Thursday, August 18, 2016

Did you know there's an important pollution permit out for public comment?



In case you haven’t heard, there’s an important state-wide pollution permit out for public review. It’s called a National Pollution and Elimination System (NPDES) permit for concentrated animal feeding (CAFO) operations. The CAFO permit is one of dozens of permits that are required by the federal Clean Water Act.

A CAFO is a livestock operation that confines animals for a total of 45 days or more in any 12-month period in a location where crops or vegetation are not present in the normal growing season over any portion of the area where where the animals are confined. It is estimated that there are between 450 - 500 livestock operations in Washington State that qualify as CAFOs, and these will need to gain coverage under the permit, once it is finalized. Washington State’s permit that regulates CAFOs expired in 2011. The final draft version of the permit was released for public comment on June 15th, and the deadline for the comment period is August 31 at 5pm.

In Washington, most of the livestock operations are dairies, and almost all of these dairies and will be required to gain coverage under the CAFO permit. The two counties in Washington that have the most dairies are Whatcom and Yakima. According to the state Department of Agriculture, there are about 100 dairies in Whatcom County, and about 54 dairies in Yakima County. Yakima county’s livestock operations are much larger than those in Whatcom, and there are also some very large heifer feeding operations in Yakima county that supply milking cows to the dairies.


Washington State’s estimated 200,000 adult dairy cows produce over 20 million pounds of manure every day. Fecal matter from these cows (and from humans, other livestock, pets, and wildlife) contains fecal bacteria which can survive outside of the animal, thereby elevating bacteria concentrations if they enter a stream. Even a small quantity of fecal material escaping into surface water from any kind of livestock can cause a substantial impact.



Unlike human waste, dairy waste is untreated. Manure is applied to farmland by a variety of methods: big gun spraying, liquid injection, and spreading solids. The best scenario is that just the right amount is applied when the plants are actively growing. If it's overapplied during the winter or other times when active plant growth is not occurring, serious problems can arise. Manure is sometimes over-applied to farmland, contaminating soil, groundwater, and surface water. In Whatcom County, almost all dairy waste is stored for part of the year in unlined manure lagoons that have been proven to seep into groundwater.



We are concerned with pollution from dairies for two reasons: surface water and groundwater pollution. We’re very concerned with bacteria pollution in surface water in Whatcom County - all of our lowland streams and the lower Nooksack River are polluted with fecal coliform bacteria (bacteria). Most of our urban streams are also polluted with bacteria, but these streams do not contribute to the loading from the Nooksack River that causes the shellfish closures. We are not blaming, and we have never blamed this pollution entirely on farms. Farms are one of the sources, as are septic tanks, hobby farms, pets, and wildlife.

The amount of bacteria in our lowland agricultural streams has been steadily trending upward since 2002. In 2014, about 500 acres of the Lummi Nation’s shellfish beds were conditionally closed to harvest, and about 300 more acres have just added to the closure. The Lummi Nation has said the closure affects thousands of families and costs millions of dollars in lost revenue. In Skagit County, the Samish shellfish harvest areas also suffer from closures typically following major rain events.



In Yakima County, a system of irrigation canals (called “drains”) create a vein-like pattern throughout dairy country, and many of these drains are extremely close to livestock feedlots. The feedlots that we viewed had huge piles of manure stockpiled in areas adjacent to these drains, which flow to the Yakima River. The Yakima River has suffered serious pollution issues for the last 20 years, and it is listed on the State’s list of most polluted waters list for dissolved oxygen, bacteria, temperature, pH, and other pollutants.



Groundwater pollution from nitrates is a huge concern in both Whatcom and Yakima counties. Where it comes from is open to debate - but there is no doubt that a great deal of it comes from manure applications. Manure, as well as human waste and dead plant material, contains a lot of organic nitrogen. When an appropriate amount of manure is applied to land when plants can use it for growth, it’s a valuable fertilizer. If too much is applied, or applied when plants can’t utilize it, it leaches through the soil into groundwater. The EPA health limit for nitrate in drinking water is 10 mg/L. Nitrate is a serious health concern in drinking water and is of special concern to infants and pregnant women. It creates the condition known as methemoglobinemia (referred to as “blue baby syndrome”) in which blood lacks the ability to carry sufficient oxygen to individual cells in the body.

The Sumas-Blaine Aquifer, in northern Whatcom County, is home to numerous large dairies, and is the major drinking water source for up to 27,000 people. The Department of Ecology and the U.S. Geological Survey report 29 percent of the sampled wells in this aquifer exceed the EPA health limit of 10 mg/L, and an additional 14 percent more wells containing more than 20 mg/L of nitrate. Similarly, over-application of manure to fields in Yakima county is estimated to contribute 66 percent of nitrate inputs to these residents’ water supply.

The Department of Ecology released the draft CAFO permit in mid-June, with a 60 day public comment period. Two public hearings were offered in late July - in Bellingham and Yakima. At these meetings, the permit writers presented information about the permit, and listened to public comments and concerns.



About 100 people attended the first public hearing, in Bellingham. A lively question and answer session preceded the public hearing. Members of the farming community expressed their discontent with the permit for a variety of reasons: fear that the permit was over burdensome and too costly, statements that agriculture is already over regulated, statements that lagoons don’t leak, fear that required buffers will put them out of business by taking acres of land out of production, and other concerns. Members of the environmental community brought up the reasons why they wanted a stronger permit: concerns about the multitude of lowland streams that are polluted with fecal coliform, statements about the number of drinking wells that have nitrates above the safe drinking water level, concerns that the permit is not compliant with the federal Clean Water Act, and concerns that winter applications and poorly tracked export of manure are too risky and result in pollution of streams and groundwater.

In an effort to increase our understanding of the people passionately arguing on all sides of the state about this issue, we traveled to Yakima County, which has the largest number total cattle in Washington. We wanted to view this issue in a state-wide context, see the larger CAFOs, and hear what the locals had to say. A Yakima Indian Reservation resident took us on a tour to see three CAFOs near her home. The three farms we viewed likely had more cattle than all the farms combined in Whatcom County.



The first thing I noticed was the smell. It was strong - really strong. We also noticed that huge piles of dry manure were stacked up right by irrigation ditches, which connect to the Yakima River. At the third stop, we drove up to a small house located behind a dairy with 16,000 cattle. As we walked between the house and the huge cattle feedlot, we flushed two great horned owls - one of them landed in a tree right above us.

We watched 16,000 cattle standing around in extreme heat - about 107 degrees F. Clouds of dust were wafting off the huge manure piles onto on the siding and roof of nearby homes. The smell was overpowering. Although air emissions from dusty operations like these can pause serious health concerns, the CAFO permit does not address air emissions. Many people in the Yakima area who live near CAFOs are worried about how these operations are impacting their air quality.

We believe that the draft CAFO permit does not regulate manure applications strongly enough to protect our water resources, and there are many ways the permit should be strengthened. We urge you to become educated about the importance of clean water in our state. Learning about this issue and commenting on this permit is one way you can make a difference. We urge you to read the draft permit, and to comment to the Department of Ecology before 5:00 pm on August 31. Thanks for reading - we appreciate your interest in clean water. For further information:

WA Dept of Ecology CAFO permit and background information page here.
RE Sources CAFO permit information page here.
Want a stronger CAFO permit? Add your name to our letter here.

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