Concentrated Animal Feeding Operation (CAFO) General Permits Reissuance Public Comment Period

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Comment From: Scott and Lori Halstead

8/31/22 @ 12:00 AM
Attachments:

Comment From: June Robinson

8/17/22 @ 11:59 PM
To Whom it may concern:
I am writing in response to draft policy created by the Washington State Department of Ecology which contains proposed permitting requirements for maintaining animals and livestock. People have owned and maintained animals for...↓
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Comment From: Laurine Syverson

8/17/22 @ 11:29 PM
I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston and Yakima county farm bureaus.

L. Syverson
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Comment From: Ryan Riches

8/17/22 @ 11:28 PM
Links to cited information may be found within the text of the attached docx file.

My name is Ryan Randolph Riches. I am a second year Law student at the University of Washington School of Law and a legal intern with the Northwest Animal Rights Networ...↓

The newly proposed CAFO general permits are greatly improved from their original incarnation but there are still major extant issues that the new permits have not addressed. Furthermore, even the new CAFO permits have failed to live up to the objectives set out in Washington Department of Ecology's CAFO focus sheet.

Current Environmental Regulations on CAFOs are Severely Underenforced
Currently, in all of Washington State's 284 dairies that might be required to apply for a CAFO permit, only 15 total are permitted. The most egregious example of this underenforcement is one CAFO that has nearly 7,000 milking cows, does not have a CAFO permit, and has not received sufficient oversight from the Department of Ecology. Beyond dairy based CAFOs, some estimates put the number of CAFOs in Washington at nearly 1,200. 1% of CAFOs being covered by permit is an egregious dereliction of duty by the Department of Ecology. As the Department of Ecology has designated in their Concentrated Animal Feeding Operation: National Pollutant Discharge Elimination System and State Waste Discharge General Permit that an operation with more than 200 mature dairy cows is a CAFO and will require a CAFO permit, this is unacceptable. (6)

Underenforcement of CAFOs Directly Harms Humans and Wildlife in Washington
By allowing CAFOs to skirt enforcement of the current regulatory framework, the Department of Ecology and Department of Agriculture are failing in their duties to provide for a clean and healthy environment for the citizens and wildlife of Washington.
Clear examples of the harm that a lack of enforcement to these CAFOs causes is in the pollution of groundwater around these CAFO sites. By inundating the groundwaters surrounding these sites with various pollutants (including nitrogen, fecal coliform, and algal blooms), the CAFOs harm both the health and livelihoods of all those near them. For example, due to increased pollution from dairies, since 2010, the Lummi Nation has lost roughly $850,000 per year due to shellfish farms being forced to close. Furthermore, algal blooms caused by the discharged pollutants from CAFOs depriving bodies of water of oxygen directly harms the entire food chain. Of special note is the effect this has on Chinook salmon. As the salmon are a large part of the southern resident orcas' diet, when salmon populations are decimated, this directly harms the orca as well.
Finally, these issues extend directly to human health and safety as well. Obviously drinking polluted water is not good for anyone's health. As these CAFOs are allowed to pollute without repercussions, in some areas upwards of 25% of the wells did not meet safe drinking water standards. (23) Some studies by the Department of Ecology have even found that nearly 60% of Washington residents may be at risk of health issues due to groundwater pollution.
Allowing these CAFOs to continue recklessly polluting as they are, with insufficient oversight from the Department of Ecology and the Department of Agriculture, is a direct risk to the health of Washingtonians, wildlife, and the environment.

What Needs to be Improved
While the improved CAFO permits are unequivocally a step in the right direction, there are clear flaws in the proposed framework that need to be addressed. Some of the biggest issues involve monitoring, inattention to climate change, increased public involvement and transparency, and expanding the types of CAFOs that are required to apply for a permit.

a. A Lack of Proper Monitoring has Led to a Lack of Enforcement
Currently, many CAFOs that either would require a permit and don't have one or that do have a permit but are in violation of the regulations are ignored by the Department of Ecology and the Department of Agriculture. Some CAFOs have been ignored for years, despite clear violations of CAFO regulations. This must be changed. As the CAFO permits only require reporting of violations if they are directly observed by the Department of Agriculture's inspectors and these inspectors are not being sent out at reasonable intervals, CAFOs are being allowed to harm the environment and the health of Washingtonians without repercussion. As such, both Departments should increase how often they inspect known CAFOs and the process should be made much more transparent to the public. This should apply doubly to CAFOs that are known to have flaunted the law. Furthermore, the process for the public to submit complaints of violations by CAFOs should be streamlined and made easier to submit. CAFOs have been and are currently harming the waters that we all rely on. It is time for the Department of Ecology to put the health of Washingtonians and our environment above agricultural profits.

b. CAFO Permits Should be Required for All CAFOs in Washington
Large dairies currently are under the supervision of the Department of Ecology but are only inspected by the Department of Agriculture. This division of labor has led to many CAFOs avoiding their responsibilities as the Department of Agriculture has been lax in its duties to police CAFOs. As stated above, some CAFOs have not seen a single inspection for years all while violating the regulations that the Department of Agriculture and Ecology are supposed to enforce. Beyond the large dairies that, by state and national law, must have CAFO permits, it is short sighted to not require CAFO permits for other types of farms. Not only dairies produce waste and there is no reason that other CAFOs that produce similar amounts of pollution should not also be required to apply for a permit and be monitored.
Similarly, according to the CAFO fact sheet provided by the Department of Ecology, only new operations are required to notify the public when applying for their CAFO permit. (36). The public must be given all the information necessary to make informed decisions about the potential environmental hazards that current and future CAFOs will create.
Finally, as part of the Department of Ecology's legal obligation under the State Environmental Policy Act, they must consider the effects of climate change when making rules like these CAFO permits. Climate change is likely to lead to even more stormwater runoff and algal blooms. The current draft policy does not address possible increases of both of these phenomena. Ecology should further investigate the potential effects increased stormwater runoff and algal blooms could have under their proposed CAFO permit plan. Currently, stormwater does not trigger a requirement to apply for CAFO coverage under the proposed draft and this too must be addressed.

Conclusion
While positive steps have been taken to strengthen the proposed CAFO permits in Washington, these changes have not yet gone far enough. Loopholes and a lack of enforcement must be closed and addressed in order to ensure a safe and healthy environment for all those who make Washington home.
Attachments:

Comment From: Tracy mclean

8/17/22 @ 10:52 PM
Chelsea Morris 17 Aug. '22
Washington Department of Ecology
PO Box 47696, Olympia WA. 98504-7696

Hello Chelsea,
It is my opinion that the entire subject is poorly addr...↓
This land used to be swarming with a variety of herds. If a property can sustain its livestock and is forced to import feed, then the livestock count exceeds the natural process of purifying water. Though density in a particular area needs to be monitored by the steward. Sensibly managed to work along with Nature so it is taken care of.
This is how I think the program should be organized and how the direction of the editing should be. It should clearly exclude small hobby farms raising a few animals and are teaching their children how to contribute to their family's chores, to care for and about, something other than themselves. And at their dinner table they enjoy the fruits of harvest for their labor knowing they are eating toxin-free foods that they grew or raised themselves.
We already have laws for manure composting programs beginning at a 5 cu yd volume. Remember when collecting rain water was illegal in Thurston County? That law was reformed. This one should be as well.
Thank you for the opportunity to share my perspective.
Tracy H. McLean, Rural Resident of Thurston County
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Comment From: Susan Kyle

8/17/22 @ 10:45 PM
I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with those who raise livestock on a small scale providing locally sourced food.

Applying CAFO stan...↓

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Susie
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Comment From: Sandra Hintz

8/17/22 @ 10:38 PM
Chelsea Morris, Washington Department of Ecology
PO Box 47696
Olympia, WA 98504-7896

Dear Chelsea

I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima County Farm Bureaus. We need to work with those who raise ...↓

Sincerely,

Sandra Hintz
August 17, 2022
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Comment From: Anonymous Anonymous

8/17/22 @ 10:10 PM
As a small farmer, I responsibily confine my livestock to a heavy use area during the rainy months of the year in order to protect water quality. This permit requirement would contradict Best Management Practices for livestock in Western WA. Statewid...↓
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Comment From: Josef Christ

8/17/22 @ 10:05 PM
I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with those who raise livestock on a small scale providing locally sourced food.

Applying CAFO stan...↓

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,
Josef
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Comment From: Vienna Christ

8/17/22 @ 10:05 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Vienna Christ

August 17, 2022
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Comment From: Alisa Deleon

8/17/22 @ 9:58 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus. Ecology is overreac...↓

We need to work with those who raise livestock on a small scale providing locally sourced food. Local food is good for the environment. Local food is healthy for our citizens. Local food is good for the economy. Local food must be protected, not regulated.

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security. At a time when inflation and supply chain problems are rampant, Ecology's drafted rules are deplorable!

Ecology must recognize the work of the Voluntary Stewardship Program (VSP) and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality. Those of us who raise their own animals have a very personal stake in protecting our environment, and especially water quality. We know our animals, land, and water better than any bureaucrat from Olympia ever will! We already want to do the right thing. The vast majority of us are already good stewards of our water, land, and animals. We absolutely do not need Ecology bullying us when we are not doing anything wrong and local help is readily available.

The Washington Department of Ecology needs to leave us alone, and we will continue utilizing the existing, proven, resources we already have with our local conservation districts and the VSP!

Sincerely,

A. Deleon

August 17, 2022
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Comment From: Raul de Leon

8/17/22 @ 9:56 PM
Dear Chelsea,

I am totally opposed to the current CAFO language and also opposed to the proposed amendments to the existing rule and completely agree with comments provided by the Okanogan, Yakima-Klickitat, Thurston, Grant, and Benton County Farm Bur...↓

Proposed language is vague, broad reaching, and leaves way too much at the discretion of one agency.

There was no public involvement or community outreach, prior to creating these rules and although many expert resources such as the VSP and the Conservation Districts are available in our communities, these were not consulted either, prior to drafting these rules.

This is unfortunately, an all too familiar top-down approach commonly practiced by our State agencies and a defective process, that creates distrust and resentment against these agencies, from the communities that they are supposed to represent and help.

Ecology has a seat available at the Thurston County VSP Advisory Board, yet they have been absent. The VSP Has accomplished great things and surpassed its expected goals, which help both communities and our environment. It is a waste of tax dollars, staff time and overall effort, not to have included them or the conservation districts in the discussions.

Unfortunately it seems to be that bureaucracies have a tendency to become yet bigger bureaucracies and soon they start losing touch with their communities, the realities of life and sound stewardship practices; which have been working well and sustaining our citizens and our environment, for thousands of years.

Most everyone is opposed to harmful excesses and most of us want to leave a better place for our children. It is almost as if Ecology assumes that we are all bad stewards. Such attitude will never work and it creates discord, stifling any desire to work together towards achieving common goals.

People have the right to feed themselves, farm and raise livestock to do so, without government intervention. Ecology needs to focus on the real offenders and assist all small producers and livestock owners, with help and education to prevent problems

No agency should have the power, to forbid anyone from raising or growing their own food, feed their families and continue being good stewards of the land.

Many of us have worked all our lives to fulfill our dream to do just so and now you're proposing to potentially regulate it out of existence, at your discretion...

Local food is good for our communities, local food is security and local food is natural.

You are loosely using the term CAFO, Which should only be applied to what the acronym states; concentrated animal feeding operations. The term CAFO or for that matter a Small CAFO, should only be applied to what the acronym stands for; concentrated animal feeding operations!

Your language has lumped the keeping of all animals for any reason (recreation not excluded) and labeled it all as CAFOs in one form or another.

What is concentrated?, How many animals is a concentration?, How large of a lot is a concentration?, how many animals in a lot is it concentration?

These concerns do not even address the other concerns presented by the county Farm Bureau's, the Washington Farm Bureau, the Washington dairy Federation, and others, which have expressed concerns with the overly complex regulations, the far-reaching negative impacts that it would have to small producers and livestock owners, its regulatory complexities, the costs involved with implementing these, the privacy concerns or the surveillance requirements

All these are contained in a document exceeding 100 pages AND again; drafted without reaching out to those it impacts and without reaching out to the hands-on experts with the VSB program and the local conservation districts.

Is this representative of a government by the people and for the people? I'd say not.

Ecology needs to involve the citizens these regulations will directly impact at all levels, work with and enlist the help available through the VSP program and the local conservation districts - then draft new clear language that will achieve the environmental goals, without harming our rural citizens


Sincerely

R. de Leon. August 27, 2022
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Comment From: Xenia Midence

8/17/22 @ 9:42 PM
I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurtson, and Yakima county farm bureaus. We need to work with those who raise livestock on a small scale providing locally scoured food. Applying CAFO standards to small op...↓
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Comment From: Dan Bartelheimer

8/17/22 @ 9:36 PM
I am a third generation farmer located in the Snohomish River valley. I farm with my son as Sno-Valley Farms, Inc. I am also the president of the Snohomish County Farm Bureau.
It is disappointing to see that governments response is always similar, i...↓

An alternative approach of encouraging and rewarding farmers for being good stewards would be better received and possibly improved the end results. With the rewards being significant, a farmer may not be able to financially survive unless he was also a good steward. Rewarding for doing the right thing verses penalizing for doing the wrong thing seems to be more appropriate.
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Comment From: Eran Ben-Sira

8/17/22 @ 9:31 PM
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Comment From: Anonymous Anonymous

8/17/22 @ 9:11 PM
Dear Department of Ecology,

I am a Washington resident and I am writing to share my concerns with you regarding the Draft Concentrated Animal Feeding Operation (CAFO) General Permits proposed in June 2022 (the "draft permit"), currently open to public...↓

I'm greatly concerned that the draft permit does not require sufficient protections to prevent pollution from entering our waterways, including but not limited to: adequate technology to prevent leaks from manure storage, best management practices for fields such as science-based riparian buffers, sufficient controls for land-based manure application, or sufficient water quality monitoring and reporting. These concerns have been raised by members of the public in the past, and the Appellate Court's recent opinion affirms that these issues must be addressed. I am also concerned that Ecology has not adequately addressed or mitigated the climate impacts that can be caused by CAFOs, nor the impacts CAFOs can have on nearby communities—including communities impacted by environmental injustices.

Published science documents that excess nitrates, E. coli, fecal coliform bacteria, and various other pollutants coming from unregulated and poorly regulated CAFOs have damaged Washington's waterways and harmed communities. As a Washingtonian it is important for me that Ecology leverage the best available science and known modern technologies—as required by the Clean Water Act—to protect the environment and people from water pollution coming from CAFOs. It is also important to me that Ecology live up to its obligations and commitments to Tribes and Indigenous persons, including by protecting salmon from water pollution that can be caused by CAFOs.

In the final permit, Ecology should at least make the following major changes: (1) implement modern technologies to prevent leakage from waste storage facilities and lagoons; (2) implement stronger soil, surface, and groundwater monitoring requirements that will sufficiently detect pollution; (3) safeguard against the overapplication of manure to land; and (4) implement meaningful discharge limitation standards and best management practices based on science—such as riparian buffers—to comply with water quality standards and keep our waterways fishable, swimmable, and drinkable. In short, I urge Ecology to comply with the recent court order to implement reasonable, science-based protections for people, water, and aquatic life from pollution from CAFOs.

Respectfully,

Nichole Novak
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Comment From: Tamara Kelley

8/17/22 @ 9:02 PM
To whom it may concern,

I am writing today to encourage the Department of Ecology to enact effective Concentrated Animal Feed Operation (CAFO) waste regulations through the general permits reissuance.

CAFOs are a major contributor to growing climate is...↓

Here are my major concerns:

-Harmful algae blooms, caused by CAFOs, not only pose a risk to the ecosystem and wildlife, they also pose a health risk to humans and local communities.
-Pollutants discharged without permitted regulations will directly violate Washington State Law, and the federal Clean Water Act, and pose a threat to multiple species protected under the Endangered Species Act including wild Chinook salmon and the critically endangered Southern Resident killer whales.
- Wild salmon and steelhead trout depend on cold, clean, and oxygenated water to survive. Harmful algae blooms and acidification caused by pollutants from CAFOs can negatively impact water quality and conditions. This will impact all species that depend on these fish, as well as tribes and local communities.
- The tiny-shelled marine snail (Pteropods) are among the marine creatures most vulnerable to ocean acidification. Pteropods are an important food source for Pacific salmon, therefore the loss of pteropods means fewer Chinook salmon which the endangered Southern Resident killer whales (protected under the Endangered Species Act) need to survive.
-Killer whales are at the top of the food chain. Pollution caused by CAFOs will work its way into the ecosystem, causing irreversible damage and contributing to the ongoing issues facing the endangered Southern Resident killer whales.
-Effective CAFO waste regulation would promote the well-being of Washington residents who depend on groundwater for drinking, as well as all those who depend on Washington's waterways and natural resources for recreation, economic prosperity, education, and quality of life.

I encourage the Department of Ecology to fulfill its legal obligations with regard to the Endangered Species Act and the Clean Water Act by making the following changes to the CAFO General Permit Reissuance:

1. Implement best management practices based on science, which includes mandatory riparian buffers
2. Implementation of all known and reasonable methods of prevention, control, and treatment for existing manure lagoons and compost areas
3. Completely prevent violations of surface and groundwater quality standards
4. Implement monitoring practices which may include visual inspections and soil sampling to ensure compliance
5. Provide public participation in the development of site-specific nutrient management plans
6. Consider the effects of climate change
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Comment From: Sandra Burnett

8/17/22 @ 8:47 PM
I would like to register my absolute opposition to the CAPO program. As currently written, it is placing an unfair and onerous burden on small scale livestock operations. This will impact local food production and, in an increasingly challenging and ...↓

Please reconsider. Encourage participation in the voluntary programs and you are bound to get better results and happier communities.
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Comment From: Jean Mendoza

8/17/22 @ 8:42 PM
Dear WA State Dept. of Ecology,
Would you please post the supporting documents that Kevin Freeman and Scott Stephen reference in their comment letter on behalf of the WA Dairy Federation? It is not possible to verify the accuracy of many statements in...↓
Thank you.
Jean Mendoza
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Comment From: Friends of Toppenish Creek, Si... (Jennifer Calkins)

8/17/22 @ 8:20 PM
Please see attached comments
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Comment From: Donna Smith

8/17/22 @ 8:10 PM
Oppose CAFO. Too broad & impact to small farmers is detrimental.
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Comment From: Teri Blankinship

8/17/22 @ 7:32 PM
Chelsea, I am writing to you from a small farm in rural Thurston County. My husband and I are simply living out our retirement on a beautiful piece of property with our cows, chickens and sheep. It is doubtful, with the current prices of feed, hay,...↓
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Comment From: James Creer

8/17/22 @ 7:26 PM
I imagine over 95% of Washington State residents are not owners of CAFOs. It would help if you would define what a Non-CAFO normally is since Table 2 insinuates a small CAFO could potentially/routinely consist of one animal. You could caveat the ge...↓
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Comment From: Chris McNerney

8/17/22 @ 7:17 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Chris McNerney

August 17, 2022
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Comment From: Emily French

8/17/22 @ 7:11 PM
As a long term resident, veterinarian, horse and livestock owner in Thurston county I am concerned with the implications and unclear language in the proposed CAFO. I have experienced the miss-use of "loose" county regulations by county officials and ...↓
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Comment From: Paul Thomsen

8/17/22 @ 7:10 PM
Paul Thomsen

Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need ...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Paul C. Thomsen

August 17, 2022
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Comment From: K. gervais

8/17/22 @ 6:51 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

K. Gervais

August 17, 2022
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Comment From: Ronda W

8/17/22 @ 6:47 PM
I oppose the CAFO RULES as drafted. We need to work families who raise livestock on a small scale and provide locally sourced food for themselves and neighbors. Applying CAFO standards to small operations will be devastating to local food production ...↓
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Comment From: Kevin Scott

8/17/22 @ 6:46 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Kevin Scott

August 17, 2022
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Comment From: melinda kerlee

8/17/22 @ 6:42 PM
We don't need anyone else dictating what we do with our land. Enough rules.
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Comment From: Anonymous Anonymous

8/17/22 @ 6:41 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Amanda Z.
August 17, 2022
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Comment From: Anonymous Anonymous

8/17/22 @ 6:33 PM
I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston, and Yakima County Farm Bureaus. We need to work with those who raise livestock on a small scale providing locally sourced food.
Applying CAFO standards to small ope...↓
Instead of regulating, the Department of Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.
No attachments

Comment From: Jesse Moore

8/17/22 @ 6:28 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Jesse J. Moore

August 17, 2022
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Comment From: Barbara Tietjen

8/17/22 @ 6:20 PM
Dear Chelsea,
I am writing with concern about the CAFO permit. It is unclear who will be implicated by the permit. The permit is too vague. Will this affect personal scale farms or homesteads? Applying CAFO standards to small operations will be de...↓

Sincerely,
Barbara Tietjen
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Comment From: Gretchen Fulton

8/17/22 @ 6:17 PM
I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima county Farm Bureaus.We need to work with those who raise livestock on a small scale.
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Comment From: Monica Baxter

8/17/22 @ 6:11 PM
I am vehemently against this. Our local farms are struggling as it is and this does nothing but hurt our community.
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Comment From: Bruce GORSKY

8/17/22 @ 5:54 PM
I strongly oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima
county Farm Bureaus.

We do not need or want government interference with rural families trying to make it in trying times.
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Comment From: Nadja Galadram

8/17/22 @ 5:51 PM
Chelsea Morris 17 Aug. '22
Washington Department of Ecology
PO Box 47696, Olympia Wa 98504-7696

Dear Chelsea
I oppose the CAFO rules as drafted. I agree with the comments of Okanogan, Thurston and Yakima County Farm Bureaus. For example: https:...↓

We need to work with those who raise livestock on a small scale providing locally sourced food, or even have a small egg business with the households on their road, for example. Work with, since the Dept of Ecology does NOT have an active presence on the ground with the folks you propose to regulate. Work with, as in help the Conservation District and other groups who already have the "in" with people keeping livestock or poultry at home -- to knowledgeably and voluntarily handle the waste themselves, if they are not.

This measure would add enormous hardship on the very folks we should support and applaud for their efforts to provide local food, even if only for themselves. Especially this year and next to come, with supply chain issues, crop failures and small business struggles. My rural clients have been far more saavy about working long term with nature to preserve nature day to day, than those in Lacey and Olympia who keep no chicken or livestock, regardless of their environmental ideals. Look at the landscape practices!

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts, as well, and support them, not force them, with informal and funding resources to do what they are already chartered to do. They have helped many poultry and livestock owners I've known since the 90's; smart, warm, respectful and convincing, co-creative. As have I, one by one, listen to and helped them.

Instead of regulating the small animal/poultry holders, Ecology needs to encourage participation in wise voluntary programs, proven to protect water quality. With all respect, I know from my own work to protect the environment, working with just such people since 1989, that these backyard gardeners and homesteaders, want to protect their water quality, long term investment and put into action, many changes in practice we devised together. Top down never works, people! Once fees are levied they only go UP. I learned that there are many services, businesses and groups that already have the trust of the "small animal and poultry caretakers" who could be involved in galvanizing good practices, where needed.

This proposal is near-sighted, rather than the "far sighted" solution it purports to be, "for the planet." The planet starts here in our own State, on each plot of land. Not with a one size fits all program such as CAFO is proposed to be. But involving grass roots water protection, by educating and supporting the grass roots in new ingenious ways. Starting with listening to the land owners themselves, what they face, what they have tried and do, where they need help. Generally they have a keen intelligence. Consider asking the Dispute Resolution Center to facilitate meaningful problem solving from the bottom up. Helping the small holders, is in the best interest of every region in Washington State.
Sincerely,Nadja Galadram, Let's Grow Soil: Lab & Support, letsgrowsoil@fairpoint.net,
17 Aug. 2022
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Comment From: cory Woodiwiss

8/17/22 @ 5:47 PM
Attachments:
Download
Download

Comment From: Friends of Toppenish Creek, Ce... (Jennifer Calkins)

8/17/22 @ 5:47 PM
Please see attached comment from Friends of Toppenish Creek, Center for Food Safety.
Attachments:

Comment From: Stevens County (Wes McCart)

8/17/22 @ 5:40 PM
Attachments:

Comment From: Ed/Susan Cogan

8/17/22 @ 5:19 PM
Attention: Chelsea Morris, Permit Writer
We oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston & Yakima County Farm Bureaus .We need to work with those who raise livestock on a small scale providing locally sourced foo...↓
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Comment From: Robert J. & Alice M. Swidecki

8/17/22 @ 5:04 PM
 We oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus. As a small farm owner, both my wife and I are very concerned over the passing of any type of Legislation that ...↓
Attachments:

Comment From: Alic Swidecki

8/17/22 @ 5:04 PM
Dear Jeff, I am not sure if I am supposed to send this concern to you or a person named Chelsea Morris, but I could not find her Email address posted, so I am hoping that you can pass our concern along to the correct person or people.
We oppose the CA...↓
Attachments:

Comment From: Western Environmental Law Cent... (Andrew Hawley)

8/17/22 @ 5:03 PM
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Comment From: Tracy Anderson

8/17/22 @ 5:00 PM
The CAFO is so wrong and hurting small family operations. We already have to follow strict rules to keep our operations going now. Instead of hurting small operations you should help us survive and stop putting all these restrictions on us. This i...↓
I oppose the CAFO rules drafted and concur with comments of the Benton, Grant,Okanogan,Thurston and Yakima counties Farm Bureau's. Dear "God" we need your help to work with us not to destroy us.
Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Don't destroy us because of the Washington State Yuppies who want to control our state. There is other communities in Washington State other than Seattle. When the ecology and Inslee has destroyed the small operation they will go after the bigger ones. So if there is no agricultural big or small there is no food!
Sincerely
Tracy Anderson
August 17, 2022 at 5:00 pm
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Comment From: Priscilla Hoback

8/17/22 @ 4:58 PM
To Dept of Ecology regarding the CAFO rules: I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima County Farm Bureaus. Applying CAFO standards to small operations will be devastating to local food producti...↓
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Comment From: Steve Klein

8/17/22 @ 4:55 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

While I agree with Ecology's approach in that large CAFOS do need better regulations, most family farms need a different direction from Ecology.

Therefore, I ...↓

The permit is poorly written in applying CAFO standards to small farming operations, which could potentially imperil them.

Sincerely,
Stephen R. Klein
P. O. Box 201
McKenna, WA. 98558
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Comment From: Northwest Chicken Council (Timothy Christopher)

8/17/22 @ 4:55 PM
Attachments:

Comment From: Russ Mills

8/17/22 @ 4:51 PM
Ms Chelsea Morris
I'm writing to say I'm opposed to the CAFO rules as drafted and agree with the comments of Okanogan, Thurston and Yakima County Farm Bureaus. We need to work with those who raise livestock on a small scale which supplies locally sou...↓
Applying CAFO standards to small operations will be devastating to the local food producers and our overall food security. DOE must recognize the work of the Voluntary Stewardship Program and/or the local conservation districts.
Rather than regulating, DOE needs to encourage participation in these voluntary programs which are proven to protect water quality.
Please reconsider and develop another draft for the Small CAFO. Thank you
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Comment From: Silent Majority Foundation (Pete Serrano)

8/17/22 @ 4:46 PM
I'm writing to express concern resulting from the lack of clarity on the regulation of small CAFOs. Specifically, I did not see where Ecology clearly defined "significant contributor." Without a clear definition of the term, it appears that Ecology h...↓
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Comment From: Ted Mahr

8/17/22 @ 4:36 PM
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Comment From: Anonymous Anonymous

8/17/22 @ 4:34 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Xavier Stage

August 17, 2022
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Comment From: North Yakima Conservation Dist... (Michael Tobin)

8/17/22 @ 4:13 PM
Chelsea Morris
Washington State Department of Ecology
PO Box 47696
Olympia, WA 98504-7696

RE: Concentrated Animal Feeding Operation (CAFO) General Permits Reissuance

Dear Ecology,

The North Yakima Conservation District (NYCD) wishes to submit the following...↓

NYCD has no formal comment on the "reissuance" guidance at this time related to the larger CAFO permits. However, we would encourage any current or future policy changes to promote the use of voluntary conservation as a first alternative to regulation. The role of Conservation Districts serves this voluntary process perfectly. Historically the Department of Ecology and the 45 Conservation District of the State had in-place, functioning agreements for "water quality referral" complaints. Within these agreements DOE and the individual CD agreed to how any complaint would be addressed. The different levels (4) described the formal relationship between the two parties. The agreement(s) were developed based upon the CD's capabilities to provide technical assistance and or cost-share to address the complaint. The goal of these agreements was the protection of water quality in an effective, cooperative, informative manner where all parties' goals are met. Historically this process was highly effective at implementation of practices that met W/Q standards. NYCD believes that this "agreement" process would still be effective if placed into the policies related to all CAFO / AFO regulation. Reverting to the use of these agreements also addresses Ecology's own finding that application of standards (CAFO) to small operations has a "disproportionate expense" to those farms.

It has been NYCD's experience that when we work with any landowner on water quality issues, we have gained more in the end through a cooperative process rather than a regulatory process. In doing so the NYCD has also maintained local customs and culture related to agriculture and land use. The benefit of doing so has multiple outcomes such as local food security, environmental awareness as well as protected water quality. The NYCD would welcome any discussion related to our comments. Please contact Michael Tobin, NYCD Manager if necessary (mike-tobin@northyakimacd.org).

Sincerely,
NYCD Board of Supervisors
Mr. Gail Thornton
Mrs. Cindy Reed
Mr. George Cameron
Mr. Dustin Melius
Mr. Frank Hendrix
Attachments:

Comment From: Rachel Grayless

8/17/22 @ 4:08 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

The CAFO proposal under consideration is too ambiguous for families who are simply homesteading and responsibly caring for their own property. Water protect...↓

In a time of current and impending food shortages, we should be encouraging good stewardship of our lands instead of imposing vague restrictions that could remove our ability to simply homestead.

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with those who raise livestock on a small scale providing locally sourced food.

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Rachel Grayless

August 17, 2022
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Comment From: Rhonda Raney

8/17/22 @ 3:55 PM
Dear Chelsea,
I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston, and Yakima County Farm Bureaus. We need to work with those who raise livestock on a small scale providing locally sourced food. Applying CAFO standa...↓
Sincerely,
Rhonda Raney
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Comment From: Roberta Brittingham

8/17/22 @ 3:54 PM
Washington Department of Ecology.
Dear Chelsea Morris,
The purpose of this letter is to communicate to the Department of Ecology my opposition to the CAFO rules as drafted in your publication. I furthermore, concur with the comments of Okanogan, Thurst...↓
Sincerely,
Roberta Brittingham.
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Comment From: R. Wall

8/17/22 @ 3:41 PM
Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with those who raise livestock on a small scale providing locally sourced food.

Apply...↓

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Reid W.
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Comment From: Alex Williams

8/17/22 @ 3:38 PM
I am a Washington resident and I am not satisfied with the Draft Concentrated Animal
Feeding Operation (CAFO) General Permit proposed in June. The permit does not
require adequate technology, or sufficient monitoring and reporting, to prevent
pollution ...↓
Ecology's published science showing decades of damage to Washington's waterways
as a result of pollution from excess nitrates, E. coli, fecal coliform bacteria, and
various other pollutants being discharged by the mega-dairies, beef feedlots, and other
CAFOs across the state.
As a Washingtonian, I expect the Department of Ecology to uphold its commitment to
"protect, serve, and enhance Washington's environment for current and future
generations." I fear that this permit will only allow for more destruction of my state's
environment and lead to a bleaker future for all, but especially for those who live,
recreate, and work at or near these facilities. If your department truly strives for
"equity and environmental justice," it must fully consider the ongoing impacts of
CAFOs on Washington's waters, lands, residents, and EJ communities when drafting
its final permit.
In the final permit, your department should make the following major changes: (1)
implement feasible modern technology (AKART) as required by the Clean Water Act,
such as impermeable lining for liquid and solid waste storage lagoons; (2) implement
soil, surface, and groundwater monitoring that will sufficiently detect pollution; (3)
safeguard against the overapplication of waste to lands; and (4) implement meaningful
discharge limitation standards and best management practices to comply with water
quality standards to keep waterways fishable, swimmable, and drinkable.
The Department of Ecology must do what the court ordered you to do in the re-issued
permit and protect people, water, and aquatic life from pollution. If you do not
significantly improve this permit now, you will not fulfill your duty to protect
Washingtonians and our environment from further degradation.
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Comment From: Anonymous Anonymous

8/17/22 @ 3:37 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Angie Karnes

August 17, 2022
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Comment From: Mark Gregory

8/17/22 @ 3:36 PM
The Department must establish minimum numbers of animals, by type and/or operation, that meet the definition of "Small CAFO". The proposed minimums must be submitted for public review and comment.
Respectfully,
Mark Gregory
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Comment From: Vernanne Matson

8/17/22 @ 3:29 PM
I am against the CAFO rules as drafted and agree with the comments of Okanogan, Thurston and Yakima County Farm Bureaus. Small family farms and Buy Local are in much need. However, the proposed "Small CAFO" definition is backwards! It needs to be a...↓
Why would DOE even consider the proposed definition when DOE has already stated it would create a "disproportionate impact" on small operations?
If I understand it correctly, if I wanted to apply fertilizer to my strawberry patch or my garden boxes when prepping to plant a garden in the spring, I would have to first determine whether it might rain within 24 hours of the application?? How preposterous to think that can be done; this is Washington, the Evergreen State. It doesn't get green because of an arid climate.
Join forces with the VSP's and conservation districts to work with the people rather than against us. Many people struggle for affordable fresh food but can afford it from the neighbors farmstand; others count on the side income from selling a few dozen eggs to offset monthly household expenses. Why would DOE want to create a potential deterrent to enterprising individuals and put local food sources in jeopardy?
Please rethink and revise the draft currently being considered. In my opinion, it's in great need of revision.
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Comment From: Anonymous Anonymous

8/17/22 @ 2:57 PM
This is my comment on the CAFO regulations that the Federal EPA is forcing compliance on all state governments. I will remain anonymous to forestall retaliation.

Please note that the EPA is an unaccountable, corrupt, unelected bureaucracy that has tu...↓

During this time of inflation being the highest in five decades, fuel costs higher than ever, more than 100 food suppliers throughout the country have been destroyed by fire, people across the country being unable to have food security, supply chain issues for all products that used to be readily available, government spending that is the highest ever recorded along with the ever increasing national debt, interest rates dramatically rising, the death of the petro dollar is imminent, covid vaccinations killing people with all manner of diseases all over the world especially with our younger people getting heart issues, droughts in California farmland, the midwest farmland decimated by weather, farmers paid by the US government to destroy their crops, nitrogen fertilizers to become unavailable, illegal covid lockdowns that destroyed most of main street businesses, proxy war in Ukraine targeting Russia (one is foolish to mess with Russia, they have more and better weapons than the US does), Taliban takeover in Afghanistan with the loss of billions of dollars worth of military equipment and loss of control of the billion dollar base along with the deaths of a dozen military personnel all caused by inept leaders of this country who stole the election in 2020. There is more, but enough of that for now.

It is obvious that there are people and organizations within and without our nation that are in the business of destroying this nation. The WEF, Soros, UN, WHO and the Marxist Democrat party are five easily identified organizations. While China wants to see the end of the US, our current leaders coddle the CCP and even do their bidding. Notice the incredible influx of illegals from 141 nations, many of whom are military trained and/or dangerous criminals who will do damage to this nation into the foreseeable future.

Now you will be fining and imprisoning people who are in the business of providing food (milk, eggs, beef, poultry, pork, vegetables) and any one who has a small patch of land with a few chickens and other fowl. If nothing else food prices will rise dramatically solely because of your efforts.

It is long known that food will control a population. The lack of it will cause chaos. You will be sewing the seeds of the destruction of this 240 year experiment in freedom. Make no mistake, everyone complicit in this will be held accountable. You are warned.
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Comment From: JoyAnna Pratt

8/17/22 @ 2:53 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

JoyAnna Pratt

August 17, 2022
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Comment From: Steven Pratt

8/17/22 @ 2:49 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Steven Pratt

August 17, 2022
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Comment From: Washington Farm Bureau (Rosella Mosby)

8/17/22 @ 2:44 PM
Attachments:

Comment From: Anonymous Anonymous

8/17/22 @ 2:36 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696
Dear Chelsea,
I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.
We need to work with...↓
Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.
Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.
Sincerely,
Linda Evans
August 17, 2022
No attachments

Comment From: Guiomar Azevedo

8/17/22 @ 2:33 PM
Attachments:

Comment From: Washington State dairy Federat... (Jay Gordon )

8/17/22 @ 2:25 PM
Dr. Morris, I could not see that the attached support document came thru on my first submission... so, sorry if this is a duplicate but wanted to make sure you had the support document we referenced.
Thanks.
Attachments:

Comment From: Stefanie Fuller

8/17/22 @ 2:22 PM
I'm opposed to this rule/regulation. I'm a responsible hobby farmer and this is just insane. I take care of my land very responsibly. You are just forcing people to move outside this state. I was born and raised here. I don't want to move but with th...↓
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Comment From: Washington State Dairy Federat... (Jay Gordon )

8/17/22 @ 2:16 PM
Washington State
Dairy Federation

August 17th, 2022


To: Dr. Chelsea Morris, Washington State Department of Ecology

From: Dan Wood, Executive Director, Washington State Dairy Federation

Re: Comments on CAFO Draft Permit.


The Washington State Dairy Federat...↓



1. On page 22. Section S.4.J Sub 3. -This draft unfortunately continues to apply an arbitrary date in requiring a fall "post-harvest" soil testing that must be done by October 1 and after harvest. This is virtually impossible for any farm in the state. We know of no dairy farm in the state that is done with harvest by the first of October.

Suggested change - Change the language to require fall soil testing occurring a. after harvest and then b. before application of nutrients and/or significant applications of water (irrigation or rainfall). If the department still wants to use dates, we suggest testing not later than November 15th on Eastside of state and not later than October 31st on Westside. Most years fall cover crop planting as well as final harvest of grass or alfalfa and fertilizing are done by those dates.

2. On pages 33-34. Section S5.B. Sub 2 - (and a few other places) The department chose to revert back to requiring Total Kjeldahl Nitrogen (TKN). This is not a useful test for farmers. We heard your reasoning as there are more labs that test for TKN. We submit that farmers have not had a problem getting soil testing done and this is still the wrong test for agriculture and maybe an answer in search of a problem.

Suggested change- Leave soil and manure testing the same as the last permit. (Testing for Organic Matter, Ammonia/Ammonium).


3. On page 25. S4.K, Sub3.f -This draft again continues to use T-Sum 200 on the Eastern side of the state. The science behind the choice to use T-sum 200 is wrong for use on the Eastern part of the state. We submitted comments earlier this year that give plenty of reasons and science behind the use instead of a t- sum 100 protocol on the Eastern side of our state. We will include those comments again as an appendix to these comments.
To be abundantly clear - The science supporting the use of T-Sum 200 was done for wet conditions such as Western Oregon/Washington, SW British Columbia, and England.

Suggested change –Only on the Westside of our state is T-Sum 200 appropriate. Consider the science, data and information and use a Spring application start date of T-Sum 100 on the East side of the state. We believe the waters of the state are well protected with the use of T-Sum 100 in Eastern Washington, in conjunction with the other conditions (no applications to frozen, snow covered or saturated soils or applications prior to significant imminent rainfall).


4. On page 29. S4.N, Sub 3.a. –This draft language adds a fourth option for "riparian protection" in addition to the standard options and language that there should be no manure applications within 100' of water body on bare dirt OR 35' if there is a vegetative buffer OR no buffer if there is a berm or dike between field and water.

This fourth option – cited in the draft as Appendix J of the 2023 Ecology funding guideline. Appendix J then imposes the requirements from the recent released Department of Fish and Wildlife (DFW) document; Riparian Ecosystems, Vol. 2 (RE 2) ( https://wdfw.wa.gov/publications/01988 ).

Those requirements for any farm in a floodplain would require the farm to stop farming a distance that includes any part of the farm in the entire floodplain plus an additional "site potential tree height" (SPTH) from the outer edge of the flood plain. (A typical SPTH is 230' in Western WA and 100' in Eastern WA.) No farm in a flood plain can or would choose this option since they would not be allowed to farm their land and cease to be a farm.

This added option needs to be removed for the following reasons:

A. We believe this is a violation of some principles and "rules" associated with developing, drafting, including provisions and protocols into a CAFO permit. Ecology staff over the years have explained for example one "rule" in permit drafting and construction is that permit conditions and requirements should or must be based on quality science. Another principle is that the provisions and practices in the permit are designed to prevent water quality problems and discharges on a CAFO. This added condition does neither. Specifically,

i. It is not science. – The statement at the bottom of page 5 of the DFW - Riparian Ecosystems, Vol. 2 manual (link above) states
"The information presented in this management recommendation document is not, in and of itself, science. Rather, it consists of policy recommendations which are informed by the best available science..."
We submit that if this is the new standard for allowing permit conditions, then anyone can ask to have their opinion included in the permit if they claim their suggestions and opinions are somehow informed by science.

ii. Even if it was science – which it is not – it is not water quality science. It is a collection of suggestions on wildlife buffer recommendations based on opinions of DFW staff. DFW staff are generally not trained on water quality Best Management Practices. Water quality protection practices should be based on appropriate water quality science with at least the best professional judgement of individuals trained in water quality protection rather than wildlife biology or the best riparian buffer for a bear or salmon migration.

iii. Finally, RE, Vol.2 dictates - as mentioned - that the riparian buffer shall include all the active flood plain (See page 8 of RE, Vol. 2) PLUS the distance of a 200-year-old site potential tree height. So, for example, every farm in a flood plain (i.e., Nooksack, Chehalis, or Snohomish Valley) - if they choose this option - would have to stop farming all their land in flood plain plus around another 230' and replant it back to native vegetation. Now the farm doesn't have land to spread nutrients and grow crops on. If the farm is out of the crop and dairy business, then it's not a CAFO anymore. Why would the department include an option that puts a crop and livestock farm out of business if it complies? We strongly question why this is being included in a Water Quality permit for livestock agriculture?

Suggested change –Eliminate the Language in S4.N3.a!!! It is wrong for all the reasons above.


5. Pages 22,24. S4. K.Sub.1- the Draft uses the word "nutrient" too loosely- from S4.K. Sub. 1- "the permittee shall ensure plant available nutrients do not exceed nutrients required to reach crop estimated yield." We ask Ecology to clarify, better define and improve consistency in language in the permit around what "nutrients" you all are referring to. Does the above referenced language mean all known Macro and Micronutrients or just nitrogen? Balancing for every nutrient on every crop, every year, for expected yield is impossible.

Suggested change – Clarify or improve the consistency in the use of the word "nutrient".
Attachments:

Comment From: Jon Borcherding

8/17/22 @ 2:15 PM
I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston and Yakima County Farm Bureaus.
We need to work with those who raise livestock on a small scale providing locally sourced food.
Applying CAFO stand...↓
Families and local producers need and DEMAND the freedom to produce necessary food on their own private property.
Ecology must recognize the work of the Volunteer Stewardship Program and local conservation districts instead of pushing for heavy-handed regulation.

Sincerely,
Jon M Borcherding
Roy WA
8/17/22
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Comment From: Cindy Wills

8/17/22 @ 2:05 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Cindy Wills
August 17, 2022
No attachments

Comment From: Heidi Howard

8/17/22 @ 1:59 PM
I oppose the CAFO rules that have been drafted. In a time like the world is in right now, you should be encouraging and educating farmers of all sizes on how to be good stewards of the land, not making it more difficult. This will only hinder our a...↓
No attachments

Comment From: Washington State Dairy Federat... (Jay Gordon )

8/17/22 @ 1:58 PM
Dr. Morris, Please accept our comments on the Draft CAFO permit and a supporting document that we include as we are suggesting a specific change to use T-sum 100 on the eastern side of the state. In our comments we referenced this document of earlier...↓
Thank you .
Attachments:
Download
Download

Comment From: Nicole Miller

8/17/22 @ 1:38 PM
Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima County Farm Bureaus
We need to work with those who raise livestock on a small scale providing locally sourced food.
Applying CAFO standards to...↓
Ecoloav must recognize the work of the Voluntarv Stewardship Proaram and local conservation districts.
Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.
Sincerely,
Nicole Miller
No attachments

Comment From: Anonymous Anonymous

8/17/22 @ 1:22 PM
I oppose the CAFO rules as drafted and concur with the comments of the Thurston, Benton, Grant, Okanogan, and Yakima County Farm Bureaus. I am concerned that this draft is too vague. It potentially implicates animal owners who are not operating a co...↓
No attachments

Comment From: rob inlow

8/17/22 @ 1:20 PM
We as producers do not need the state to force us into good stewardship, we already do this either on our own or in partnership with NRCS or like agencies for projects on our ranches. this just add another layer of burden to producers. Your broad wri...↓
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Comment From: Michele Marie

8/17/22 @ 1:05 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Michele Marie

August 17, 2022
No attachments

Comment From: Angele St Hilaire

8/17/22 @ 12:56 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Angele

August 17, 2022
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Comment From: Orca Conservancy (Steven Christianson)

8/17/22 @ 12:55 PM
To Whom it May Concern,

I would bring forward in comments, those submitted by Executive Director Shari Tarantino on August 14, 2022 for Orca Conservancy. I would also emphasize the following 6 concepts:

The WA Department of Ecology must make the follow...↓

1) Implantation of best management practices based on science which includes mandatory riparian buffers;

2) Implementation of "all known, available, and reasonable methods of prevention, control, and treatment" (AKART) for existing manure lagoons and compost areas;

3) Completely prevent violations of surface water quality standards and groundwater quality standards as outlined in Ch. 173- 201A WAC and Ch. 173-200 WAC, respectively;

4) Implement monitoring practices (visual inspections and soil sampling) sufficient to ensure compliance;

5) Provide public participation in the development of site-specific nutrient management plans, as required by the Clean Water Act;

6) Consider the effects of climate change, as required by Washington State Environmental Policy Act (SEPA).

Sincerely,
Steven Christianson, Esq. - President, Orca Conservancy
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Comment From: Anonymous Anonymous

8/17/22 @ 12:25 PM
This proposal is going to adversely affect small farmers, 4-H/FFA kids and their projects, backyard poultry and the like.
It will also have an affect on the "Buy local" movement that has been growing these past few years.
Washington Farm Bureau and oth...↓
This proposal is ambiguous and lacks scientific merit.
Remember, "Population will be limited to the local food supply in the future".

Paul
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Comment From: Evelyn Pratt

8/17/22 @ 12:22 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Evelyn Pratt

August 17, 2022
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Comment From: Patrick Leblanc

8/17/22 @ 12:15 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Patrick Leblanc
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Comment From: Gary Kocha

8/17/22 @ 12:13 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

[Gary Kocha]

August 17, 2022
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Comment From: Vivienne Kelland

8/17/22 @ 12:07 PM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

[Vivienne Kelland]

August 17, 2022
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Comment From: Troy Lenssen

8/17/22 @ 11:53 AM
I am writing you to note some concerns with this new CAFO permit regulations.
One area I really wish would be removed is the arbitrary dates. On page 22. Section S.4.J Sub 3. -Ecology has continued same arbitrary and rather ridiculous language requir...↓

Also, On page 29. S4.N, (3.a) Ecology added permittees a fourth option for "riparian protection" in addition to the standard options and language that there should be no manure applications within 100' of water body on bare dirt OR a 35' vegetative buffer OR no buffer if there is a berm or dike between field and water. No farm in a flood plain can or would choose this option since they would not be allowed to farm and cease to be a farm!

This is a violation of some principles and "rules" associated with developing a CAFO permit.
These rules are permit conditions and requirements must be based on quality science. Provisions and practices in the permit are designed to prevent water quality problems and discharges on a CAFO. This condition does neither. t's not science – The statement at the bottom of page 5 of the DFW RE, Vol. 2 manual states
"The information presented in this management recommendation document is not, in and of itself, science. Rather, it consists of policy recommendations which are informed by the best available science...". This opens up the permit process to anyone with a 'opinion'....quite problematic.

On pages 22 - 24. S4.K. (1)- the Draft uses word "nutrient" too loosely- from S4.K. Sub. 1- "the permittee shall ensure plant available nutrients do not exceed nutrients required to reach crop estimated yield." We will ask Ecology to clarify, better define and improve consistency in language in the permit around what "nutrients" are they referring to. For example, does the above language mean all known Macronutrients and Micronutrients or just nitrogen.

Balancing for every nutrient on every crop, every year, for expected yield is impossible on every farm everywhere.
.
Regard,
Troy Lenssen
President Whatcom County Farm bureau
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Comment From: Elio Serra

8/17/22 @ 11:44 AM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Elio Serra

August 17, 2022
No attachments

Comment From: Valerie Serra

8/17/22 @ 11:36 AM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Valerie Serra

August 17, 2022
No attachments

Comment From: Rose Shepherd

8/17/22 @ 11:33 AM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus.

We need to work with...↓

Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,

Rose Shepherd

August 17, 2022
No attachments

Comment From: Washington State Senators (Senator Judy Warnick)

8/17/22 @ 11:32 AM
Attachments:

Comment From: Johnny Huston

8/17/22 @ 11:19 AM
Dear Ecology,
We wish to submit the following comments on behalf of the members of the Benton, Grant, Okanogan, and Thurston County Farm Bureaus.
In reviewing the updated CAFO documents we agree with the Washington State Dairy Federation and the Washin...↓
This program and associated permit requirements should stay focused on water quality and must not become a forum or tool to address other desired, but unrelated, public policy issues. A number of new requirements (as addressed specifically by the Dairy Federation) include policy recommendations that go beyond the direct impact of livestock operations. Ecology should resist including additional regulations beyond the direct focus of the CAFO program.
We now wish to focus on a major flaw in the CAFO program. Specifically related to small CAFOs. Ecology should rewrite section S1 of the CAFO General Permit to eliminate the small CAFO designation or at least better define what a small CAFO is and how Ecology determines if an operation is a significant contributor of pollutants to surface water.
This provision should be eliminated due to Ecology's own finding that application of CAFO standards to small operations has a "disproportionate expense" to those farms. (Economic Impact Analysis 2017 and 2022)
Additionally, the definition of small CAFO (less than the number of animals for a regular CAFO), is overly broad and not understood as to the significant implications on Washington rural residents. The predominant understanding is that the CAFO designation applies to feedlots and larger operations that concentrate significant numbers of animals. Few outside of large commercial operations are even aware of the Small CAFO provisions, let alone the fact that they could apply to a "herd" of one animal as well as to animals not specifically listed in the permit language. We believe significant public outreach and communication must take place (including greater emphasis on public comment) to ensure landowners are aware of these provisions.

This confusion and lack of knowledge is further compounded by the fact that Ecology discretion determines if an operation is "a significant contributor of pollution," triggering the costly CAFO permit for small operations. Lack of a clear definition of "significant contributor" means animal owners do not have a clear standard to meet, but are completely subject to the discretion of Ecology staff.
When the significance of penalties is added into this equation, we reach the level of greatest concern. Violations of the act are subject to penalties of up to $10,000 per violation per day, plus costs of prosecution, or imprisonment at the discretion of the court.
We believe that application of CAFO standards puts small farming operations, especially backyard farmers who raise a few animals to feed their family and neighbors, at great risk. The permit does not provide additional, scientifically proven benefit to clean water. Rather, it threatens local food production and places our overall food security at risk. All of this is based on broad discretion by Ecology staff as to what constitutes pollution.
In recent months, we have seen how devastating interruptions in the supply chain can be. Delays, cost increases, and empty shelves were clearly visible. Local food production helps blunt these impacts. Eliminating or discouraging small scale agriculture will exacerbate the problem.
Rural landowners need to be fully informed of these impacts and significant outreach and public education must be delivered prior to consideration of extension of these regulations to small operations. The good news is there is already a process making great strides in this area.
We strongly recommend Ecology change course. The answer is not the current approach but providing a robust technical assistance effort and relying on proven ways to reach compliance. We have an excellent option for 27 counties in the state- the Voluntary Stewardship program (VSP). For the other counties, conservation districts are designed to deal with these issues through technical assistance and the development of farm plans as appropriate. The success of VSP turns on community outreach and strong landowner technical support.
Now is the time for Ecology to rethink this process and move forward with an alternative, collaborative program that ensures effective environmental protection, respects the rights of private landowners, and focuses on voluntary measures to achieve desired goals while also ensuring local food security. Directly connecting with VSP will help guarantee success.
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Comment From: Denise Bryant

8/17/22 @ 11:02 AM
So after reviewing information I received on this topic and reading material on the DOE site, and looking at the language, I strongly oppose this. As written it is very broad and could negatively impact small operations and the backyard farmer who b...↓
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Comment From: Anonymous Anonymous

8/17/22 @ 10:53 AM
I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima County Farm Bureaus.
We need to work with those who raise livestock on a small scale providing locally sourced food.
Applying CAFO standards to small opera...↓
Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts.
Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.
No attachments

Comment From: Chuck Hopkins

8/17/22 @ 10:40 AM
I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima County Farm Bureaus. We need to work with those who raise livestock on a small scale providing locally sourced food.
Applying CAFO standards to small oper...↓
Instead of regulating, Ecology need to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,
Boyd C. Hopkins
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Comment From: Phyllis Farrell

8/17/22 @ 10:33 AM
Greetings, I am a citizen concerned about both global warming and the impact of current farming practices. I grew up in Iowa where the Farm Bureau was a conservation group (no longer!). My father practiced what is now known as regenerative farming...↓

Regarding the proposal to reissue Concentrated Animal Feeding Operation (CAFO) National Pollutant Discharge Elimination System and State Waste Discharge General Permits, I have several comments:
*DOE has failed to consider the impacts of climate change in authorizing CAFO discharge into our waterways.

* In the draft, there is no requirement for all WA CAFOs to obtain permits. This means that over 200 WA CAFOs are discharging to ground and surface water, and no one is measuring the discharge or regulating it.

* Washington is looking closely at requirements for riparian buffers and DOE has developed draft guidelines that will protect salmon from pollution and save salmon habitat. These guidelines should be an enforceable part of the CAFO permit, and they are not.

* There are 53 CAFO dairies in Western Washington flood plains. Last fall, DOE spent several hundred thousand dollars helping Whatcom County farmers pump manure out of lagoons to prevent overtopping during extreme flooding. With Climate Change, these extreme weather events will increase, including flooding that sends pollutants directly into the rivers and into Puget Sound.

*DOE has an obligation to define "All Known, Available and Reasonable Technology" (AKART) for CAFOs, and we don't see that definition in the permit.

*Manure lagoons contribute to global warming. Storing manure in lagoons produces methane, a GHG far more potent than CO2. Washington State sends over a million metric tons of GHG CO2 equivalent into the atmosphere every year from manure lagoons. When cows are kept on pasture, this does not happen. I sympathize with farmers who followed the best available advice when they built lagoons years ago.R They were told, and they believed, that lagoons would protect the environment. Now, we know that the side effects are huge, and I wish to see farmers assisted in transitioning away from this practice.
Respectfully,
Phyllis Farrell
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Comment From: Larry CAMPBELL

8/17/22 @ 10:29 AM
LIVESTOCK FEEDING OPERATIONS HAVE PLENTY OF RESTRICTIONS ALREADY, THIS IS ANOTHER CONTROL ON PEOPLE BY CONTROLING HOW MUCH FOOD IS PRODUCED, AND BY PUTTING US FARMERS AND RANCHER OUT OF BUSINESS, ALL THE FOOD WILL HAVE TO COME FROM OTHER COUNTRIES, I...↓
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Comment From: Amy Malik

8/17/22 @ 10:22 AM
Chelsea Morris
Washington Department of Ecology
PO Box 47696,
Olympia WA 98504-7696

Dear Chelsea,

I oppose the CAFO rules as drafted and concur with the comments of the Benton, Grant, Okanogan, Thurston, and Yakima County Farm Bureaus. Why would you crea...↓

We need to work with those who raise livestock on a small scale providing locally sourced food.
Applying CAFO standards to small operations, will be devastating to local food production and our overall food security.

Ecology must recognize the work of the Voluntary Stewardship Program and local conservation districts. Instead of regulating, Ecology needs to encourage participation in these voluntary programs, proven to protect water quality.

Sincerely,
Amy Malik
August 17, 2022
No attachments

Comment From: Sherrie Zollinger

8/17/22 @ 10:11 AM
While I am in favor of limits on feed lots, and other large commercial growing operations that produce "serious" amounts of methane and other toxic stuff, I am NOT in favor of limiting people who "grow" their own animals for food or for limited distr...↓
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Comment From: Mardi Perry

8/17/22 @ 10:04 AM
There is a portion that states this applies even if you have only one animal! This should not be the case!! Please stop taxing EVERYTHING! Now, the state literally wants to tax poop?? I realize this is a "permit" not technically a tax - but nonet...↓
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