Friday, March 9th the EPA held a hearing on CAFOs at Sheman in Ames.
It was attended primarily by cattlemen. At one point someone asked all the
men who would have to go out of business to stand and approximately a
hundred did. If these regs succeed the EPA would require zero discharge
into groundwater and the cost of installing the liners is somewhere around
$60-70,000, according to what men standing near me were saying.
I gather that the companies who have maneuvered these men into this
position are not even thinking about helping bear the cost of making the
process environmentally safe.
Steve Veysey spoke about the need to preserve special places.
I mentioned the hazards created by too much phosphorus (encourages the
growth blue-green algae, some strains of which can produce potent toxins
that can kill a mouse in as little as two minutes, a dog in fifteen, other
toxins that will kill animals (including cattle) in a matter of days. I
asked what was being done to let producers know about the seriousness of
these hazards and a lady on the panel droned on about... The fact is they
only say there is too much phosphorus and nitrogen which can cause algal
blooms that aren't healthy, but they don't tell the whole gruesome story.
It's time to get it out there.
One CAFO owner who spoke against the regs is responsible, I am told, for a
20-25 mile fishkill below his facility.
I am troubled by several things here. One is that honest Iowans who have
lived on the land for as many as five generations are being forced to
choose between selling their land and polluting it. In answer to one
question about the regs, an EPA rep told the questioner that the answer to
his problem was to confine more of his animals. The fact that
circumstances, including regs are conspiring to make producers raise their
animals in unnatural settings away from fresh air and sunshine I find
deeply disturbing.
A man from the cattlemen came up and spoke to me as I was leaving. His
parting remark was that water running off a prairie area was compared to
water running off of row crops and it was found that there was more
phosphorus in the prairie runoff. I didn't have the presence of mind to
explain the difference in the amount of water that would run off of
rowcrops compared to prairie and how that might mean a very different
figure when you consider the actual amount of phosphorus being added to the
stream.. Of course, the equation being considered that day was not the
difference between rowcrops and prairie.
Below, are my notes from the meeting. If anyone spots an error, let me know.
Peggy Murdock
EPA presenters began by affirming the value of agriculture. Then they
began describing the program.
Under the proposed guidelines 95% of the Animal Feeding Operations (AFOs)
would be unregulated and only 5% regulated, however this would regulate 60%
of the manure.
60-65% manure generated by CAFOS is in excess of the operations
needs. This excess manure would have to be transported off site and
disposed of elsewhere.
It is estimated that 12,000 facilities should have NPDES permits, however,
only 3,000 do at present.
Nationwide, 73 counties have too much nitrogen and another 160 have too
much phosphorus.
The proposal would Include all poultry operations, set standards for
heifer and swine operations and require CAFOs to apply for a permit.
The regulations should be easy to understand, flexibile, and provide for
accountability.
1st core proposal is similar to current regulations.
A operations with more than 1000 animal units would be considered CAFOs
The three tier proposal works like this.
Largest 1000+
Middle 300-1000
Smallest would be under 300 animal units. These would be regulated only if
found to cause a problem
In the two tier structure the threshold dividing the group would be at 500
animal units.
It was pointed out that the three tier structure is more flexible.
There would performance standards and regulations about how manure is
applied to fields.
The regulations would distinguish between an existing operation or new
source. A new operation would be defined as one that or is undergoing
expansion. Praise Be! Hope that one gets through.
Operations would have definite performance standards to meet and could
choose any technology that will achieve them.
Beef and dairy requirements would be for a 25 year 24 hr design with a zero
discharge to groundwater standard, requiring the installation of liners and
impermeable pads beneath stockpiles.
Swine operations would be required to have a zero discharge with no
overflow allowed for a storm event.
These facilities don't need to capture contaminated stormwater because the
animals are completely housed.
The source requirements for beef and dairy would continue to be the same.
Swine requirements add only the zero discharge to groundwater provision.
There would be additional controls for pathogens in wastewater and manure
which were not described.
Land application would be addressed by having each operation develop site
specific plan that takes into account other sources. This an be part of a
comprehensive nutrient plan. A 100+ foot setback would be required from
surface waters or conduits to surface waters such as sinkholes. the
regulation would not this land to be taken out of production.
The majority of manure would be transported off the site. This could be
accomplished by reauiring transfer to recipient who says they intend to
apply it properly, understand their responsibilities and intend to do it
properly. the CAFO would give a copy of the manure analysis to the
recipient and a brochure about proper handling. This requirement could be
waived in states that have a plan to take care of this.
The other alternative is to maintain a record of how the manure was
distributed and who it was distributed to. The EPA does not want to create
a disincentive for people to take the manure.
The challenge is how to provide for accountability and make sure the manure
is used for ag purposes and not disposed where it is not needed.
Co-permitting will be required where processors exercise control over the
operation. Co-permitting would be waived in states where there is an
adequate plan to deal with this problem.
There is a 120 day comment period closes on May 14th. The provisions should
be signed by the administrator by September 15, 2002
You can send your comments to [log in to unmask], however, it would be
more effective to mail them. The address is:
CAFO Proposed Rule
USEPA Office of Water
Engineering and Analysis Division (4303)
1200 Pennsylvania Avenue NW
Washington, D. C. 20460
http://www.epa.gov/owm/afos/proposedrule.htm gives the text of the proposed
regulation as announced in the Federal Register
http://www.epa.gov/owm/afos/rule.htm is where to find a factsheet
describing the proposed rule.
http://www.epa.gov/owm/afos/rule.htm is where to find the schedule of
public meetings.
There is a dedicated number for questions. It is (202) 564-0766
More information can be obtained over the web at epa.gov/
It's in your best interest to send comments in writing
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