Comment NOW about Aviagen’s Permit for Zenith Site #30

Local and supporting voices are needed to protect threatened water resources in karst terrain. Aviagen Zenith Site #30 received a DEP stormwater pollution control permit in October 2020, which expired in October 2021 before permit-related work was completed. The current permit application is for a reissuance of that permit. The reissue application includes significant changes that also affect Site #31.

HOW: Submit via email to or by regular mail:
ATTN: Rick Adams, Permitting
West Virginia DEP, Division of Water and Waste Management
601 57th St. SE, Charleston, WV 25304-2345
Phone: 304-926-0499

Your Local and Supporting Voices are Important! Comments made during the first public hearing and comment period for Site #31 helped convince the WVDEP to deny Aviagen’s permit application and request significant changes – the only time that Aviagen has been denied a DEP permit in Monroe County.

If I commented on the Aviagen Site #30 permit last year, should I comment again this time? YES! Aviagen has made significant changes to the application that they submitted in December 2022 so it is important that people comment on the new version of the permit.

Aviagen, Inc. owns property for two neighboring turkey operation sites on the Peters Mountain side of Zenith Road. Zenith Site #30 received a DEP stormwater pollution control permit in October 2020 which has now expired. The current permit application is for a reissuance of that permit.

In multiple written comments to DEP, Indian Creek Watershed Association has noted that Aviagen’s Zenith Sites are located on karst at the base of Peters Mountain where there are known sinkholes and blind valleys, and that all neighboring families and farms rely on private springs and wells. No water testing or dye tracing has been done to determine which streams and springs might be impacted by runoff waters from these operations. For the past two years, ICWA has requested that dye tracing be done and that stronger pollution control measures and water monitoring procedures be put In place before permits are issued. In December 2022 Two streams in the Indian Creek watershed likely to be affected are Dropping Lick and Turkey Creek.

The WV Department of Environmental Protection is receiving comments from the public about whether Aviagen’s proposed NPDES Permit would comply with West Virginia’s groundwater protection regulations; whether the system described in Aviagen’s application would protect local groundwater from contamination by the construction and operation of Aviagen’s proposed turkey operation on Zenith Road in Monroe County.

Some Important Issues to Raise on Aviagen’s Site 30 “Reissuance” Application to DEP 2023

  • Aviagen is located on karst. Run-off into unlined ponds and sinkholes puts people and critical water resources at risk.
  • Aviagen’s treatment plan will not protect the groundwater along this section of Peters Mountain.
  • Aviagen has not identified what water is affected and has not disclosed what chemicals will be used.
  • Aviagen’s operations put the community’s pristine water supply at risk.

Suggested Requests to DEP

  1. Deny the Site 30 application based on the vulnerability of the location. The problems with this site cannot be mitigated, and the water resources that it puts in jeopardy are too valuable.
  2. Require dye-tracing from sinkholes on Sites 31 and 30 to determine where run-off water flows.
  3. Require Aviagen to pay for independent baseline water testing and monitoring for all residents in the area, not limited to within 1/4-mile of the unlined infiltration pond.