To Iowa Sierrans:
My lobbying colleague for Sierra Club in Wisconsin, Caryl Terrell forwarded
this . . .
NATIONAL CAMPAIGN FOR SUSTAINABLE AGRICULTURE
URGENT ACTION NEEDED
STOP FACTORY FARM POLLUTION &
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 than 1,000
animal units. Both USDA and EPA acknowledge in the Draft Strategy that:
*factory farm operations are a source of significant surface and round
water pollution problems and risks
*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. See Details Below. 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, 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:
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 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 tandards
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.
FACT SHEETS AVAILABLE
Fact Sheet #1: Environmental Degradation and Public Health Threats
From
Factory Farm Pollution
Fact Sheet #2: Sustainable Alternatives to Factory Farm Animal
Production
Fact Sheet #3: Environmentally Sound Standards for the Land
Application of Animal Waste
Fact Sheet #4: The Factory Farm Quagmire: An Overview of All Factory
Farm Problems
Fact Sheet #5: A Sustainable Agenda for the Research Plan of the
USDA-EPA - Unified National Strategy for AFOs: Pollution Prevention, Not
Mitigation and Cleanup
STOP FACTORY FARMS!
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
National Campaign for Sustainable Agriculture
P.O. Box 396
Pine Bush, NY 12566
P: 914-744-8448; F: 914-74-8477
[log in to unmask]
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
John E.Peck c/o UW Greens, 731 State St., Madison, WI 53703
"The hottest places in hell are reserved for those who, in times of great
moral crisis, maintain their neutrality." - Dante
____________________________________________
Lyle Krewson
6403 Aurora Avenue #3
Des Moines, IA 50322-2862
[log in to unmask]
515/276-8947
515/276-6844 - FAX
____________________________________________
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