The DNR is proposing new environmental standards for large open feedlots
and we have until Monday at midnight to weigh in on the rules. Please take the
time to read the following talking points and send some brief comments, in your
own words, to Gene Tinker at the DNR at
[log in to unmask]- We support the DNR's policy of
requiring each open feedlot CAFO
(concentrated animal feeding operation) to
apply for individual operating permits. General "one size fits all" permits
would be inappropriate for open feedlots and would violate the DNR's existing
agreement with the Cattlemen's Association
- We support the DNR's
proposed deadlines of 180 days' notice before building or expanding a feedlot.
This should not be shortened.
- We believe that all open feedlot CAFOs
should be required to submit their Nutrient Management Plans (NMPs) to the DNR
and that the NMPs should be public record. Allowing feedlots to write their own
NMPs and keep them private, as proposed in these rules, does nothing to protect
water quality. The public has a right to know whether factory farms are
over-applying manure, and these feedlots must be held accountable to the DNR and
the public for having protective NMPs.
- DNR should not allow any open
feedlot CAFO construction or expansion in Karst regions; allowing earthen or
formed manure basins in areas with fractured rock poses a serious threat to
groundwater and public health.
- DNR should prohibit artificial lowering
of the groundwater table to
accommodate a manure effluent basin. Past
experience with mechanical failure (pumps failing, etc.) shows that lowering of
the groundwater table does not adequately protect groundwater from manure
contamination.