Factory Farming
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Transcript of Factory Farming
Factory Farming
The Health and Environmental Risks
Overview• Current regulatory frameworkCurrent regulatory framework• Shortcomings Shortcomings • Federal CAFO regulationsFederal CAFO regulations• IDEM proposed CAFO regulationsIDEM proposed CAFO regulations• Indiana State Chemist proposed Indiana State Chemist proposed
manure use and distribution manure use and distribution regulationsregulations
• HEC recommendationsHEC recommendations• How to get involvedHow to get involved
Definitions:Industrial Scale Livestock
ProductionConfined Feeding Operation (CFO)Confined Feeding Operation (CFO)• 300 cattle300 cattle• 600 hogs or sheep600 hogs or sheep• 30,000 fowl30,000 fowl• Any operation that causes a violation of water pollution Any operation that causes a violation of water pollution
laws or rules. laws or rules.
Concentrated Animal Feeding Operation Concentrated Animal Feeding Operation (CAFO)(CAFO)
• 1000 cattle or equivalent1000 cattle or equivalent• 2500 hogs or sheep2500 hogs or sheep• 100,000 fowl100,000 fowl(Source: Indiana Administrative Code 327 IAC 15 and 16; I.C. 13-18-10)(Source: Indiana Administrative Code 327 IAC 15 and 16; I.C. 13-18-10)
Performance standards• A confined feeding operation shall be managed to
avoid an unpermitted discharge into waters of the state.
• Minimize non-point source pollution• Design, construct and manage waste management
systems to prevent discharge• Stage and apply manure in a manner that does not
threaten the water supply(Source: 327 IAC 16-3-1)(Source: 327 IAC 16-3-1)
Enforcement• CFO may opt-out of regulation by declaring no discharge or
proposal to discharge• General or individual NPDES permits, must be renewed
every five years• Nutrient (Manure) Management Plan, not an enforceable
part of the permit• Soil & manure samples taken by operator• Records kept on-farm (not public)• Inspectors visit production areas but do not routinely visit
land application areas during or after manure spreading
Real problem is lack of funding and political will
Pathways to Pollution40 spills in 2008, 295 spills in the last 5 years
(IDEM)-lagoon overflow-pit overflow-transportation-manure stockpile or staging area-improper land application (most spills occur during land application)-equipment breakage-deliberate dumping
Report a Spill• Enters waters of the state• Crosses property boundaries• Operation not managed in a manner that
prevents a threat to waters of the state• Threatens to damage waters of the state
Shortcoming of Current Program
• No consideration of air emissions and stormwater runoff.• Inspections focus primarily on production area• Fertilizer rates for nitrogen allows overloading of
phosphorus• No consideration of pathogen content of manure• No consideration of existing pollution• Nutrient (Manure) Management Plan is NOT enforceable
part of the permit • Manure management information is not available to the
public – treated as proprietary
Water Quality Standards for
E. coli 235 colony forming units/100 ml
maximum safe for recreational useOne study of dairy waste found: • 110,000 cfu /100 ml in field tiles the
same day• 38,000 cfu/100 ml 6 days later.
Many Indiana waterways are polluted
Indiana’s biggest pollution problems
• E. coli 822 water bodies• Biotic communities 505• Dissolved oxygen 140• Nutrients 98• Phosphorus 50• Algae 20• Taste & odor 12
Impacts of Industrial Livestock on Rural
Communities• Property values• Quality of life• Rivers and streams unsafe• Limited opportunities for other
economic development• Reduced opportunity for tourism
and recreation
Impacts on Public Health
• Poor Air & Water Quality• Neighbors get sick, suffer longer• Workers may carry antibiotic resistant
pathogens to general population• Many county health departments
struggling with MRSA (methicilllin resistant Staphlycoccus aureus)
Antibiotics as Growth Promoters
• 70% of all antibiotics used in the U.S. are fed to livestock at sub-therapeutic doses
• Antibiotics increase growth rate by 2-10%
New Federal Rules• CAFO that discharges or proposes to discharge must
apply for an NPDES permit• Unpermitted CAFOs must certify that they do not
discharge or propose to discharge• Nutrient Management Plan must be submitted with
application for individual NPDES permit• Authorities must review NMP and allow public
notice and comment• CAFOs can substitute best management practices
that will result in no discharge rather than approved containment structures if it can demonstrate that the system will comply with effluent limitations
• Water quality based effluent limitations may be required from land application and production areas that are not exempted as “agricultural stormwater”
• Best conventional technology must be used to control fecal coliforms (E. Coli)
Indiana
• IDEM developing new rules for CAFOs• (LSA Document #09-213)• Indiana Register, April 8, 2009• Office of the Indiana State Chemist (OISC)
developing rules to address the distribution and use of manure as fertilizer
IDEM Rulemaking
• Design Standards• Nutrient Management Plans• Facility Closure• Transitions• Public Notice and Comment
Design Standards
• Prohibit construction of manure lagoons over mines
• Require additional protection for manure storage facilities in karst terrain
HEC’s Choice
• Prohibit location of CFOs and CAFOs in karst terrain and floodplains
• Use of groundwater monitoring device to ensure that drinking water is not being contaminated
• Incorporate best management practices such as setbacks from waterbodies and wetlands
Nutrient Management Plans
• Adds phosphorous as a limiting factor for manure application rates
• Annual manure analysis for all manure types
HEC’s Choice
• Require water monitoring as part of NMP
• Control pathogens• Incorporate Best Control
Technology limitations
Facility Closure
• IDEM intends to clarify guidelines• Require a closure certificate
HEC’s Choice
• Comprehensive closure plan should be required as part of the permit
• Operator should be required to provide financial assurance for required closure activities
Transitions
• CAFO owners who certify that they do not discharge or propose to discharge can avoid the need for an NPDES permit by transitioning from a CAFO designation to a CFO designation
• All operations must have a general CFO permit.
HEC’s Choice
• Concern over ability of CAFO to self regulate
• IDEM should require NPDES permits for all CAFOs
Public Notice & Comment
• Forty (40) day comment period for adjacent landowners
HEC’s Choice
• Public, not just adjacent landowners, should be provided with an opportunity to comment on permits
OISC Rulemaking
Must comply with more stringent rule when there is
overlap between IDEM and OISC
-HEC believes that jurisdiction must be better defined-Which agency will be responsible for inspections and
enforcement-OISC should acknowledge the best fertilizer regulation practices
employed in29 Indiana counties by adopting a more stringent standard or
providing awaiver to counties who have more stringent ordinances
OISC-Recordkeeping
Requires OISC to maintain records for two years
-Permits are renewed every five years; therefore, OISC should maintain records for five years-Records should be made public-Rule should include specific parameters for the type of information that will be maintained
OISC-Restrictions on Use & Distribution
• Staging (temporary storage) 72 hours if not covered
• 90 days if covered• Incorporates Setbacks currently in
IDEM rule
HEC’s Choice• Supports shorter staging time frames• Supports larger setbacks• Surrounding states have much more
stringent setbacks• Many Indiana counties have
ordinances requiring more stringent setbacks
• Include setbacks for land application• Proximity can be easily altered at the
least expense
Remaining Concerns
• Air emissions• Rural economic development• Antibiotics• Algae blooms• Costs to the taxpayers
What You Can Do• Change your consumer habits• Become a HEC Water Warrior• Inform HEC staff of local developments• Educate others, including decision makers
What You Can Do
Support laws that hold industrial agriculture
accountable:-provide comments to IDEM and OISC-advocate for setbacks-support industry financial assurance-support a ban on the use of antibiotics in livestock solely to increase feed efficiency and promote growth-Urge your Congressmen to support PAMTA
Questions and Discussion
Citizen’s Guide to Lobbying
A Few Good Points• Now (before the session) is great time to talk• Less frantic, more casual pace – more quality
interaction• In person meetings in the district are the
most effective type of contact• Legislators want to hear from constituents
Making Contact
• You have the chance to meet in a relaxed atmosphere in your local area—a big bonus!
• Remember: every visit has an impact!
Be effective
• Your credibility is important: only present accurate information!
• Provide compelling information; your job is to persuade
• You may not be an expert, but you can provide valuable information to legislators
• Local perspective important
Be informed
• Who are your legislators? • Know the facts about your legislator:
political party, occupation, leadership positions, legislative committee assignments
• Copies of bills• Find it all at Indiana General Assembly
Web site www.in.gov/legislative
Setting Up a Meeting in Your District
• Call your legislator at local office Call your legislator at local office or home; ask to meet in or home; ask to meet in convenient locationconvenient location
OrOr• Approach him/her after Approach him/her after
community eventcommunity event
At the Meeting
• Bring an extra copy of the bill you Bring an extra copy of the bill you will discuss or informative will discuss or informative materials about the issue to materials about the issue to support your positionsupport your position
• Be on time!Be on time!
Follow-up
• Email or letter to legislator with thank you
• Report on meeting to HEC staff
How to Contact Your Legislator
By phone:By phone:
• Indiana State Senate- Indiana State Senate- 317.232.9400 or 800.382.9467317.232.9400 or 800.382.9467
• Indiana House of Representatives- Indiana House of Representatives- 317.232.9600 or 800.382.9841317.232.9600 or 800.382.9841
How to Contact Your Legislator
If you must leave a message, be sure If you must leave a message, be sure to include:to include:
• Your nameYour name• Your address & city Your address & city • Please (support/oppose) issue or bill Please (support/oppose) issue or bill
number Xnumber X
If by written message:• An e-mail will be most timely• Find legislator’s e-mail addresses at
www.in.gov/legislative• A written letter must be sent promptly
as the legislative session moves quickly
How to Contact Your Legislator
How to Contact Your Legislator
Written letter:The Honorable ____ Indiana Senate / Indiana House of
Representatives 200 W. Washington Street Indianapolis, IN 46204
Questions and Discussion
Find us on
Facebook.com/hecweb twitter.com/hec_ed
and at hecweb.org
Thank you!