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E-M:/ Report on CAFO NPDES permit hearing, Part 2 of 3

Part 2 -- refer to part 1 for background:


-          Requiring standards and prohibiting practices that fail

o        Janet Kauffman of ECCSCM talked about the critical need to require professional inspections of lagoons on an annual basis, citing the recent failure of a waste lagoon in New York that caused catastrophic problems.  Janet noted one of the biggest problems that has been disclosed through the years of monitoring by ECCSCM which is that field tiles are a major source of contamination.  She also called for the elimination of winter spreading or spreading of wastes on no till fields, which would prevent incorporation into the soils.  Storage facilities for these operations are required to have six months storage which should allow for waste to be spread only when conditions are acceptable.  She called for requiring all facilities to apply for individual permits because of impacts, and that because of these facilities agriculture has become one of the worst polluters of surface water today.

o        Leland Townsend and Sandy Nordmark, both speaking on behalf of the Farmers Union, covered an extensive list of the types of practices and designs that are critical for requiring of any industrial livestock operations.  Leland read the policy of the National Farmers Union (found on page 57 of the national policy book at http://www.nfu.org/documents/policy/2005_nfu_policy_e.pdf ).  Sandy raised specific issues relating to Michigan, calling for strong regulatory and permitting requirements consistent with MDEQ’s overall policies.  She noted as well that the 2002 Census of Agriculture found that there are 53,000 farms in Michigan, but that the approximately 200 to 250 CAFOs in the state have historically had an impact environmentally disproportionate to their numbers.  And for those saying this is the demise of agriculture, she reminded them of banning DDT which had similar reactions.  NPDES permits are not on the list of threat to the continuing existence of farming, she said.

o        James Clift of Michigan Environmental Council analogized the regulation of industrial livestock operations to that of other industries, saying that these facilities are unique in being allowed to take a point source and turn it into a non-point source site.  Visual observation would be laughed at by for any other type of regulated facilities, he noted.  He called on requiring testing at the edge of fields during rain events to truly monitor the pollution from these facilities.

o        Helen Leblanc of Williamston noted that the DEQ should be assuring that the regulation of these industrial livestock operations is preventing pollution, because that is what this is supposed to be about. 

o        David Holtz of Clean Water Action praised aspects of the proposed permit that are good, including requiring permits for all industrial livestock operations and requiring field by field assessments.  But he raised concern that Michigan should have model legislation for these types of operations, and this proposed permit falls short, followed by providing specific examples.

o        Jan O’Connell of Grand Rapids also raised similar concerns about the failure of the require critical information to be provided with the permit application, the need for better monitoring and disclosure of those findings.


-          Other categories

o        James Hurst from United for Justice said that the issuance of permits for industrial livestock operations gives our states stamp of approval for these facilities.  He noted that the industry has been benefiting from society’s good will toward traditional farmers even though these are not at all the same.

o        Judith Hooper, a Ferris State University faculty member, discussed a paper by Marlene Halverson (http://www.awionline.org/farm/halverson.pdf ) that she read a few years ago which began her education about these issues, and that she has continued to research the issue since.  She raised concerns about the health and ethical aspects regarding the welfare of animals in industrial livestock operations.

o        Jim Roland of Port Austin talked about the experience he and his neighbors have as their beach, Oak Harbor Beach, has been covered with sludge that tests at 2.5 times the allowable E.coli levels, about people getting sick, about dissolved oxygen levels at zero, and how Sierra Club’s Lynn Henning had showed up there last week and helped to identify the likely source (a drain running into Lake Huron).  He noted another 4000 head dairy is going in and how concerned he is about this. 




Anne Woiwode, State Director

Sierra Club Mackinac (Michigan) Chapter

109 E. Grand River Avenue, Lansing, MI 48906

517-484-2372   fax 517-484-3108

Enjoy, Explore and Protect -  www.michigan.sierraclub.org