Talking Points: Public Comment on the Draft CAFO General Permit

Montana DEQ is revising its permit that addresses the water pollution and health impacts of Concentrated Animal Feeding Operations (CAFOs).  You can comment in-person at a hearing Monday August 19th or through written comments due Friday August 24th.

Livestock farming has undergone a significant transformation in the past few decades. Production
has shifted from smaller, family-owned farms to large farms that often have corporate contracts. Most meat and dairy products now are produced on large farms with single species buildings or open-air pens. Modern farms have also become much more efficient. Since 1960, milk production has doubled, meat production has tripled, and egg production has quadrupled.

New technologies have allowed farmers to reduce costs, which mean bigger profits on less land and capital. The current agricultural system rewards larger farms with lower costs, which results in greater profit and more incentive to increase farm size. Unfortunately it has also resulted in extremely concentrated impacts on landscapes and waterways, and the challenge of managing significant volumes of wastes and pollution issues.

What’s A CAFO?

A CAFO is a specific type of large-scale industrial agricultural facility that raises animals, usually at high-density, for the consumption of meat, eggs, or milk. To be considered a CAFO, a farm must first be categorized as an animal feeding operation (AFO). An AFO is a lot or facility where animals are kept confined and fed or maintained for 45 or more days per year, and crops, vegetation, or forage growth are not sustained over a normal growing period.

CAFOs are classified by the type and number of animals they contain, and the way they discharge waste into local water resources. CAFOs are AFOs that contain at least a certain number of animals, or have a number of animals that fall within a range and have waste materials that come into contact with local waters. This contact can either be through a pipe that carries manure or wastewater to surface water, spreading application, or by animal contact with surface water that runs through their confined area.

What’s the Problem?

AFOs were first identified as potential pollutant sources in the 1972 Clean Water Act (CWA) which protects fishable, swimmable, drinkable water across the United States. The CWA identified “feedlots” as “point sources” for pollution along with other industries, such as fertilizer manufacturing. Consequently, a pollution permit program entitled the National Pollutant Discharge Elimination System (NPDES) was created which set pollution effluent limitation guidelines and standards (ELGs) for CAFOs. CAFOs have since been regulated by NPDES or a state equivalent since the mid-1970s. The definitions of what was considered an AFO or CAFO were created by the EPA for the NPDES process in 1976. These regulations remained in effect for more than 30 years, but increases and changes to farm size and production methods require consistent updates to the permit system.

This August 2018, the Montana Dept. of Environmental Quality is tackling the once-in-5-year opportunity to update its CAFO NPDES permit. Because one of the largest multi-species slaughterhouses in the Pacific Northwest is proposed for right outside Great Falls, and industrial scale slaughterhouses are proven to incite the creation of CAFOs nearby,  it is critical that DEQ uses this permit renewal opportunity to update its CAFO rules with best available science that protects our waterways, landscapes, and local communities.

Here are the actual documents comprising the “CAFO General Permit” that DEQ has published for public comment (click to download):

A Brief Summary of Environmental Health Impacts

The most pressing public health issue associated with CAFOs stems from the amount of manure they produce. CAFO manure contains a variety of potential contaminants. It can contain plant nutrients such as nitrogen and phosphorus, pathogens such as E. coli, growth hormones, antibiotics, chemicals used as additives to the manure or to clean equipment, animal blood, silage leachate from corn feed, or copper sulfate used in footbaths for cows.

Depending on the type and number of animals in the farm, manure production can range between 2,800tons and 1.6 million tons a year.  Annually, it is estimated that livestock animals in the U.S. produce each year somewhere between 3 and 20 times more manure than people in the U.S. produce, or as much as 1.2–1.37 billion tons of waste.

While manure is valuable to the farming industry, in quantities this large it becomes problematic. Many farms no longer grow their own feed, so they cannot use all the manure they produce as fertilizer. CAFOs must find a way to manage the amount of manure produced by their animals. Ground application ofuntreated manure is one of the most common disposal methods due to its low cost. It has limitations, however, such as the inability to apply manure while the ground is frozen. There are also limits as to how many nutrients from manure a land area can handle. Over application of livestock wastes can overload  soil with macronutrients like nitrogen and phosphorus and micronutrients that have been added to animal feed like heavy metals. 

When manure is applied too frequently or in too large a quantity to an area, nutrients overwhelm the absorptive capacity of the soil, and either run off or are leached into the groundwater, polluting local streams, creeks, groundwater, and drinking water supplies. Storage units can break or become faulty, or rainwater can cause holding lagoons tooverflow. While CAFOs are required to have permits that limit the levels of manure discharge, handlingthe large amounts of manure inevitably causes accidental releases which have the ability to potentially impact humans.

The increased clustering and growth of CAFOs has led to growing environmental problems in many communities. The excess production of manure and problems with storage or manure management
can affect ground and surface water quality. Emissions from degrading manure and livestock digestive processes produce air pollutants that often affect ambient air quality in communities surrounding CAFOs.

All of the environmental problems with CAFOs have direct impact on human health and welfare for communities that contain large industrial farms. Human health can suffer because of contaminated air and degraded water quality, or from diseases spread from farms. Quality of life can suffer because of odors or insect vectors surrounding farms, and property values candrop, affecting the financial stability of a community.

The Opportunity to Improve Protections For Our Waterways, Landscapes, and Communities

Montana DEQ is soliciting public comments right now on proposed revisions to its Draft General Permit for Concentrated Animal Feeding Operations (draft CAFO GP). The CAFO GP is the tool by which the state of Montana can control the pollution effects of industrial scale animal agriculture on the local environment, and particularly on our water resources.

Although Montana has less than an estimated 150 CAFOs, these operations already create significant environmental consequences on their local landscapes and waterways, and the potential for the mega-sized Madison Food Park Slaughterhouse outside Great Falls dramatically increases the potential for future CAFOs in Montana.

The opportunity at-hand is clear: comment on the draft CAFO GP and help Montana DEQ do its job in protecting human and environmental health by improving the terms and conditions of its permit for CAFOs based on best-available science, clean water law, and a good dash of common sense.

Waterkeeper has pulled together a short summary of issues in the draft CAFO General Permit – click below to download a copy.  

We encourage concerned citizens to, if available, attend the public hearing on the CAFO GP in Helena Monday, August 19th at 10am in Rm 111 of DEQ’s 1520 E 6th Street headquarters. This is one opportunity to ask our decisionmakers to put strong, science-based rules on the books that protect our outdoors and waterways.

If you aren’t able to attend Monday’s public hearing – don’t worry! You can submit a letter to DEQ via email anytime before 5pm on the 24th.  We recommend you take a peek at the suggested talking points, above, and then craft your own personal comment letter and submit to DEQ.  Submit your comments via email to:

Upper Missouri Waterkeeper is working with experts to develop a robust technical comment letter that we will submit by the deadline for public comment this Friday, Aug. 24th COB.

Here Are a Few Comment Writing Tips (both public speaking and written comments):

  • If speaking at a hearing, speak slowly and focus on problems in the Permit that affect you
  • Don’t miss a deadline… get your comments in on-time
  • Write and speak in your own words.  If sending a letter in by email, remember quoted and form letters aren’t counted as individual comments, and neither do sign-on letters
  • Make your comments relevant.  How do industrial scale animal feedlots affect you and your family? DO you live near a feedlot or animal operation now, or recreate near one, and if so how does it affect your family/outdoors/fishing/hunting/boating/enjoyment of the outdoors?
  • Be concise, be respectful, and use proper grammar
  • Close your comments by asking DEQ to address the identified problems and oversights in its draft General Permit to better protect public health and the environment

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Upper Missouri Waterkeeper is the only conservation organization bird-dogging proposals that would harm our waterways, communities, and businesses throughout the entire 25,000 sq. miles of Montana’s Upper Missouri River Basin.  We don’t take corporate monies and we aren’t government funded, meaning its people like you who help us protect special places and improve state rules that will provide critical defense in the future.

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