Waterkeeper and National Organizations File Comments to Improve Statewide CAFO Permitting
Yesterday, Upper Missouri Waterkeeper and several national organizations submitted technical comments to the Department of Environmental Quality’s (DEQ) on the proposed renewal of the Concentrated Animal Feeding Operation General Permit (CAFO GP). Waterkeeper is recommending numerous improvements to the permitting requirements in order to protect Montana’s clean water resources from factory farm and feedlot pollution.
Montana’s General Permit for CAFOs sets rules and standards for the majority of industrial CAFOs in the state, which currently includes over 100 industrial operations. Factory farms discharge pollutants such as nitrogen and phosphorus, the two most pervasive pollutants degrading Montana’s waterways, as well as pathogens, heavy metals, and pharmaceuticals that threaten wildlife and public health in addition to water quality. These and other concerns make it ever more important that pollution from CAFOs is properly regulated, controlled, and disposed of properly.
“Concentrated feedlots and factory farms are a major source of waste and water pollution across the country. If we continue to operate under weak permit terms, Montana’s waterways will unnecessarily bear the brunt of pollution these industrial operations create,” said Guy Alsentzer, Executive Director of Upper Missouri Waterkeeper. “The majority of Montana’s main waterways are impaired by excessive nutrient pollution, and each summer we continue to see related side effects such as algal blooms and fisheries decline. Montana needs to update and strengthen its General Permit for CAFOs to ensure harmful pollution isn’t being discharged into our waterways.”
Upper Missouri Waterkeeper is recommending that the DEQ update the CAFO General Permit in four discrete ways:
- Implement mandatory monitoring of potential CAFO discharge areas, including downgradient locations of production and waste/manure/mortality storage areas. Currently, the CAFO GP lacks any monitoring that would ensure zero discharge of pollution, despite federal monitoring requirements.
- Require more detailed criteria for waste containment structures. DEQ should prohibit the placement of waste storage facilities within 100 year floodplains or areas with high groundwater to ensure CAFOs won’t degrade local ground or surface water.
- Disapprove any permit or waste disposal that is directly adjacent to streams that are sensitive to pollution or already impaired by excessive nutrients. The current GP has little discussion about where approved permits are located.
- Ban winter and wet-weather manure application. Despite the proven risks of runoff and water contamination from winter manure disposal, the GP still allows the practice.
Waterkeeper will continue to work to ensure that DEQ brings state CAFO regulation in line with the federal Clean Water Act and works to require polluters to follow permits, limit discharges, perform regular monitoring, and protect our clean water resources.