DBA comments on definition of significant discharge
Aug. 22, 2018
At the beginning of August, the Wisconsin Department of Natural Resources (DNR) released a draft guidance document meant to help county land and water conservation staff determine when a “significant discharge of process wastewater” or “direct runoff from feedlots to Waters of the State” has occurred. Both concepts are terms of art used in the agricultural performance standards found in NR 151, the administrative rule that deals with runoff management. DNR solicited public comments on their draft and DBA responded on behalf of its dairy farmer members.
You can see a copy of our , which were submitted electronically. While we praised certain parts of the guidance document and recognized the importance of helping to define these important terms, we argued DNR still left “significant discharge” largely undefined. Instead of trying have county staff focus on events that are indicative of a systemic problem, there is too much emphasis on documenting discharge under the least favorable weather conditions possible. Ultimately, the line dividing significant and insignificant discharges remains far too subjective in the draft, and suggestions were made on how to provide more clarity.
DBA signs onto letter urging action on milk labeling
July 6., 2018
DBA joined its sister organization, Edge Dairy Farmer Cooperative
, and several other agricultural organizations in writing a letter
to Food and Drug Administration (FDA) Commissioner Scott Gottlieb. The letter was also sent to several key staff at FDA and the Chairmen and Ranking Members of the U.S. Senate Committee on Health, Education, Labor & Pensions and the U.S. House Energy & Commerce Committee. In the letter, the groups called on Commissioner Gottlieb to enforce the existing law regarding how milk is defined and to stop misleading labeling by plant-based products that do not fit that definition. This letter adds to the growing pressure on FDA to take action on this subject.
DBA seeks to join lawsuits over HCW permits
Jan. 6., 2017
The high capacity well (HCW) permitting process had been mired in delays. Last year, Atty. Gen. Brad Schimel provided clarity by spelling out the limits of the DNR’s authority to regulate HCWs. Unfortunately, some object to what the Attorney General did. Clean Wisconsin has filed eight separate lawsuits challenging HCW permits. DBA recognizes how important a predictable HCW permitting system is for the dairy community. For that reason, together with other similar groups, we’ve filed a petition and brief in support of our request to participate in these suits as an intervenor. This would allow us to better tell our story about why a reasonable HCW permitting system is both important and legally necessary.
DBA supports business court pilot and judicial pay increase
Jan. 3., 2017
DBA joined other business groups in a letter to Governor Walker supporting the new three-year business court pilot project. This effort, which will be focused in Waukesha County and the Eighth Judicial District in northeastern Wisconsin, will explore what the benefits of a having a dedicated commercial case docket. The hope is it will help to resolve commercial cases more quickly, saving businesses and the courts valuable time and money. In the same letter, DBA showed support for judicial pay increase proposed by Chief Justice Patience Roggensack, which is meant to attract and retain more highly-qualified judges.