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E-M:/ Land Use Institute corrects MDA



------------------------------------------------------------------------- Enviro-Mich message from Patty Cantrell -------------------------------------------------------------------------


Land Use Institute Corrects Agriculture Department
February 19, 1999 Contact: Patty Cantrell, 616-882-4723 ext. 18


The Michigan Land Use Institute stands by the details and the conclusions of its investigation of the Michigan Department of Agriculture’s Right-to-Farm Complaint Response Program. The MDA has taken issue with a few of the particulars. The Institute’s response to each criticism is listed below for clarification of the facts in question.

MDA's Feb. 16 release can be found at:
http://www.mda.state.mi.us/news/0299/021699.html

For a copy of the Institute's report, please call Patty Cantrell at 616-882-4723 ext. 18 or write to the Institute, PO Box 228, Benzonia, MI, 49616.

Point-by-Point Response

Inaccuracy?
The Department of Agriculture claims the Institute’s accounting of taxpayer money spent to support Michigan State University programs that encourage the industrialization of livestock agriculture is incorrect.

You decide.
In 1993-94, the Legislature appropriated $74 million for the Animal Livestock Initiative, as the MDA states. Every year since then, however, the Initiative has received an additional $4.5 million out of the state’s base budget. That adds up to $96.5 million by 1999, and the subsidy continues to grow.

Research funded by the Initiative covers drug residues, microbial contamination and other production and processing concerns in addition to “how to” raise livestock in factory confinement facilities. Unfortunately, such research is made more necessary because of polluted confinement conditions, which require unprecedented levels of drug use in livestock production and which provide prime habitat for thriving populations of dangerous microbes.

Inaccuracy?
MDA claims it is incorrect to say that Michigan seeks exemption from forthcoming federal regulations for industrial-scale livestock production.

You decide.
Michigan is indeed leading a coalition of Midwest states that is proposing a “functionally equivalent strategy” for regulating animal feeding operations. The “model” for this strategy is Michigan’s existing oversight and technical assistance scheme, which the Institute’s investigation found to be wholly inadequate because of the central role of the Right-to-Farm Complaint Response Program.


MDA fails to apply technical standards and specifications and to heed advice from technical assistance experts when it responds to complaints. As a result, pollution persists and producers run afoul of the state’s “stiff enforcement measures.” When manure spills or builds up to emergency levels in waterways, the Department of Environmental Quality must consider using its power to levy fines of up to $25,000 per day and to require producers to invest in costly, after-the-fact remediation.

Note: Michigan is the only state in EPA Region 5 (IL, OH, IN, MN, MI, WI) that has no proactive permitting or inspection process. The current inadequate, reactive response program is the only insurance rural communities have that livestock factories operate responsibly. The MDA and Michigan Farm Bureau are proposing a certification process for larger livestock operations. It would, however, also be voluntary and guided by the same inadequacies of the complaint response program.

Inaccuracy?
The MDA interpreted mention of “hog hotels” to mean the Institute was insisting that Michigan was a haven for ultra-large farms.


You decide.
The word “haven” or anything like it does not appear in the Institute’s report. The Institute does call attention to a well-recognized trend in livestock agriculture that is now showing up in Michigan and which promises to grow, in part, because of the state’s well-funded Animal Agriculture Initiative.

While the number of operations with 1,000 or more hogs dropped as a whole since 1992, the category of operations with 5,000 and more hogs increased by 50 percent.

Furthermore, the Michigan Agricultural Statistics yearbook for 1997-98 (as revised to reflect new information from the recent 1997 Census of Agriculture) shows some clear shifts in size distribution of hog operations in recent years.

While smaller operations decreased, operations with 1,000-1,999 head increased 15% in one year, 1997-98, and operations with 2,000-4,999 head increased 20% in the same year. (Revised Table 11.11 available from Michigan Agriculture Statistics Service.)

Inaccuracy?
The Michigan Department of Agriculture corrected the Institute’s statement that the MDA was one of the state’s largest agencies.

You decide.
The MDA is correct. It is the seventh smallest of 18 agencies. The Institute regrets not having re-checked that one fact out of hundreds that it reported correctly.

Inaccuracy?
The MDA takes issue with the Institute’s assessment of the Generally Accepted Agriculture Management Principles as “vague voluntary guidelines that allow any semblance of manure management to pass the department’s review.”
You decide. The principles do indeed refer producers to USDA, MSU extension, NRCS, and soil conservation district standards and experts. The problem is that MDA does not adequately or consistently use the standards, specifications, or experts in its responses to manure mismanagement complaints.
The fact that the principles do not require producers nor MDA to follow technical standards or advice is the basis for the Institute’s accurate conclusion. Actual complaint files indicate that, in fact, vague voluntary guidelines allow any semblance of manure management to pass the department’s review.

Inaccuracy?
MDA cites a 33 percent complaint referral rate from DEQ as evidence that the environmental experts of the state’s enforcement agency are not kept out of the response process.

You decide.
The Memorandum of Understanding between the two agencies requires DEQ to refer agriculture-related complaints to MDA unless - or until - they are an emergency.

It is this Memorandum of Understanding that the Department of Agriculture consistently cites in subtle protest letters to DEQ whenever Surface Water Quality Division staff attempt to interject some technical advice. The internal files the Institute reviewed clearly show many cases in which MDA rebuffed SWQ staff efforts to help solve a manure management problem before it reached emergency levels.

Call for Audit
The Michigan Land Use Institute and its four partners in this project -Michigan Environmental Council, West Michigan Environmental Action Council, Sierra Club, and Clean Water Action - continue to call on the MDA to immediately fulfill its obligations under existing law, such as using the technical standards and specifications cited in the Generally Accepted Agriculture Management Principles.

The coalition also calls on the Legislature to initiate an audit of MDA’s complaint response program; to establish a task force to use the results of the audit for developing appropriate, effective regulations for industrial-scale livestock operations; to appoint an ombudsman for rural neighbors of concentrated animal feeding operations in the meantime; and to reject new public policy (such as S.B. 205) that would preempt local zoning authority.




Patty Cantrell
Economic Analyst
616/882-4723 x18
patty@mlui.org

*************************************
MICHIGAN LAND USE INSTITUTE

"Careful research and reasoned advocacy
to protect the environment, enhance
economic opportunity, and support
vibrant communities."

P.O. Box 228
Benzonia, MI 49616
616-882-4723 /*\ 616-882-7350 fax
mailto:info@mlui.org


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