The proposed CAFO permit will be costly!

Your comments on this proposed permit are necessary to protect your interests. Please read these details and provide comments to the Department of Ecology.

Send comments to Ecology. They must be received no later than 5 p.m. on Aug. 31. Send comments to:

Washington State Department of Ecology
Water Quality Program
Attn: Jon Jennings
PO Box 47696
Olympia, WA 98504-7696

jonathan.jennings@ecy.wa.gov

http://www.ecy.wa.gov/programs/wq/permits/cafo/publicinvolvement.html

It is extremely important to make your voices heard by August 31th.

Here are links to more information to assist in making comments.

Washington State Dairy Federation materials:

• WSDF comments submitted August 29, 2016
• WSDF overview of the CAFO permit
• WSDF background and analysis of CAFO permit
• WSDF suggested comments on the proposed CAFO permit
• Tips on testifying on the CAFO permit

Department of Ecology materials:

• Main page with information and the form for submitting comments electronically
• Draft state-only permit
• Draft combined permit
• Draft fact sheet for state and combined permits
• Draft Application for Coverage Notice of Intent (NOI) for Coverage under a CAFO General Permit
• Draft annual report
• Draft yearly field nutrient budget
• Draft record keeping calendar
• Draft export record keeping
• Draft Small Business Economic Impact Analysis
• Draft Manure and Groundwater Quality: Literature Review

Other materials:

• Storman, Ecology Letter to NRCS
• Effects of Leakage from Four Dairy Waste Storage Ponds on Ground Water Quality (Denis Erickson, Washington State Department of Ecology)
• Ground Water Quality Assessment, Sheridan Dairy Lagoon, Adna, Washington (Denis Erickson, Washington State Department of Ecology)
• Addressing Nitrate in California’s Drinking Water (University of California, Davis)
• Implementation of Nutrient Management Training Program for Farmers (Washington State Department of Agriculture)
• Evaluation of the Effects of Edge-of-Field Grass and Shrub Filter Strips on Fecal Coliform Bacteria Transport in an Agricultural Setting
• Western Dairy News: Using Vegetated Buffers or Setbacks to Reduce Fecal Coliform Bacteria Runoff from Dairy Pastures
• Flow Pathways and Sediment Trapping in a Field-Scale Vegetative Filter (See chart on p. 957.)
• Infiltration Mechanism Controls Nitrification and Denitrification Processes under Dairy Waste Lagoon (Baram et al.)
• Effects of Land Application of Dairy Manure and Wastewater on Groundwater Quality
• Land Application Requirements: Separation Distances (Andersen et al.)

 

 

Your farm, family, and future will be affected by this CAFO permit. It is very important to understand the impact and make comments. When doing so, speak about what you know best — your life, family, farm, and livelihood. Let public officials know what it is like to care for the environment every day.

The following are examples of things you may want to talk about during the hearing:

• The history of your farm
• Examples of the conservation work you have done on your farm — nutrient management, wildlife habitat, water quality protection, etc.
• Investments you have made in conservation and environmental protection — equipment, systems, nutrient management, monitoring, buffers, wetlands, conservation tillage, etc.
• Awards about, recognition of, and pride in your stewardship — clean water, productive cows, healthy crops, jobs, etc.
• Community service in the environment — service on conservation district boards, watershed improvement districts, irrigation districts, groundwater management boards, etc.
• Innovative projects — digesters to produce power and recycle nutrients; energy efficiency projects such as fans, lighting, variable frequency pumps, etc.
• Your past and ongoing compliance with existing rules and guidance from WSDA, NRCS, CD, and private consultants; your updates to farm plans, the time and expense of consultants, work with technical experts at CDs and NRCS.
• Your ongoing education in stewardship and nutrient management.

Ask “Why more regulations?” The report from WSDA shows that dairy producers are doing the work that is resulting in high levels of compliance and protection for surface and groundwater. Data across the state shows that diary is already doing its part. While more can always be done, this extra permit is unnecessary, and increased and unnecessary costs mean less money to invest in other places.

The nutrient management system is working. The data confirms that dairy producers and work with CDs, NRCS, WSU, etc., is working to protect the environment.

Where is the problem that demands such a burdensome, additional layer of regulations? Why regulate us more?

Here is a video developed by Whatcom Family Farmers about the CAFO permit that may be helpful when you prepare testimony.

And here are several videos about environmental efforts by dairy producers:

The proposed CAFO permit has two options: A combined federal/state permit (if there are surface water discharges) and a state-only groundwater permit. Dairies with fewer than 200 mature cows would be exempt. All dairies with lagoons are presumed to be dischargers and would need one of the permits.

Requirements for either permit would include:

1. Fall and spring soil tests
2. Daily/weekly inspection of systems (including in-ground portions)
3. Manure pollution prevention plan
4. Provide an engineering assessment on lagoons (within two years of permit issuance)
5. 100-foot buffer (from waters/wetlands) of no spreading of nutrients or use of a 35-foot vegetated buffer
6. Manure testing
7. Public disclosure of reports
8. Limits on nutrient application
9. Other requirements

While the state or combined permits would provide some degree of protection in the face of lawsuits, the preliminary estimate of compliance are extremely high:

• Estimated costs to a 300-acre western Washington farm, with 10 percent loss (corn) due to buffers from any waters of the state, equals $36,000/year.
• Estimated costs to a 1000-acre eastern Washington farm, with 10 percent loss (corn/triticale rotation), equals $185,000/year.