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

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Comment From: Jeff Chapman

8/14/22 @ 11:03 PM
With the State Board of Health very recently revising the WAC for Domestic Animal Waste WAC 246-203-130 to regulating "domestic livestock" manure for water quality issues, there is a concern that this will be coupled with small CAFOs when County heal...↓
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Comment From: Melissa Swan

8/14/22 @ 10:09 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 Okanogan, Thurston and Yakima County Farm Bureaus.

We need to work with those who raise liv...↓

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,



Melissa Swan


August 17, 2022
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Comment From: Lacie Rotella

8/14/22 @ 9:48 PM
Including small hobby farms and animals owners in CaFo will be devastating to local small operations. With inflation and cost to keep animals in todays market the vast majority have already been forced to quit operations and including this to the lis...↓
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Comment From: Mary Annoni

8/14/22 @ 8:07 PM
Concentrated Animal Feeding Operation (CAFO) General Permits Reissuance Public Comment Period
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 ...↓



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.
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Comment From: William Townsend

8/14/22 @ 7:01 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 o...↓
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Comment From: Rebecca Wheeling

8/14/22 @ 6:21 PM
We oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima County Farm Bureaus. Those of us in agriculture are the best stewards of the land and should be respected not restricted in our efforts to feed local ci...↓
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Comment From: River's Edge Ranch (Jennifer Sather)

8/14/22 @ 6:19 PM
Our family run rotational regenerative grazing ranch supports not only our family, but multiple other local, county and WA businesses and their employees.

The DOE does a poor job of defining "large," "medium," and "small" CAFO. Being subject to DOE de...↓

Will the DOE consider confining animals for safety a "CAFO"? Note due to WA poorly controlled predator issue and regulations, animals must be confined for their safety at night and especially during birthing seasons. Another undue pressure on our farmers and ranchers, that has added cost to mitigate or reduce losses incurring large costs to combat with no reimbursement from the state.

Our ranch is located near many water sources and 100-foot setbacks from surface water are burdensome, costly and down right impracticable not to mention has been the subject of frequent attacks on small farmers and landowners in recent proposed laws, to which this is another. Not only would this impact seasonal grazing and the subsequent fire-protection it abides to neighbors including fellow grain farmers who benefit from control of flammable grasses.

35-foot vegetative filter strips/dirt berms to mitigate nutrient leaching are burdensome and costly.
Soil tests take weeks to be returned, undercutting the ability to apply nutrients to fields at crucial times, along with post-harvest soil tests with a hard deadline of Oct. 1 are impractical. Farmers and ranchers who are successful at tending to their ground know their ground, area and weather better than any bureaucrat.

We, strongly oppose this rule and urge you to side with farmers and ranchers to the best of our communities, food supply chains and our environment as we ARE the best stewards of the land and rules like this will put our family and small ranchers out of business, especially in an already depressed economy of Eastern Wa.
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Comment From: Lee Grauman

8/14/22 @ 6:07 PM
I am in absolute opposition to any of the proposed changes. I think our government has no business in the lives of small farms. I see this as only harmful to the already waining family farms in Washington state. We should have confidence in the respo...↓
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Comment From: Donald E Morgan

8/14/22 @ 6:01 PM
Skip to the content
RuralCitizens.org
We Are Citizens For Independent Rural Living, Food Production, And Sound Stewardship
Supporting Your Right
To Grow & Raise Your Own Food
Allowed? Denied! CAFO - Not CAFO?
Ecology's new proposed rules define what a CAFO...↓

As such, these new proposed rules could (at Ecology's discretion) classify anyone who raises animals as operating a CAFO and be subject to complex and very costly regulations with potential harsh penalties.





WOULD YOU....

• Like Ecology AS YOUR "Landlord"?
•Enjoy Ecology DICTATING whether you can have animals or not?
•Want costly permits & inspections for the "privilege" of keeping animals?
•Be able to afford up to a $10,000 fine PER DAY?
•Be willing to serve jail-time just for raising animals?

If your answer is NO! – Take Action NOW!

A CAFO is a CONCENTRATED Animal Feeding Operation. The program was designed for confined-feed lots with high concentrations of animals and waste.

A small CAFO is defined by ecology as anything "less than – 150 horses, 300, beef, 15– ducks or 25,00 laying hens."

If you have at least one animal – you could qualify as a small CAFO! Ecology has complete discretion determining if you are a small CAFO.

The Department of Ecology can apply CAFO requirements to small producers, home farmers, and horse owners, as if they were bad stewards.

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

August 14, 2022

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 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,

Donald E Morgan
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Comment From: irene morgan

8/14/22 @ 5:47 PM
Skip to the content
RuralCitizens.org
We Are Citizens For Independent Rural Living, Food Production, And Sound Stewardship
Supporting Your Right
To Grow & Raise Your Own Food
Allowed? Denied! CAFO - Not CAFO?
Ecology's new proposed rules define what a CAFO...↓

As such, these new proposed rules could (at Ecology's discretion) classify anyone who raises animals as operating a CAFO and be subject to complex and very costly regulations with potential harsh penalties.





WOULD YOU....

• Like Ecology AS YOUR "Landlord"?
•Enjoy Ecology DICTATING whether you can have animals or not?
•Want costly permits & inspections for the "privilege" of keeping animals?
•Be able to afford up to a $10,000 fine PER DAY?
•Be willing to serve jail-time just for raising animals?

If your answer is NO! – Take Action NOW!

A CAFO is a CONCENTRATED Animal Feeding Operation. The program was designed for confined-feed lots with high concentrations of animals and waste.

A small CAFO is defined by ecology as anything "less than – 150 horses, 300, beef, 15– ducks or 25,00 laying hens."

If you have at least one animal – you could qualify as a small CAFO! Ecology has complete discretion determining if you are a small CAFO.

The Department of Ecology can apply CAFO requirements to small producers, home farmers, and horse owners, as if they were bad stewards.

CAFOs are required to meet invasive and expensive planning and reporting requirements. Ecology admits that CAFO requirements have "a disproportionate impact" on small operations. If you raise livestock; whether they are a hobby, pets, horses to ride, or just chickens for eggs – you are on the hook!

WHAT COULD THIS DO TO OUR ASPIRING YOUNG FARMERS IN 4H AND FFA?

AND – if you plan to use your livestock's manure or "chicken-tea" as fertilizer on your garden, these rules will prevent you from manure application "24 hours before a rain event" – an almost impossible task! Even NOAA cannot reliably predict weather, so how can you work within these arbitrary and capricious parameters?

Do you know where every seasonal pond on your property is? If your livestock come in contact them – you will be in violation!

Fencing every pond is not only costly, but it is not a science based approach. Will you be able to free-range your chickens or let your horse roam your pasture? Not likely...

There Is An Alternative

Ecology must recognize the good work of the Voluntary Stewardship Program and local conservation districts.

Instead of regulating, they should encourage participation in these voluntary programs proven to protect water quality.


WE NEED TO TAKE ACTION


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

August 14, 2022

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 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,
Irene F Morgan
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Comment From: Carmelita Hoogkamer

8/14/22 @ 5:27 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 t...↓

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,

Carmelita Hoogkamer
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Comment From: Cassie Townsend

8/14/22 @ 3:32 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 standard...↓
Sincerely,
Cassie Townsend
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Comment From: Royal Hudspeth

8/14/22 @ 3:25 PM
No to CAFO. Government need to stop trying to tell us what we can and can't grown. I raise my own meats and food. Now the government wants to take that all aways from us small farmers.
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Comment From: Nancy Spain

8/14/22 @ 3:22 PM
I oppose the CAFO rules as drafted and agree with the comments of Okanogan, Thurston and Yakima County Farm Bureau.
We should be working with those that raise livestock on a small scale which provides locally scorched food.
Applying the proposed CAFO s...↓
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Comment From: Jean Handley

8/14/22 @ 3:18 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...↓
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Comment From: David Fong

8/14/22 @ 3:10 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 Okanogan, Thurston and Yakima County Farm Bureaus.

We need to work with those who raise liv...↓

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, David Fong
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Comment From: Marilyn Kelly

8/14/22 @ 3:02 PM
I (our family) oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima Farm Bureaus. There needs to be more cooperation with those who raise livestock on a small scale providing locally sourced food. Families a...↓
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Comment From: Sonya El Debssi

8/14/22 @ 2:38 PM
Concentrated Animal Feeding Operation (CAFO) General Permits Reissuance Public Comment Period

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 ...↓

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,

Sonya
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Comment From: Michael Gilskey

8/14/22 @ 2:07 PM
This set of regulation is much too broad and ambiguous. Rural residents in county locations with just a few animals for local production, 200 animals or less, shouldn't even need a permit, especially if it is simply a homeowner having a few dozen ch...↓
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Comment From: Patricia Richker

8/14/22 @ 1:53 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 Okanogan, Thurston and Yakima County Farm Bureaus.

We need to work with those who raise liv...↓

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.
No attachments

Comment From: Michor Gentemann

8/14/22 @ 12:48 PM
I OPPOSE THE RULES OF CAFO AS DRAFTED AND I CONCUR WITH THE COMMENTS FROM Thurston, Yakima, AND Okanogan County Farm Bureau.
Applying CAFO standards to small operations (if even considered seriously) needs, at the very least, to change the number of a...↓
Locally produced and sold foods sustain our communities, especially in a time like this when prices have risen so much many people can no longer even afford the groceries to care for and feed their families. Local produce right now is truly a Godsend and lifesaver for many families.
Additionally, in the long run, ecologists' PURPOSE is to look forward to the future and maintain the programs that DO support the ecological goals we have set in each State or district to be good stewards.
Local grassroots experiences TEACH each economical and ecological stewardship management of our lands, streams, animal, and vegetable local food sources to ALL ages! Much is hands-on, experience-based; AND much is volunteer because we so believe in doing this right!
Our local conservation districts and our voluntary programs need support from you NOT MORE REGULATIONS.
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Comment From: Janet Kerns

8/14/22 @ 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 Okanogan, Thurston and Yakima County Farm Bureaus.

We need to work with those who raise liv...↓

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,



Janet Kerns



August 17, 2022
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Comment From: Jason Veach

8/14/22 @ 11:47 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 Okanogan, Thurston and Yakima County Farm Bureaus.

We need to work with those who raise liv...↓

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,

Jason Veach



August 14, 2022
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Comment From: Dean Rae

8/14/22 @ 11:46 AM
I 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

This provision should be eliminated due to Ecology's own find...↓
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. This definition must be changed to eliminate anyone other than the large feedlots who actually ARE concentrated feeding operations.
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Comment From: Karen Rae

8/14/22 @ 11:43 AM
I 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

This provision should be eliminated due to Ecology's own find...↓
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. This definition must be changed to eliminate anyone other than the large feedlots who actually ARE concentrated feeding operations.
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Comment From: Bill McCarthy Answers

8/13/22 @ 9:00 PM
I fully support the Farm Bureaus plan to allow them to follow the Voluntary Stewardship program (VSP). It is difficult enough to raise a few cattle, sheep, goats, poultry for resale and extra income without having to deal with burdensome regulation. ...↓
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Comment From: Francis Fauls

8/13/22 @ 8:32 PM
I oppose the CAFO rules as drafted and concur with the comments of Okanogan, Thurston and Yakima County Farm Bureaus.
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Comment From: Gerald Steel

8/13/22 @ 5:55 PM
Chelsea Morris, WDOE
PO Box 47696, Olympia WA 98504-7696

Dear Chelsea,

I oppose applying DOE rules to operations currently proposed to be defined as a "small CAFO." Cities and County's have the right and obligation under the GMA to protect critical are...↓
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Comment From: Ronald Cox

8/13/22 @ 5:47 PM
This proposed program (CAFO) should only apply to areas that endanger water sources or have animals for commercial use ie. dairy, meat, wool, or any other commercial use. Personal pets or hobby animals (horses to ride etc.) should be excluded as sho...↓
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Comment From: Erica Fehr

8/13/22 @ 3:39 PM
Attachments:

Comment From: Friends of Toppenish Creek (Jean Mendoza)

8/13/22 @ 8:54 AM
Dear WA Dept. of Ecology,
Please accept the attached comments on the proposed NPDES permits for CAFOs from the Friends of Toppenish Creek.
Thank you.
Jean Mendoza
Attachments:
Download
Download

Comment From: Agrimanagement Inc (Scott Stephen)

8/13/22 @ 8:47 AM
Attachments:

Comment From: James Hanson

8/13/22 @ 8:31 AM
To maintain a vibrant, healthy enviroment you must allow innovators and producers to flourish. This arbitrary rule making is one more step toward enviromental destruction. Please remove the yoke of bureaucracy from the producers before it's too late....↓

Also you should not consider any comments from individuals or groups from other states and countries.
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Comment From: Fred Likkel

8/12/22 @ 8:48 PM
Attachments:

Comment From: Angelika Wieczorek

8/12/22 @ 8:44 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 Okanogan, Thurston and Yakima County Farm Bureaus.
We need to work with those who raise l...↓
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, Angelika Wieczorek August 12, 2022
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Comment From: mark stanley

8/12/22 @ 7:55 AM
You must be joking. I oppose this. We are in the USA, not the old Soviet Union.
First, for the Washington State Department of Ecology to refer to themselves in any document as "Ecology" is questionable from a legal perspective, and imbecilic from a li...↓
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Comment From: Victoria Blazejewski

8/11/22 @ 2:44 PM
This proposal utterly oversteps Ecology's jurisdiction and control. It attempts to control agriculture/animal husbandry in an already over-burdened regulatory state. It will also adversely impact producers, thus adding an addition endangerment to th...↓

Victoria Blazejewski
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Comment From: Mary Tereszkiewicz

8/11/22 @ 2:28 PM
I am totally against this 'money grabbing' proposal. Leave people alone to their own private lives.
We do not need the Department of Ecology to CONTROL and INVADE people's PRIVACY! We don't need another police force! This is a violation of people's ...↓
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Comment From: Anonymous Anonymous

8/11/22 @ 8:37 AM
The draft permit as written does not exclude small hobby farms. There needs to be a minimum quantity per land unit set forth to qualify as a CAFO and allow exclusions for small hobby farms.
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Comment From: GEORGE JOHNSON

8/11/22 @ 8:03 AM
I am a small farmer in Enumclaw Wa. The DOE proposed CAFO permit requirements will disproportionately burden small business farms, and put them in a position of having to try to comply CAFO regulations that will ultimately spread to all farms, with ...↓
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Comment From: Michael Stockin

8/10/22 @ 11:17 PM
This law would be exceedingly harmful to small family farms. I urge the state to reconsider this legislation. Food security depends on the supports and cultivation of small, local agricultural assets. Please do the right thing.
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Comment From: Chris Cochrane

8/10/22 @ 10:37 PM
Please do not pass this as it is one size fits all and will destroy small family farms. This will harm the local production of food. We are seeing in unprecedented in modern times the need for additional local sources of food with food shortages over...↓
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Comment From: noah whitney

8/10/22 @ 6:08 PM
This is another way to put farmers out of business and increase food prices. People raising their own livestock for personal use will also suffer. This should not happen! Don't penalize farmers and people just trying to put food on their table.
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Comment From: Sean Ziemathis

8/10/22 @ 5:49 PM
Individuals, villagers and towns like ours have held livestock in pens, barns and fields for centuries without any harm to the environment. My comment is an absolute NO to this absurd idea of taking away our independence.
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Comment From: Scott Lisonbee

8/10/22 @ 5:14 PM
Wow!!! No absolutely not!!!

I should not be amazed by the audacity of the power you are attempting to wield with this proposal. First full disclosure I do not have any livestock at this time. I have in the past (not at my current property)raised cow'...↓

I also suspect the current world view for a growing number of government officials is that "we the citizens " are seen as surfs peasants or subjects for the government to beneficently grant us privileges as they see fit. Never mind that pesky Constitution it is so old fashioned and we will just do as we please. What does our governors buddy Klaus say "you will own nothing and you will be happy ".

Good luck with your quest to crush us. You might want to ask the Dutch government how that is working out for them.
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Comment From: Hettie cochrane

8/10/22 @ 1:13 PM
I appose the CAFO rules as drafted and agree with all of Washington State Farm Bureaus. Decimating small local farms are depriving communities of fresh locally raised food sources that cut down on climate change effects not increase them. Devastati...↓

Regretfully,
Hettie Cochrane
august 10, 2022
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Comment From: Magali Cota

8/09/22 @ 1:44 PM
Like many other concerned citizens I am aware of the negative effects CAFOs have on our communities. From developmental issues in infants to the toxins absorbed by wildlife, CAFOs should be a concern to all of us, but more specifically to the agency ...↓

During the CAFOs permitting process the Department of Ecology has the opportunity to regulate CAFOs as defined by the Clean Water Act and to abide by the Washington State Court of Appeals' order to rewrite the Washington CAFO water pollution permit to protect Washington's waters from contamination and to take climate crisis into account. Ecology has the opportunity to enact important provisions, which would require the use of modern pollution control technologies and practices to eliminate discharges to waterways and protect our communities. I am supporting these updates because as currently written, not only do these permits fail to protect our communities and environment, but they also violate federal and state law.

We have a brief window to make positive changes to the CAFOs permits before Washington is significantly affected by the pollution created by ineffective CAFOs regulations and climate change. As a Gonzaga law student and resident of Spokane, I encourage the Department of Ecology to rewrite and champion these important updates to the CAFOs permits to improve the livability of our community for all residents.

I appreciate this opportunity to comment on both the draft CAFO general permit AND the associated SEPA DNS. Please do your jobs better.


Sincerely,
Magali Cota
Spokane resident
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Comment From: Natural Resources Conservation... (Don Hanson)

8/09/22 @ 10:57 AM
Attachments:

Comment From: Terra Leigh Bell

8/08/22 @ 5:12 PM
Dear Department of Ecology,

I am a born-and-raised Washingtonian, and the granddaughter of farmers. I am writing to share my concerns with you regarding the Draft Concentrated Animal Feeding Operation (CAFO) General Permits proposed in June 2022 (the ...↓

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 already 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,

Terra Leigh Bell
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Comment From: Paul Cox

8/05/22 @ 11:32 PM
This is a ridiculous over reach of state government. Stop the insanity of trying to regulate everything down to such a small scale.
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Comment From: Tawna Hubbard

8/05/22 @ 12:16 PM
Concentrated toxins from over populated cattle lots seeps into ground water, runs into nearby streams during seasonal high water events, destroys soil health for future farming needs to grow ground crops and must empilement mitigation strategies to a...↓
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Comment From: Anonymous Anonymous

8/03/22 @ 6:43 PM
Attachments:

Comment From: Center for Food Safety (Joey Lee)

8/03/22 @ 5:35 PM
I have attached 269 comments on behalf of 269 Center for Food Safety members who live in Washington.

The comments read as follows:

I am a Washington resident and I am not satisfied with the Draft Concentrated Animal
Feeding Operation (CAFO) General Perm...↓
require adequate technology, or sufficient monitoring and reporting, to prevent
pollution from reaching our waterways. This draft permit ignores the Department of
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.
Attachments:

Comment From: Kate Lunceford

8/03/22 @ 8:37 AM
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 comment.

I think CAFOs are ...↓

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,
Kate Lunceford
No attachments

Comment From: priscilla martinez

8/02/22 @ 8:43 PM
We need to take better care of what is left of our environment, for wildlife, marine life, plant life, and people.
No attachments

Comment From: James R. Nichols

8/02/22 @ 7:01 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,
James R Nichols
No attachments

Comment From: Derek Benedict

8/02/22 @ 6:27 PM
Dear Department of Ecology,

I am an ecological and environmentally aware 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 "dr...↓

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,

Derek Benedict
No attachments

Comment From: Joanna Curran

8/02/22 @ 5:18 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 concerned that the draft permit does not require sufficient protections to prevent pollution from entering our waterways, and I encourage you to consider some suggestions. Please keep our society and state in a continual state of improvement. The final permit is an opportunity to require that applicants implement (1) modern technologies to prevent leakage from waste storage facilities and lagoons, (2) surface and ground water monitoring that will detect pollution so that accidental pollution may be cleaned up, and (3) include science based BMPs that will aid in preventing accidental spillage or overapplication from harming aquatic systems. These can be as simple as a riparian buffer, which provides additional benefits of bank stabilization. In short, I urge Ecology to keep our state an example of how our society can continue to do better.

Respectfully,
Joanna Curran
No attachments

Comment From: Lori Stefano

8/02/22 @ 2:43 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,

Lori Stefano
No attachments

Comment From: Virginia Davis

8/02/22 @ 12:45 PM
Thank you for the opportunity to comment on the Concentrated Animal Feeding Operation (CAFO) General Permit draft permit. I urge Ecology to comply with the recent court order to implement reasonable, science-based protections for people, water, and ...↓

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.
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.
No attachments

Comment From: Abbey Olivo

8/02/22 @ 10:41 AM
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,
Abbey Olivo
No attachments

Comment From: Patrick Conn

8/02/22 @ 10:35 AM
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 this draft permit, like so many before, 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 constantly been raised by members of the public in the past, and the Appellate Court's recent opinion finally affirms that these issues MUST BE FORMALLY ADDRESSED. I am also concerned that Ecology (for what unconscionable reason I cannot comprehend) has not adequately addressed or mitigated the SCIENTIFICALLY PROVEN and DOCUMENTED climate impacts that can be caused by CAFOs, nor the impacts CAFOs can have on nearby communities—including communities impacted by environmental injustices. This should be addressed IMMEDIATELY.

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,
Patrick Conn
No attachments

Comment From: Leah Murr

8/02/22 @ 10:04 AM
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 lives 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, Leah Murr
No attachments

Comment From: Dean Jackson

8/02/22 @ 9:56 AM
Washington State Department of Ecology

At this time has the Department of Ecology requested private industry farmers to conduct their own investigations of CAFO's and to report their findings accordingly? A simple question and I'm sure the DOE has co...↓

Thank You
Dean Jackson
Mountlake Terrace, WA
No attachments

Comment From: Matthew Anderson

8/02/22 @ 9:52 AM
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,

Matthew Anderson
No attachments

Comment From: Martha Hall

8/02/22 @ 9:23 AM
I am a resident of WA State. I have lived in several counties where concentrated farm animals of over 100 mostly dairy cows or livestock raised for meat were kept in small areas. I've seen and read about how this impacts the ground water, wells, and ...↓

I'll mention just a few of the things that are not adequately addressed in the draft. First, one of the primary tasks for the DOE is to protect our streams and rivers and the draft does not do this. The draft fails to address the all too often leaks from manure storage. It fails to adequately address pollution from manure applied to fields. Why isn't the best science used for establishing riparian buffer where no manure can be added? Why isn't regular water quality monitoring and reporting through an unbiased process required? Too often heavy snowfall and/or rainfall have created unusual run-off that deposits this manure in our streams and rivers. How will DOE make sure that in extreme events this does not happen? Climate change is here and is impacting our state in many ways. Why are these changes not disclosed and addressed? We've seen and heard about manure storage facilities and lagoons leaking.
It doesn't require rocket science to address these problems. Reliable monitoring equipment is available, equipment that monitors and reports data. Why doesn't DOE require use of these? It is also
possible to develop standards that limit the amount of manure that goes on fields so this manure stays on these fields. We know how wide riparian buffers must be to protect riparian areas in extreme weather events. The people of our state count on the Dept of Ecology to know how to regulate dairies, livestock feed lots, and other facilities where livestock are contained.

Why do we still have documentation that proves that excess nitrates, E. coli, and fecal coliform bacteria from concentrated animal feeding operation are still polluting our state's waterways? Why are some communities still being impacted by these? Why isn't DOE requiring the best science and practices that are required by the Clean Water Act? Millions of dollars have been spent in our state to improve our streams and rivers. This is often done to help salmon. Yet DOE refuses to step up the plate and do what it is required to do, protect our streams and rivers from livestock operations? Please do your job. The people of our state highly value our riparian areas, our wetlands, streams and rivers, and the many species of wildlife who need these to be protected in order to survive.

I am personally upset by the lack of standards and requirements for feed-lots and places where large numbers of livestock are confined before being slaughtered in our state. I drive by one outside of George, WA, which should be closed. That any animal is forced to live in a horrible facility like this one until they are slaughtered is horrendous. On very hot day so many animals must be suffering and I'm sure some die. How can our progressive state not care about this?

Thank you for reading these comments,
Martha Hall
Anacortes, WA
No attachments

Comment From: Stuart Mork

8/02/22 @ 8:54 AM
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,

Stuart Mork
No attachments

Comment From: MaryJane Gasdick

8/02/22 @ 8:32 AM
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 comment.


I'm greatly concer...↓


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.



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,
MaryJane Gasdick
No attachments

Comment From: JL Angell

8/02/22 @ 8:26 AM
I want to see the new draft permit implement science-based protections for Washington's public health and environment. I have concerns with you regarding the Draft Concentrated Animal Feeding Operation (CAFO) General Permits proposed in June 2022 (th...↓

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.

I look forward to your revisions addressing all of the above to actually meet the standards of the law and court decisions.
No attachments

Comment From: Washington Cattle Feeders Asso... (Jack Field)

8/02/22 @ 7:05 AM
Attachments:

Comment From: Darlene Schanfald

8/01/22 @ 9:14 PM
Why are we having this conversation about permitting CAFOs? This and other permit "input "opportunities" are a waste of the public's time and Ecology's time and budget; i.e. public funds. And personally, I would be selling out myself by participatin...↓

CAFO is a major polluting industry and WA State should be cancelling permits for CAFOs of any kind – land and water (e.g. industrial aquaculture CAFOs-of-the-sea). Ecology, as an agency, needs to turn itself around and actually protect the environment. We need a director of Ecology that promotes ecology, not industries.

CAFOs emit methane which damages the air and the damaged air circulates globally. CAFOs, damage water bodies and aquifers. Permits are an aide to continue the pollution. And think cumulative effects.

This is a cruel industry. CAFO treatment of animals is inhumane and unethical. Crowding the animals and making them graze on food abnormal to their natural dietary needs, including forcing them to graze on sewage-laden fields, stresses and "toxifies" the animals. The toxic animals and their meat and milk are fed to humans. What Ecology permits is damage-to-human-health and an increase in human health problems and medical costs. Has staff no conscience? No compassion?

Ecology takes money to clean up Puget Sound, yet permits it to be polluted. We have a global meltdown and this industry, around the country, significantly contributes to global warming. It is perilous enough without the WA State Department of Ecology wanting to permit the worsening of the already dire situation.

Ecology seems to be in business to support industries. Does Ecology staff not read the news on the damage the CAFO industries cause, as well as other industries it permits?

How can this agency, in any degree of good consciousness, continue as it is? It should be changing RCWs and WACs to protect the health and welfare of our natural resources, wildlife and public health.

Stop the cruelty. End permitting CAFOs.
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Comment From: Esther Kronenberg

7/31/22 @ 2:51 PM
The draft NPDES permits for CAFO's are not stringent enough to protect Washington state waters.

It does not include ALL CAFOs, thus leaving 200 or more completely unregulated.
It does not provide for enforcement of riparian buffers to protect salmon.
It...↓
It does not consider the effects of methane on climate change.

Please correct these deficiencies and provide effective enforcement to protect our environment.
Thank you.
No attachments

Comment From: Yonit Yogev

7/30/22 @ 4:42 PM
To Whom it May Concern,
Below are some of my concerns about permitting for CAFOs.

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 mea...↓

* 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. We sympathize with farmers who followed the best available advice when they built lagoons years ago. They were told, and they believed, that lagoons would protect the environment. Now, we know that the side effects are huge, and we wish to see farmers assisted in transitioning away from this practice.
It is my hope that CAFOs will eventually be eliminated altogether. I realize this is a process and hope that you will take these comments to heart. Thank you.
No attachments

Comment From: JJ Lindsey

7/30/22 @ 2:27 PM
I'm very concerned about the many problem issues which CAFO's create.
As a vegetarian, my vast preference would be to never see a cow have to live under such conditions which cruelly fail to recognize that they are sentient and worthy life forms, not ...↓
I strongly request that we SEE these operations in all their polluting, cruel, methane-producing truth.
We need to commit to the acknowledgement of these truths, and legislate and make rules accordingly.

Particularly concerning:
~ DOE has failed to consider the impacts of climate change in authorizing CAFO discharge into our waterways. THIS IS CRUCIALLY IMPORTANT IN THIS DAY OF CLIMATE CRISIS, AND MUST BE PRESENT GOING FORWARD.

~ In your draft, there is no requirement for all Washington 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. How are we allowing this under federal Clean Water Act?

~ Washington is looking 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....BUT THEY ARE NOT!

~There are 53 CAFO dairies in Western Washington flood plains.
Last fall, DOE spent a lot of money helping Whatcom County farmers pump manure out of lagoons to prevent polluting 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. Where is it??

~ Manure lagoons contribute to global warming.
Storing manure in lagoons produces methane, a Green House Gas (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. Farmers may have followed the best available advice when they built lagoons years ago. They were told and they believed, that lagoons would protect the environment. Now, we know that the side effects are huge, and we wish to see farmers assisted in transitioning away from this practice.

Please, CAFO's should not exist. They are unhealthy places for both cows and those that consume them, AND for the world due to their polluting and toxic contributions.
We need strict rules for how these exist in our environment.
Please take this seriously and make conscientious and safe rules under which these operate.
Thank you~
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Comment From: Elizabeth Hauser

7/30/22 @ 12:32 PM
*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 sur...↓

* The draft guidelines from WA State for riparian buffers to protect salmon should be 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. We sympathize with farmers who followed the best available advice when they built lagoons years ago. They were told, and they believed, that lagoons would protect the environment. Now, we know that the side effects are huge, and we wish to see farmers assisted in transitioning away from this practice.

***It's time we start considering quality of life as well as the amount of money someone is making when making decisions.
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Comment From: Mark Canright

7/30/22 @ 8:52 AM
Hi there! As a farmer and business owner, I encourage and ask you to please reduce the amount of concentrated animal feeding operations in our region. They pose great risk to our ecosystems, human communities and to animal welfare. Let's instead inve...↓
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Comment From: Mark Canright

7/30/22 @ 8:14 AM
Hello! As a young person who cares about protecting our environment, I ask you to please take action to safeguard our environment, animals and human communities from the negative effects of industrial scale animal agriculture. Please do all you can t...↓

* 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. We sympathize with farmers who followed the best available advice when they built lagoons years ago. They were told, and they believed, that lagoons would protect the environment. Now, we know that the side effects are huge, and we wish to see farmers assisted in transitioning away from this practice.
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Comment From: ELYETTE weinstein

7/29/22 @ 9:46 PM
*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 sur...↓

* 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. We sympathize with farmers who followed the best available advice when they built lagoons years ago. They were told, and they believed, that lagoons would protect the environment. Now, we know that the side effects are huge, and we wish to see farmers assisted in transitioning away from this practice.
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Comment From: Olympia Physicians Climate Tas... (Gordon Wheat)

7/29/22 @ 10:03 AM
Science evolves and policy must evolve with the science. The administration has made its methane pledge, and Washington needs to do its part. DOE has failed to consider the impacts of climate change in authorizing CAFO discharge into our waterways.
Ma...↓
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Comment From: Jean Maust

7/29/22 @ 9:59 AM
The Department of Ecology has failed to include consideration of the impacts of climate change in authorizing CAFO discharge into our waterways.

The draft permit guidelines do not require all WA CAFOs to obtain permits. This means that over 200 WA CAF...↓

Washington state's guidelines for riparian buffers to reduce pollution and protect salmon should be an enforceable part of the CAFO permit, and they are not.

There are 53 CAFO dairies in Western Washington flood plains. Many of these large dairy operations are in areas with very high water table. The water quality in these areas has been terrible for years. Many of Ecology's studies have made many recommendations to improve water quality. Still,last fall, Ecology 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.

Ecology must 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 releases 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.

The permit guidelines do not seem to address the inhumane living conditions of the cattle in these large facilities. If animals were not confines in these ways, our environment would be better, cows and human workers would be better off too. Farmers need realistic and thoughtful guidance to transition away from CAFOs.
Thank you.
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Comment From: Geoff Browning

7/29/22 @ 9:45 AM
Hello,
Has the DOE has failed to consider the impacts of climate change in authorizing CAFO discharge into our waterways? Why is it not part of the consideration since these operations contribute significantly to Green House Gas emissions?

Manure lagoo...↓

How will this operations help or hurt WA achieve our overall GHG emissions reduction target? That needs to be part of the consideration and calculations.
Thank you.
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Comment From: Snoqualmie Indian Tribe (Kelsey Payne)

7/28/22 @ 8:38 AM
Please accept the comments attached to the form. Thank you.
Attachments:

Comment From: Concerned Citizens of the Yaka... (JANICE WHITEFOOT)

7/28/22 @ 8:24 AM
Ecology will acknowledge and honor Yakama Nation Tribal resolutions T103-92 and T174-08 banning any new Dairy CAFOs and or expansions within the Yakama Reservation boundaries.

Ecology will revamp CAFO, NPDS discharge permits so they protect the waters...↓

Ecology will stop allowing Dairy CAFOS to discharge into the Yakima River at the Granger Drain site and all other tributaries to the Yakima River. Ecology's Granger Drain Study clearly stated the over 200 tons a day of manure was being discharged from 5 dairies is a danger to the Yakima River and nearby residents.

Stop all unpermitted lagoons by dairies. I called on a new lagoon. Yakima County replied that dairies need no permit to put a lagoon wherever they wanted.

Investigate and stop all CAFO injection wells. Ecology themselves published a paper on this serious problem.

Ecology needs to stop giving well permits and enforce any illegal wells drilled by CAFOs to CAFOs.
Since a former ecology employee stated at a state water law conference, The Yakima River is over 400 per cent over allocated, Ecology will not allow any new CAFO wells to be dug effective immediately.

Environmental Impact Statements should be filled out by scientists, not Potential Polluting Parties.

All dairy lagoons will be lined whether they be new or old. Ecology will take this responsibility and add severe penalties for those who fail to comply within a two year time period.

Ecology will implement the proceedings to assist Yakima County with declaring Yakima County a sole source aquifer. Recharge rates will be reported to the public once a year. Fossil water areas will also be reported to public.
Dead CAFO cows will not be allowed to be put into manure and called "Organic."violaters will be prosecuted by Ecology.

Water meters will be put on all Dairy CAFO wells and users will pay water consumption rates according to local Ecology/local policies.

Ecology, immediately needs to implement a moratorium on all CAFO new permits and expansions in Washington State since Ecology has refused to design, implement and enforce CAFO rules that protect the health and water quality of Washington State citizens. See Charlie Tebutt/CARE lawsuit.

Concerned Citizens of the Yakama Reservation
We do not represent the Yakama Nation
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Comment From: Western Environmental Law Cent... (Andrew Hawley)

7/28/22 @ 12:00 AM
Good evening. My name is Andrew Hawley, staff attorney with the Western Environmental Law Center, and I live in Seattle. Thank you for the opportunity to present our comments on this important process. This permit represents an opportunity for Ecolog...↓
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Comment From: J & K Dairy (Jason Sheehan)

7/28/22 @ 12:00 AM
Hi, this is Jason Sheehan. I'm a dairyman and farmer and permit holder in Eastern Washington. Just a couple of quick points um the T Some 200 has not been scientifically proven to support the way that the the climate is in Eastern Washington. I'd lik...↓
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Comment From: Magali Cota

7/28/22 @ 12:00 AM
Hi, my name is Magali Cota. I'm a third year law student at Gonzaga University School of Law and thank you for the opportunity to speak. I don't believe ecology can approve the CAFO permits without violating this SEPA and Washington law as it's curre...↓
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Comment From: Ryan Riches

7/28/22 @ 12:00 AM
hello, my name is Ryan Riches and I'm a first year law student at the University of Washington. I'm very happy to see the steps that ecology is taking to strength though the CAFO permit in Washington. 00:11:31 Ryan Riches I have, however, there are s...↓
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Comment From: David Haggith

7/28/22 @ 12:00 AM
Just a uh, a few things. The the TSUM200 complaint on the east side. It was never intended for a high desert climate and it it's never been proven on a in a high desert climate. 00:16:36 David Haggith I think you you haven't got any evidence that wou...↓
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Comment From: Magali Cota

7/28/22 @ 12:00 AM
It's not a question, it's more of a comment. Uhm. I'd also like to add that for future hearings, ecology, try a little harder to make commenting more accessible, especially to communities that don't speak English, because we're all affected by these ...↓
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Comment From: Natural Resource Conservation ... (Don Hanson)

7/26/22 @ 7:23 AM
Attachments:

Comment From: Western Environmental Law Cent... (Jennifer Calkins)

7/26/22 @ 12:00 AM
00:02:00 Jennifer Calkins Hi, so I'm Jennifer Calkins again, Western Environmental Law Centre, and I actually have a clarification. It was my understanding that this hearing was to provide testimony about the draught permit and about the sepia DNS. I...↓
Attachments:

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

7/26/22 @ 12:00 AM
00:08:48 Jay Gordon Afternoon, Chelsea and everybody. My name is Jay Gordon. I'm with the Washington Dairy Federation and I have five comments. I'll try and get him in in the three minutes. 00:08:59 Jay Gordon First comment is why the switch back to ...↓
Attachments:

Comment From: Friends of Toppenish Creek (Jean Mendoza)

7/26/22 @ 12:00 AM
00:12:15 Jean Mendoza Thank you. I'm Jean Mendoza from friends of Toppenish Creek in Yakima County, and I just want to state for the record that 3 minutes is not long enough for me to explain to everybody here why I'm so concerned about the lagoon po...↓
Attachments:

Comment From: Northwest Animal Rights Networ... (Hannah Thompson Gardner)

7/26/22 @ 12:00 AM
00:13:15 Hannah Thompson Gardner Thank you. Good afternoon. My name is Hannah Thompson Garner and I'm the Director of Advocacy for the Northwest Animal Rights Network, or NARN, a nonprofit based in Seattle. 00:13:25 Hannah Thompson Gardner On behalf ...↓
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Comment From: priscilla martinez

7/23/22 @ 7:45 PM
We need to take better care of what is left of our environment, for wildlife, marine life, plant life, and people.
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Comment From: Jolie Misek

7/23/22 @ 4:19 PM
Factory farms produce a lot of waste. Mega-dairies in Washington produce tens of billions of pounds of waste a year. The permit the Department of Ecology has proposed is inadequate to prevent further pollution of our increasingly scarce water.

The dra...↓

Instead, this permit allows factory farms to dump toxic cow poop on land in vast excess of what plants actually need, which introduces untreated waste into our rivers and groundwater. Even worse, the proposed permit hides the factory farms' data from the public, leaving us in the dark about how much waste is being dumped onto our lands and into our waters.

We need a permit that can protect us through the next five years of our climate crisis. We cannot suffer another five years of this industry's unchecked pollution, especially those of us who live in the Yakima Valley whose drinking water is already dangerously contaminated.
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Comment From: Pamela Gray

7/23/22 @ 2:21 PM
You can do better. I live near the perpetually toxic Anderson Lake in Jefferson Co. The cause of the annual lethal toxic algal bloom is previously contaminated groundwater. Other county lakes are also starting to show this annual toxic algal bloom, t...↓
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Comment From: Doug Swanson

7/23/22 @ 1:34 PM
Please be sure our water remains safe without excess pollutants. Thank you.
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Comment From: Sara Lewis

7/22/22 @ 8:04 AM
I am opposed to CAFO's and the issuance of more permits for CAFO's. Please do not allow for CAFO's to operate. CAFO's are huge contributors to climate change due to methane emissions, and are also a danger to water when placed in flood plains or ripa...↓
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Comment From: Dean Effler

7/21/22 @ 4:45 PM
Attachments:

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