Concentrated Animal Feeding Operations
Concerns regarding Draft CAFO Permit
SUMMARY LIST OF MAJOR CONCERNS REGARDING DRAFT CAFO DISCHARGE PERMIT
1. The DNRE should establish a review and construction permit process for CAFO waste storage facilities similar to what is done for municipal and industrial wastewater treatment facilities. Included with these standards should be a prohibition on above-grade storage facilities that depend on earthen berms. Also, perimeter drains and monitoring wells should be installed around storage structures, and these monitoring wells should be adequately sampled and the results should be reported to the State.
2. The Department should not allow winter application of CAFO wastes, which do not constitute agronomic applications since no crops are actively growing on the land at the time that could take up these nutrients. As a result, the nutrients are available to pass into the groundwater and eventually into nearby surface waters, threatening water quality and wasting valuable nutrients that should be cycled back to the land.
3. The Department should maintain the language as written in the most resent draft copy regarding public notification of new fields. If the requirements of the discharge permit are being met, CAFOs should have more than enough time to provide public notification for any new land application fields. The permit should encourage CAFOs to view CAFO wastes as a valuable fertilizer commodity rather than a liability requiring disposal.
4. The Department should require all fields currently being used for disposal of CAFO wastes be reevaluated based on the new information submittal requirements in the draft permit to ensure that the surface and ground waters of the State are protected. Public notice should be required for these fields if not previously given.
5. Tile drain outlets from land application fields should be sampled to analyze and verify that water leaving the field does not exceed water quality standards, and these results should be submitted to the State for review. Fields that produce drainage that exceeds water quality standards should be required to make modifications to ensure that CAFO wastes do not degrade nearby surface waters.
6. CAFO wastes transferred or manifested to other farms or land appliers should only be applied to soils that have been thoroughly assessed, inspected prior to and after application, or that they are applied at agronomic rates or incorporated within 24 hours as required on lands owned and operated by large CAFO waste generators. The same requirements should apply to ANY field that CAFO wastes are applied to, INCLUDING manifested wastes.
7. Michigan TU is very concerned that CAFOs employing liquid manure systems could degrade nearby groundwater quality. High strength wastes that are land applied have been known to result in leaching of metals such as iron, manganese, and arsenic from the soil which can impair water quality. The Department requires other industries that apply their wastewater to the ground to monitor groundwater leaving their property, and the same should be required of CAFOs facilities and land application fields.
Concentrated Animal Feeding Operations
Concentrated Animal Feeding Operations, or CAFOs, are large scale industrial farming operations where animals are kept and raised in confined enclosures. CAFOs generally congregate animals, feed, manure and urine, dead animals, and production operations on a small land area. Feed is brought to the animals rather than the animals grazing or otherwise seeking feed in pastures, fields, or on rangeland. Animal waste and wastewater can enter water bodies from spills or breaks of waste storage structures (due to accidents or excessive rain), and non-agricultural application of manure to crop land.
WHY IS MICHIGAN TROUT UNLIMITED CONCERNED ABOUT CAFOs?
In recent years, Michigan Trout Unlimited has become increasingly concerned about the potential damage that can occur as a result of the misapplication of manure within coldwater watersheds. This concern became tragically evident in late July, 2006 when a large amount of fecal material made its way into Tyler Creek near Freeport, Michigan, resulting in a total loss of the fish population along 4 miles of one of the finest trout streams in southern Michigan. Since then, other spills of manure or agricultural waste to streams have occurred throughout Michigan, including two spills in 2009 along the Black River in Sanilac County and along a tributary of the River Raisin in southern Michigan. Both of these spills resulted in fish kills. It is Michigan Trout Unlimited’s goal to work alongside the agricultural community to develop long-term solutions to these potential threats which will ensure the viability of both our coldwater resources as well as the surrounding agricultural community. But most importantly, Michigan Trout Unlimited will stand steadfast in our mission to protect Michigan’s coldwater watersheds. Michigan Trout Unlimited views agricultural practices that result in fish-kills or impairment to trout and salmon populations and habitats in coldwater watersheds as completely unacceptable. And while we also acknowledge that there are a wide variety of environmental and public health concerns related to CAFO operations, Michigan Trout Unlimited’s primary objective is to ensure that waters that have designated uses as coldwater fisheries, as well as the groundwaters and watersheds that feed into them are protected, restored, and allowed to thrive.
WHAT IS MICHIGAN TROUT UNLIMITED DOING REGARDING CAFOs?
Since 2006, Michigan Trout Unlimited has been actively engaged in conversations with the agricultural industry, the Michigan Department of Agriculture (MDA), the Michigan Department of Environmental Quality (MDEQ), Conservation Districts, and other concerned conservation and citizen organizations to address these concerns. Our local chapters and grassroots volunteers have donated thousands of hours in restoring and enhancing coldwater streams like Tyler Creek that have been affected by manure spills. Michigan Trout Unlimited has submitted public comments related to the MDA’s Generally Accepted Agricultural Management Practices (GAAMPs), and has participated in Stakeholders Meetings held by the MDEQ related to the soon to be revised National Pollutant Discharge Elimination System (NPDES) Draft CAFO General Discharge Permit.
HOW CAN I LEARN MORE ABOUT CAFOs AND MICHIGAN TROUT UNLIMITED’S ADVOCACY EFFORTS?
Below you will find links to Michigan Trout Unlimited’s Position Paper on CAFOs, advocacy letters submitted related to CAFO rules and regulations, as well as some informative and helpful links from the EPA, MDA, and MDEQ websites. Additional information will be posted from time to time, so check back often.
- Michigan Trout Unlimited’s CAFO Position Paper
- Michigan Trout Unlimited’s 2010 Draft GAAMPs public comment letter
- MDA’s response letter to all public comments submitted regarding the 2010 Draft GAAMPs
- Michigan Trout Unlimited’s 2010 Final NPDES CAFO General Permit No. MIG019000 public comment letter
- CAFO's and Trout Presentation
Other Useful Weblinks:
Various EPA CAFO weblinks: