The growth of industrial farms in America’s dairyland is outpacing regulators tasked with reviewing permits and overseeing compliance with waste regulations.
Wisconsin currently has 370 active or pending concentrated animal feeding operations (CAFO) permits, most of which are dairy farms with about 700 or more cattle. Wisconsin dairy farms produce roughly 12 billion pounds of manure annually, according to the University of Wisconsin Extension office.
The Wisconsin Department of Natural Resources monitors and oversees management of these permits that track manure waste at the state’s largest farms. As of early March, there were 13.5 full-time-equivalent field staff members in the department overseeing the CAFO program, well short of the 20-staff benchmark the state has long said it needs.
State officials originally set a goal of one staff member for every 20 farms when permitting laws took effect in 1985. The department has not met this goal since 2010, and today the ratio is roughly 27 farms per CAFO program staff, the highest the ratio has ever been.
The department has rarely achieved this ratio in the past two decades, while the number of Wisconsin CAFOs has increased 160%. This comes at a time when the state has lost nearly 18,000 dairy farms, mostly small-scale operations.
While CAFOs have increased, the DNR’s budget for monitoring them has not.
Last year, Wisconsin Gov. Tony Evers, a Democrat, requested an increase in staff positions, but his budget proposal was rejected by the state’s majority-Republican legislature. A DNR spokesperson said the agency had planned to hire new staff last year, but federal cuts to funding that support the program left vacant positions in limbo.
DNR staff monitor operations, approve and review wastewater permits. The department administers Wisconsin Pollutant Discharge Elimination System permits, which outline methods for protecting the state’s water quality under the federal Clean Water Act.
These permits require farms to prepare plans for where they spread manure and how the farm would handle and report a manure spill. The WPDES permits do not monitor air, odor, land use or other issues related to CAFOs.
DNR staff are also responsible for ensuring the waste is properly disposed of and managed to prevent runoff into nearby waterways, groundwater and communities. Research indicates that a single dairy cow produces approximately 120 pounds of manure per day.
“The Department of Natural Resources faces staffing limitations across all programs,” a DNR spokesperson told Investigate Midwest. “Over the past 20 years, the department has lost over 500 FTE positions due to cuts in the biennial budget process.”
The DNR said it is allotted for 15.5 FTE regional CAFO specialist positions, but staff departures last year reduced the levels. A DNR spokesperson said the department is recruiting new staff to bring this level back up, but does not have a timeline for when it will be fully staffed again.
The issue of low DNR staffing levels isn’t new to Midwest Environmental Advocates, an environmental law firm based in Wisconsin.
The law firm filed a petition with the U.S. Environmental Protection Agency in 2016 to review the agency’s permitting process. Among its claims for review, the law firm cited staffing levels as reasoning for a backlog of permits and enforcement actions to protect the state’s waterways.
“Wisconsin water quality will suffer if DNR understaffing continues and if the permit backlog increases each time a new policy or water quality standard is adopted,” the 2016 petition stated.
Adam Voskuil, a Midwest Environmental Advocates staff attorney, said little has changed a decade later.
“It’s frankly very concerning,” Voskull told Investigate Midwest.
Over half of the state’s impaired waterways are caused by phosphorus and E.Coli pollutants, which are primarily attributed to animal waste and agricultural runoff, according to the state’s most recent water quality report submitted to the EPA.
Voskull said the department has to work to keep its head above water, and without more staff, they aren’t able to work proactively. He pointed to citizen groups throughout the state who have done the work of monitoring and reporting problems with CAFO permits.
“It puts an obligation on community members and citizens to do that work,” he said.
In recent years, residents in rural western Wisconsin have successfully passed a series of local ordinances that farms must comply with to operate as CAFOs. This effort has been challenged in the court by dairy industry groups.
Communities across Wisconsin have become accustomed to the effects of CAFOs. Last year, a dairy CAFO in northern Wisconsin spilled an unknown amount of manure into the nearby Trappers Creek, leaving fish dead in a five-mile stretch of the waterway. The state DNR was not aware of the spill until several days later.
Wisconsin citizens have also taken farm operators to court when farms step out of line. A group of citizens in eastern Wisconsin contested a CAFO’s newly issued permit in December 2025 after the DNR acknowledged the farm had been operating without a permit and had exceeded the allowed animal threshold since at least 2023.
Voskull said that if the state DNR were properly staffed and resourced, it would be able to recognize when farms are operating without permits or outside regulations sooner than it does now.
In addition to proposing four new full-time staff positions to the department’s CAFO permitting program, Evers’ budget proposal would have increased the permit application fee from $345 to $545, allocating more funds to the department’s oversight of these farms.
The governor’s proposal was shot down by the Joint Finance Committee, the Republican-majority legislative committee that crafts the budget.
“Despite the increase in CAFOs statewide, the Republican-controlled budget committee removed these provisions from the budget, as well as hundreds of other positions across the administration that would have helped decrease wait times and backlog of permitting, licensing, and more,” an Evers spokesperson told Investigate Midwest.
Leadership at the Joint Finance Committee did not respond to requests for comments.
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