By Kim Ferraro

Animals raised in concentrated animal feeding operations (CAFOs) generate five times more raw waste than humans in the United States. This animal waste contains substantial amounts of nutrients, pathogens, heavy metals, and other contaminants that is commonly applied, untreated, to cropland associated with CAFO operations, stored in open manure lagoons, or transferred off site. When over-applied the raw waste runs off of fields into waterways, causing toxic algal blooms, fish kills, and contributing to dead zones.

At the Hoosier Environmental Council, we often hear from Indiana residents about their concerns for their drinking water, property values and air quality due to large factory farms moving in to their communities. Unfortunately, it is difficult to obtain even basic information about these facilities or their emissions and discharges because, unlike many other industries, CAFOs are not required to disclose facility-specific information to the EPA or IDEM.

Specifically, Section 308 of the Clean Water Act authorizes EPA to gather information from any “point source” when that information will assist EPA in fulfilling its obligations under the CWA. EPA has long used its authority under CWA § 308 to gather information from other point sources but has not used this authority to obtain even basic information from CAFOs.

Under a recent settlement agreement with environmental groups, the EPA promised a regulation that would require CAFOs nationwide to report their location, number of animals housed, and amounts of waste produced. Despite this promise, EPA’s proposed reporting rule contains an option limiting the universe of CAFOs subject to the rule to those in “focus” watersheds, i.e. those with water quality concerns likely due to CAFOs. This option is nonsensical because CAFOs, not in focus watersheds, may nevertheless still be significant sources of water pollution that EPA and the public should be aware of.

EPA is taking comments on the proposed CAFO reporting rule until January 19, 2012. For more information about the proposed rule and to submit comments go to:

http://www.federalregister.gov/articles/2011/12/19/2011-32472/national-pollutant-discharge-elimination-system-npdes-concentrated-animal-feeding-operation-cafo

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