Follow @michigansierra (Using Safari may cause problems--please use another browser to sign up.)
> Healthy Great Lakes, Healthy Michigan
> Facts About CAFOs
Facts About CAFOs
What is a CAFO?
Also see CAFO in the glossary and CAFO Basics below.
What pollutants do CAFOs produce?
Another type of CAFO is the feedlot, which keeps the animals outdoors in pens. Here the manure waste accumulates on the ground, often washing off into nearby ditches and streams.
What's in CAFO waste?
In addition to plant nutrients such as phosphorus and nitrogen, CAFO waste is likely to contain:
Nutrients in this CAFO waste can cause bright-green algae blooms in ditches, streams, and lakes. As these surface-water algae blooms die off, the oxygen in the water is depleted. What does this do? It can lead to fish kills. Additionally, drinking-water plants must remove these nutrients before water is fit for consumption.
Pathogens such as E.coli bacteria, cryptosporidium, and salmonella, all of which can cause sickness or death in humans and animals, may be present in CAFO wastes.
How do CAFOs pollute water?
Water pollution is possible at virtually any point in a CAFO's operation.
It may take dozens of trips per day by semis or tanker trucks to dispose of CAFO waste. These trucks haul the wastes from the production area waste-storage structures to fields that are often many miles away.
One of the main sources of CAFO-caused pollution in Michigan comes from discharges of manure and other wastes through the soil into field drainage tiles, which carry the wastes directly into county drains and streams.
When CAFO wastes are applied to farm fields, water pollution can be caused by overapplication of wastes, direct runoff into surface waters, or by traveling through the ground- or catch basins into field tiles or drainage ditches that discharge directly into surface waters. Tests have shown that waste applied to the surface of a field can take a little as 45 minutes to reach the field tiles three to four feet below the surface.
How do CAFOs pollute air?
Some of the sources of CAFO air pollution are:
The air pollution inside the buildings is potentially deadly to the animals and humans inside if the fans ever stop operating. Normally the fans simply blow the contaminated air to the outside where it can pollute the whole community. Poultry operations blow ammonia and particulate matter, including feathers and chicken feces out of the buildings.
Hog operations often build the waste storage structure immediately beneath the area where the animals are kept, with slats in the floors to allow wastes to simply drop into the pit.
The CAFO wastes stored in waste storage structures is not treated or aerated, often resulting in extreme off-gassing of pollutants such as hydrogen sulfide (H2S) when the wastes are transported and sprayed onto farm fields.
For example, once or twice each year many liquid waste CAFO systems will scrape the solids out of the bottom of the waste storage structures and spread these thick, fermented wastes onto farm fields, causing even worse air pollution.
How do CAFOs impact human health?
Are CAFOs sustainable?
Do CAFOs need taxpayer subsidies?
CAFOs can't survive without taxpayer subsidies. CAFOs receive many subsidies, such as milk price support guarantees, federal EQIP money through the Farm Bill, Development Right Agreements, tax abatements, grants, bonds, even economic development funds for roads.
These taxpayer supports not only encourage the growth of this industry, they undercut the ability of traditional livestock operations to compete with CAFOs. Without the subsidies, CAFOs would fail financially.
How are CAFOs regulated and permitted?
Federal laws establish minimum standards for the regulation of any activity that causes air pollution or water pollution. However, through aggressive lobbying by the promoters of CAFOs, federal laws for the environmental oversight of CAFOs are extremely weak.
Currently, the U.S. Environmental Protection Agency provides no regulation of air pollution problems from CAFOs. Under the Right-to-Know provisions of CERCLA 42 U.S.C. §11001 et seq. (1986). Also known as Title III of the Superfund Amendments and Reauthorization Act (SARA), the Emergency Planning and Community Right-to-Know Act - otherwise known as EPCRA (pronounced EP-kra) - was enacted by Congress as the national legislation on community safety. This law is designed to help local communities protect public health, safety, and the environment from chemical hazards. CAFOs are required to report emissions of some pollutants, most notably ammonia. This requirement led to disclosure that the largest emitter of ammonia in the country is a dairy CAFO in Oregon.
The federal Clean Water Act does provide some regulation of CAFOs, although interpretations of the extent of those requirements are being litigated. State laws must be at least as restrictive as the federal law, but in Michigan and some other states it has required citizens to bring challenges to state's delegation under the Clean Water Act to force the agencies to implement the laws. Federal law requires that any CAFO which has had an illegal discharge into surface waters must obtain a National Pollutant Discharge Elimination System (NPDES) permit in order to continue operations. Several states (including Michigan) now require NPDES permits for all CAFOs, including new ones.
It is important to review the regulations in your state in order to understand what is allowed and not allowed. (View EPA links to state program websites.)
State and federal agricultural agencies often play a role in establishing voluntary standards that CAFOs and other livestock operations are expected to abide by. In some instances, the agricultural agencies will act as the gatekeeper for securing any enforcement actions by the state, particularly in the area of air pollution. In Michigan, for example, the Department of Agriculture is given the responsibility for investigating air pollution complaints from CAFOs, although they have no enforcement authority. Except in an emergency, the agriculture director must make a referral to the Department of Environmental Quality before any action can be taken by the environmental agency regarding those complaints.
No, it is not illegal to spread CAFO manure waste on the ground. While this website describes many different situations in which a CAFO may be spreading their waste on land, and many possibly harmful effects of that activity, it is not of itself illegal. It is illegal if a CAFO spreads waste in such a manner that it moves off the land and into waters of the state, and this "discharge" causes or contributes to a violation of Michigan's water quality standards in waters of the state.
What is in CAFO manure?
CAFO manure contains the animals' feces and urine, plus, the definition also includes other materials such as bedding, compost, and other raw materials. CAFO manure is also loaded with the plant nutrients nitrogen and phosphorus, which can cause algae blooms if released to surface water, and pathogens such as Escherichia coli (E. coli), and other fecal coliforms.
Manure may also contain:
There are 168 chemicals in and around manure according to a 2001 USEPA Report (Appendix A, page 235-244).
Methane digesters do not:
Can composting the manure solve the CAFO's waste problem?
In short, no. And, as you read the bulleted list below, remember that a Michigan CAFO can have a compost pile within 200 feet of its neighbor.
What is a CAFO discharge?
Discharge means any direct or indirect release of any waste, waste effluent, wastewater, pollutant, or any combination thereof into any of the waters of the state or upon the ground. View the Part 21 DEQ Wastewater Discharge Permit Rules, 67KB pdf.
Are CAFO operators allowed to spread animal waste on snow?
The real answer should be "no, not under any circumstance."
Instead the answer to this question is "maybe". How would you find out?
Are CAFO Operators allowed to dump manure in piles on fields?
This is a grey-area question. By dumping manure piles, a CAFO creates an off-site production area of waste. This off-site production area cannot discharge to waters of the state. See page 6 of the Part 21 DEQ Wastewater Discharge Permit Rules for the official definition of "production area".
Are CAFO Operators allowed to spread waste before precipitation or rainfall?
This can also be a cloudy area. If you go the Michigan Department of Environmental Quality CAFO website, scroll down to download the 2-page PDF Instructions for Determining Precipitation Forecasts to see how weather forecasts are applicable to CAFOs. You may use the instructions along with the CAFO's CNMP to determine if they are spreading waste in violation of their NPDES permit.
The photo at right, taken in Lenawee County just before a predicted rainfall, shows manure waste application on a fairly steep slope.
Is there a time of year when CAFOs can't spread wastes?
Not necessarily, this may be different for each CAFO. Each CAFO's NPDES permit guides what can and cannot be done.
Are there fields CAFOs can never spread waste on?
Yes. Soil testing for phosphorus must be done for fields that will be used for land application of CAFO wastes. If the soil tests indicate high amounts of phosphorus, a CAFO cannot apply waste to that field. That information is included in the Comprehensive Nutrient Management Plan.
How far away does the CAFO waste have to stay from water, lake, wetland, and so on?
This refers to a "setback", and the required setback information would be found in the CAFO's NPDES permit.
Is it legal for CAFO operators to spill the waste in the road?
No. However, you would need to contact your local road commission or police department to file a complaint on this issue. Unless the spill gets into waters of the state, or is an extreme amount, it is necessary to contact the government agency that has jurisdiction over roads.
Do I need to worry about a CAFO going in near my house?
What will happen to my property values with a CAFO nearby?
How does the CAFO waste end up on my property?
CAFO waste can be sprayed, irrigated, blown by the wind, spread further through surface ponding of rainfall, or from runoff that may reach your property. High powered fans used to cool the hundreds of animals in the buildings often blow out bedding or other contaminated materials.
Are there human health effects from exposure to CAFO manure?
Yes. Many people have become ill living near and working at CAFOs. Some people develop breathing problems, coughs, headaches, hydrogen sulfide poisoning, and ammonia poisoning. Here are two articles from Environmental Health Perspectives: Health Effects of Airborne Exposures from Concentrated Animal Feeding Operations, and The Potential Role of Concentrated Animal Feeding Operations in Infectious Disease Epidemics and Antibiotic Resistance.
What do I do when they are spreading CAFO waste next to my house?
First, this activity may not be illegal. But there are provisions the land applicator must follow to protect your home and property. So first, to be safe - get your children indoors, close your windows, and take down your laundry. Then start documenting your observations, in case the activity is causing a problem.
How do I document the activities I observe about the CAFO?
In a nutshell, you will take pictures, take water samples, and even smell the water at your own risk (smell it for manure or some other wrong smell.) Carry a notebook and keep information, such as a journal or a checklist. Have someone else verify your information, if at all possible.
Without trespassing onto private property, and only working from the road-right-of-way, or from the property of a landowner who gave you permission, take photos of:
How can I protect myself while monitoring?
You must never trespass. Check for road right-of-way distances. Realize that state highways are different than local roads. A CAFO operator may file charges against you if you are trespassing on their property. If you plan to access a stream away from the road, you must get permission from the landowner.
What should I do if I see:
Yes. A CAFO can go after you if you report them. Some agencies take anonymous tips, and you can report them that way. Remember that documentation is extremely important, so be diligent in your investigation before you report a violation. Always document your investigation, and always be credible.
Why is my lake green? White? Black? Brown?
Is the wetland on my property dead because of CAFO waste?
Water testing is needed to verify if there is waste in the wetland. Though water quality standards are slightly different, E. coli and other fecal coliforms may still signal the presence of fecal material in the wetland.
Is it safe to touch the water? No. Never assume that water is safe near a CAFO or a land application site. Always wear clean rubber gloves. If bloodworms are present in the water, this can be an indicator that you may get hepatitis if you are not wearing gloves. You could also get cryptosporidium, giardia, pfisteria, or other illnesses from the fecal matter in the water. If you have an open cut anywhere, you may want to have your companion take any water samples.
What do I do if I fall in the water?
Depending where and how you fall in, clean up as soon as possible.
Is a roadside ditch considered part of the surface water?
You would have to contact the proper agency to make this determination. If the roadside ditch connects to waters of the state it may be considered surface water, open drain, or county drain.
What do I do if you see dead fish downstream from the CAFO?
Document the dead fish by taking pictures; count how many and what kind if you can identify them. If there is a large number of dead fish, such as any number above 8 or 10, contact the agency in charge in your state. In Michigan this would be the Department of Natural Resources. You should also notify the MDEQ.
Where do CAFOs keep their animals?
All the animals are kept inside large cramped barns, they are not allowed outside to graze.
What types of water pollution can come from CAFOs, and what health problems can arise?
Surface and groundwater pollution can come from CAFOs. Groundwater contamination can cause E. coli poisoning and blue baby syndrome. Surface water contamination can cause illness from cryptosporidium, giardia, and pfisteria. See How do CAFOs pollute water?
What kind of air pollution can come from CAFOs, and what health problems can arise?
There are over 168 chemicals in and around manure. Some of the main gases are methane, ammonia, hydrogen sulfide, carbon monoxide, and carbon dioxide. You may have trouble breathing when the CAFO operators are spraying the fields with waste. If you feel ill from waste application, notify your local health department or physician immediately. See How do CAFOs pollute air?
What is a CAFO permit and where do I find it?
Michigan CAFOs are required to have only one permit. It is a National Pollutant Discharge Elimination System, or NPDES permit, given to authorize discharges to waters of the state only under particular circumstances. By signing the permit application, a CAFO owner shows good intentions to do the right thing. But the permit is only as good as the management at the CAFO. Permits do not guarantee compliance with the law. They do not protect public health. Remember, from a CAFO's point of view, it is easier to ask forgiveness than to ask permission!
You can find NPDES permits at the Michigan Department of Environmental Quality Concentrated Animal Feeding Operation website. Be sure to see How to apply for a NPDES permit. You can also see the U.S. Environmental Protection Agency NPDES webpage, note the upper left corner of that home page references the federal Final 2008 CAFO Rule.
There are two categories of NPDES permits for CAFOs. Some CAFOs are required to apply for an Individual NPDES Permit, that is written specifically for that one particular CAFO. Others are allowed to apply for a Certificate of Coverage (COC) to be covered under the CAFO General Permit, where the terms of the permit are applied to all the CAFOs with COCs. The General Permit language assumes all the CAFOs covered are alike, so they all have the same requirements. See the MDEQ CAFO website for more information.
The agriculture department says they follow generally accepted agricultural management practices (GAAMPS) and the "MOU". What is this?
See GAAMPS The Michigan Right to Farm Act, P.A. 93, was enacted in 1981 to provide farmers with protection from nuisance lawsuits. This state statute authorizes the Michigan Commission of Agriculture to develop and adopt Generally Accepted Agricultural and Management Practices (GAAMPs) for farms and farm operations in Michigan. These voluntary practices are based on available technology and scientific research to promote sound environmental stewardship and help maintain a farmer's right to farm.
See MOU. This refers to a Memorandum of Understanding between the Michigan Department of Agriculture and the Michigan Department of Environmental Quality, entered into for the purpose of delineating the respective roles and responsibilities regarding state agency response actions to environmental and nuisance complaints about farm operations.
What organizations can help you find information about CAFOs?
There are many organizations that can help.
Environmentally Concerned Citizens of South Central Michigan (ECCSCM)
Society for Responsible Agriculture
U.S. EPA (Visit state agencies for your state)
Also visit CAFO Help Contact Info for more information.
© Copyright 2001-2014 Sierra Club. All rights reserved.