This is the text of the petition requesting rules be written on the mining moratorium law in preparation for the Natural Resources Board meeting on Wednesday, Sept. 29 in Sturgeon Bay.

TO:

Secretary of the Department of Natural Resources, and
The Natural Resources Board
P.O. Box 7921
Madison, Wisconsin 53707

The undersigned citizens of the State of Wisconsin hereby petition the Wisconsin Department of Natural Resources (WDNR) and the Natural Resources Board to conduct rulemaking to assure thecorrect interpretation of the mining moratorium act, Wisconsin Statute §293 .50, (hereinafter §293. 50) The intent of the law is clear; the task before the WDNR is to interpret it properly. Last year, George Meyer, Secretary of the WDNR, stated that rulemaking was in order. Robert Imrie, Thompson Signs Mining Moratorium Bill, Star Tribune, Apr. 23, 1998. We, the petitioners, believe that rulemaking is required. Further, it is common practice to create rules to implement a major new law. In fact, every substantive mining law has rules.

Rules have been requested prior to this formal request. Thirty-two legislators and forty-two environmental groups wrote letters, dated October 8, 1998 and September 8, 1998, respectively, to Secretary Meyer requesting rules for §293. 50.

We, the petitioners, believe the WDNR is misinterpreting language in §293.50 and, thus, making de facto rules to implement §293.50. Rules allow interpretation of §293.50 to take place in public with public scrutiny, not behind closed doors.

This petition is filed pursuant to the provisions of Wisconsin Statutes §§227.11 (2) (a) and 227. 12 (1 ) and (2) and Wisconsin Administrative Code NR 2.05. A petition for rulemaking must state the substance or nature of the rule requested, the reason for the request, the petitioners' interest in the requested rule, and a reference to the agency's authority to promulgate the requested rule, Wisconsin Statute §227.12 (2) . This petition fulfills these requirements and describes why rules are urgently needed.

I. NATURE OF REQUESTED RULES

1. A rule defining "significant environmental pollution", §293.50 (2m) (b) , to mean any situation in which a Wisconsin standard for ground or surface water has been exceeded.

2. A rule requiring that only one mine shall qualify for the two ten-year terms specified in §293.50 (2) (a) and (b) Thus, the rule should establish that a single example mine must meet both the first and second ten-year requirements specified in §293.50.

3. A rule requiring the criteria promulgated under §293.50 shall be analyzed by the WDNR after the mining applicant's Environmental Impact Report (EIR) is submitted to the WDNR and before the Draft Environmental Impact Statement (DEIS) is issued by the WDNR.

4. A rule requiring the first ten-year precondition in §293.50(2)(a) to begin upon ore extraction. Periods of ore extraction cessation shall not be included in the requisite tenyears. The second precondition in §293.50(2) (b) which requires that the example mine has been "closed" for at least ten years, shall begin after final reclamation and termination according to NR 182.15, Wis. Stat. §§293.01(23) and 293.21(l) (c) respectively, and discontinuation of water treatment facilities.

5. A rule requiring the words, "verified by the department, " §293. 50 (2) (a) and (b) to mean
   1. ) data that a state regulatory agency or independent research agency collected and

   2. ) the WDNR shall be able, using independent methods, such as research done by the Army Corps of Engineers (ACE) or the U.S. Environmental Protection Agency (EPA), to accurately duplicate the data submitted and

   3. ) if it is not possible to duplicate the data, other types of verification requirements shall apply, such as the requirements in NR 106.06 (use of verified mathematical water quality models); NR 150.25(c) (analysis by a laboratory certified for that purpose by a state or federal agency shall be accepted by the department as verified); NR 440.71 (continuous inward flow of air shall be verified by observation using smoke tests, streamers, tracer gases or other means approved . . . ); NR 445. 02 (9g) (reference concentration means a verified reference concentration developed by the United States Environmental Protection Agency); NR 516.07(b) (extrusion welding machine performance shall be verified by a minimum of 2 test scans per day per machine . . .

6. A rule requiring the words, "net acid generating potential", §293.50(2)(a) and (b), to mean that, when mined, the sulfide ore body, with the host rock, has the potential to actually create acid mine drainage. Thus, if an example mine is located at a site where no significant amount of water reaches the mine or disposal sites, either because of aridity, permafrost, and/or other conditions, then there would be no acid generating potential. The example mine, therefore, would not constitute an acceptable mine under §293.50.

7. A rule requiring the words, "relevant data," §293.50(2m)(b), to mean
   1. ) information about the example mine must be collected by or under the supervision of a government agency. Specifically, information must be excluded if it was collected independently by a mining operator without government verification and supervision and

   2. ) adequate base-line data collected from the example mine site prior to any mining related activity. If sufficient base-line data is not collected before mining activity occurs, it would be impossible to prove or disprove 'degradation", §293.50(l)(a), caused by mining at the example site and

   3. ) data for all substances that are regulated under Wisconsin ground and surface water laws. In order to make this determination, the data must be identical or equivalent to Wisconsin monitoring requirements for ground and surface water. Criteria for comparability includes placement of monitoring wells, number of wells, substances monitored, frequency of monitoring, placement of monitoring stations on potentially polluted waterways and the substances monitored in the potentially polluted waterways and at the treatment site.

8. A rule requiring "tailings", §293.50(2)(a), (b) and §293.50(2m)(b), to be defined as, but not limited to
   1. ) waste material resulting from the benefication of crushed ore at a concentrator. NR 132.03(24).

   2. ) "waste material resulting from the washing, concentration or treatment of crushed ore." Wis. Stat. §107.30(3) and

   3. ) "the remaining portion of a metal-bearing ore after some or all of such metal, such as uranium, has been extracted." 42 U.S.C. 7911(8).

9. A rule requiring that "tailings site", §§293.50 (2) (a), (b) and (2m) (b) , mean any place where waste materials were deposited from the mine including after benefication, smelting, or any other processing.

II. REASONS FOR RULES REQUEST

Rules are always needed to implement law. The WDNR is currently misinterpreting the intent of §293.50 by allowing two mines to meet the twenty-year test, §293.50 (2) (a) and (b) , thus, the need for rules is plain. Rules. allow interpretation of §293.50 to take place in public with public scrutiny, not behind closed doors. The WDNR has already made decisions regarding the twenty-year test behind closed doors. The WDNR is required to adopt rules for §293.50. Wis. Stat. §293.13(l)(a). Section 293.50 and its implementation are vital to protection of Wisconsin's invaluable natural resources, such as the Wolf River which is one of the few Wisconsin Rivers to be designated as an Outstanding Resource Water.

The mining industry is notorious for its historically poor environmental record. There are currently 557,650 abandoned hardrock mining sites in the United. States and the estimated cost for cleaning-up these sites ranges from $32 billion to $71.5 billion. Lyon, Hilliard, and Bethell, Burden of Gilt, Mineral Policy Center 4 (June 1993).

Wisconsin's natural resources are an important part of our history. These resources are also vital to the state economy. Furthermore, the natural resources in Wisconsin provide marvelous recreational opportunities.

The petitioners seek to ensure §293.50 is interpreted to guarantee that dangerous substances produced by mining operations do not threaten their health and welfare or the resources they enjoy.

The Wolf River, the fifth most endangered river in North America, is one of the last wild, whitewater, trout riverways in the Midwest and it is a component of the National Wild and Scenic Rivers System. Sara E. Johnson, Wolf River Named One of Most Endangered Rivers in North America, River Alliance of Wisconsin, Apr. 16, 1997; Beth Norcross, Wolf River Threat: Zinc/Copper Sulfide Mine, American Rivers, Apr. 1997. The Wolf River is specifically designated by the state as an Outstanding Resource Water. At least seven endangered and threatened species depend on habitats provided by the Wolf, including bald eagles and osprey. The petitioners fear that the Wolf River will be contaminated by mining waste from Nicolet Minerals' proposed enormous metallic sulfide mine. The mine is to be built in the river's fragile headwaters area which is located north of Mole Lake Reservation and the Mole Lake rice beds. Waste from the mine could also harm Menominee Nation and Chippewa resources which are associated with the Wolf River. The mine threatens to harm tribal cultures and depress the important tourism and recreation-based economy of the area. If §293.50 is not implemented correctly, the Wolf River could be in jeopardy.

The petitioners are concerned about the gamut of consequences that could result from construction of the proposed Crandon mine. It appears that the proposed mine's most significant environmental impacts would be on surface and ground water resources and waste management as it relates to these water resources. There are several additional aspects of the proposed mine construction that are important to the petitioners, however, such as air and noise pollution. The petitioners hope that a rulemaking will assure that these issues will be properly addressed by the WDNR.

Significant Environmental Pollution
The term "significant environmental pollution", §293.50 (2m) (b) , should be defined by Wisconsin ground and surface water standards because the intent of §293.50 is to protect Wisconsin's natural resources, according to Wisconsin standards, from being polluted by mining waste. Data from an example mine that is considered in the light of Wisconsin standards is useful because the example mines should demonstrate mining capabilities that can meet our standards. Wisconsin Statute §293.13 uses the phrase "significant environmental pollution" in relation to ensuring that mining activities in Wisconsin will be conducted in a manner consistent with the purposes and intent of the mining chapter which includes standards for the protection of surface and ground waters.

One Mine for Two Tests
Recent press accounts indicate the WDNR is not requiring one mine to meet both ten-year tests under §293.50. We disagree with this analysis because the petitioners and the public have always understood §293.50 to require that one mine meet both ten-year tests. The WDNR is misinterpreting how the ten-year tests are to accumulate under §293.50. All participants in the debate of SB3 indicated that the test applies to only one mine. Representative Spencer Black, co-author of §293.50, has consistently indicated that the intent was to require that one example mine meet both ten-year requirements. On May 12, 1997, Representative Spencer Black stated,

My bill will prohibit the opening of a new mine in a sulfide ore body until a similar mine has been operated elsewhere for at least 10 years and reclaimed for 10 years without significant environmental damage.

State Representative Spencer Black, Statement to the Assembly Environment Committee,
May 12, 1997, Ladysmith, Wisconsin.

Throughout legislative consideration of SB3, the WDNR interpreted legislation to mean that one mine must meet both tests. On February 17, 1997 at a Green Bay hearing on the mining moratorium bill, Stan Druckenmiller, Executive Assistant of the WDNR, speaking on behalf of WDNR Secretary George Meyer, stated,

. . . the applicant would have to find, and the Department would have to evaluate, a mine at least 20 years old that was operated with a comparable technology proposed by the applicant.

Stan Druckenmiller, WDNR, SB 3 Hearing,
February 17, 1997, Green Bay, Wisconsin.

Furthermore, in an October 3, 1997, letter to Representative Marc Duff, Chair of the Wisconsin State Assembly Committee on the Environment, WDNR Secretary George Meyer wrote,

. . . for a mine to qualify as an example of sound technology, it must have been operated a minimum of 1.0 years and closed another minimum of 10 years.

George Meyer, WDNR Secretary, Department Comments on SB 3 and Assembly Amendment 1 to SB 3,
October 3, 1997.

Even individuals and organizations working in industry understood §293-50 to mean that one mine should meet both tenyear tests. On October 14, 1997, in a memo to the Wisconsin Assembly Committee on Environment, James Buchen, Vice President of Wisconsin Manufacturers and Commerce, a leading opponent of SB3 who spent considerable resources lobbying against SB3, stated,

. . . before a mining permit can be issued in Wisconsin there must be proof that a mine has operated in the US or Canada for at least 10 years without polluting groundwater or surface water, and that the mine has been closed for 10 years without polluting groundwater or surface water.

James Buchen, Memorandum to Wisconsin Assembly Committee on Environment,
October 4, 1997.

The January/February 1996 issue of the Badger State Miner, a publication by the Wisconsin Mining Association, reported the mining moratorium bill would,

. . . place up to a 20-year moratorium on sulfide metallic mining in the state of Wisconsin. More specifically, the bill says there must be proof a mine has operated in the U.S. or Canada for at least ten years without polluting groundwater or surface water, and that the mine has been closed for ten years without polluting groundwater or surface water.

Badger State Miner, Wisconsin Mining Association,
Jan/Feb 1996.

Now, the WDNR interprets the law to mean that one mine may meet the operational ten-year test and another mine may meet the closure ten-year test. We feel this change constitutes a serious deviation from the intent of the law and -could endanger our precious resources.

We believe the WDNR is misinterpreting the law in such as way as to operate contrary to the spirit of §293.50, its own original interpretation and previous public interpretations of the law.

Finally, §293.50 itself repeatedly refers to one mine. In §293.50 (2) (a) and (b) , the law states,. "A mining operation. In §293.50 (2m) (a), the law states, "any mining operation that has been listed on the national priorities list, 11 and "any mining operation for which the operator is no longer in business". Section 293.50(2m) (b) refers to "A mining operation" and states, "THE mining operation has not caused significant environmental damage, " and "at THE tailings site or at THE mine site". Wis. Stat. §293.50 (1998) emphasis added. The intent of the law is clear. one min mine is to meet both ten-year tests in §293.50 (2) (a) and (b).

Timing of WDNR Analysis of Example Mines our understanding is that the DEIS will contain an analysis of the example mines the company submitted to the WDNR. We believe that the analysis is crucial at the DEIS. stage. If this analysis occurred at a later point and the example mines were found to be unacceptable, the time and energy expended in creating and evaluating the permit application would be squandered. We think example mines should be considered before the DEIS is issued because consideration at any other time is a waste of WDNR and taxpayer time and resources.

Operation and Closure
Both ten-year time frames should be defined because the petitioners fear that example mines will be accepted that have not actually been operated for ten years or truly been closed for ten years. The term "closed", §293.50 (2) (b) , in regard to a mining facility, is not currently defined in Wisconsin mining statutes and should be defined so as to accurately gauge an example mines capacity to defeat the pollution problems most metallic mines experience. The petitioners assert that the intent of §293.50 is to protect Wisconsin resources, thus, Wisconsin reclamation and termination standards are the proper protective interpretation of §293.50 (2) (b) .

WDNR Verification
The data from example mines should be collected by state regulatory agencies or independent research agencies and should either be able to be duplicated or be verified by accepted methods because the petitioners question whether mining applicants would otherwise have sufficient incentive to accurately measure environmental data at the example site.

Net Acid Generating Potential
An example mine that does not actually produce acid mine drainage because it does not come into contact with water is not acceptable under §293.50. This phenomena could occur if the example mine was located in an area that experiences permafrost or arid conditions. For example, Nicolet Minerals Company has submitted the Homestake Cullaton Lake mine which is located in Northern Canada where permafrost conditions keep the mine wastes from seeping. into the ground and also keep the wastes from producing acid. The ASARCO Sacaton I mine in desert Arizona receives far less precipitation than does Wisconsin.

Relevant Data
Data must be sound in order to demonstrate an example mine's capability to exist without contaminating natural resources. The petitioners opine, therefore, that §293.50 requires data to be collected or supervised by a governmental agency in order to be relevant. Since the intent of the law is to discover whether a sulfide mine has operated without exceeding Wisconsin standards, it is necessary that the data used to make this determination be collected in a manner comparable to Wisconsin regulation..

Relevant data or evidence is"[e]vidence tending to prove or disprove an alleged fact." Black's Law Dictionary 1291 (6th ed. 1990). The Mining Moratorium Law, §293.50, clearly requires that the WDNR cannot use data from an example mine purporting to satisfy §293.50 if the data from that mine does not tend to prove that the proposed mine will not cause contamination or render unclean or impure the air, land or waters of Wisconsin. This would arguably exclude any and all example mines from regions with significantly different air, land and water characteristics than those found in Wisconsin. It would also arguably exclude any and all example mines from areas with significantly different climates and geological, soil, groundwater, and surface water characteristics.

Tailings
The word "tailings", §§293.50 (2) (a), (b) and 293.50(2m) (b), should be interpreted according to NR regulations, state and federal law because the intent of §293.50 is to protect Wisconsin resources. The petitioners agree that the legislators referred to all of the materials defined in the NR regulations, state and federal law when they addressed tailings in §293.SO.

Tailings Site
Mine wastes and tailings from a proposed example mine which have been transported to another site, separate from the example site, should be included in §293.50 analysis because waste management techniques used at the example site are the basis upon which the WDNR must evaluate example mines under §293.50. Removal of mining wastes from the mining site is a form of waste management, therefore, the WDNR should evaluate the sites onto which the wastes were removed.

Wisconsin Statute §293.50, and the manner in which it is interpreted, will affect the proposed Crandon mine and future mining in our state. Each of us personally enjoy the area that is the proposed Crandon mine site as well as areas down-river and adjacent to the site. We want to ensure that the areas we use and enjoy are protected from pollution and degradation. We believe, therefore, that the Wisconsin Department of Natural Resources should promulgate rules that will serve to interpret and implement §293.50 correctly.

III. AGENCY AUTHORITY TO ADOPT RULES REQUEST

Section 293.13 (1) (a), requires the WDNR to adopt rules implementing ch. 293 which governs metallic mining. The mining moratorium bill is part of ch. 293 and, therefore, the WDNR is required to adopt rules governing the mining moratorium. Section 293.13 (2) (a) further requires the Department to adopt minimum standards that are consistent with the purposes and intent of the chapter. We believe these rules are consistent with the purpose and the intent of the mining moratorium law. In addition, §293.15(9) allows the Department to adopt rules that are more stringent for any particular applicant.

Chapter NR 132 contains the Department's rules on metallic mineral mining. The purpose of the rules is to establish procedures and standards for the comprehensive regulation of metallic mineral mining. NR 132.02. In that chapter, the WDNR sets forth minimum design and operation requirements for metallic mining. See NR 132.17. The chapter also sets forth location criteria and environmental standards. See NR 132.18. The proposed rules contained in this petition also set forth criteria that should be used by the DNR and mining companies in determining if there are any mines that satisfy the language in the mining moratorium bill.

Finally, additional authority for adopting rules can be found in the Wisconsin Environmental Policy Act (WEPA) §1.11, which governs governmental consideration of environmental impacts. WEPA is the Legislature's mandate that environmental regulators, such as WDNR, consider the environmental consequences of their actions..

IV. PETITIONERS' INTEREST IN REQUESTED RULES

The rulemaking process is needed to allow citizen participation and evaluation of the WDNR's interpretation of §293.50. Decisions regarding implementation of the law will need to be made. Rulemaking allows these decisions to be made in public and with public scrutiny, not behind closed doors within the WDNR. The rulemaking process is, therefore, more protective of the public interest than interpretation by agency staff or an administrative law judge.

The petitioners are individual citizens of the state of Wisconsin who have a direct and continuing interest in ensuring that the resources they use and enjoy are unpolluted. The petitioners' health, well-being and right to use and enjoy waters and air of this state are adversely affected when unsafe metallic sulfide mining practices cause degradation of the quality of the air and surface or ground waters of the state. The petitioners recognize that mining is an extremely valuable industry in Wisconsin. Their concern is that improper mine permitting will represent a threat to the health and welfare of the resources and citizens of the state. The petitioners, therefore, request that the rules proposed in this petition be adopted. Approval of these rules will allow for the conduct of all necessary mining practi

Petitioner Spencer Black resides at 5742 Elder Place in Madison. He is a Representative in the State Assembly and coauthor of the Mining Moratorium Law, 1997 Wisconsin Act 27. For many years Representative Black has enjoyed the Forest County area for recreation and has a vested interest in preserving the natural beauty of this pristine area. Representative Black's constituents also use the area and have interests in protecting its natural resources. As the Assembly Author of the Mining Moratorium Law §293.50, Representative Black seeks to ensure the law is enforced and interpreted consistently with the legislature's intent. Representative Black supports the rules submitted in this petition.

Petitioner Kevin Shibilski, Wisconsin State Senator and coauthor of §293.50, resides at 457 Scenic Circle in Stevens Point. Senator Shibilski is a lifelong resident of central Wisconsin and has hiked and fished the Wisconsin River area for years. Kevin and his wife own recreational property near the Wisconsin River in both Lincoln County and Portage County and have a vested interest in preserving the natural resources and landscape of the area. As the Senate author of the Mining Moratorium, Senator Shibilski's interest is to ensure the law in enforced consistently with the legislature's intent. Senator Shibilski is in complete agreement with the rules submitted in this petition.

Petitioner Roger McGeshick, Mole Lake Chair, resides on the Mole Lake Indian Reservation in Forest County, Wisconsin. His family has lived in the area for over 300 years and has always been involved in traditional rice harvesting and gathering resources from the local land and waters. He lives and depends on the lands and waters near and around Swamp Creek, Rice Lake and the area known as the Crandon mine site. Mr. McGeshick gathers plants for food and medicine, water, fish and game on these lands and waters. He uses these lands and waters for subsistence, religious ceremonies and other cultural and recreational purposes. Mr. McGeshick would be directly and personally affected by. the proposed Crandon mine, should it be permitted. Mr. McGeshick would like to ensure that the Mining Moratorium Act, §293.50, will protect his interests in Forest County. In order to be able to continue the uses of the area that would be affected by the proposed mine, Mr. McGeshick supports the rules submitted in this petition.

Petitioner Chuck Sleeter resides on Pickerel Lake in the Town of Nashville. He has been elected Town Chairman twice to represent the interests of the people of Nashville. Chairman Sleeter has been a vocal supporter of the Mining Moratorium Act on *.behalf of his constituents. The Town of Nashville will be the first community that will be negatively impacted by the Crandon Mine proposal. Chairman Sleeter knows that it is his duty to protect the health, safety and welfare of Nashville's citizens. It is because of this, that he strongly supports the rules submitted in this petition to ensure that the law is enforced to be consistent with the legislature's intent of the Mining Moratorium Act.

Petitioner Apesanhkwat, Chairman of the Menominee Indian Tribe, lives, works and recreates on the Menominee Reservation. He is responsible for the well-being of his tribal members, as well as his family, not only for the short-term, but for the next seven generations. Protection of tribal assets and resources depend on not merely reducing, but eliminating the threat of negative impacts from the proposed Crandon mine to the pristine Wolf River which runs through the reservation. He strongly supports the rules submitted in this petition to ensure that protection.

Petitioner Herb Buettner resides at N4297 Buettner Road, White Lake, Wisconsin, 54491. Mr. Buettner owns property abutting the Wolf River and has operated the Wild Wolf Inn for 25 years and Herb's Raft Rental for 32 years which employ 57 people. Mr. Buettner's livelihood depends on the uncontaminated, pristine character and natural beauty of the Wolf River. The proposed mine threatens the water quality and quantity of the Wolf River on which the entire ecosystem depends. Mr. Buettner has worked with the WDNR and Tribal governments for the past 50 years in protecting and enhancing this unique and priceless resource.

Petitioner Kira Henschel, who resides at 3805 Paunack Avenue, Madison, Wisconsin 53711, is former President of the Mining Impact Coalition of Wisconsin and founder of Kids for Clean Water. She owns property in northern Wisconsin near the proposed Crandon Mine and would be directly impacted by the mine's operation. Ms. Henschel is also a geologist who has witnessed first-hand the environmental, economic and social impacts of mining in Europe, Canada and the United States. She is petitioning on behalf of her daughter, Loris, and the hundreds of other children who would have to suffer the environmental and economic consequences of the proposed metallic sulfide mine, which would devastate the pristine Wolf River watershed and create Wisconsin's largest toxic landfill. Ms. Henschel is petitioning to ensure that the Mining Moratorium Act, §293.50, will protect the interests of these future generations.

Petitioner John Berge, Chair of the John Muir Chapter of the Sierra Club, resides at 1529 Crabapple Drive, in Racine Wisconsin, 53405. He canoes frequently in the Crandon area and hikes extensively along the Wolf River. Mr. Berge wishes to protect the Wolf River because he views it as an invaluable pristine resource. Mr. Berge has canoed all around the state. He feels that the proposed Crandon mine site is probably not an appropriate place to mine, therefore, he would like to see the strictest standards used to protect it from potential mining mishaps. Mr. Berge is petitioning to ensure that his interests in hiking healthy forests, wetlands, and prairies and in canoeing clean waters in the Crandon area are preserved by these implementation rules for the mining moratorium act, §293.50.

Petitioner Keith Reopelle, who resides at 183 Harvest Circle in Oregon Wisconsin, 53575, is the Program Director for Wisconsin's Environmental Decade. Mr. Reopelle has fished and harvested game fish, including walleye and smallmouth bass, from the Wolf River since boyhood. Mr. Reopelle is one among many members of Wisconsin's Environmental Decade who would be directly and individually affected by the proposed Crandon mine. Mr. Reopelle is also petitioning on behalf of all Wisconsin's Environmental Decade's other, 29,000+ members who recreate and earn their livelihood on and. around the Wolf River, the Crandon mine site and the adjoining affected environment. Mr. Reopelle is petitioning to ensure that the Mining Moratorium Act, §293.50, will protect the interests stated above.

Respectfully submitted,


Laura Owens Sierra Club Mining Policy-Specialist

Mailing Address:
214 North Henry Street Madison, Wisconsin 53703
(608)-257-4994