From the National Campaign for Sustainable Agriculture
The USDA and EPA are taking public comments on a "Draft Unified National Strategy For Animal Feeding Operations (AFOs)." This Draft Strategy is the overall blueprint for dealing with surface water pollution from all AFOs, including large-scale, confined animal factory farms with more than 1,000 animal units. Both USDA and EPA acknowledge in the Draft Strategy that:
Submit individual comments on the Draft Strategy (see details below). The Draft Strategy is available at the EPA's website and in the Federal Register, Vol. 63 at pp.50192-50209 (September 21, 1998). Mail Comments to Denise C. Coleman, Program Analyst, Natural Resources Conservation Service, ATTN: AFO, Box 2890, Washington, D.C. 20013-2890. Comments must be received by January 19, 1999.
Go to the Public Hearings (called "Listening Sessions") in your region. The closest hearing to our region will take place on November 30 in Madison at the Sheraton Madison Hotel, located on 706 John Nolan Dr. The hearing will run from 12:30 pm to 4 pm, and registration begins at noon. The Clean Water Network will post the times and places for the listening sessions as soon as they are available. You can also contact the National Campaign for Sustainable Agriculture for information on the listening sessions.
A second Listening Session on the Draft Animal Feeding Operations Strategy will be held in Eau Claire on Wednesday, December 2, from 10:00-11:30 am. This will be in conjunction with the Wisconsin Land and Water Conservation Association annual conference at the Ramada Inn. Staff from USDA Natural Resources Conservation Service and the state Department of Natural Resources will briefly review the Strategy and discuss its expected impact in Wisconsin. Interested individuals are invited to attend and comment on the Strategy. All comments will be shared with the national leadership at the Department of Agriculture and the EPA.
Contact your local media, newspapers, radio, television, etc. and let
them know of your concerns about factory farms and the health and well-being
of rural communities. Provide them with the Campaign
Information Fact Sheets packet on Factory Farms and the Draft Strategy,
available November 1, 1998, or refer them to the National Campaign
for Sustainable Agriculture for more information.
HOW TO WRITE COMMENTS
1.) Recommend sustainable alternatives to factory farms.
Many large-scale factory farms handle massive amounts of animal waste with
primitive, open-air cesspool "lagoons" and sprayfields that contaminate
groundwater, streams, and the air. In many regions, these factory
farms are often crowded together on small land bases and animal waste is
dumped on the land at rates far exceeding those recommended as sound practice
for agricultural production. People in neighboring communities around
the nation are vigorously protesting the disruption to their lives and
health from the stench and air pollution and the fouling of drinking water
and recreational water resources caused by these factory farms.
The Draft Strategy acknowledges the roots of factory farming pollution
problems: the decoupling of animal production from feed production
and the concentration of large amounts of manure and wastewater on farms
and in watersheds. Yet, the Draft Strategy assumes, erroneously,
that large-scale factory farming is both inevitable and potentially sustainable,
and recommends the expenditure of large amounts of public funds for technical
assistance and cost-share money to encourage and subsidize factory farms
and for a regulatory system that will attempt to bandage over some of the
excesses of a deeply flawed production system.
Economic and environmentally-sound sustainable alternatives exist to
large-scale factory farms. The Draft Strategy should recommend that
these existing, truly sustainable livestock production practices be encouraged
as alternatives to factory farms.
2.) Require individual clean water act permits, instead of rubber-stamping general permits or watershed permits. The Draft Strategy acknowledges that current regulations and standards for dealing with factory farm pollution are inadequate, that a backlog of almost 10,000 operations need Clean Water Act permits, and that many of these facilities are currently the source of significant water pollution problems. The Draft Strategy proposes, however, that most existing operations be regulated under a general permit process, which does not give neighboring communities notice or an opportunity to review and comment before the permit is granted.
Most of these permits will be issued in advance of proposed regulatory amendment and new requirements for nutrient management plans, providing factory farms with rubber-stamp approval to continue using large-scale, liquid manure storage facilities and land application sprayfields. Proposed watershed permits may be even more inadequate, allowing for a blanket approval of all factory farms packed into a single watershed without adequate analysis of the cumulative impacts on the watershed or sufficient public participation in the permitting process.
The Draft Strategy should be revised to require that existing large-scale, liquid manure handling systems be phased out and these systems be prohibited in any permit for new or expanding operations. In addition, a sound Strategy should impose a moratorium on new or expanding factory farms, until environmental impacts are assessed and adequate regulatory measures are adopted for dealing with these impacts.
3.) Land application of animal waste should be based on sound standards for water quality protection. The Draft Strategy represents a big step forward in that both USDA and EPA now acknowledge that land application of animal waste from factory farms should be regulated. The Draft Strategy, however, depends heavily on USDA Natural Resources Conservation Service (NRCS) standards as the basis for Clean Water Act permits for factory farms, including the standards for land application of animal waste.
These NRCS standards, however, may vary greatly from county to county and are in need of significant revision and national guidance from USDA on their application. Although the Draft Strategy calls for Comprehensive Nutrient Management Plans for factory farms with permits, the Draft Strategy provides little detail as to what standards will actually govern the content of these plans.
The Draft Strategy should clarify that the standards for Comprehensive Nutrient Management Plans will include both nitrogen and phosphorus limitations, based on water quality protection, for land application of factory farm animal waste. The Draft Strategy should also clarify the relationship between EPA's effluent guidelines for land applied animal waste and the NRCS technical standards for nutrient management. All permitted facilities should have a Comprehensive Nutrient Management Plan, which the public can review before the permit is approved and whose implementation is a fully enforceable condition of the permit.
4.) Impose legal liability and financial responsibility for factory farm pollution on vertical integrators. Vertical integrators are the processing companies, which often own the animals raised on factory farms and dictate operating conditions on the factory farms. The vertical integrators are the fat cats in the factory farm system, but the Draft Strategy allows vertical integrators to dodge any financial or legal responsibility for a factory farm system that has made them billions of dollars in profits.
The entire financial burden for dealing with factory farm pollution
in the integrated systems falls on contract farmers and the taxpayers.
This is a double blow for independent livestock producers who must compete
with companies that can dodge financial responsibility for the problems
they cause and who will also pay taxes to subsidize the costs of cleaning
up the mess left by the factory farm production system.
The Draft Strategy should require that vertical integrators who own
the animals in factory farms and/or dictate the conditions for operation
of factory farms be legally liable and financially responsible for factory
farm pollution.
National Campaign for Sustainable Agriculture P.O. Box 396 Pine Bush, NY 12566 P: 914-744-8448; F: 914-74-8477 campaign@magiccarpet.com