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Environmental groups respond to Concentrated Animal Feeding Operation (CAFO) final permit

posted Jan 31, 2017, 2:55 PM by Unknown user   [ updated Sep 26, 2018, 2:41 PM by Hannah Coughlin ]
Republished with permission from the Western Environmental Law Center. Read the full statement from environmental, public health, and social justice advocates.

In January, a coalition environmental, public health, social justice and public interest advocates and organizations representing tens of thousands of Washingtonians responded to the Washington State Department of Ecology’s issuance of a revised concentrated animal feeding operation (CAFO) general discharge permit, five years after the former permit expired. 

Faced with the opportunity to protect Washingtonians from pollution for agriculture operations, Ecology failed to address the four major sources of pollution from CAFOs: land application, lagoons, compost areas and animal pens. Instead, Ecology issued a problematic, two-tiered permit scheme that fails to protect our most fundamental natural resource — clean water.

The waste produced by the CAFO industry is vast. The more than 260,000 adult dairy cows in Washington state produce over 26 million pounds of manure each day collectively. Too much of this manure enters Washington’s surface and groundwater, causing significant public health and pollution problems. 

The Sumas-Blaine Aquifer in north Whatcom County, home to numerous dairy farms, is the major drinking water source for up to 27,000 residents. This new permit ignores Ecology’s own determination that confirms nitrate loading due to over-application of manure from CAFOs “contributes significantly to groundwater nitrate contamination.”

After being held hostage by the political influence of the agriculture industry during a five-year renewal process, the agency’s new permitting scheme does little to address the four major sources of CAFO pollution. Instead of issuing one permit that prevents discharges of pollution to surface and groundwater in accordance with federal law, Ecology adopted the agriculture industry’s unsuccessful legislative attempt to require a state-only permit that authorizes groundwater discharges. This regulatory regime blocks transparency and prevents citizens from protecting their right to clean water.

Ecology disregarded the recommendations of its own scientific experts and did not require groundwater monitoring as part of the permit, even though that monitoring is routine for agriculture operations that are known to discharge to groundwater. Ecology has previously acknowledged that all CAFOs with manure lagoons discharge to groundwater and has characterized groundwater monitoring as “the best indicator of risk.” But after two decades of knowing about the widespread drinking water contamination, it is still not required in the permit.

Ecology caved to the agriculture industry’s desire to avoid numeric manure application limits, thereby allowing CAFOs to apply manure to the land in a manner that pollutes surface and groundwater. The land application of manure is known to be the largest source of drinking water contamination from CAFOs. Lagoons, compost areas and cow pens have also proven to be significant sources of pollution, yet Ecology fails to include measures in the permit that prevent pollution from these sources.

To protect Washington families, friends, and neighbors from being exposed to dangerous levels of nitrates, fecal coliform, and other pollutants in their drinking water, this coalition advocated for the following provisions in its final permit:
  • Mandatory groundwater monitoring
  • Science-based manure application requirements and restrictions
  • Science-based riparian buffers for salmon-bearing streams
  • Implementation of best technology for CAFO operations such as synthetically-lined manure lagoons and other known and reasonably available technologies to eliminate discharges to surface and groundwater
Despite claiming substantial stakeholder engagement and public feedback, Ecology did not include these provisions in its final permit.

The coalition includes Citizens for a Healthy Bay, Friends of the Earth, Sierra Club, the Center for Food Safety, Snake River Waterkeeper, OneAmerica, the Socially Responsible Agricultural Project, Aqua Permanenté, the Waterkeeper Alliance, the Center for Environmental Law & Policy, RE Sources for Sustainable Communities, Spokane Riverkeeper, Planned Parenthood, Puget Soundkeeper, Environment Washington, Safe Food and Fertilizer, and Wendy Harris.

Republished with permission from the Western Environmental Law Center. Read the full statement from environmental, public health, and social justice advocates.

More information

Report: Agricultural Pollution in Puget Sound: Inspiration to Change Washington’s Reliance on Voluntary Incentive Programs to Save Salmon

Puget Sound lagoon distance from nearest water body map: http://bit.ly/1MZnLzz
Whatcom and Skagit counties distance from nearest water body map: http://bit.ly/1SkvfzX
Whatcom and Skagit counties lagoon excavation depth map: http://bit.ly/1feWygS