Forwarded from Jane Clark at [log in to unmask]
==================================================
Tell EPA to Crack Down on Factory Farms! Comment Period on Draft
Guidelines for Permitting Factory Farms Ends October 25

EPA is accepting comments on the draft guidelines for permitting factory
farms under the Clean Water Act through October 25, 1999. This guidance is
meant to tell states that are charged with implementing the Clean Water Act
permit program, who needs a permit and what those permits should look like.
This guidance is the first action taken by EPA and the USDA since they
released their Unified National Strategy for Animal Feeding Operations in
March. So, this is our first chance to really judge how committed the two
agencies are to cleaning up the factory farm mess.

Submit comments by October 25!

For a sample comment letter on the guidance, contact Merritt Frey at
[log in to unmask] or 202-289-2392. Basic points to make in your comments
are:

· EPA must stick to its pledge to require permits for ALL factory farms.

· Existing manure storage facilities, for both dry and liquid manure,
must be covered and lined in order to protect groundwater and surface
water resources and to reduce air emissions. The use of lagoons for
manure storage should be phased out.

· Land application rates for manure from CAFOs must be based on what the
crops on that site can actually use. The rates must be calculated using
a system that ensures consistency across the country.  Aerial spraying
of waste should be banned.

· Factory farms must not be cited in or near environmentally vulnerable
areas such floodplains, impaired waters, etc.

· Water quality monitoring at permitted facilities must be required to
ensure that our rivers, lakes and coastal waters are protected.

· Pollution concerns beyond surface water quality – air emissions,
groundwater pollution, and atmospheric deposition to surface waters –
must be addressed.

For a copy of the draft guidance, go to:
http://www.epa.gov/owm/afoguide.htm

Hurricane Floyd and Factory Farms: A Prime Example of Why Factory
Farms Don't Belong in the Floodplain

As you undoubtedly are aware, eastern North Carolina has faced an
unprecedented natural disaster. Extensive flooding from the rains of
Hurricane Floyd has displaced tens of thousands of people, destroyed
homes and businesses, and created a public health and environmental
crisis.

Early reports indicate that an estimated 100 animal waste lagoons were
submerged by floodwaters, another dozen or more breached, and the
farmers who can reach their lands are spraying manure into wetlands and
floodwaters to keep their lagoons from collapsing. Poultry and turkey
operations have also flooded, and their litter piles are being washed
into rivers. News reports estimate at least 500,000 hogs and more than 4
million chickens and turkeys have drowned. Reports are still coming in,
and the exact numbers are not known at this time – and perhaps never
will be known.

Clean Water Network members from North Carolina have been working hard to
assemble recommendations for learning from the lessons of Floyd. The
Network has distributed their recommendations to Congress and is working to
educate the press about the bigger picture lessons from Floyd. For more
information and for a copy of the North Carolina groups' recommendations,
contact Merritt at [log in to unmask] or 202-289-2392.

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
To get off the IOWA-TOPICS list, send any message to:
[log in to unmask]