Introduction:

Specific action ideas

AgBiz - Chicken farms and the megadairies

Links to various information sources

The U.S. has seen a trend toward the introduction of large-scale animal feeding operations, including large chicken, hog and dairy operations near our locations here in western Ohio.  It is also an international phenomenon, as the former Buckeye Egg Farms were owned by a German, and dairy farmers from the Netherlands set up in Ohio and Michigan, where they can afford to operate. There is a similar trend elsewhere in the US (e.g., Virginia) and in western Canada.

The issue here in Ohio is a confusing mix of agriculture (1) attempting to respond to the market with economies of scale and at the same time, and (2) being on a steep (progressing?) learning curve to prevent adverse environmental impacts, with some notable practical setbacks. Mix that with regulatory and permitting processes that seem to have some glaring weaknesses in the attempt to deal with these operations and their impacts.

Such has been the case elsewhere, and both state and U.S. federal government has been swinging into operation.

• The U.S. EPA Final Rule on CAFOs, information sheets, and links to supporting information can be found at this link. Some of the potential problems are scary.
• The State of Ohio, finally, in exasperation, acted to shut down Buckeye Egg Farm's facilities after nine years of trying to get them to manage flies, egg wash discharges to surface water streams, etc. See a summary of those actions. Buckeye's facilities have been purchased by Ohio Fresh Eggs, which pledges better performance. Other links include in-force Ohio Dept. of Agriculture rules and guidance.
• Ohio Department of Agriculture (ODA) regulates and permits CAFF under OAC Title IX Section 901. These are undergoing revision (comments end May 25, 2005).  What and how to make comments (or go to the LEPP home page (see links below).
  

However - Federal and state laws governing water quality have some gaps, either in the letter of the law or its interpretation in regulation. Quoting from the League of Conservation Voters commentary on "factory farms":

" Federal and state environmental regulations are failing to keep up with the rapid growth of factory farms and their resulting pollution. Serious water pollution problems - such as contaminated drinking water, massive fish kills and large algae blooms - in at least 30 states have been linked to inadequate pollution control and lax enforcement of environmental regulations. For example, the rapidly growing poultry industry on the Eastern Shore of Delaware, Maryland and Virginia is one of the main sources of pollution in the Chesapeake Bay and other area waterways. In North Carolina, 'hogs now outnumber [the state's] citizens and produce more fecal waste than all the people in California,' according to Robert F. Kennedy Jr., chief prosecuting attorney for the Hudson Riverkeeper and senior attorney for the Natural Resources Defense Council."

Among these failings is the issue of nonpoint-source contamination of ground water. The U.S. Clean Water Act has provisions that can be applied to ground water, but the NPS program typically focuses on surface waters. This is the case at both the federal and state levels. Ohio surface water programs, for example, appear to be focused on upgrading small-system wastewater treatment plants. The Eastern Shore ag operations can hardly avoid impacting ground water - the whole Eastern Shore is a big sandbox and the impacts in North Carolina post-Hurricane Floyd should be a "wake up" call. Agricultural NPS guidelines focus on preventing runoff and give cursory attention to ground water-contaminating infiltration. There is certainly still room for innovation, invention, and better planning.

(2) If you are a concerned neighbor: It appears that the most valuable response to potential agricultural environmental impacts is to use information and a sense of shared community.  Most "factory farm" operations are actually locally owned and operated - by family farmers. They drink the water, too. They are typically earnest, hard-working people. Be a neighbor in the Christian sense. If you are concerned, arm oneself with maps and data, and deal directly with the operator.

• Work together with the operations (who - usually - won't go away) and one another. These operations have to follow fairly comprehensive regulations for manure storage and land application of manure. However, as an expert in the permitting process noted, "It is up them to perform." If necessary, bring available local political power and "people power" to bear, rather than relying on regulatory authority.
• Be responsible. Don't get caught up in somebody else's agenda. Avoid the shouting and unpleasant displays. Write your legislators, state governor, and key environmental officials (to be on record, if nothing else). Be factual. Know the regs. Be able to provide data. Be prepared to spend some money on professional advice to document your case if you still feel that the process is failing you. Funding is available for many purposes (see below for a link to some possibilities).
• Be a moral voice: People will respond to the moral beacons they know. Even today, a bishop or a pastor wields influence. Don't be mean, hateful, ridiculing or otherwise unneighborly.
• Protect yourselves even if you have to bear the cost. You may need to move or reconstruct wells, or install point-of-entry or point-of-use water treatment to assure water safety. Test it.
• Make sure, if you find drinking water contaminated, that it is not due to another reason unrelated to the ag operation. Make sure the wells involved are constructed according to standards, protected and maintained, and there is no backflow or cross-connection cause. Our links page can help you reach good helps on this.

1) Buckeye Egg Farms debacle in Ohio. The experience with Buckeye Egg in Ohio has not been a confidence builder. You be the judge: Foreign firm builds operations "on the seams" at the boundaries of (1) counties and (2) representation districts on the opposite side of the county line from towns with public water supplies in areas with typically low overall income and conservative tendencies. They go through several management teams and two business names, followed by handoff to a consultant. They hire and strand foreign workers. Flies appear, finally traced to manure piles soaked with water from leaking pipes. Beetles are imported to parasitize flies and take up residence (all over). Years later, they still have problems with flies. Gosh folks, based on this writer's review of the ag engineering state-of-the-art, people could do better than that, don't you think? Evidently, finally, the state of Ohio thinks so, too.

In 2000, under pressure from federal regulators (threatening to withhold $3.5 million in Clean Water Act funding), the Ohio EPA ordered Buckeye Egg and other large animal feedlots to control water pollution via the permit process.   Buckeye Egg did not submit an application, and filed an appeal saying the company does not meet the legal definition of a confined-animal feeding operation (incredible as that may seem, as the federal threshold is 100,000 chickens per permitted facility).

In January 2001, Buckeye Egg Farm promises to pay a $1 million fine and control fly infestations under terms of an agreement reached with the Ohio attorney general's office and state environmental regulators.  The agreement prohibited Buckeye Egg from expanding its flocks for three years at its farm in Licking County and for five years at its farms in Hardin and Wyandot counties.  The company also agreed to upgrade its barns and manure-handling systems in an attempt to end a 13-month legal battle with the state.  At the time, Attorney General Betty Montgomery was cautiously optimistic that breakthrough had occurred, but she needed to see action. In December 2001, Buckeye Egg settled a civil lawsuit filed by a group of neighbors of its egg-production facilities in Croton. The settlement ending the two-year legal battle let stand a $19 million verdict against Buckeye Egg awarded to the neighbors by a Licking County jury in September, 2001.

In March 2002, the company removed large manure piles from near the Scioto River, on state orders. The Ohio EPA had said the piles could have contaminated central Ohio's drinking water (reservoirs on the Scioto are major sources of Columbus' water supply). Also in March 2002, the federal EPA threatened to penalize Buckeye Egg unless it reduced airborne clouds of dust laden with chicken manure. The EPA's analysis said Buckeye Egg's operations at Marseilles, Ohio, would blow more than 100 tons of dust and other small particles into the air each year if exhaust fans ran eight hours a day.  Ohio regulators have no authority over the air emissions from ag operations unless they exceed certain levels.  National farm groups think the decision to apply the law to a large confined-animal feedlot could set a precedent. They persuaded the EPA to sponsor a study by the National Academy of Sciences of air emissions from agricultural operations (linked below).

By Easter, 2002, Ohio patience was exhausted. In April 2002, the Ohio EPA proposed revoking 15 wastewater permits the company needs to operate its 125 egg-production barns in Licking, Marion, Wyandot and Hardin counties. The barns housed about 15.5 million egg-laying hens, according to the state. Mrs. Montgomery's office also filed the ninth set of contempt charges against the company in Licking County Common Pleas Court for repeated violation of state and federal environmental laws, and sought jail time for Buckeye Egg owner Anton Pohlmann as well. Buckeye appealed the revocations, but lost the appeal.

The four properties and 64 barns of Buckeye Egg have been purchased by Ohio Fresh Eggs LLC in association with Hillandale (who will market the eggs) and ODA permits to operate granted. Renovation of barns and installation of essential environmental management equipment and systems is under way. We trust that the Buckeye Egg experience is behind us now.

Still no discussion of potential ground water impacts. Permits issued in October 1998 addressed many concerns by commenters in the revised plan, however, our concern (addressed with a really lame response -- see our comment letter on the permit application by Buckeye Egg Farms for Wyandot County, Ohio, sites) that there are shallow-bedrock areas marked for land application of manure and these are vulnerable to runoff and ground water contamination were never addressed.

• Basically, 1) no one at the state checks these things out, 2) available Ohio guidance referenced by Land Application of Animal Waste rules (ORC 901:10-xx) do not provide adequate assurance for ground water contamination prevention (particularly microbiological), and 3) Ohio environmental regulatory oversight is so hopelessly fractured - if you were trying to design a structure to frustrate citizens, you could do no better - that hearings become numbing ordeals of addressing one permit item and not forums for addressing comprehensive plans.
• Shutdown of the Buckeye Egg facilities due to other permit violations leaves this weakness in addressing ground water impacts of other facilities unaddressed.

Yes, how quaint. Our pastoral Eastern-Midwestern dairy scene has been whacked like a good back kick from old 588 by western megadairies driving down milk producer commodity costs through economies of scale (prices of milk remain strong at the retail outlet). Likewise, dairy farmers in the Netherlands have been faced with astronomical land and operating costs in their crowded, environmentally active country. Our immigration laws force them to be willing to make huge investments to immigrate, just about forcing them to plan huge operations here (write your Senator or representative to change that if you want).

Enter Vreba-Hoff Dairy Development LLC, which assists European and Canadian dairy farmers in establishing operations in the tri-state region. This company is an outgrowth of Vreba-Hoff Dairy LLC, Hudson, Michigan, established by U.S. and Dutch dairy families in 1997 to be a "financially sound, environmentally conscious dairy enterprise" milking well over 2000 cows. By all accounts, Vreba-Hoff bears little resemblance to Buckeye Egg, planning ahead on manure management and taking the approach that they live on their farms and with their neighbors. Vreba-Hoff helps them get started but when they are in operation, the owners are responsible. This article in DairyBusiness Communications describes the focus and manure-management system of the home Vreba-Hoff Farm.

Despite this commitment by this particular company, the potential for problems is there and many have their doubts. An individual cow puts out 30 times the manure produced by an individual human. Thus a 699-cow dairy operation built in Hardin or Putnam counties is equivalent in potential impact to Findlay moving in - without sewers. However, this manure can be a valuable resource (see links below), and some row-crop land can be converted to ensilage and hay farming to support dairies. More forage acreage reduces watershed nonpoint source runoff, improves recharge, and enhances or restores soil.

• ODA is convinced that manure management plans controlling N and P loading on soils prevents ground water contamination by these constituents and that manure storage and application methods limit bacterial contamination. They claim (emphatically, impatiently) that there is no ground water contamination linked to properly permitted and operating CAFF.
• When we get reference to publications that provide the monitoring data (with good QA/QC) to back that up, we're reference it here.
• Meanwhile - "geologic exploration" studies that are supposed to accompany permit applications are (in our opinion) woefully inadequate and heavy on paper study. Geology is to be supervised by an engineer - which may or may not be a good thing. Hydrogeology involved is inadequate and at time manipulated to avoid triggering difficult siting requirements. We are sorry to note that some hydrogeologists cooperate in this manipulation to fool ODA (engineer) reviewers. Responses to comments on draft permits indicate that ODA swallows these stories hook line and big ole lead sinker). We point out that certified hydrogeologists (CGWP or CPG) have a code of ethics that they are supposed to follow (see our discussion of ethics). 

The book has still to be written on how these operations will affect Ohio rural life and the environment. It is hoped that the people involved live up to their ideals.

What we hope to see is agriculture, earth science people such as us, public health people, and the public working together to solve problems and let agriculture prosper in our area without using up the environmental capital our descendents will be counting on to sustain them.

The following are resources we identified that you may wish to consider. Please send any recommendations for others you would like to see here to "smithwells at hotmail.com". NOTE: Don't bother with the PETA or veggie stuff. I'm a big fan of chicken, pork, eggs, milk, leather and fur... And farmers and a vital rural economy, too.  

• U.S. Geological Survey information on AFO effects on hydrologic resources.
• Environmental and regulatory sources
• Scary: Our mass-manure microbiology evolution experiment
• Responsible agriculture sources
• Moral dimensions

• Paper from the Centers for Disease Control (CDC) effort in Emerging Infectious Diseases on multi-drug antimicrobial resistance (MDR) in Salmonella enterica serover Typhimurium DT104 in human and cattle populations in the USA Northwest. They cite other papers.
• The above Davis et al. 1998 paper was too conservative, say these CDC researchers, who cite evidence of antibiotic use in livestock as a source of DT104 emergence in Asia and Europe. They cite other papers. Note that Davis et al replied, not quarreling with reducing antimicrobial use, but emphasizing the need for infection control.
• Another CDC-related paper (published in the New England J. of Medicine) on the increased occurrence of serover typhimurium DT104 in CDC surveillance nationwide in the USA. This strain has apparently become widely distributed (it is also widespread in the U.K. and has shown up elsewhere. It may have started in Asia.)
• Account of another MDR Salmonella strain found in Greece, and possibly associated with a food source.
• Antibiotics in the aquatic environment. (Abstract of conference paper, 1999). This is one of a number of papers on this and related subjects at the 1999 conference.

Environmental, health and regulatory sources of information in this topic:

• Ohio Department of Agriculture Livestock Environmental Permitting Program
• Local Buckeye Egg Farm background from Ohio State Marion campus students (and apparently is an orphan - not recently updated)
  
• The University of Georgia Engineering Extension has publications on animal waste management.
• Animal Waste and the Environment -- University of Georgia Agricultural Extension
• U.S. Geological Survey Animal Feeding Operation Effects on Hydrologic Resources (good links and bibliography for further study).
• National Academies of Science publication on air emissions from animal feeding operations
• Public Health Plan to Combat Antimicrobial Resistance, Interagency Task Force on Antimicrobial Resistance (.pdf document)
• U.S. EPA Nonpoint Source Pollution Control Program has a large amount of information and training on non-point-source contamination control. See National Management Measures to Control Nonpoint Source Pollution from Agriculture
  
• USDA's Natural Resources Conservation Service has information on water quality issues and animal waste management.
• Water Quality Group, North Carolina State University
• North Carolina State University information on Pfeisteria bloom research linked to agricultural runoff into coastal waters.
• Natural Resources Defense Council paper on the status of CAFOs state-by-state (yeah, it's an eco-source :-))
• Clean Water Network has information on CAFO advocacy.
• Animal production systems - NorthWest Science and Environmental Policy center (generally unfavorable to large operation practices, focuses on antibiotic resistance
  
• CDC's Emerging Infectious Diseases on-line journal
• Ohio's fractured Pleistocene deposits and soils -- Impermeable, you say?
• Funding sources for watershed issues -- Apply now!

• WWW Virtual Library on Sustainable Agriculture
• Agri-Surf! A Yahoo-like central search and link source on ag topics, including the environment
• OSU Extension's Bulletin 604: Land Application of Animal Waste
• Manure Education and Research from the University of Minnesota
• AgNIC -- Agriculture Network Information Center
• "Grassfarmer.com" This site is devoted to pasture-raising of livestock -- offered as an economical alternative to CAFOs -- and is produced by the American Farmland Trust.
• Odor control for hog farms - University of Minnesota Biosystems and Ag Engineering
• Factoryfarm.org -- Another "anti" site with useful resources.
• Deep bedded swine production methods -- Another great bedding idea from Sweden
• farmweb.org from Farmers Against Rural Messes in Illinois and becoming a livestock facility manager in Illinois
• Opportunities for a Market-Based Environmental Policy in the Poultry Industry -- American Farm Bureau Federation
• Turning Manure into Cash from the American Farm Bureau Federation. Closing the cycle in sustainable agriculture, and turning waste into a "cash crop."
• The Ohio State University Agricultural Extension -- Multiple resources and links to others
• OSU Extension - Questions pertaining to large dairy enterprises in Ohio
  
• Family farming -- Another voice for dispersed, humane farming.
  

• How do we treat people in food processing?
• Is it nothing that our livestock is confined as they were never intended to be? In February 2002, Mercy for Animals (MFA) rescuers, some of whom had helped rescue hens last year when a tornado smashed 12 Buckeye Egg Farm sheds, trespassed at Wyandot County shed at night. "Once inside the sheds again this time they were overwhelmed by the wanton destruction of life, exemplified by strategically placed trash cans for dead birds.... one hen 'was lifting her head up from among the dead birds in the can, and this is what struck me: these hens are like garbage. They're treated like garbage and are thrown away in it.' Some birds were suffering from feather damage, eye and sinus infections, paralysis, vitamin deficiency, hernias, and blindness. About 10 percent of the birds seen by MFA were visibly ill; others were trapped under feeding trays or caught in the cage wire by various body parts.
• Factory Farming (Humane Farming Assn.) These chickens, hogs, etc. are God's creatures, and while they are given to us for food, surely we should treat them with respect.
• What kind of large scale microbial evolution experiment are we running anyway?

• National Catholic Rural Life Conference -- Has thoughts about the ethical and moral dimensions of agricultural methods and food. "The Book of Leviticus reminds us that the Earth is the Lord’s, and we are but strangers and guests. Isaiah (5:8) warns us, 'Woe to those who join house to house, who add field to field.' Such is the state of agriculture today as farmland is consolidated in the hands of a few and rural communities continue to dwindle. Urban sprawl makes farmland that much more threatened and contributes to greater intensity of production in increasingly confined areas."
• RuralMinistry.com -- Center for Theology and Land (University of Dubuque and Wartburg Seminaries with links to other resources). Not heavily devoted to the CAFO issue, but deals with ecological justice.
• The Web of Creation -- Some other spiritually motivated sustainability sources.
• Then, there is the Bible itself (The American Bible Society has a scripture keyword search tool), in which God is quoted as having a lot to say about land and justice (150+ passages found in search = "justice"), even humane treatment of farm animals ("don't muzzle the ox when treading out the grain" applies to oxen as well as figuratively to working folk.). Islamic? Ref. the Qu'ran.

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