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Factory Farming The Health and Environmental Risks.

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Presentation on theme: "Factory Farming The Health and Environmental Risks."— Presentation transcript:

1 Factory Farming The Health and Environmental Risks

2 Overview Current regulatory frameworkCurrent regulatory framework ShortcomingsShortcomings Federal CAFO regulationsFederal CAFO regulations IDEM proposed CAFO regulationsIDEM proposed CAFO regulations Indiana State Chemist proposed manure use and distribution regulationsIndiana State Chemist proposed manure use and distribution regulations HEC recommendationsHEC recommendations How to get involvedHow to get involved

3 Definitions: Industrial Scale Livestock Production 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 laws or rules.Any operation that causes a violation of water pollution laws or rules. Concentrated Animal Feeding Operation (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)

4 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)

5 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

6 Pathways to Pollution 40 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

7 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

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11 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

12 Water Quality Standards for E. coli 235 colony forming units/100 ml maximum safe for recreational use One study of dairy waste found: 110,000 cfu /100 ml in field tiles the same day 38,000 cfu/100 ml 6 days later.

13 Many Indiana waterways are polluted

14 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

15 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

16 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)

17 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%

18 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)

19 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

20 IDEM Rulemaking Design Standards Nutrient Management Plans Facility Closure Transitions Public Notice and Comment

21 Design Standards Prohibit construction of manure lagoons over mines Require additional protection for manure storage facilities in karst terrain

22 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

23 Nutrient Management Plans Adds phosphorous as a limiting factor for manure application rates Annual manure analysis for all manure types

24 HEC’s Choice Require water monitoring as part of NMP Control pathogens Incorporate Best Control Technology limitations

25 Facility Closure IDEM intends to clarify guidelines Require a closure certificate

26 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

27 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.

28 HEC’s Choice Concern over ability of CAFO to self regulate IDEM should require NPDES permits for all CAFOs

29 Public Notice & Comment Forty (40) day comment period for adjacent landowners

30 HEC’s Choice Public, not just adjacent landowners, should be provided with an opportunity to comment on permits

31 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 in 29 Indiana counties by adopting a more stringent standard or providing a waiver to counties who have more stringent ordinances

32 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

33 OISC-Restrictions on Use & Distribution Staging (temporary storage) 72 hours if not covered 90 days if covered Incorporates Setbacks currently in IDEM rule

34 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

35 Remaining Concerns Air emissions Rural economic development Antibiotics Algae blooms Costs to the taxpayers

36 What You Can Do Change your consumer habits Become a HEC Water Warrior Inform HEC staff of local developments Educate others, including decision makers

37 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

38 Questions and Discussion

39 Citizen’s Guide to Lobbying

40 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

41 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!

42 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

43 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

44 Setting Up a Meeting in Your District Call your legislator at local office or home; ask to meet in convenient locationCall your legislator at local office or home; ask to meet in convenient locationOr Approach him/her after community eventApproach him/her after community event

45 At the Meeting Bring an extra copy of the bill you will discuss or informative materials about the issue to support your positionBring an extra copy of the bill you will discuss or informative materials about the issue to support your position Be on time!Be on time!

46 Follow-up Email or letter to legislator with thank you Report on meeting to HEC staff

47 How to Contact Your Legislator By phone: Indiana State Senate-Indiana State Senate- 317.232.9400 or 800.382.9467 Indiana House of Representatives- 317.232.9600 or 800.382.9841Indiana House of Representatives- 317.232.9600 or 800.382.9841

48 How to Contact Your Legislator If you must leave a message, be sure to include: Your nameYour name Your address & cityYour address & city Please (support/oppose) issue or bill number XPlease (support/oppose) issue or bill number X

49 If by written message: An e-mail will be most timely Find legislator’s e-mail addresses at www.in.gov/legislative www.in.gov/legislative A written letter must be sent promptly as the legislative session moves quickly How to Contact Your Legislator

50 Written letter: The Honorable ____ Indiana Senate / Indiana House of Representatives 200 W. Washington Street Indianapolis, IN 46204

51 Questions and Discussion

52 Find us on Facebook.com/hecwebtwitter.com/hec_ed and at hecweb.org

53 Thank you!


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