--- begin forwarded text From: Ken Midkiff [mailto:[log in to unmask]] >Sent: Tuesday, September 12, 2000 7:52 PM >Subject: Big Egg Producers - EPA set to cave in - Sept. 22 comments >deadline > >Clean Water folks: > >Well, while our attention was on the Guidance Document, new regs, and >effluent guidelines for CAFOs, the EPA was cutting a deal with the United >Egg Producers to give these folks "regulatory flexibility" under what is >called Project XL. > >What this means in reality is that a General Permit will be given to ALL - >even the very largest - Egg Laying Operations in exchange for a promise to >adopt certain "environmental management systems". But, Project XL is not >designed to achieve regulatory compliance, only to implement certain >procedures. > >Here is EPA's line of rationalization: "The United Egg Producers came to us >and asked that they be allowed to develop a program that would clean up >their industry. They are good guys that want to do the right thing...and if >EPA and UEP make this agreement, EPA can focus on the problem CAFOs and not >have to deal with Egg Producers." > >This is a load of unmitigated crap. > >The facts are that large egg production facilities are the worst polluters >around. We have three such facilities in Missouri and all are currently >involved in some type of enforcement actions by the State. Each of these >has from 1.3 to 1.5 MILLION laying hens - two use wet-handling systems for >the houses (open pits, sprayfields) and all use egg-washing operations that >results in chicken shit and broken eggs in wastewater discharges. Johnson >County Egg (Rose Acre owned) was issued 5 NOVs for discharging to waters of >the state without an NPDES permit. > >Two of these are owned by Rose Acre "Farms", Inc. of Seymour, IN. Rose Acre >has other facilities in Iowa and Indiana, and likely other midwestern >states. > >We have all heard of Buckeye Egg in Ohio...and their horrible record. The >only thing that distinguishes Buckeye from any other massive laying facility >is that they got caught - citizens pressured the Ohio agency and Region V >EPA to do something. Buckeye's pollution is probably the norm for large egg >production facilities. EPA would rather pretend that it is the exception. > >We need to get comments in to EPA - ASAP, right now, and immediately. Let >them know that giving this pass to the egg producers is completely and >totally unacceptable. > >Points to make: > >-Egg producers have not come forward "voluntarily" to be good neighbors. >The only reason they're trying to get exemptions via Project XL is because >the state and the feds - and citizens groups - are beginning to crack down >on CAFO polluters. > >-There are no provisions in XL to reach environmental compliance. >Environmental management systems make no guarantee that state and federal >laws and regulations will be complied with... > >-NO environmental groups were involved in the development of Project XL - >the alleged environmental participants were a couple of think-tanks (one >from DC and the other in Indiana). > >-We had been told all along that the "largest" CAFOs would be required to >get individual site-specific permits - now EPA proposes to grant General >Permits to the largest of the large. > >-Egg laying facilities are among the worst polluters in the agri-business >world. Buckeye is NOT an exception because of pollution, it is an exception >only because agencies and citizens enforced existing laws. > >Write to: all addressees are at: US Environmental Protection Agency > 1200 Pennsylvania Ave. N.W. > Washington, DC 20460 > >Richard Farrell >Associate Administrator >Office of Policy, Economics and Innovation (Project XL headquarters) > >J. Charles Fox >Assistant Administrator >Office of Water > >Steve Herman >Assistant Administrator >Office of Enforcement and Compliance Assurance > >NOTE: The Notice was printed in the Federal Register of Sept. 8 - we have >only two weeks from that date to get comments in: Comments are due on >**Sept. 22**. > >Thanks, > >Ken Midkiff --- end forwarded text -- ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ Rex L. Bavousett Photographer University of Iowa Our old name: University Relations - Publications Our new name: University Communications & Outreach - Publications 100 OPL, Iowa City, IA 52242 http://www.uiowa.edu/~urpubs/ mailto:[log in to unmask] voice: 319 384-0053 fax: 319 384-0055 ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - To get off the IOWA-TOPICS list, send any message to: [log in to unmask]