This is forwarded from the Clean Water Network. There is a summit here in Ames. You might want to consider attending it. The Clean Water Network's suggestions for improving the permitting process follow the announcement. Peggy Murdock, Ames >Release No. 0409.99 > >Media Contact: Andrew Kauders (202) 720-4623 >[log in to unmask] >Public Contact: June Davidek (202) 720-3876 >[log in to unmask] > >CONSERVATION CHALLENGES FEATURED IN UPCOMING USDA FORUMS > > WASHINGTON, Oct. 13, 1999 - Agriculture Secretary Dan Glickman > today announced that the U.S. Department of Agriculture will hold a > series of regional forums in late October to discuss conservation issues > affecting America's farms, forests, and ranch lands. > > "The loss of prime agricultural land to development, the > restoration of salmon runs in the Pacific NW, the health of our > watersheds, and the future of private forestlands are some of the > challenges facing the Nation,"said Glickman. "The conservation and > forestry programs in USDA can play a stronger role in addressing these > and other issues affecting the health of our environment." > > "These forums will serve as a sounding board to assess what new > directions USDA should take to improve the nation's environmental > quality and the health of the American landscape." > > Regional forums are currently planned for Sacramento, Calif; > Portland, Ore; Denver, CO; Syracuse N.Y; and Atlanta, Ga. A > National Conservation Summit will be held in Ames, Iowa to discuss the > need for new direction in USDA's conservation and forestry programs. > > In recent years, USDA has expanded its conservation efforts beyond > curbing soil erosion to include farmland protection, improving water > quality, restoring wetlands, protecting soil productivity, managing > livestock manure, enhancing fish and wildlife habitat, and promoting > conservation in the nation's cities and communities. > > Each forum will be hosted by a senior USDA official and will > include a public comment session. Written comments from audience > members will be welcomed as well. The sessions will center on a > dialogue among Governors; members of Congress; farmers, ranchers, and > foresters; and state and regional representatives from agricultural, > environmental, consumer, and other groups and businesses regarding > conservation challenges, farm bill issues, and future budget needs. > > "The health of the land is critical to the wealth of our Nation. > The farmers, foresters, and ranchers who manage 70 percent of our > landscape can contribute greatly to our nation 's environmental health, > natural resource sustainability, and a sound economy," said Glickman. > "We look forward to frank, public discussions on conservation issues > that are important to us all." > Summit: > Ames, Iowa, Tuesday, Dec. 14 > Scheman Center > Iowa State University > Ames, Iowa > Contact: Lynn Betts, NRCS, Des Moines, IA, 515-284-4262, > [log in to unmask] Here are the Clean Water Network recommendations: The following list of management practices are recommended by the Clean Water Network's Feedlot Work Group for inclusion within the "Guidance Manual and Example NPDES Permit for Concentrated Animal Feeding Operations". Inclusion of these special conditions in all NPDES permits will help protect water quality and create a national level playing field for pollution control expectations at factory farms. For a more detailed set of recommendations on the permit guidance see "Clean Water Network General Recommendations for EPA's Model Individual NPDES Permit for CAFOs". To be inserted in section 3.3.2.2 of the Permit Guidance: To ensure that water quality is protected, at least the following special conditions shall be explicitly incorporated into all NDPES permits for CAFOs: 1.) Land application rates shall be restricted to the agronomic rate of uptake for the plants grown on individual sites. The rate of application of waste will be based on the pollutant most likely to cause pollution problems -- nitrogen, phosphorus, heavy metals, salts or pathogens for the particular site's soil types and runoff potential (including factors such as subsurface tiling). NOTE: The Work Group calls upon EPA to establish minimum national standards for land application that take into account soil types and runoff potential. 2.) Land application fields shall have buffer strips to protect ecologically vulnerable locations including lakes, rivers, streams, areas with agricultural drainage wells, highly erodible soils, and wetlands. 3.) No waste storage facilities shall be sited in ecologically vulnerable locations including lakes, rivers, streams, areas with karst topography, over agricultural drainage wells, in sandy or highly erodible soils, floodplains, and wetlands. 4.) Wastewater control and retention structures or holding pens, barns, or other confinement areas for new CAFOs and existing CAFOs that are intending to undergo significant expansion shall not be located in the 100-year flood plain or in wetlands. 5.) Ground and surface water quality shall be tested on a regular basis to ensure compliance with permit terms. Baseline ground and surface water monitoring shall be required before a new facility is constructed or before a new permit is issued for an existing facility. (NOTE: see the CWN's Feedlot Work Group's more detailed recommendations for site-specific monitoring details.) 6.) Waste storage structures shall be lined but not clay-lined and covered and any other measures necessary to prevent toxic air emissions shall be taken at liquid manure storage facilities. Dry manure storage structures shall be cement lined and covered. Waste storage facilities shall not be built below the level of the seasonal high water table. Liquid waste storage structures shall maintain a minimum of two feet of freeboard at all times. 7.) Waste must be injected directly into the soil. Aerial spraying of waste is prohibited. 8.) Manure application on ice, snow or frozen or saturated soil is prohibited. Manure may not be applied during any precipitation event or when precipitation is expected in the next 24 hours. 9.) Dead animals and animal parts must not be buried. Animals and animal parts must be rendered or composted within 24 hours or within 3 days if refrigerated in such a way as to ensure that public health is protected. 2.) Review of Comprehensive Nutrient Management Plans: EPA or the state water quality agency must evaluate the adequacy of the individual CNMP and evaluate whether the CNMP protects water quality. As the regulatory agencies charged with protecting our waters, EPA and the state water quality agencies have a legal duty to review these plans and approve them only if they ensure compliance with the Clean Water Act. These agencies must review a CNMP for adequacy whenever a permit is renewed. Prior to agency approval of a CNMP, public review and comment procedures must be followed and the agency must revoke the permit if the CNMP is not approved. NOTE: this position is exactly the same as the one nailed down this spring in our 19 page "model permit" for factory farms. 3.) "Functional equivalency" for state permitting programs. This discussion was mainly an update on where state requests' stood for this provision. Work Group members should be aware that the Oct. 1 deadline for application to have a state program declared "equivalent" to the federal Clean Water Act program seems to be a loose one even if your state has not yet applied, they may be allowed to at a later date. Rumors about states which have applied/are working on applying include: NC, OH, and MI. Less certain rumors include: IN and VT. AL was declared equivalent earlier this year. For more information on this convoluted issue, contact Merritt at [log in to unmask] or (better yet) 202-289-2392. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - For SC email list T-and-C, send: GET TERMS-AND-CONDITIONS.CURRENT to [log in to unmask]