WWM: What We Are and Are Not

This past September 19 a local agricultural businessman told the Indiana State Legislature’s Interim Study Committee on Agriculture & Natural Resources, “Today, our county’s (Whitley) agriculture producers are challenged with a group (Whitley Water Matters) trying to change the structure of county governance on agricultural land that has been in production for decades.”
Another agricultural businessman at the same meeting stated that groups like Whitley Water Matters “systematically utilize the press and the courtroom as fund raising devices to support their organizations’ fund raising efforts.”
Both of these statements are included in the committee’s permanent records which can be found online, and both of these statements are misleading at best, outright fabrications at worst.
Let’s begin with what Whitley Water Matters is before moving on to what it isn’t.
“Whitley Water Matters, LLC, is a grass roots organization whose purpose is to advocate for responsible management of the land, lakes, air and water ways in Whitley County, Indiana and neighboring communities through education and changes in local ordinances and state legislation.” This is WWM’s mission statement, and it’s also an accurate and complete description of the organization itself. defines grass roots as “the common or ordinary people, especially as contrasted with the leadership of a political party, social organization, etc.,” and WWM fits that description to a “T.”
The organization began in northern Whitley County in late April of this year when some Goose Lakes residents learned that a large poultry CAFO they believed they had blocked in 2016 was going forward. Some internet research led them to Barbara Sha Cox, a fourth-generation family farmer who founded Indiana CAFO Watch when her 240-acre farm was threatened by a large-scale mega-dairy. It was from Cox that they learned about two other pending permit applications before the Indiana Dept. of Environmental Management (IDEM): one was to expand an already existing CAFO near Troy Cedar Lake to 10,000 hogs; the other was to convert a small cattle operation of approximately 100 head of cattle less than 1.5 miles south of Shriner Lake to a 1,300-head confined animal feeding operation. Alarmed by this news, four residents of Goose and Shriner Lakes attended the next meeting of the Tri-Lakes Property Owners Association where they were told that the planned CAFOs were nothing they should be worrying themselves about. They then reached out again to Cox, who encouraged them to organize a meeting of nearby residents.
Consequently, on April 29, some 30 to 40 area residents convened at the Thorncreek Township fire station, where Cox described the effects of manure runoff, animal composting barns, water testing and the potential reductions in property values near CAFOs. That meeting led to the formation of the grass roots organization that is now Whitley Water Matters, LLC, and the adoption of the mission statement above.
Were you to judge from the two statements at the top of this column or listen to talk on the street, you’d think that this small organization composed of seven executive committeemen and women and a mailing list of a few hundred local residents has grown extremely powerful in five short months and threatens the very existence of farming in Whitley County, the state of Indiana and quite possibly the entire Midwest.
Here’s what this powerhouse of an organization actually does:
  1. The seven executive committee members (plus a hanger-on or two) meet weekly for about three hours at one of several lakeside homes;
  2. Some 50 to 60 lake area residents attend a monthly meeting at a neighborhood church for updates on CAFO-related developments locally and statewide and to hear from ag experts such as Matt Pearson of the Indiana state chemist’s office;
  3. Members have traveled to Indianapolis on several occasions to testify before IDEM and the aforementioned Interim Study Committee on Agriculture & Natural Resources;
  4. Three members participated in the county Plan Commission’s committee to try to reach a consensus for an Interim Overlay Ordinance that would establish temporary protections for lake and rural residents while the county develops updated zoning ordinances that accounts for changes that have occurred in agriculture and rural residential areas since the existing ordinance was adopted 11 years ago.
  5. We have worked with the Whitley County Health Dept. to address high e.coli levels of Catfish Lake, which drains into Shriner Lake;
  6. Just last week, several of our executive committee members took a guided tour of the Tri-Lakes Sewer District’s facilities and its lagoons;
  7. We have conducted extensive research on CAFOs and disseminated our findings to our members through email, our website and social media pages;
  8. We are currently raising funds through sales of Christmas greenery and scented candles to help offset legal costs associated with litigation against the Board of Zoning Appeals for their decision to create an AGP (Agricultural Production) zone to allow for 160,000 chickens to be confined just over 1/2-mile from an already impaired Goose Lake and to appeal IDEM’s decision to allow the above-mentioned 1,300-head cattle CAFO a mile from Shriner Lake.
Bottom line: We’ve been busy. We’re working hard. But Whitley Water Matters is not anti-farm, as we are so often portrayed by members of the ag community. Nor are we anti-CAFO. We are, as an organization, agnostic on the issue. We simply want to ensure that any high-intensity factory farms established in Whitley County are situated far enough away from lakes and densely populated residential areas so as not to negatively impact public health and safety and residential property values.
This goal has been stated in any number of public forums and many times in the press. But that hasn’t stopped ag leaders from repeatedly accusing us of being something we’re not.
We were recently “informed” by one farmer that WWM wants to get rid of 4-H by putting per-acre limits on how much livestock can be owned (one acre per cow, 1/2 acre per pig, etc.). This is beyond silly.
At one Overlay Ordinance Committee meeting, we were accused of being funded by the Humane Society in an effort to shut down all CAFOs in Whitley County. What?
The same farmer who made that claim stated that we were creating problems where there are none because there isn’t a current or anticipated huge influx of CAFOs in Whitley County. Yet Greg Slipher, a livestock development specialist for Indiana Farm Bureau, stated in the July 24 issue of “The Hoosier Farmer,” “We’ve been actively working with farmers up there [in Whitley County] for about two years.” If the CAFO issue is a figment of our imagination, what exactly has Mr. Slipher been doing up here the past two years?
While we have presented well-researched, fact-based arguments in the press and elsewhere, we have been characterized by some in the ag community as “affluent lake people” who are acting on their emotions and creating problems where none exist – this despite the fact that evidence of the harm to public health and safety that CAFOs can cause is available to anyone with access to Google.
Whitley County is in large part an agricultural community, and lake residents and other rural residential property owners have been living side by side with farmers for many decades. What’s happening now is that farming itself is changing. The demands of meeting the needs of a growing population on increasingly dwindling agricultural land are changing economies of scale, gradually forcing the consolidation of smaller family farms into larger, high-intensity factory farms.
Regardless of anyone’s personal feelings about this trend, nobody in the leadership of Whitley Water Matters believes that we can stop it – here or anywhere else. What we can do is try to prevent the proliferation of factory farms in areas where they present a potential threat to public health and safety. We can fight to preserve the water quality of northern Whitley County’s glacial lakes, one of the area’s most valuable natural resources. And we can encourage government officials to find ways to achieve the stated vision of the Whitley County Comprehensive Plan, among which is to foster “a community focused on creating the best climate to develop and grow industry, including the agricultural industry, while acknowledging the importance the environment plays.”
We would like to work with the ag community and with county government to ensure that everybody’s property values and all the county’s natural resources, be they arable land, aquifers or glacial lakes, are protected for future generations, and we strongly believe that this is in the best interest of every county resident – farmer and non-farmer alike.

Letters & Meetings

The Hinen CFO has been approved by IDEM, Whitley County has issued a building permit and Whitley Water Matters is weighing its legal options. In the meantime, permission for another CFO, located about a mile from Goose Lake is being sought. This poultry CFO would require a rezoning from Agriculture (AG) to Agriculture Production (AGP) and would be the first AGP-zoned area in Whitley County. We are not opposed to AGP zoning in Whitley County, but we strongly believe that AGP zones must be located well away from residential areas and, most importantly, the lakes and waterways of northern Whitley County.
We need your attendance at public meetings and, even more important, your letters to the Indiana Department of Environmental Management and the various county boards involved in the decision-making process.
Following is information on the Whitley County Plan Commission, the Board of Zoning Appeals, IDEM and surface water issues, along with letter-writing ideas and contact information.

Staff: Nathan Bilger
Mailing Address:
Whitley County Plan Commission
220 W. Van Buren St.

Columbia City, IN 46725 
Members: Elizabeth Deckard, Chad Banks, John Johnson, Kenneth Kerch, Mark Mynhier, Tom Western (Whitley County Commissioner), Brad Wolfe, John Woodmansee, Doug Wright (Whitley County Council)
Next Meeting:
Wednesday August 16, 7 p.m. 
Whitley County 4-H Center (note location change)
680 W Squawbuck Rd, Columbia City
This is a very important meeting; please try to attend and show up early!
Ideas for Letter Writing:
  • IDEM states in their approval of the Hinen CFO “the CFO regulation provides a great deal of oversight when it comes to issues that address protecting Indiana’s ground and surface water quality. “ Still IDEM did not perform a single water quality test at the facility site or any of the manure management fields that several have slopes and highly erodible soils. Impaired waterways means surface water moving through rivers, streams, ditches. Both Eel River Watershed and Tippecanoe Watershed are on the impaired waterway list.
  • Property rights – everyone – We as Lake Property and Residential Property owners have rights also. When does one farm property out- weigh over a thousand residents at lakes and residential property owners over all northern lakes.
  • The Lopez chicken CFO operating as Adlock Boilers LLC, 5300 N. 250 West, Columbia City, is less than a mile from the shoreline east of Goose Lake and have asked to amend the county Zoning map to reclassify their property to an AGP (Agricultural Production District). They have applied for 40,000 boilers in their application.

    The Whitley County Board of Zoning Appeals is a quasi-judicial body of 5 citizens. The Board is charged with the responsibility of hearing appeals, requests for variances to the land use regulations and special exception uses within the County. The Board conducts public hearings for citizen input before making their decision.
    Mailing Address:
    Whitley County Board of Zoning Appeals
    220 W. Van Buren St.
    Columbia City, IN 46725
    Members: Danny Wilkinson (Chairman), Tim Denihan (Vice-Chairman), Doug Wright (Secretary), William Klein, Elizabeth Deckard, Brad Wolfe (Alternate)
    Next Meeting:
    Tuesday, August 22, 7:30 p.m.
    Whitley County Government Center
    County Council/County Commissioner Meeting Room (1st Floor)
    220 W. Van Buren St., Columbia City
    Ideas for Letter Writing:
  • IDEM states in their approval of the Hinen CFO “the CFO regulation provides a great deal of oversight when it comes to issues that address protecting Indiana’s ground and surface water quality.” Still IDEM did not perform a single water quality test at the facility site or any of the manure management fields that several have slopes and highly erodible soils. Impaired waterways mean surface water moving through rivers, streams, ditches. Both Eel River Watershed and Tippecanoe Watershed are on the impaired waterway list.
  • Property rights – everyone – We as Lake Property and Residential Property owners have rights also. When does one farm property out- weigh over a thousand residents at lakes and residential property owners over all northern lakes.
  • The Lopez chicken CFO operating as Adlock Boilers LLC, 5300 N. 250 West, Columbia City, is less than a mile from the shoreline east of Goose Lake and have asked to amend the county Zoning map to reclassify their property to an AGP (Agricultural Production District). They have applied for 40,000 boilers in their application.

    Address envelope to:
    Confined Feeding Section
    100 N. Senate Ave.
    Indianapolis, IN 46204
    Include a return address on your envelope; you should receive a response letter.

    When writing about the Lopez farm, use this heading:
    Farm ID#6986 Adlock Broilers, LLC
    Att’n: Project Chief Joe Williams
    Project Manager Emily Kauffman

    IDEM only considers:
    Private wells and well water
Ditches that flow in the area of the CFO and manure sites Streams and Rivers
Lakes (Goose Lake)
Slope of ground
Wetlands (Goose Lake)
Endangered Species-both state and federal
Impaired waterways
Soil types
Vectors-flies/insects drawn to these sites
    Joe Lopez has filed with IDEM using Adlock Broilers LLC as his operation name. The IDEM application received date is 7/28/17. He has applied for 40,000 broilers to be located less than one mile east of Goose Lake on 250 W 5300 N. 250 West, Columbia City, IN, 46725.

The agriculture sector, including CAFOs, is the leading contributor of pollutants to lakes, rivers, and reservoirs. It has been found that states with high concentrations of CAFOs experience on average 20 to 30 serious water quality problems per year as a result of manure management problems (EPA, 2001). This pollution can be caused by surface discharges or other types of discharges. Surface discharges can be caused by heavy storms or floods that cause storage lagoons to overfill, running off into nearby bodies of water. Pollutants can also travel over land or through surface drainage systems to nearby bodies of water, be discharged through manmade ditches or flushing systems found in CAFOs, or come into contact with surface water that passes directly through the farming area. Soil erosion can contribute to water pollution, as some pollutants can bond to eroded soil and travel to watersheds (EPA, 2001). Other types of discharges occur when pollutants travel to surface water through other mediums, such as groundwater or air.

    Source: Carrie Hribar, MA, Project Coordinator – Education and Training, National Association of Local Boards of Health

    Write Plan Commission, Media

    Judging from social media comments, many members of the ag community feel that our organization is anti-farm. Nothing could be further from the truth. Many of us have lived alongside family farms for decades, and farmers in northern Whitley County have generally been very responsive to concerns about water quality and public health in and around the lakes. They are our neighbors and friends and, in some cases, family members.
    Large confined animal feeding operations, such as the one proposed on State Road 9 between 400 North and 500 North, are significantly different than what most consider traditional family farms, and they bring significantly increased risks to surface water, public health and property values.
    We strongly encourage our members and friends to research CAFOs by following the links on this page or finding other sources of information and making your voices heard by plan commissioners and the Whitley County Commissioners.
    You can do so by writing letters to your county commissioner (Tom Western represents District 1 which encompasses Cleveland, Etna-Troy and Richland townships), Plan Commission chairman Doug Wright (c/o Whitley County Plan Commission, 220 W. Van Buren St., Columbia City, IN 46725) and local media.
    Here are addresses to some local media:
  • The Post & Mail, 927 Connexion Way, Columbia City, IN 46725 (
  • IN Whitley County / Churubusco News, 123 N. Main St., Churubusco, IN 46723 (
  • Fort Wayne Journal Gazette, P.O. Box 88, Fort Wayne, IN 46801 (
  • The News-Sentinel, 600 W. Main St., Fort Wayne, IN 46801 (
  • Next Round of Water Testing

    Waste from agricultural livestock operations has been a long-standing concern with respect to contamination of water resources, particularly in terms of nutrient pollution and E. coli contamination. Our Labs are offering water testing services to establish baseline levels of contaminants in ground water.
    Sandhill Environmental Services has completed a first round of collecting water samples, and we are encouraging home and property owners around the lakes to sign up for baseline water testing if they haven't already been testing.
    The test package by conducted focuses particularly on contaminants that could be introduced in water by waste of livestock operations. The baseline water testing package will check for the following:
    Baseline Water Testing Package 
    Total Coliform / E. coli
    Total Nitrate / Nitrite
    Sample Collection services TOTAL $69.00
    Water testing by concerned citizens is valuable because it documents potential pollution problems. CAFO designs allow manure or other pollutants to enter surface waters. Most CAFOs have production areas, lagoons, barns, silage bunkers or other facilities too close to surface waters. Inlets are built too close to field tiles and other conveyances to state surface waters.
    Through good water-sampling technique, thorough documentation and quality-controlled accurate results, you build credibility, which in turn helps convince state agency staff that you are an ally in their enforcement of water quality standards.
    The goal of your water sampling is to convince state agencies to conduct complete inspections by authorized state officials. Official inspections can lead to mandates to install containment structures, to remove inlets, drainage tiles, and any other conveyances from around production areas, and to reroute surface and subsurface drains away from water. Water sampling is a crucial first step toward reducing the number of illegal discharges from production areas.
    Test results should be available around July 17 and will be emailed or mailed to each person who has paid.
    We intend to set up an additional round of testing at a later date. If you've missed this round, you can sign up at the July 11 Whitley Water Matters meeting or email your information to

    We have a new email address – – if you wish to contact our steering committee for any reason. You can also call and leave a voice-mail at (260) 503-9097.

    Address to the Whitley Co. Planning Commission

    Good evening everyone, and thank you for this opportunity to introduce you to Whitley Water Matters and to outline some of our concerns regarding current Whitley County Zoning ordinances with regard to large scale farming operations. My name is John O’Connell, I own property on Shriner Lake and am 1 of the 7 members of the Executive Steering Committee of Whitley Water Matters. I am not a lawyer, I am a concerned property owner, like many others here tonight. Whitley Water Matters, LLC, is a grassroots organization formed to advocate for responsible management of the land, lakes, air and waterways in Whitley County, Indiana and neighboring communities through changes in local ordinances.

    This grassroots organization was formed in late April as a response to a CFO (confined feeding operation) permit application that was nearing the end of the permit process at IDEM for a large CFO farm to house 1320 head of cattle 1.5 miles south of Tri-Lakes. Since that time we have had several large meetings with concerned citizens who were unaware of this application and the many factors that accompany large scale farming such as waste management in the form of designated manure fields, dead animal control that accompanies this scale farming and many other factors that can effect residential quality of life.

    Let me be clear, we are not against farming or farmers. We are against industrial or factory size farming that is not suited to the terrain of northern Whitley County. Lake and residential communities have lived alongside traditional farming operations in Whitley Co. for decades and we recognize the importance of these operations to the economic livelihood of Whitley County and during that time have worked with farmers to address environmental concerns in a spirit of goodwill and cooperation.

    Our position is this: Whitley County has not developed adequate zoning regulations to protect areas of high residential occupancy to accommodate large scale farming operations. Furthermore, current zoning ordinances to not take into consideration the significant growth in residential populations north of Columbia City; nor do they allow for the specific kind of terrain, mainly rolling hills, that cause a great deal of intermingling of our waterways, aquafers and farming tiles that currently impact much of the water systems feeding Tri-lakes and the private wells of rural Whitley County.

    Specific to the current Hinen Family Farm application for the 1320 cattle CFO farm; we are concerned about the location of the two barns so close to, as you have defined in your 2011 masterplan, lake residential property as well as the number of designated manure fields identified in the IDEM permit. Please note that these fields run along both sides of SR 9 and beyond to the top of the Tippecanoe Watershed. Please see the map we’ve provided, many of the manure fields lie to the west of SR 9 directly on property you have recommended be residential property in the 2011 plan.

    The heavy rains of early May were clear indications of the water run-off of the land along 9 directly into Tri-lakes as water levels of the lakes rose to significant levels. We watched part of Catfish lake, the small lake west of 9 that feeds Shriner lake, become ‘fake’ blue from the run-off of a personal pond across the street treated with Aqua Shade. That pond sits adjacent to one of the larger manure fields in this application.

    I have provided for you to review the maps we presented to IDEM that clearly layout that many of the proposed manure fields are either adjacent to or have running through them, active and already contaminated waterways. Several of these waterways have already been identified as ‘distressed’ by the Hoosier Environmental Council as having Impaired Biotic Communities and/or E. coli. You will see by the topography maps I’ve also provided that most of the manure fields in the permit could with improper setbacks and uncontrolled run-off, easily add to the level of distress to these waterways.

    Approximately 20 years ago, Indiana invested almost 6M to clean up Tri-lakes from the sewer drainage from personal property. Home owners all invested $1,200 to $1,500 to join the public sewer system in an effort to save the lakes. Even today, some home owners continue to pay at a higher rate of utility costs to cover their share of this investment. And now we want to build a factory farm a mile south of this investment with the potential for waste and other run-off that could significantly affect the quality of our water, the property values of all the residential land surrounding both the farm and the potential waste management fields and ultimately have a significant impact on the tax revenue generated to Whitley County by a drop in property values and home ownership?

    According to Part 1 of Whitley County’s Comprehensive Plan, adopted by this very Planning & Building Commission, one of the county’s planning principles is nurturing environmental integrity, which “strives to protect environmental resources” and “promote public health and safety.”

    The county’s zoning ordinance designate Tri-lakes as Lake Residential and states “the provisions that regulate this land-use-district should protect, maintain, and promote where possible the ‘lake character’ around the lakes in Whitley County.” A CAFO located one mile south of Shriner Lake would run counter to that intent.

    In 2011 this Commission made significant recommendations to re-zone and redefine many areas of Whitley County as seen on your map of 2011 (with example). Included were more residential areas along SR 9 and the adoption of AGP or Agricultural Production zoning areas, presumably AGP zones might be for larger farm operations.

    However this commission never officially proceeded on any zoning ordinances that would follow these recommendations. This proposed CFO’s permit application calls for 1,320 head of cattle, which meets the regulatory definition of a “Large CAFO” and would seem to be exactly why AGP zoning was created in the first place, yet never implemented.

    According to the county zoning ordinance, the goals of AGP land use “would be for enhanced Right-to-Farm protection, recognition by community, and to promote agricultural economic development.”

    This reading infers that the AG or Agricultural zoning, which permits residential development, would restrict agricultural operations to those that do not present extraordinary hazards to the residential communities within them or adjacent to them.

    Despite the provision for AGP land use in the county’s zoning ordinance, no AGP zone has ever been established. As I said, we are not anti-farming, we believe that AGP zones, well away from densely populated residential areas, aquifers and waterways should and ought to be established and large CAFOs (exceeding 1,000 animal units) should be restricted to those areas.

    We might just as easily argue that large factory farms are more suited to IN (or Intensive Use) Districts, described in Whitley County Zoning Ordinance as “intended to provide a land use category for intensive uses that may be considered noxious under certain circumstances.” We should point out that the number of cattle included in Hinen Family Farms’ application to IDEM exceeds the county’s zoning restrictions for confined feeding operations (1,200 animal units or less) and would require a special exception.

    So what are we asking for? We are asking for this commission to consider a moratorium on new CFO or CAFO permits until such time that your own recommendations from 2011 can be considered and new zoning ordinances can be put into place that recognize that the Whitley County of 2017 does not reflect the Whitley County of 2006 regarding residential and agricultural populations and that the current zoning ordinances do not protect residential and lake home owners from possible loss of quality of life due to factory farming operations.

    Again, we believe current zoning regulations to not take into consideration the fact that much of northern Whitley County has terrain not conducive to protecting our waterways and our lakes. As concerned citizens, we want to be involved, with area farmers, in developing and writing zoning ordinances that reflect the current and projected future of Whitley County and guarantee a safe and healthy environment for years to come.

    I would point out that while IDEM has codified regulations and restrictions regarding CFOs and CAFOs, and every county surrounding Whitley County has adopted ordinances that require additional setbacks, buffers, regulations and standards for these types of farms, Whitley County stands alone as having no “home rule” ordinance pertaining to CFOs or CAFOs – no zoning district buffer, no municipal boundary buffer, no religious institution, school or recreational area buffer, no property line or right of way setbacks, no requirement for proof of IDEM permit, no existing violation clause, no odor control or manure management standards, no animal mortalities standards, no transportation or well/water standards, no screening/shelterbelt standards, no standards at all beyond the State of Indiana’s minimum requirements.

    We hope at minimum for an ordinance that recognizes the enhanced residential nature of northern Whitley County and has in place zoning regulations that protect the many waterways that feed residential and recreational water use; protect our quality of life from air pollution and vector nuisance; and ensure that the protection of both the Tippecanoe and the Eel River Watersheds is paramount to any new ordinance.

    What are we afraid of? We are afraid that not enough research has been done to ensure that this size farm and its many by-products, so close to a Lake Residential zone, will not do harm and cause irreparable damage to our lakes and quality of life. Thus reducing property values resulting in significant tax revenue loss. While a moratorium is in place, an economic impact study of CAFOs and their impact on residential life could occur. Many of these studies already exist and the results can be alarming to property owners and tax revenue.

    We do not want to suffer the ills of Lake Shipshewana to our north. A beautiful lake declared “dead” in 1989 by the state; banning swimming, hampering boating due to algae and bringing fishing almost to a complete stop. A Feasibility Study by FX Brown Inc. determined that the lake problem was a result of animal wastes not being controlled in the watershed as land surrounding the watershed was 82% agricultural. Costs projected to clean up all aspects of that lake are upwards of 3M-6M dollars.

    Finally, I restate our claim that we are not against our neighbor farmers or farming but we are against CFOs and CAFOs that are better suited on land that can contain the many by-products of factory farming.

    I conclude with a quote from a recent article I was given wherein dairy farmer, Guy Choiniere, said about his contribution to the contamination of Vermont’s Lake Champlain: “Conservation is about keeping your soil and minerals on your own farm. And that’s exactly what I wasn’t doing.” Thank you very much for your time.

    Letters, letters, letters

    Concerned citizens are encouraged to write letters to the Indiana Department of Environmental Management (IDEM) and to the Columbia City/Whitley County Joint Planning and Building Dept. You should write separate letters to IDEM regarding both the Hinen Family Farms LLC and the Doug Western Farm permits.
    When writing to IDEM, address envelope to IDEM, Confined Feeding Section, 100 N. Senate Ave., Indianapolis, IN 46204. Put a return address on your envelope; they should send you a response letter. When writing about the Hinen Family Farm LLC, use this heading:
          Farm ID#6957 Hinen Family Farms LLC
          Att’n: Project Chief Joe Williams
          Project Manager James Matthews
          Current Date: xxx
    When writing about the Doug Western farm, use this heading:
          Farm ID#6482 Doug Western Farm
          Att’n: Project Chief Joe Williams
          Project Manager Daniel Bruggan
          Current Date: xxx
    Your letters to IDEM can only address the following subjects:

    1. Private wells and well water
    2. Ditches that flow in the area of the proposed CFO and manure sites
    3. Streams and rivers
    4. Lakes
    5. Slope of ground
    6. Wetlands
    7. Endangered species (both state and federal)
    8. Impaired waterways
    We can provide you with a sample letter if you need one.
    All members of your household 18 years old and older can write a letter to IDEM. IDEM will also accept letters from family and friends who visit your home and/or have used our lakes for recreational purposes, but the letters must follow the guidelines above. Multiple letters can be sent in one envelope. IDEM will continue to accept letters until they have reached a decision. Keep a copy of your letter. There are other officials that need to be made aware of our concerns, and you can use your IDEM letter to assist in writing additional letters.

    Letters to other county and state offices You can write letters containing every issue in the IDEM letter and add the subjects listed below:
    1. Road conditions and repairs
    2. Property devaluation
    3. Tourism
    4. Quality of life
    5. Health concerns
    6. Air pollution
    The most important letter you can send right now is to:

    Columbia City/Whitley County Joint Planning & Building Department
    220 West Van Buren Street, Ste 204
    Columbia City, IN 46725
    Attn: Executive Director Nathan Bilger, AICP

    Talking Points Against a Proposed Steuben Co. Hog CAFO

    I have a long-time water ski friend who was a hog farmer his entire live from west central Indiana. I would go to his tournaments, and for lunch it wasn’t the usual burgers and dogs, it was pork burgers and they were good. A couple of years ago he told me that he and his brother were getting out of raising hogs. I thought nothing of it at the time. But when I was asked by our lake association to become involved, I gave him a call to find out more as to why they decided to exit the hog production industry. He alluded to these factors:

    • Price – they could not be competitive
    • Model – unwillingness to adopt the CAFO industry model
    • Control – did not wish to become saddled with debt and lose control of their farming operation by mandates from the Big Boys on how they would operate their family farm if they borrowed all that money. The income stream would become paramount to assuring that their family farm would not be lost.
    Next I began to look at how a CAFO operates.
    Large pork producers supply the young herd to the local farmer. That means the farmer doesn’t own them.
    Large pork producers supply:
    • the feed
    • the hormones
    • the antibiotics
    • and many other supplies
    They say it is purchasing power which lowers costs and equates to a lower price to all of us. Sure, currently they pass along about ONE CENT PER POUND … at least until they monopolize the entire chain. The Chinese aren’t dumb.
    They also say it is to assure the herd is fed with the right formula. Right for what?? Etc., etc., etc.
    In reality, it is profit-motivated total industry control.
    The third generation farmer will be supplied with all the inputs. He gets paid on the numbers added. That is his job.
    Very little economic stimulation will be realized from this model. 4,800 50-lb. pigs will be housed in two 200’x100’ structures with a 7’ deep lagoon under the entire building.
    • Surely concrete in that mass will not crack or leak.
    • But just to be safe a membrane will be added. Hopefully no gas will build up under the membrane which would require a perforation in the membrane to keep the lagoon capacity where it needs to be so the membrane doesn’t restrict the manure capacity of the lagoon.
    • The bottom of the lagoon is less than 10 feet above the top of the aquifer in this area.
    • The aquifer is that same one that thousands of residents get their well water from.
    • A hog produces over three times as much waste as a human. It will drop into the lagoon along with the occasional spill of hormones and antibiotics to later be applied as much-needed “nutrient rich fertilizer” – aka IFW (Industrial Farm Waste). But before application occurs, it sits in the lagoon and discharges ammonia and hydrogen sulfide. To alleviate this issue, the buildings are equipped with rows of massive exhaust fans. This dissipates the odors as well as particulate matter exceeding the EPA-recommended PM2 level 24-7. This farm is located southwest of Pine Canyon, Crooked, Gage, Lime, Jimmerson and James, all within smellin’ distance depending on the prevailing wind speed, barometric pressure and humidity.
    • Within six months the operation is between herds. It is time to clean up from the last herd. There is a very narrow window to get this accomplished in. It is crucial that the operation not get out of sync with the calendar. You see, IDEM regulates when the shitty fertilizer can be applied so the ground isn’t frozen and the grain farmer will not let them in his field after planting or before harvest. Hmmm … let’s see, that would be late October-November and April-May. No chance in those periods for a gully washer. IDEM regulates this too. And they will check, at least ever five years unless there are complaints.
    • Anyway, off to the fields to spread the poop. The farmer can truck it, pump it or get it to the field however he wishes. Obviously, closer fields are better, as this is where the local farmer can increase his profits by reducing transport costs. Accidents happen. If pumping is used, the hose might break and leak into a ditch by the road. If trucked, there might be a spill. Remember, time is critical, and as Grandma said, haste makes waste. But that same hast increases the local farmer’s profits as well.
    • The poop is then injected or knifed into the ground to assure that it doesn’t run off of the hill it is applied to, and hopefully the soil isn’t so porous that it doesn’t leach through the soil into the groundwater.
    • So we have the perfect storm: a short window to get ready for the next herd; the profit motive to cut costs (aka corners); the rainy season. What could possibly go wrong?.
    • Oh, sadly, some of the herb didn’t survive. About 10 percent die. Those 960 hogs that die every year will be placed in a compost facility located behind the barns. The compost facility is a three-side structure with a roof. The carcasses will be piled up and covered with sawdust to compost.
    So that is an overview of a CAFO operation.
    Now let’s discuss the impacts to the community:
    Property valuations. Studies from leading appraisal experts indicate negative impact for up to 10 miles. The distance from the external negative influence is the driving force behind the amount of property value loss
    • With 1/2 mile it is 90 to 100 percent loss in value
    • Within 1/2 to 1.5 miles it is 40 percent loss in value
    • Within 1.5 to 3 miles it is 20 percent loss in value
    • Our experts believe the above ranges will experience the most impact. Pine Canyon Lake is slightly further than 1/2 mile, the 2nd and 3rd basis of Crooked Lake are within one mile, the 1st basin of Crooked and Gage are within 1.5 miles with Lime just outside 1.5 miles. Jimmerson is 2.5 miles, and Lake James is 3.75 miles.
    • Within the 3-mile radius there is approximately $395 million of assessed valuation. Our experts anticipate potential revenue impact to the county is slightly over $1 million annually. An impact of this magnitude will affect MSD of Steuben County and Prairie Heights School Districts which rely heavily on property tax revenue.
    • The $27,000 farm assessed value will see little impact. The proposed structures will add to that tax value, but they too will have an argument of diminished value resulting from their own operation and result in very little additional revenue to support schools.
    • With the support of Steuben Lakes Environmental Consortium, a group of us are considering our options with legal council, should this be approved, regarding how we will seek property tax revaluation through the filing of hundreds of appeals annually or other litigation against the County. We are in the exploratory stages of these actions.
    Economic Impact. We are evaluating the impact this will have on the county. It is believed that this may have far reaching impacts. Tourism will diminish if their are air or water contaminations. Simply look to Grand Lake St. Marys as an example. This will trickle down through all levels of the local economy that relies on tourism: restaurants, hotels, the state park, retailers, service providers to these businesses and so forth.
    Environmental Impact. We are evaluating the environmental impact. There are many components to this, including hydrology studies, drainage studies, air quality, meteorological studies, etc. All of these tie together. We are in the midst of these studies presently.
    Aviation Impact. Due to the compost facility the FAA considers these to be a hazard to airports. The FAA restricts location of these operations and would likely withhold funding as well as restrict future improvements to the airport. These operations attract scavengers. Increases in scavengers are a danger to aircraft due to increases in “in-air” strikes as well as ground strikes. Currently we are examining these impacts with aviation engineers.
    Road and Traffic Impact. We are studying the impact on roads that serve this location. We believe that CR 600 will require substantial additional maintenance for the entire 2-mile stretch from U.S. 20 to the farm. Heavy truck traffic will be frequent occurrences along this stretch. Further, many of the other county roads will be impacted in the manure application process.
    While Lake James residents may not feel threatened due to their distance from the location of this CAFO, please be mindful that there is also a greater fight: to send a message that Steuben County Lakes region will not tolerate this sort of development. Pull out a zoning map and take a look at the agriculturally zoned property within 1,000 feet of the Lake James chain. And with recent legislation at the State House, agriculture now has a favored and protected position. This legislation has passed with an alarming level of support by our legislators. It essentially will weaken the ability of local community governments to regulate agriculture activities in their county.
    Does this protect the family farmer? Was the family farmer being threatened in the first place? Why does this industry need preferential protected that is not afforded to all business? What about residents rights?

                Provided by Tom Danford

    A Dozen Talking Points on CAFOs

    Water Pollution: Millions of gallons of liquid manure on the landscape often leads to pollution of streams, lakes and well water. In Michigan where the Sierra Club Water Team did water quality monitoring around CAFOs, 100% of the CAFOs polluted the neighboring watersheds. Karstic geology, such as in SW Wisconsin is particularly vulnerable. And once ground water is polluted here, it will be polluted likely forever because we have an aquifer that does not flow and flush itself.
    Air Pollution: At the least, the quality of life of neighbors is seriously reduced. No more evening barbeques, gardening with joy. At the worst, serious respiratory illness results. Workers are also hit hard, with at least 25% developing permanent respiratory illness.
    Property Values Reduced: Residential property values lower from 10-90% depending on how close property is to a CAFO. Who would chose to live in a place where the stench can be so bad as to make you gag?
    Little Local Control: Law, largely written by the CAFO industry, has stripped local governments and citizens of most of their rights to determine local economic development. No other industry on the rural landscape is given such a complete legal advantage over other economic ventures.
    Economic Deterioration: Incompatibility with other rural economic ventures including family farming, farmstead businesses, tourism, basically any venture that includes the need for high quality air and water.
    Farm Economy: Local farming builds local economy and community with farm related businesses and a direct interest in the land and local resources. Once built, CAFO feed is largely trucked in, animals trucked out, and low paid immigrant labor used. This scenario robs communities of local economic, environmental, and social benefits.
    Road Repair: Local governments pay for the extensive road repairs from CAFOs.
    Lack of Enforcement: Industry claims that CAFOs are the most “regulated industry in the state”. They fail to say that monitoring and enforcement is minimal. For example, in the NE part of the state where there are 95 CAFOs, the DNR has just 3 staff people to monitor the operations.
    Cheap Food: Industry claims of cheap food leaves out the fact that we all pay to support their profits. Citizens foot the bill in hundreds of billions of dollars in taxpayer subsidies, medical expenses, insurance premiums, declining property values, and mounting clean up costs.
    Production Efficiency: “Bigger is Better”, is a myth perpetuated by the industry. Do not confuse high production with efficiency. The reliance on a heavily subsidized system to produce feed, large amounts of capital to dominate markets, and tax enforcement regulations to deal with waste disposal all are essential to making this industry “efficient”. Market controls leverage an unfair advantage over smaller produces and cloud a more holistic view of efficiency. In other words, diverse family farms are far more efficient in sustainable use of the land, growing food, and feeding the local economy.
    Good Food: The Centers for Disease Control and Prevention (CDC) estimate that contaminated meat and poultry related infections make up to 3 million people sick each year, killing at least 1000. And these figures are likely under reported. And confinement increases infectious bacteria such as E. coli and Salmonella, which cause these diseases. Add that CAFO meat is often contaminated with hormones and antibiotics from the feed that gets passed on to consumers and washed into the water system, and we understand why consumers want to have CAFO meat labeled as such.
    Animal Welfare: The crowded conditions and confinement restricts movement for animals. Often they cannot even turn around. This causes intense distress for animals and increases disease potential. Pasturing is more humane, sustainable, and less polluting.

    Press Release Being Mailed This Week

    A fast-growing organization of area residents has emerged to combat the threat to Whitley and neighboring counties’ water supply, air quality and public health from several proposed Concentrated Animal Feeding Operations (CAFOs) in the area.
    Several area farmers have applied for CAFO permits that are currently before the Indiana Department of Environmental Management (IDEM). Among these is Hinen Family Farms which is seeking a permit to build two 46,000-square-foot beef fattening barns, each of which would hold 660 cattle. Hinen Family Farms is a limited liability company located just over one mile south of the Tri-Lakes system in northern Whitley County.
    The organization has held three informational meetings to date, with a fourth meeting scheduled for 7 p.m. Thursday, June 8 at the Big Lake Church of God on North State Road 109. Additionally, representatives of the organization traveled to Indianapolis on May 10 to meet with IDEM to deliver a Power Point presentation outlining their objections to the Hinen CAFO and to deliver 213 hand-carried letters of objection.
    If, as anticipated, IDEM approves the Hinen CAFO, the group intends to file an appeal.
    Additional pending CAFO projects in Whitley County are a hog farm located near Troy Cedar Lake and chicken CAFO that would house 180,000 chickens in four barns on a farm near Goose Lake.
    Residents near the proposed CAFOs are concerned about contaminated air, noxious odors, risks to groundwater, reduced property values, disease-causing pathogens and the impacts on area lakes, watersheds and aquifers. The group opposes large CAFOs, essentially factory farms housing large numbers of livestock or poultry in confined feeding areas. According to the Environmental Protection Agency, states with high concentrations of CAFOs experience on average 20 to 30 serious water quality problems per year as a result of manure management issues.
    According to the group’s presentation to IDEM, 43 Whitley County lakes, rivers, branches, creeks and ditches are listed as impaired, and that three lakes near the proposed CAFO – Shriner, Troy Cedar and Little Cedar – are already considered impaired due to their high phosphorous content. High levels of phosphorous resulting from runoff from fertilized acreage can increase the growth of blue-green algae which, in turn, produce toxins in affected waterways. Some of the proposed manure fields to be served by the CAFO directly encroach on impaired or distressed waterways in northern Whitley County.
    A report from the Colorado College Dept. of Economics states that “the magnitude of the economic loss suffered by the neighbors of a CAFO can be significant.” The effect on the value of neighboring properties “lowers the taxable value of these properties and shifts costs to all other residents of the region.”
    According to the July, 2001 Appraisal Journal, a real estate appraisers’ publication, “… diminished marketability, loss of use and enjoyment, and loss of exclusivity can result in a diminishment ranging from 50 percent to nearly 90 percent of otherwise unimpaired value.”
    For example, a hog CAFO in northeast Clark County, Illinois, resulted in a 30 percent reduction in the property assessment for homes within a half-mile of the facility, a 20 percent reduction with one mile and a 15 percent reduction within 1.25 miles, and the county had to establish an assessment abatement for the 50 residential homes near the facility.
    Officially, Tri-Lakes encompasses a land area of 3.42 square miles, ranging from County Rd. 500 North to County Line Road and from State Rd. 9 to County Road 350 East. In includes .6 square miles of lakes, including Shriner Lake, Round Lake, and Little and Big Cedar lakes, and has approximately 1,350 full-time residents.
    John O’Connell,
    Paul Mills,


    Map of Whitley County CAFOs and Overlay Ordinance-Protected Areas
    Whitley County Land Classification Map (from the 2011 County Comprehensive Plan)
    Regulatory Definitions of Large, Medium & Small CAFOs
    CFO Rules
    List of Impaired Waterways in Indiana
    The Confined Feeding Operation Rule (327 Indiana Administrative Code 19
    The Fertilizer Rule (355 Indiana Adminsitrative Code 8)
    NRCS Animal Manure Management Brief, December 1995
    Whitley County CFO Regulations (hint: there aren't any)
    Journal-Gazette: Whitley CAFO Control Essential
    Adlock Broilers, LLC (Lopez) CFO Permit Application and Supporting Documentation
    IDEM's First Notice of Deficiency Letter to Adlock Broilers
    Poor manure practices culprit in thousands of fish deaths
    Guardians of Grand Lake St. Marys
    Eel River Watershed Initiative
    Tri-Lakes Property Owners Association
    CFO Guidance Manual
    CFO Rule 327 IAC 19
    Animal Operations and Resident Property Values
    The Evidence for Property Devaluation
    Court ruling is a first step toward controlling air pollution from livestock farms
    Gov. Cooper vetoes hog nuisance bill; new court documents show fecal bacteria from hogs in homes
    Can manure from so many cattle be safely spread on the land?
    Indiana residents fight back against imported manure
    A river of waste: The hazardous truth about factory farms
    Bloom of resident antibiotic-resistant bacteria in soil following manure fertilization
    CAFOs: Five essential tools for local regulation (ABA)
    A model zoning ordinance for animal feeding operations


    Whitley County Plan Commission
    The Whitley County Plan Commission is a body of nine members charged with the responsibility of guiding the development of the county by: preparing a comprehensive plan including a land use plan; enforcing land use zoning and subdivision regulation ordinances; reviewing and approving subdivision plats; and advising the County Commissioners on zoning map and ordinance amendments. The Commission conducts public hearings for zoning and subdivision applications.

    Watch Whitley County Commissioner Meetings on YouTube Soil and Water Conservation District
    The purpose of a Soil and Water Conservation District or SWCD is to provide information about soil, water and related natural resource conservation, identify and prioritize local soil and water resource concerns, and connect land users to sources of education, technical and financial assistance and to implement conservation practices and technologies.
    SWCD's mission is to promote soil conservation and water quality in Whitley County on both rural and urban land. To educate the people of the county about water qualities issues and motivate them to adopt the use of soil and water conserving practices.

    Whitley County CommissionersThe Board of Commissioners of Whitley County consists of three elected people who serve together and have powers over the unincorporated areas of the County. As the executive and legislative body of the county, the County Commissioners are responsible for the administration of county business and may enact ordinances and resolutions as provided for in the state law. Each member is responsible for his own district. District 1 commissioner, Thomas Western, is responsible for Cleveland, Etna-Troy and Richland townships. District 2 commissioner, George A. Schrumpf, is responsible for Coumbia, Thorncreek and Washington townships. District 3 commissioner, Don Amber, is responsible for Jefferson, Smith and Union townships.

    Indiana Department of Environmental Management (IDEM)IDEM's mission is to implement federal and state regulations to protect human health and the environment while allowing the environmentally sound operations of industrial, agricultural, commercial and government activities vital to a prosperous economy.

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