairy used to haul manure to a lagoon on Packard Road during the spring thaw is expected to be more than three times the $55,000 bond the dairy posted in January for a haul route permit." See full article in Adrian Daily Telegram.

March - April - 23 new violations at Vreba-Hoff facilities, since Jan 1, 2007, documented in DEQ Notice Letters of March 14, March 21, April 11.

March 12 - Vreba-Hoff contempt hearings drag on and on.Thaw has begun, fields are saturated, road weight-limit laws in effect.  How, where, will Vreba-Hoff dispose of these millions and millions of gallons of sewage?

Jan 26 - ECCSCM joins Lenawee County Commissioners and asks for a moratorium on CAFOs, as well as an immediate halt to new construction of CAFOs and lagoons in Lenawee and Hillsdale Counties, mandatory groundwater permits, mandatory monitoring wells around all new and existing CAFOs, a limit to the amount of CAFO waste applied in each watershed. and effective waste treatment of CAFO waste. See full press release.

Jan 19 - DEQ, Attorney General's office ask the 30th Judicial Circuit Court to find Vreba-Hoff in contempt of court for ongoing violations of the Consent Judgment of 2004. Petition asks for reduction in herd size until Vreba-Hoff can demonstrate to the satisfaction of the Court and DEQ that it can properly manage all wastes produced by the dairies without harming water resources of the state. See DEQ press release.

Jan 10, 2007 - Lenawee County Commissioners vote unanimously (8-0) for a moratorium on CAFO construction, for pollution bonds for CAFOs, for on-site wastewater treatment similar to those for municipalities. See Resolution.

Jan 9, 2007 -Vreba-Hoff lagoons full, at the point of breaching. Vreba-Hoff began massive emergency dumping, pivot-spraying of manure at multiple locations late this afternoon, in violation of a court judgment prohibiting application in winter. DEQ officials today confirmed the CAFOs are taking evasive action and that they are aware of the violations. (see stench alerts for more details). Jan 10 - dumping continues - ECCSCM calls for an injunction to stop the illegal dumping, and asks DEQ to shut the CAFO down (after years of mis-management and repeated violations, at least 75 documented before this current onslaught of violations)

Christmas, 2006 - Just as the holiday and agency vacation time began, Vreba-Hoff began construction of a new manure lagoon (no construction permit required, no DEQ approval required? no oversight under the Consent Judgment?) on Packard Hwy west of Bothwell -- a gravel road, a 2-mile hauling drive from the facility on Dillon. No assessment was made so far as we know about the soils, the site, the possible connections to tiles, to nearby wetlands.

Vreba-Hoff's Consent Judgment requires treatment of manure to stop the pollution, not more and more pits of untreated waste, more and more hauling, more and more dumping.

quick-dug Vreba-Hoff lagoon (at top) adjacent to wetlands; close-up on right - Dec. 29, 2006

Dec, 2006 - Vreba-Hoff proposes new 5,000-cow CAFO near Adrian in River Raisin Watershed.  This site drains to Black Creek, already listed as "impaired." Black Creek joins the River Raisin just upstream from Blissfield, a city that takes its drinking water from the River.  Vreba-Hoff's test wells already dried up a neighbor's well.
See Adrian DailyTelegram article, Dec. 20, 2006.

See 2 studies from Union of Concerned Scientists on environmental/health benefits of pasture-based agriculture: Greener Pastures and Greener Eggs & Ham

Dec 1, 2006 - Noncompliance letters to Vreba-Hoff from both DEQ and the Attorney General's Office cite multiple, substantial violations (see complete list), including unlawful discharges and mismanagement of waste.The Attorney General cites "numerous violations at both of your farms...the apparent failures of the Press Treatment System and resulting accumulation of excessive amounts of CAFO waste, treated and untreated." The letter notes more than a dozen violations in 6 areas -- Unlawful Discharges, Press Treatment System, Compost Pads, Waste Storage Structures (overfull), Storm Water Management, Recordkeeping & Reporting. In October, DEQ found the Waste Treatment System was "not in operation" during numerous inspections, and noted "...based on your estimate of production, you should be running the system no less than 12 hours a day, 364 days a year in order to treat all manure currently being produced annually."

Dec 1 - rain, field flooding, after a month of heavy manure application.  Think what's flowing to Lake Erie from black manure fields, bare ground saturated with waste, no crop.  Nov 25 - Thanksgiving weekend - heavy field applications (always on holidays), including illegal discharges of liquid manure through field tiles at two locations: Vreba-Hoff 1, discharge (E. coli count 10,000/100ml) to Covell Dr, trib of Bean Creek, and Hartland Farms discharge (E. coli count 55,000/100ml) to tributary of South Branch of River Raisin.

  Nov 25, 2006 - black water in Covell Drain, flowing to Bean Creek; sample in bottle

Nov, 2006 - updated Health Impacts from CAFOs and Liquid Manure Application Observed in Lenawee and Hillsdale County: 2002 -2006, now available. This report by ECCSCM volunteer and R.N., Kathy Melmoth, documents public health concerns and health impacts from local CAFO air pollution. (Full report; or 1-page overview)

Major air pollutants from CAFO manure application include Hydrogen sulfide, Ammonia, Volatile Organic Compounds (VOCs), and Particulates. Hydrogen sulfide is a powerful neurotoxin; it can cause permanent brain damage. Short term symptoms of Hydrogen sulfide include headaches, breathing problems, shortness of breath, throat irritation, chronic bronchitis, and nausea. Long term injury can include memory loss, loss of balance, delayed reaction time, and damage to other cognitive or thinking functions. Death can come quickly in high doses. Inhaling Hydrogen sulfide is the most common route into the body and it goes directly from the lungs to the blood stream. Ammonia causes cough, eye and nose irritation, sinus, skin and breathing problems. Ammonia is usually inhaled. There can be hundreds of Volatile Organic Compounds in CAFO emissions including alcohols, hydrocarbons, phenols, etc. Particulates can include bioaerosols such as bacteria, fungi, and viruses. People also breathe small particles of fecal matter, skin cells, feed, etc.  Any of these pollutants can trigger asthma, or make respiratory problems worse.

Oct 17, 2006 - rain last night and manure fields are flowing after heavy field applications this weekend (see stench alerts). Major contamination entering Bean Creek Watershed. Some drains are overflowing at CAFO facilities:Shierson Drain at Bruinsma; Bennett Drain at Waldron Dairy (fields flooded); wetland at Vreba-Hoff on Dillon is black.

Sept 26, 2006 - Missouri Hog CAFO must pay $4.5 million to neighbors suffering from stench. (see full article)
        "KANSAS CITY, Mo. - The nation's second-largest pork producer must pay $4.5 million to three families bothered by the smell from a northwest Missouri hog farm, a jury ruled.
        The same Jackson County jury also found grounds for punitive damages against Kansas City-based Premium Standard Farms, but the company agreed not to appeal the actual damages award and the plaintiffs in exchanged dropped their request for punitive damages.
        The families own or owned property near the company's farm near Trenton.
        The families' lawyer, Charles Speer, said Friday's verdict was "by far and away the biggest award (in the nation) against a major confined animal producer."
        Kirk Goza, an attorney for Premium Standard Farms, declined to comment after the verdict.
        Speer is handling more than 50 other lawsuits against Premium Standard Farms. A separate class action lawsuit involving a consortium of law firms seeks to represent anyone who owns property within 10 miles of the company's more than 20 hog farms in Missouri..."

Sept, 2006 - Mich Dept. of Ag reports two local CAFOs have applied for expansion: Vreba-Hoff 1, on Dillon Hwy, from 3,900 cows to 4,929; and Hoffland Dairy on Haley Rd (formerly Vander Hoff Haley, from 868 to 1,680 cows. That's like adding the waste from a good-sized city, 54,000+ people, to the huge waste-stream already flowing on fields in this area.

August 2006 - Vreba-Hoff cited by U.S. Food and Drug Administration for numerous animal/drug violations: An FDA investigation at Vreba-Hoff on Dillon Hwy "found that you hold animals under conditions that are so inadequate that medicated animals bearing potentially harmful drug residues are likely to enter the food supply.Vreba-Hoff was cited for offering "an animal for sale for slaughter as food that was adulterated" with penicillin. Previous investigations had found oxytetracycline in tissues in a cow offered for sale. "In regard to this oxytetracycline residue, our investigator noted that you administered an approved animal drug via a route, intrauterine, which was not indicated in the labeling, without benefit of a valid veterinarian-client-patient relationship and that you failed to maintain adequate treatment records."
FDA letter, (August 14, 2006 -
see full letter)

August - see timeline on the suffering of neighbors, their symptoms and sickness from State Line Farms hog emissions, Jan - Aug, 2006.  36 days of stench so intolerable that neighbors called DEQ. State Line has received two Letters of Violation for air pollution, citing dozens of days violating air quality law. Still no fines for this polluting facility.

July, 2006 - Front page article,"Cattle emissions: Hazardous to health?" in the Adrian Daily Telegram (7/2/06) describes a pilot project under development for Hillsdale and Lenawee Counties to assess health impacts from CAFO facilities and land application, including a 4-page draft questionnaire for residents with exposure to CAFO emissions.
Excerpt from the Telegram article (full article here):
... A four-page complaint form has been developed for people who believe they may be affected by large livestock operations and liquid manure applied on surrounding farmland. Forms can be obtained from the Lenawee County Health Department by calling 264-5202.
   “This is the first time we've done something like this,” said Dr. Dean Sienko, Michigan's acting chief medical executive.
   Complaints about odors and pollution from the large dairies are required to go to Michigan's Department of Environmental Quality and Department of Agriculture, he said. But those agencies do not evaluate human health issues that some residents are concerned about.
   “Looking at this as a physician and as chief medical executive for the state, I felt it's important we try to get some information on the type of symptoms and concerns people have,” said Sienko.
   I'm glad they're doing something,” said John Klein, a neighbor of one of the dairy operations south of Hudson in Hillsdale County.
   “It's not just an occasional odor,” Klein said. When the wind brings emissions from the nearby Vreba-Hoff dairy on U.S. 127 to his home, Klein said, it makes him physically ill.
   “For the last two weeks I couldn't open the windows without feeling headaches and getting sick,” Klein said. “The headaches are a reality. You open the window and it hits you,” he said. “Most people get up in the morning and look to see if its raining. I look to see which way the wind is blowing.”
   Klein, a leader in a local environmental group [ECCSCM] formed in response to development of the dairy operations, said he and others in the area have complained about a variety of symptoms for years. Because the source of the emissions is farms rather than industrial plants, he said, the state government has taken little notice.
   Seinko said the growing volume of complaints from people in the area helped convince him that more information is needed to understand what is happening.

June, 2006 - Monitoring in progress--Dissolved Oxygen levels plummet downstream from Vreba-Hoff.

April, 2006 - New Flevo CAFO must pay $42,000 in fines and costs, and must cease land application of manure in winter, as part of settlement of lawsuit after multiple manure discharges. See DEQ press release for more details.

April 19, 2006 - After 6 years, it's the same polluted air, the same degradation and contamination of water -- after 6 years! Where's the backbone, where's the will to clean up? or shut CAFOs down if they can't clean up?  Today, with massive manure applications, the pumping of multi-million-gallon waste pits, there's stench from Bakerlads draglining, east of facility; stench from Hoffland application at two locations, also Bruinsma. Winds are carrying stench from facilities as well: State Line Farms cited by DEQ for emissions yesterday, and reported again today; stench west of Vreba-Hoff 2 along Elm Rd.  Intense emissions from Vreba-Hoff 1 along Dillon Hwy -- burns eyes, sickly stench, "nauseating," "You can't live with this. This is hell." 

Also today (see photos below) two sites draining Vreba-Hoff 1 on Dillon Hwy tested extremely low (3.6mg/L) for Dissolved Oxygen, a serious violation of Michigan's water standard, which is 5.0mg/L or higher for DO. The water at another site on Elm Rd just west of Vreba-Hoff 2 was covered with a floating, slick brown film.

Durfee Creek Extension (still impaired, trashed, eutrophied), DO 3.6mg/L on 4-19-06

Clarke Drain (slimed, slick with a brown film) just west of Vreba-Hoff 2 facility on 4-19-06.

March 2006 - red water at Vreba-Hoff stream. What is it? South Medina Drain, a stream listed as "impaired" in 2004 after multiple manure discharges from Vreba-Hoff, looks worse than ever this month -- deep blood-red. See photo-sequence of this stream through many colors of contamination: red, yellow, brown, gray, black, 2002-2006.

Letters to Editor
, see full text,Toledo Blade, March 26, on CAFO threats to communities:

"Water is our basic beverage, not milk, and clean water, the issue. If you are not outraged, you are not paying attention." Gloria Green, Chairman, Natural Resources Clean Water Committee
League of Women Voters of the Perrysburg Area

"I have documented water pollution and health problems suffered by our most vulnerable rural citizens - the elderly, children, and the immune-compromised - from involuntary exposure to air emissions from CAFOs and liquid manure applications to fields. I have also observed numerous liquid manure discharges into our streams from CAFOs since 2000." Kathy Melmoth, R.N., full-time farmer, ECCSCM volunteer

March - again, and again, with thaw and spring rains, liquid manure flows and pollutes after application to frozen fields.  When will they learn?  We go through this year after year (check it out).  Liquid manure on frozen ground will do one thing -- run off -- on the surface, or through tile inlets. Either way, pollution flows to our streams. Email DEQ ( and say, we've had enough. Michigan should prohibit application of liquid manure to frozen ground. 

3-13-06 Mericam manure water running off field to county drain and Toad Creek after spring rain
MDA "solution" - 2 STRAW BALES !!  MDA staff wrote to ECCSCM, 3-14-06 (our emphasis): "The manure appliciation conforms to GAAMPs. I reviewed the sites along Seeley Road. I noticed a spot along Camden Road where puddled manure needed to be incorporated and an open drain along Seeley Road that needed straw bales (for runoff control) in case of a storm event."  This is the "high-tech" waste system that pollutes our air and contaminates our streams.

Feb 7, 2006 -Sierra Club releases documentary, Living a Nightmare: Animal Factories in Michigan, with local farmers and neighbors describing the degradation of water and air, the damage to rural economies, and the risk to public health.
click for more information and order form

February 1, 2006 - Michigan suit against Hoffland CAFO - formerly VanderHoff Haley Dairy - is settled (see DEQ press release). Hoffland will pay $20,000 in fines, and must cease land application of agricultural waste to snow or ice-covered soil when the waste cannot be injected or incorporated. The CAFO will also be required to install a press treatment system (liquid/solid separation) for the "stabilization of waste produced in the cow barns."

January 16, 2006 - State Line Farms cited again for air emisssions.

July - November, 2005 - following investigation of numerous air quality complaints over several months, DEQ cites State Line Farms for violation of the federal Clean Air Act and Michigan air pollution law (Rule 901 - "A person shall not cause or permit the emission of an air contaminant in quantities that cause injurious effect to human health, property, or the unreasonable interference with the comfortable enjoyment of life and property"). 9 inspections between July and November found "strong" or "very strong" odors, burning sensation in the nose, "objectionable hog waste odors," etc. State Line must report by Jan 6, 2006 on the causes of the violations and on remedial action taken to prevent reoccurence of emissions. State Line refused to accept Letter of Violation sent Nov. 10, 2005. TheLetter of Violation was finally hand-delivered on December 8, 2005.

Holidays, 2005 - Winter Waste Application

Why is this practice - CAFO dumping - still legal in Michigan?
It's started again, a foul winter ritual - the spraying of liquid manure from CAFOs on snow and frozen ground. This practice is "not recommended" in Michigan's Generally Accepted Agricultural Management Practices (GAAMPs). But there's no penalty for doing it. Why not? With the first rain or first thaw, the waste flows off fields into streams.

Manure can't fertilize crops when there is no crop; it can't reach soils when the ground is covered with snow.  Spraying on snow and frozen ground serves one purpose only -- waste disposal. Dumping. It's free to CAFOs. It's costly and hazardous to the rest of us.
High bacteria counts downstream from manure-fields
Through November this year, CAFOs sprayed liquid waste on fields (see list of applications, stench alerts). On Thanksgiving, we had snowfall, then a few days later, 1.55 inches of rain.  Water samples downstream from manure-fields tested extremely high for E. coli bacteria, some sites more than 50 times the allowable level of 1,000/100 ml:

Tributary to Fisher Lake, 11-29-05, downstream from Vreba-Hoff - E. coli 22,000/100 ml
Wallace Drain to Hazen Creek, 11-29-05, downstream from New Flevo - E. coli 48,000/100 ml
Durfee Creek, 11-21-05, downstream from Vreba-Hoff - E. coli Too Numerous To Count 

Durfee Creek, November 2005. This stream is already on Michigan's list of "impaired" waters, after multiple manure discharges from Vreba-Hoff CAFO.

June 20 - Vreba-Hoff discharges manure AGAIN, into South Medina Drain, which was placed on Michigan's "impaired waters" list last year because of previous contamination from Vreba-Hoff.  Black manure water is discharging through field tiles, after pivot-irrigation of liquid manure on growing crop.  ECCSCM volunteer called DEQ hotline; DEQ took water samples.  Dissolved Oxygen is 0.5 mg/L, well below fish-kill level.  North Medina Drain is clear, South Medina Drain is grossly discolored, smells of manure. V-H resumed pivot irrigation in same location in late afternoon. ECCSCM took water samples for E. coli.  
June 23 - E. coli test results: 22,000/100ml on June 20; 32,000/100ml on June 21.
manure water in South Medina Drain on June 20, 2005; water samples, 1 from North Medina Dr, 2 from South Medina Drain.

Vreba-Hoff pivot-spraying liquid manure near Ingall Hwy, June 20, 2005 - black water flows through tiles to South Medina Drain in Bean/Tiffin Watershed.

June 13 - DEQ, MDA documents reveal months of inaction on CAFO air violations (summary below)

            Chronology of Neglect - One CAFO's Bad Air - Winter 2004 to June 2005
                   (details from DEQ,MDA documents FOIAed by ECCSCM)

DEQ and MDA documents reveal a sad story of jurisdictional confusion over CAFO air emissions, leaving neighbors stuck in stench-- the sickness of pig stink-- for a year and a half. People called MDA, they called DEQ; nobody knew who was in charge, including the agencies. The consequence? -- inaction, and prolonged suffering of neighbors in an agricultural community.

Since the expansion of a swine CAFO near Morenci in Winter 2004 -- construction which was completed without using MDA's Siting guidelines -- neighbors have pleaded for help from MDA, DEQ, their local officials, Sen. Cameron Brown, and even Governor Granholm. The CAFO was built too close, much too close, to neighbors.

Finally, in a letter to the CAFO on June 13, MDA said so: "this facility does not meet the setback requirements of the Site Selection GAAMPSs."

So, now what? Well, of course, now it's there. In the neighbors' faces. One neighbor, who's lived in her farmhouse for 50 years, wrote last year to Gov. Granholm, "It is a terrible situation-- the odor from the hogs is nauseating. We have tried to get the Mich. Dept. of Ag to help -- they do nothing." Another letter, to Sen. Brown this February, said, "I don't deserve to be driven from my home."

During the last year, DEQ received at least 18 air complaints about the CAFO, investigated them, and often found emissions "distinct and objectionable." MDA also received several calls. MDA, interestingly, found no problem, not once, barely a "whiff," one reported, complaints "not verified." Cases closed.

This February, DEQ prepared a Letter of Violation to the CAFO citing multiple violations of the federal Clean Air Act as well as Michigan's Natural Resources and Environmental Protection Act, Rule 901. The letter, however, was never sent. Although the letter cited 9 complaints and 7 follow-up inspections in Oct, Nov, Dec 2004 and Feb 2005, all documenting "distinct, definite and often objectionable odors," MDA stepped in at the last minute, argued a new process required a hard-copy referral to DEQ, not just email, etc., etc., claimed jurisdiction over air emissions, and then -- did nothing.

Since February, MDA has taken no action. They waited and waited, told complainants the GAAMPs were voluntary, sent information to the CAFO about complying, retroactively, and then waited some more. When the CAFO finally submitted details about its facility, MDA wrote the June 13 letter and recommended biofilters as a "variance" to the setback requirements. The biofilters aren't a requirement. MDA simply reminded the CAFO: "in order for MDA to accept the proposed OMP [Odor Management Plan] for this new swine production facility, odor control biofilters or equivalent odor reduction technologies must be properly installed."

How much longer will the neighbors have to wait for clean air? A long long time, if the CAFO ignores MDA's suggestion. As it can. As it has. MDA has no clout -- they have guidelines, voluntary guidelines. MDA has no rules, no air monitoring equipment, no protocol for responding to health concerns.

How bad is it? Residents report headaches, nausea, the inability to go outside; one neighbor without air conditioning described stench so bad he had to shut the windows in terrible summer heat. One DEQ investigator driving by the CAFO with his asthmatic son had to leave the scene when the son required his inhaler. Healthy neighbors, but especially children and the elderly, vulnerable populations, continue to suffer the consequences of Michigan's squabbling agencies and the CAFOs' relentless emissions.

It is wrong, a violation of our deepest values, for us to turn away from the weakest and their suffering, for us to dismiss them, turn them back into their houses -- while we give the strongest, the most negligent, a free pass to foul the air.

April - MSU report details DNA study of Cryptosporidium, a pathogen that can cause serious diarrhea and sometimes death, which was found at extremely high levels in water samples from Rice Lake Drain at Haley Rd, a River Raisin tributary, immediately downstream from Hoffland (formerly VanderHoff Haley) Dairy CAFO. Tests showed an average concentration of 10,866 oocysts/100L, with a high of 49,900 on Dec. 6, 2004. A sample on Dec. 6 showed infectivity in cell culture.  DNA testing found "the Cryptosporidium sequence from the white tile into Rice Lake drain collected on 12/7/04 has the closest relationship to sequences of the bovine genotype" (see more on MSU findings)

April 18 - Sierra Club releases report on 66 Michigan CAFOs in 15 counties. ECCSCM member and Sierra Club Water Sentinel Lynn Henning documented proximity of CAFOs to drains, streams, wetlands, and connections to tile risers, catch basins -- all potential pathways of CAFO pollution. See final report and also spreadsheet with details on each facility.

April, 2005 - all CAFOs applying liquid manure. Air emissions, stench downwind is intense.

pivot irrigating liquid manure, New Flevo CAFO, 4-14-05

Feb. 18, 2005 - DEQ disapproves Vreba-Hoff's draft plan for wastewater treatment, saying it falls "far short" of what is required under the 2004 Consent Order. DEQ cites numerous insufficiencies, including no seal by a professional engineer, no phosphorous treatment as required, no transfer system description, no sand-separation component, no piping or control details, no description of how untreated waste will be applied, inadequate sampling parameters and plan, no quality assurance plan.

end of Jan-early Feb - winter mess & stench - CAFOs are spraying manure on snow & frozen ground, not a recommended practice. At the first thaw, you can picture it - liquid manure runoff to drains and streams.

Feb. 3, 2005 - Mericam CAFO spraying on snow, on sloping field, Territorial Rd

Michigan State University Violates Clean Water Act at Livestock Operations
Jan. 24 - DEQ cites MSU Beef Cattle Research & Teaching Center for illegal manure discharges leading to contamination of the Red Cedar River.  In a Notice Letter, Jan. 24, 2005, DEQ notes a lack of proper collection and storage for silage at the CAFO, resulting in silage leachate and contaminated stormwater at part of the MSU facility. In another area, "manure runoff flows to a catch basin...and a tile riser."  These structures are inlets for runoff through County Drains to the Red Cedar River.  DEQ orders MSU to apply for an MPDES permit and to prepare (finally -- why would MSU be last in environmental protection rather than first?) a Comprehensive Nutrient Management Plan.

Vreba-Hoff CAFO must install wastewater treatment system, pay $75,000
Dec. 28, 2004 - DEQ announced that Vreba-Hoff must install a $1,000,000 wastewater treatment system by December 2005, must apply for individual NPDES permits for both facilities, and must immediately cease all land application of untreated waste in the Lime Lake basin, a drainage area on Michigan's 303(d) list of impaired waters.  Vreba-Hoff has had multiple illegal discharges from fields along Lime Lake Inlet. With these actions, in settlement of DEQ's lawsuit against the CAFO for multiple violations, Michigan takes a first step in changing the CAFO waste system to a less liquid system. Vreba-Hoff must also pay $75,000.  See DEQ press release
ECCSCM applauds Michigan's action -- the first of its kind in dealing with untreated animal waste.  Wastewater treatment systems -- eventually full wastewater treatment, as in other industries and municipalities -- individual NPDES permits, an end to land application of untreated wastes, should be requirements for all CAFOs. The liquid waste system, the practices, and the polluting discharges of Vreba-Hoff CAFOs are no different from other CAFOs here and elsewhere in the state.
Dec. 7, 2004 - rain and runoff - milky foul stream from Bruinsma CAFO flowed through Morenci Sportsmen's Club property and into Silver Creek; contaminated runoff from Marvin Farms flowed to Hazen Creek.  DEQ water samples found E. coli count of 500,000/100 ml in Marvin Farms runoff.
foul water flowing to Silver Creek                  contaminated runoff flowing to Hazen Creek
Oct. 22, 2004 - Cryptosporidium, a pathogen that can cause serious diarrhea and sometimes death, was found at extremely high levels, 2,600 oocysts/100L and 860 potentially viable oocysts/100L, in a water sample taken on October 22, 2004, from Rice Lake Drain at Haley Rd, immediately downstream from VanderHoff Haley. (see full details)
DEQ task force reports on
ag discharge data, March 2004, at CAFO sites, Lenawee/Hillsdale
Nov 18, 2004 -- DEQ files suit against New Flevo Dairy following multiple violations. The suit alleges Arnoud Schot, owner of New Flevo, "discharged agricultural wastes from his dairy operation in Lenawee County to protected waters of the state on at least ten occasions. These discharges occurred without a permit and are alleged to have impacted area waterways including the Wallace and Penrod County Drains and Hazen Creek. The DEQ alleges that these discharges contained pollutants at concentrations that may injure the public health and the environment." (from DEQ Press Release)
Mussel survey
of Bean Creek watershed, summer 2004, finds 17 species of freshwater mussels, including 3 species of special concern -- slippershell, round pigtoe, and rainbow mussel.   Best sites were in St. Joseph Creek, and poorest sites were in Silver Creek, where no live mussels were found. ECCSCM volunteers coordinated this survey conducted by aquatic zoologists with the Michigan Natural Features Inventory, MSU. For more details, photos of mussels, a clam trail, big-footed pocketbook mussel, and more! click here.
Aug 4, 2004 - DEQ files suit against Hoffland Dairy (formerly VanderHoff Haley Dairy) after multiple violations. The suit alleges Mr. Jan Vander Hoff "discharged agricultural wastes from his dairy operation to Lenawee County’s Rice Lake Drain and Bovee Drain without a permit on at least seven occasions, with the most recent occurring on July 31, 2004. In addition, the claim alleges that these discharges contained pollutants at concentrations that may injure the public health and the environment." (from DEQ press release)
(Sept. 2003) -July, 2004 - Vreba-Hoff stormwater -- contamination still flows, after 19 months (see details & photos)
Durfee Creek, Medina Drain listed as severely impaired
2 streams draining Vreba-Hoff -- Medina Drain and Durfee Creek -- have just been added to Michigan's 303(d) list of "impaired waters."  Vreba-Hoff CAFO on Dillon Hwy was the first built here, in 1997.  After 7 years of liquid manure on tile-drained fields, streams have been severely impaired.  In a few more years, what will happen to all the other streams draining all the other CAFOs?
Winter and spring pollution
As bad as last year, recent months have brought a terrible series of liquid manure discharges (50 violations, and that's only counting the days DEQ was here and taking water samples). More than half of the discharges were from Vreba-Hoff facilities and fields, with massive pollution entering Lime Lake.  DEQ also cited Vreba-Hoff for multiple contaminated stormwater discharges, noting, "Numerous water samples collected from the storm water discharge channel over the past four months have revealed high concentrations of pathogens and nutrients indicative of a direct discharge of polluting materials."
(DEQ Notice Letter, June 3, 2004)
See a few photos of discharges, below, from February. No wonder the lake turned completely green, from algal blooms in May. (See details of violations)
Pollution, health, and economic impacts cited as reasons (see APHA document)

Final report: ECCSCM Water Monitoring Project
Final report, April 2004: DEQ biosurvey of streams near CAFOs finds "significantly impaired" headwaters of two streams at Vreba-Hoff on Dillon. Both streams added to Michigan's "impaired waters" list.
Recent harassment of water monitors--trespass, vandalism

March 1, 2, 3.... on through March 24, 25...for three weeks, diesel fuel spill is flowing into Medina Drain/Bean Creek from Vreba-Hoff.  Finally March 27, after EPA action, a dam and containment system was put in place.
(above) diesel fuel spill from 1,000 gal tank in Vreba-Hoff field, March 1; HazMat booms, fuel overflowing with heavy rain March 5 

40+ illegal discharges Jan-March, 2004 --

(above) liquid manure flows in Wolf Creek (upstream from Adrian drinking water supply);black water in Lime Lake Inlet East, February, 2004

(above) manure discharging to Lime Lake Inlet East, Feb. 21, 2004,from Vreba-Hoff; May 5, 2004 - the lake turned completely green, from excess nutrients and algal bloom.

Harassment, vandalism -- ECCSCM condemns recent harassment of volunteer monitor

 Reasons We've Heard For The Foul Water

1. It's geese (or deer, or raccoons)
2. It's that house over there
3. It's those 6 horses
4. That's just sediment
5. It's tannins in the water (or cherry trees)
6. etc....

(why not "It's probably those 4,000 cows
& their millions of gallons of waste on the fields"?)



See chronology of Christmas 2003 pollution event from Vreba-Hoff manure application

Dec. 3 - VanderHoff Haley
manure pit overflows at the production area. Liquid manure enters a catch-basin and drains through tile to Rice Lake Drain, Haley Rd.  Black water flows in Rice Lake Drain leading to Bear Creek in the River Raisin Watershed.

Oct. 15 - after 1" of rain, animal wastes flowing in several Bean Creek tributaries. Mericam CAFO applied manure in the rain. The Bennett Drain, just downstream, was flowing dark brown with strong manure odor. The wetland on Dillon Hwy at Vreba-Hoff was flowing fast, black water, with Dissolved Oxygen at dead-zone levels, 2.28mg/L.

black water and DO reading at wetland, Dillon Hwy, 10-15-03

September-- Michigan DEQ files suit against Vreba-Hoff for "unlawfully discharging agricultural wastes to waters of the state from its two facilities." DEQ asks Vreba-Hoff to construct a waste treatment system -- this is a first and major step towards cleaning up CAFOs, cleaning up our streams, and stopping contaminated liquid manure from entering field tiles, drains, and waterways.  DEQ is requesting that the court require Vreba-Hoff to "thoroughly evaluate the design and management of its agricultural operations and make the necessary changes, including a potential reduction in livestock, to eliminate illegal discharges to waters of the state."
See full DEQ press release:,1607,7-135--75227--,00.html

Sept. 19
--19 days of excessive stench and flies with no relief, along Beecher and Cadmus Roads west of Bakerlads dairy.  This facility has sprayed thick, liquid manure since Labor Day-- including on Labor Day --and almost every day since without turning it under. 

flies on inside of car roof, near Bakerlads, 9-3-03; flies in jar, after 10 days at picnic area, Beecher Rd, near Bakerlads. 9-18-03

week of Sept 15 -- extreme odor along US-127 south of Hudson, near Vreba-Hoff manure application
Sept.12 -- manure odor/emissions from field application in several areas -- stench in Hudson;along US-127 south of Hudson; and in vicinity of Dillon Hwy/Medina Rd
Labor Day weekend: excessive flies and stench, after liquid manure application west of Morey Hwy, north of Cadmus Rd. 
Aug 27:stench along Plank Rd near Hughes Hwy
week of Aug 18: horrendous stench along Cadmus Rd east of Hudson, between Posey Lake Hwy & Morey Hwy (and 2 miles north, south, east, west, depending which way the wind's blowing). Hartland Farms applied liquid manure on Cadmus Rd property.

Aug 2- this weekend, Vreba-Hoff 2 illegally discharged the millions of gallons of contaminated stormwater (see below, April-May) by opening an in-line water strucutre during rains.  All the contaminated water flowed into the Bean Creek Watershed.  DEQ reports that the facility will be cited for a discharge violation and fined.

July 9 -- after moderate rains in early July, liquid manure is discharging at several sites, including an inlet to Durfee Lake, and South Medina Drain, where the water looks very foul, a reddish-brown color.

South Medina Drain, July 9, 2003

June 12 -- rain brings many discharges, at sampling sites throughout the area, with extremely high E. coli bacteria counts: Bear Creek at Beecher -- 21,780; Rice Lake Drain -- 20,790.

June 10, 2003 -- Another manure discharge from Jelsma/Mericam
After application of liquid manure to CRP ground (not allowed), manure enters field tiles and discharges through Timma Drain to Lime Creek (Bean/Tiffin Watershed).  DEQ found DO levels in Timma Drain at 0.9mg/L.  2 weeks later, Mericam applied liquid manure on the same field!

May 9, 2003 -- After 1" of rain overnight, and rains earlier in the week, the contaminated stormwater illegally impounded at Vreba-Hoff 2 facility overflows the temporary dikes and discharges to Lime Lake. DEQ inspects the site, but so far no action has been taken (except more dikes) to protect our watershed and the public health.  People will soon be putting in docks at Lime Lake, and swimming.  When will DEQ demand removal of this contaminated water and removal of the temporary dikes? 

April 19, 2003 -- Vreba-Hoff cited, fined for multiple violations. See list. Millions of gallons of contaminated stormwater were impounded for months around the Vreba-Hoff 2 dairy CAFO (see photos below).  This facility lies upslope and less than 1/2 mi. from Lime Lake.  The inlets to Lime Lake tested at extremely high levels of E. coli (35,640/100ml at one site; 25,740 at another on March 18).    (Aerial photos taken March 27, 2003)

Vreba-Hoff 2 facility, US-127 south of Hudson, surrounded by contaminated stormwater (above),looking north; and looking south towards Lime Lake (below)

The American Public Health Association (APHA) has issued a resolution urging federal, state, and local government health agencies to impose a precautionary moratorium on all new Concentrated Animal Feeding Operations (CAFOs). Pollution, health, and economic impacts cited as reasons for a moratorium. (see APHA document)

Feedlot runoff disrupts reproductive systems of wild fish - important findings in a study by The National Institute of Environmental Health Sciences, just published in Environmental Health Perspectives (Dec 2003). "Responding to the growth of concentrated animal feeding operations and the pollutants present in their wastewater (e.g., nutrients, pharmaceuticals, and hormones), the US EPA developed a new rule that tightens regulation of these operations. In this study, we collected wild fathead minnows exposed to feedlot effluent and observed significant alterations in their reproductive biology," including demasculinized male fish. Details and full article available at

March 2-15, 2003 -- Liquid manure applied to frozen ground has been running off fields, pouring into streams. We've seen massive contamination in three watersheds these two weeks -- 5 more confirmed discharges.  DEQ E. coli samples at one site on March 4 reached the highest levels yet: 1,340,000/100 ml (more than 1,300 times the acceptable level).  None of the pollution was contained -- it all flowed downstream into the St. Joseph River, the River Raisin, or the Bean/Tiffin River to Lake Erie.

3-2-03, manure flow in Toad Creek just reaching culvert; and 3-8-03 downstream--- Mericam Dairy. After application to frozen ground, Coman Rd (Wright Twp, Hillsdale County), manure ponded overnight in the field, then drained across neighbor's property to Farnam County Drain and directly into Toad Creek, the major tributary of Lime Creek in the Bean/Tiffin watershed.  click for video

March 2003 -- More violations from Vreba-Hoff lead to DEQ Administrative Consent Order (ACO), with $3,100 civil fine and stipulated penalties for future discharges.

February 2003 -- Vreba-Hoff finally fined!  After multiple illegal discharges to the Bean Creek Watershed, the State of Michigan fined Vreba-Hoff 1 (Dillon Hwy, Medina Twp) and Vreba-Hoff 2 (US-127, Wright Twp) $15,000 each, and stipulated penalties of $2,500 each for any additional violations. In addition, the two operations will be required to reimburse state costs, construct silage runoff control systems, and Vreba-Hoff 1 will be required to remediate a swale and wetland contaminated by silage leachate.

Sunday, March 9, 2003 -- Runoff of manure from fields, into drains and streams, continues. Six industrial dairies applied liquid manure to frozen ground in recent weeks -- pollution flows to streams today from all those applications. Here are just a few photos:

(above) most foul-smelling of all locations, Rice Lake Drain, Haley Rd;Bovee Drain, Whaley Rd
Toad Creek, Coman Rd; and manure flow inside catch-basin, Drain 261 to Toad Creek

Saturday, March 8, 2003 -- very warm during the afternoon, 40 degrees.  Massive runoff of liquid manure from frozen fields.

liquid manure from field off photo at left, flowing onto neighbor's property and into catch-basin (center front, in snow) for Miller Drain, which flows to South Branch of River Raisin.

Friday, March 7, 2003 -- weather is warming slightly.  Most streams are still solid ice, but some drains downstream from fields where liquid manure was applied are flowing brown.

Bear Creek, Hughes Hwy(left); tributary of South Branch of River Raisin (right)

Wednesday, March 5, 2003 --all sites had water discoloration, manure odor

Liquid manure applied to frozen ground is flowing today, both overland and through tile inlets to county drains and streams. The awful manure discharge into Toad Creek on Sunday looks like just the beginning.  ECCSCM Pollution Watch volunteers observed at least 5 illegal discharges today. There is clearly visible pollution of streams in 3 watersheds -- Lime Creek, Durfee Creek, and Toad Creek in the Bean/Tiffin watershed; Bear Creek in the River Raisin watershed; and a tributary of the East Branch of the St. Joe in the St. Joseph River watershed.

(above) pulled/blown tile plug US127, drains to Fisher Lake (Bean/Tiffin); Tamarack drain downstream from liquid manure application (East Branch of St. Joseph River)

(above) Aftermath of Sunday's huge manure flow to Toad Creek (Bean/Tiffin).  This field shows ponded manure draining to Toad Creek through a county drain--left, bales pulled this morning, allowing more contamination to reach Toad Creek; right, bales replaced this afternoon on order of Hillsdale County Drain Commission.

(above) Durfee Creek at Packard (Bean/Tiffin); Durfee Extension at Dillon Hwy (Bean/Tiffin);

3-13-03, manure runoff to catch-basin on Donnelly Rd, drain to Fisher Lake (Medina Twp, Lenawee Co.) -- Vreba-Hoff 2

Other field locations with massive runoff to drains and streams:
Bothwell & Packard Rds, to Bean Creek -- Vreba-Hoff 2 DEQ-confirmed discharge
Acker Rd, to Durfee Lake -- Vreba-Hoff 2
Tuttle & Tamarack Rds, to East Branch of St. Joseph River -- Vreba-Hoff 2
Ingall Hwy, to Medina Drain and Bean Creek -- Vreba-Hoff 1 DEQ-confirmed discharge
Dillon Hwy, to Durfee Creek and Lime Creek -- Vreba-Hoff 1
Forrister Rd, to Hazen Creek -- New Flevo
Hughes Hwy, to Henning Drain and Bear Creek-- Hartland Farms

January 28, 2003 -- everything else is frozen, but drains are flowing near liquid manure application. See photos.


November, 2002 -- CAFO intimidation tactics. Two manure-tankers and hauler's truck block ECCSCM Vice-President's car on a country road. See photos.


March, 2000 – Hartland Farms on Hughes Highway discharges 400,000 gal. of manure into Henning Drain and Bear Creek; after a delay of 3 wks, negotiating on the clean-up, a heavy rain washes manure and 12 million gal. of polluted water into Lake Hudson, a State Park.

February, 2000 - New Flevo Farms on Forrister Road illegally discharges 20,000 lbs. of milk into drain leading to Wallace Creek and Hazen Creek in the River Raisin Watershed.

1997-2000 - first dairy CAFOs constructed in the Hudson area