"Stop Factory Farm Pollution and Promote Sustainable Livestock
Production"
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 the
1,000 animal units. Both USDA and EPA acknowledge in the draft strategy
that --
1. factory farm operations are a source of significant surface and
ground water
pollution problems and risks.
2. currently about 10,000 of these large-scale, factory farms are
operating
without permits required under the Clean Water Act.
Many animal feeding operations pose unacceptable risks to family farms,
the environment, the health of rural communities, and to the water
resources upon which both rural and urban communities depend.
WHAT YOU CAN DO
1. Submit individual comments on the draft strategy. The draft
strategy is available on the web at <www.epa.gov/cleanwater/afo/> 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.
2. Go to the Public Hearings (called "listening sessions") in your
region. Check the website for the Clean Water Network <www.cwn.org> and
click on "what's new." 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.
3. Contact your local media: newspapers, radio, television . . . 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
What Needs Changing in the Draft Strategy:
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 opportunitiy 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 waterhsed 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 responsiblity 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.*
FACT SHEETS AVAILABLE
1. environmental degradation and public health threates from factory
farm poll.
2. sustainable alternatives to factory farm animal production
3. environmentally sound standards for the land application of animal
waste
4. the factory farm quagmire: an overview of all factory farm problems
5. a sustainable agenda for the research plan of the USDA-EPA unified
national
strategy for AFIs: pollution prevention, not mitigation and
clean-up
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