July 24, 2007 via facsimile
Mr. Wayne Dybvig, Co-Chair
International Red River Board
c/o Environment Canada, Prairie & Northern Region
Room 300, 2365 Albert Street
Park Plaza, Regina SK S4P 4K1
Mr. Michael J. Ryan, Co-Chair
International Red River Board
c/o Bureau of Reclamation, Great Plains Region
PO Box 36900
Billings, Montana 59107
Mr. Karl Rockeman
North Dakota Department of Health
Division of Water Quality
918 East Divide Avenue, 4th Floor
Bismark, North Dakota 58501-1947
Dear Sirs:
It has come to our attention that a decision for approval is pending in regard to Dakota County Swine Nursery, an 18,000 per year nursery pig operation, located within the Devils Lake watershed in Towner County, North Dakota.
It is also our understanding that an outlet has been built on Devils Lake and is currently in operation, thus changing the status of the Devils Lake watershed to one that is no longer “closed” or “isolated”, by connecting the watershed through a pipeline/canal to the Sheyenne River, which eventually flows into the Red River.
Recent analysis by Manitoba Water Stewardship, indicate that 32% of the annual phosphorus loading to Lake Winnipeg (1994 to 2001) was attributable to the Red River located in the United States. Watershed processes within the Red River basin is the largest contributor of phosphorus to Lake Winnipeg and phosphorus has been identified by Canadian researchers at the Freshwater Institute - University of Manitoba, as the nutrient causing eutrophic conditions on Lake Winnipeg.
In response to this challenge, the Manitoba government announced a nutrient reduction strategy which consists of reducing loadings to Lake Winnipeg to pre 1970 levels. Other actions within the strategy included the introduction of a phosphorus regulation, placing a moratorium on new or expanded hog operations utilizing the liquid slurry system and agreeing with other mandated agencies within the basin, to a 10% reduction of nutrients crossing the US/Canada border.
This 10% reduction goal was achieved through the Aquatic Ecosystem Committee of the International Red River Board of the International Joint Commission.
We seek clarification on the applicability of the 10% reduction agreement to this proposed concentrated livestock operation. We have been informed by concerned residents in the area that the proposal is situated in close proximity to the Mauvais and Calio Coulees, which flow into Devils Lake. We ask that the state regulator deny this approval and place a moratorium on all similar types of development until the 10% reduction plan has been implemented and that there has been a 10% reduction of nutrients crossing the border. We ask that all appropriate regulatory and enforcement agencies within the Red River basin take the necessary steps to achieve this objective so as to prevent a possible trans-boundary dispute in the future.
Sincerely,
Glen Koroluk
Community Organizer
Beyond Factory Farming Coalition
cc:
Honourable John Baird, Minister of Environment, Canada
Honourable Christine Melnick, Minister of Water Stewardship, Manitoba Eco-Network
Mr. Lance Yohe, Executive Director, Red River Basin Commission
