The announcement by the Michigan DEQ Water Bureau that they have issued NPDES permits to the Waldron Dairy CAFO and the Bustdorf Dairy CAFO was a disturbing development in these long fought permit battles. Most troubling was that the final permits issued were dramatically changed and included novel new provisions that have never been subject to public scrutiny either through draft NPDES permits or proposed regulations. It appears that DEQ screwed up by failing to understand their apparently well-intentioned “fixes” in these permits may in fact cause many new unanticipated problems that the public should have had a chance to comment on.
In particular, the permits both require 12 months worth of CAFO waste storage be available at these CAFOs. What’s wrong with this picture? More storage does not mean that there is any treatment of the waste, and in fact will result in even worse problems than the current requirements for six months storage at each facility. Untreated wastes will be accumulated in an even larger amount, in larger lagoons, with no attention to air emissions from lagoons nor from the application of these putrid, fermented wastes onto farm fields. The CAFOs will be required to clear only 6 months worth of storage room out of the 12 month lagoons in Nov-Dec each year, meaning that the wastes in the bottom of these storage structures could sit for years, concentrating pollutants and potentially leaking to groundwater through the clay liners required for these facilities. It will be quite conceivable that a CAFO could be emptied of animals and STILL have a year’s worth of waste applications in their lagoons.
We and I am sure many others are scrutinizing these new permits now, and I’m afraid we expect to find many other similar problems. Unfortunately, with the issuance of the permits as opposed to seeking additional comment on these changes, the DEQ has taken away the public’s forum to review and comment without going through legal challenges.
Anne Woiwode, State Director
ph: 517-484-2372 web: www.michigan.sierraclub.org