Forwarded by Jane Clark at [log in to unmask]
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Sierra Club Action Daily
Vol. II, #244
August 11, 2000

TAKE ACTION: PROTECT OUR WATER FROM ANIMAL FACTORIES

The EPA is in the process of developing a "Guidance Document" for a
permitting
system for large concentrated animal feeding operations (CAFOs). These
massive
animal factories have fouled America's water and air from coast to coast,
and
have run family farmers off the land. Several court cases have clearly
found
that these facilities, including land application of wastes, are to be
regulated
under the federal Clean Water Act.

But the US EPA seems not to understand the import of the court decisions or
the
impact of the CAFOs on water quality.  There are three major positions that
the
Sierra Club (and allied groups) have been asserting:

1) Every CAFO with more than 1000 "animal units" (2500 hogs, 30,000
chickens,
and 750 dairy cows) must OBTAIN a federal wastewater discharge permit.

2) The permits must contain binding, enforceable and water-quality
protective
conditions.

3) CAFOs must land apply wastes at agronomic rates, as determined by a soil
test
and the optimal rate of growth (or production) of the specific crop. (EPA
is
proposing to allow rates of application based on "soil assimilation" which
essentially means wastes can be applied right up to the point where runoff
occurs).

Please call EPA Administrator Carol Browner at 202-564-4700  (FAX -
202-501-1450) and urge her to issue a Guidance Document incorporating the
above
points.

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