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Concentrated Animal Feeding Operation (CAFO) Permit

Washington state faces a water quality crisis.

It may come as a surprise that the sparkling waters of the Puget Sound are silently suffering. The rate of damage to the nation's largest estuarine water body — from under-regulated industrial pollution, ocean acidification, and urban stormwater runoff — still outpaces the rate of recovery.

RE Sources, with partners across the region, is amplifying our efforts to raise public insistence to elevate the recovery of Puget Sound as a state priority. A big part of that work involves educating voters and advocates about sources of pollution, and opportunities to better regulate and reduce it. 

Ecology needs to better regulate all sources of industrial pollution.

Agriculture operations are one of the leading causes of pollution to waterways nationwide, and a major cause of shellfish bed and beach closures in Washington state. Manure is a source of nitrates, fecal coliform, and other pollutants.

Although their impact of agriculture operations on drinking water and marine ecosystems is significant, Washington state's Department of Ecology is not doing enough to prevent or manage pollution from agriculture operations — unlike most other industries

Poorly managed manure can pose a human health risk.

Poor management practices on agriculture 
operations and lack of oversight from Ecology results in 
high levels of fecal coliform bacteria from manure entering creeks, rivers, and the Puget Sound. 

Fecal coliform bacteria indicates the likely presence of other disease-causing organisms. When water is polluted with manure, contact with the water or eating shellfish from the water can make you sick. Fecal coliform pollution is responsible for shellfish bed closures.

Nitrate pollution, from the application of manure onto fields and the storage of manure in lagoons, passes through the soil and can contaminate groundwater and wellsNitrates can persist in groundwater for decades and accumulate to high levels as more manure is applied year after year. Drinking water with elevated nitrate levels is detrimental to human health and is associated with respiratory and reproductive system illness.

What is a Concentrated Animal Feeding Operation (CAFO)?

Concentrated Animal Feeding Operation (CAFO) is an animal feeding operation that confines animals (dairy cows, beef cows, poultry, pigs, and horses) for more than 45 days during a growing season in an area that does not produce vegetation, and meets certain size thresholds. The CAFO permit applies to operations with more than 200 dairy cows or 37,000 chickens.

The CAFO permit gives agriculture operations permission to conditionally discharge water polluted with manure into waters of the state. CAFOs should be covered by a permit that requires them to manage the manure, litter, and process wastewater generated by the operation to protect water quality.

Ecology should hold agriculture operations to the same standards as other industries.

Most industries are required to have permits to discharge pollutionBut Ecology is not doing enough to enforce federal clean water regulations for CAFOsWhen fields are over-saturated from manure spraying, or manure lagoons leak, an overload of nitrates seep into the soil and contaminate groundwater, and fecal coliform runoff enters the Puget Sound. 

This is unacceptable. As Puget Sound's degradation continues, a solution scaled to the problem requires a doubling down of commitment and coordination from federal, state, and local agencies to measure, implement, and enforce with backbone. The health of the salmon, orcas, and other native species cannot afford to succumb to Big Ag's powerful lobbyists. Clean water is essential for fish, farms, and people to thrive. 

Washington citizens deserve a protective CAFO permit.

Ecology's draft CAFO permit would not adequately manage or prevent industrial agriculture pollution harming our waterways. A more environmentally protective CAFO permit should include: 
  • Mandatory groundwater monitoring.
  • Science-based manure application requirements and restrictions.
  • Science-based riparian buffers for streams.
  • Implementation of best technology for CAFO operations.
  • Adequate agency funding to implement permits.

How to get involved:

  1. Add your name to the petition. Although the comment period for the draft CAFO permit closed on August 31st, 2016, you can still add your name to the petition showing Gov. Inslee there is a large public insistence for a more environmentally protective CAFO permit.

  2. Read the public comments. Visit the Department of Ecology website to read public comments on the draft permit, including the technical letter from RE Sources for Sustainable Communities.

RE Sources appeals CAFO permits

In January 2017, Ecology released the final version of its Concentrated Animal Feeding Operation (CAFO) General Permit.

The permit is a disappointment to environmental, public health, and social justice advocates. Ecology failed to address major sources of pollution from CAFOs, including limits on manure application and groundwater monitoring, instead issuing a weak permit that fails to protect our most valuable natural resource — clean water. Read the full statement from environmental groups.

On Feb. 17, 2017, a coalition of environmental groups filed an appeal with the Washington state Pollution Control Hearings Board (PCHB) challenging the Department of Ecology’s waste discharge permits for concentrated animal feeding operations (CAFOs). Read the press release from environmental groups. 

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