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Enviro-Mich message from Patty Cantrell <patty@mlui.org>


Dear Enviro-Michers:
The national Clean Water Network is alerting all those concerned about
pollution from livestock factories to call their U.S. representatives now
and urge them to sign on to an important letter from Congressman Evans

The letter calls for a stronger federal strategy for pollution prevention
at livestock factories, which have been plaguing rural communities
nationwide and are growing in Michigan.  The letter is in response to an
earlier letter from 36 members of the House Agriculture Committee asking
the EPA to weaken its Animal Feeding Operation (AFO) Strategy. 

Rep Vernon Ehlers (R-Grand Rapids, District 3) is a key vote and one of the
Reps. on a list of those most important for signing on.  The deadline is
quick - next Monday - because the AFO Strategy is
expected any day now.  

You can call Ehlers at 202-225-3831. If, for some reason, you can't get
through, call the main capitol switchboard and ask to be connected.  The
switchboard number is (202) 224-3121.

Below are copies of the letters to the Reps and of the letter to the EPA.
If you have any questions, please contact Merritt Frey, NRDC and Clean Water
Network at (202) 289-2392. 


March 2, 1999

Help Prevent Factory Farm Pollution

Dear Colleague:

Protecting our nation's water resources faces a new challenge with the
concentration of the animal feeding industry into fewer and larger
facilities.  Pollution from large-scale livestock, hog, dairy and poultry
farms poses a national threat to our drinking water, rivers, streams,
estuaries, and public health.  

Current efforts to control this pollution have been inadequate.  What
regulations exist generally occur at the state level resulting in
inconsistent state regulations that allow pollution to cross state
boundaries as large operations locate to states with weaker regulations.
The strongest federal authority has been the National Pollutant Discharge
Elimination System (NPDES) permitting process within the Clean Water Act
that requires operations to follow certain practices to reduce pollution.
However, the permits have not been widely issued or strictly enforced for
the large operations or confined animal feeding operations (CAFOs).  The
permits were also created nearly 30 years ago and no longer meet today's
environmental needs.  It is clear that the time has come to strongly and
fully implement the Clean Water Act.

Recognizing the jeopardy placed on our surface and ground water by CAFOs,
the United States Department of Agriculture (USDA) and the Environmental
Protection Agency (EPA) teamed up to produce the Unified Animal Feeding
Operations Strategy, which they are currently finalizing.  The strategy
includes voluntary and regulatory approaches.  For example, the strategy
encourages all operations to develop and implement a comprehensive nutrient
management plan and to develop proper land application methods to minimize
water pollution and to protect public health.  The strategy also expands
efforts to ensure that more operations are included under NPDES permits and
that the permit regulations are revised to reflect better management

As a representative from the nation's fourth largest pork producing state, I
understand how vital the animal feeding industry is to the economy.  But the
problems posed by these large operations - loss of small producers, lowered
property values, damage to the environment and public health - cannot be

Please join me in sending the letter on the reverse side to the USDA and EPA
in support of strengthening the Unified Animal Feeding Operations Strategy
and ensuring that large operations be accountable for the impact they have
on our communities.  For more information, please contact Lynh Nguyen in my
office at 5-5905.  


                                        LANE EVANS
                                        Member of Congress

                                                March 2, 1999

The Honorable Dan Glickman                      The Honorable Carol Browner
Secretary                                               Administrator   
U.S. Department of Agriculture                  U.S. Environmental
Protection Agency
Washington, D.C.  20250                         Washington, D.C.  20460

Dear Secretary Glickman and Administrator Browner:

We commend your efforts in creating the USDA/EPA Unified National Strategy
for Animal Feeding Operations.  Your cooperative approach recognizes the
importance of livestock, pork, dairy and poultry production to our nation's
economy while signifying the need to ensure that agricultural production is
done in harmony with the environment and public health.  

While we believe that the draft strategy is a step in the right direction,
it is clear that more must be done to quickly address the social and
environmental problems resulting from the concentration of the animal
feeding industry.  We are pleased that the draft strategy includes
requirements for large-scale confinement operations to adopt proper manure
handling, storage, and land application methods to reduce agricultural
runoff.   We also support your efforts to update and expand the number of
operations under the National Pollutant Discharge Elimination System (NPDES)
permits within the Clean Water Act.  However, as you finalize the strategy
we urge you to consider the following:

                  Promote sustainable agriculture.  Although we support the
Administration's request to increase funds for the Environmental Quality
Incentives Program, the primary source of USDA assistance for animal feeding
operation owners and operators, we are disappointed the draft strategy does
little to promote sustainable agriculture programs as pollution prevention
tools.  We urge that the final strategy give priority attention to directing
financial, research, and technical assistance to promote sustainable
practices.  Economically viable, environmentally sound, and socially
responsible, sustainable practices has helped many farmers and ranchers be
better stewards of their land through such methods as better soil erosion
and nutrient management.

                 Strengthen measures that allow for public involvement.
While we understand that USDA, EPA, and their state partners have limited
financial and personnel resources, protecting our nation's water resources
and public health should not be compromised.  Therefore, we recommend that
EPA require individual, rather than general permits, which not only allow
for site-specific, tailored requirements but also allows citizens to be
notified before a large or expanding animal feeding operation has been
established in their community.  Individual permits also provide citizens
the opportunity to comment on permit and permit-related information before
and after they are approved, such as the requirements outlined in a
facility's comprehensive nutrient management plan.  

AFO's Strategy
March 2, 1999
page two

                 Focus first on CAFO's.  Because of the increased threat to
water and air quality posed by the largest animal feeding operations, we
urge that efforts be focused first on permitting CAFO's before considering
smaller operations.  

                 Fully evaluate the impacts on all resources.  For better
accountability and to ensure compliance, permittees should be required to
monitor the ground and surface water quality surrounding their operations
and periodically report the results to permit authorities.  We also urge the
strategy to focus beyond water quality impacts to air, soil and wildlife

We understand the importance of state and federal programs that provide
voluntary incentives for animal feeding operations to meet environmental and
health safety standards.  However, inconsistent state regulations have made
it too easy for large operations to relocate to states with weaker
regulations.  Now is the time for the federal government to not only provide
conservation guidance but to also strongly and fully implement the Clean
Water Act to minimize fish kills, well water contamination, public health
and air quality problems affecting communities across the nation.

Once again, we commend your leadership on this crucial issue.  We look
forward to working with you on finding common-sense solutions and to timely
implement the Unified Animal Feeding Operations Strategy.  


Patty Cantrell
Economic Analyst
616/882-4723 x18


"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

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