Executive Summary

Report

Feedlot Dust
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Koch
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Pilgrims Pride
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Smith Farms
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Sustainable Livestock
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Antibiotic Resistance
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Vertical Integration
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Natural Meat
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Organic Meat
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Recommendations  

Recommendations

Vertically integrated, multi-national agricultural corporations must balance local public health and environmental issues against the demands of the shareholders and corporate profit.

US Senator Tom Harkin of Iowa, who has supported legislation to restore fairness and competition in the livestock industry, has said, "The consolidation of our food system into fewer and fewer hands also poses serious risks to the security and well-being of consumers." (130) Consumers Union supports efforts to move away from a consolidated corporate food structure and toward sustainable food production.

Moving toward sustainable practices in the meat and dairy industries will require a re-thinking of current intensive animal production practices. The necessary changes in production methods and philosophy will not occur overnight. However, there are short- and long-term measures that CAFO owners and government agencies such as TNRCC, USDA, and EPA can begin taking which will make the industry more accountable for public health and environmental protection.

Short-term Recommendations:

Address Water
Quality Concerns

Surface and ground water quality is at risk whenever CAFOs are creating more waste than the ecosystem can absorb. There are several ways in which this risk can be lessened:

• TNRCC should set more stringent standards for facilities, including minimum buffer zone requirements (setbacks) based on proximity to watersheds, recharge zones, drinking water sources, residential areas, and pristine or protected habitats. For larger CAFOs, setbacks should be at least 2 miles.
• No new CAFOs or expansions should be allowed in areas that have water bodies that have already been negatively impacted by CAFO-related pollution (i.e. Clean Water Act 303(d) listed waters-see Table 2). (131)
• TNRCC should also implement requirements for groundwater monitoring, recordkeeping of monitoring results, and regular inspections of lagoon structures to locate possible leakages. Surface waters should also be regularly monitored for bacteria and pathogens that are carried in runoff.
• The cumulative effects of multiple CAFOs located in one watershed should be considered when determining how and where CAFOs may operate. We recommend that TNRCC more stringently regulate watersheds that contain multiple CAFOs before water quality is negatively impacted and actively reduce the concentration of CAFOs in areas where the environmental damage has already been done.
• All waste lagoons should be lined to prevent seepage. Although lagoons can self-seal, cracks and pores may develop over time and increase the risk of groundwater contamination. (132) Liner inspection should be included as part of an annual lagoon evaluation since the periodic lowering of the waste level results in dry cracks that may not reseal properly.
• In the case of dry manure systems such as those used in beef cattle feedlots, the dry manure should be covered and stored in non-permeable structures to prevent runoff.
  

Address Air Quality Concerns and Odor Problems

• Farm managers should implement simple technologies to improve air quality and odors near CAFOs.
• Regular sprinkling of feedlots with water can significantly diminish the amount of particulate contamination in the air without affecting animal growth and performance. (133)
• A layer of straw on top of a lagoon absorbs odors until a more permanent lagoon cover can be fitted.
• An air "scrubber" or filter, in which dust and odorous compounds are removed from the air by forcing it through a shaft of water or soil can decrease ammonia concentrations in the air by 97-99% and odor intensity by 30-80%. (134)
• Eliminate aerial spraying of liquid manure to application fields tp reduce odor.
• Direct waste injection into the soil or application with a spreader, turning it in, limits potential dispersion to waterways and surrounding areas while reducing odors.
  

TNRCC Permits
and Enforcement

TNRCC should implement stronger regulations.

• Reduce hydrogen sulfide and ammonia emission limits at CAFOs, slaughterhouses, and rendering plants and conduct regular monitoring to ensure compliance.
• Reauthorize field investigators to issue nuisance odor Notices of Violation if they confirm a complaint.
• Refuse to implement a general permit for all CAFO operations.
• Take into account cumulative pollution effects (from multiple CAFOs in one area), prior violations by the facility in question, and proximity to residential and environmentally sensitive areas when making permit decisions.
• Require individual permits for all facilities housing 1,000 or more animal units and for smaller facilities if they are located in impaired watersheds, have a history of discharging pollutants, or have been the subject of numerous complaints.
• Follow the lead of other states and hold corporate animal owners jointly responsible with their contract growers for the pollution created by CAFOs.
• Direct more attention to monitoring and enforcing existing laws, including swift response to evidence of non-compliance and illegal pollution discharges and assessment of adequate penalties against non-compliant facilities.
• Eliminate the criteria that members of the public affected by a new permit or expansion of an existing permit must show the "technical merit" of their issues before TNRCC will grant them standing to present these issues to an impartial adjudicator. (135)
• Give affected neighbors opportunity for contested case hearings, especially for new facilities or significant expansions which pose risks to health, the environment, and the use and enjoyment of adjacent property.
  

Long-term recommendations:

Prioritize and promote research on innovative and sustainable alternatives to current livestock production methods in Texas, including environmentally responsible waste disposal.

• Develop new statewide agricultural priorities that include special emphasis on sustainable methods for growing animals and utilizing livestock waste.
• Prioritize economic development of the state's growing organic farming industry, including organic meat production.
• Investigate new methods to reduce the amonia levels in livestock waste and decrease ammonia released into the atmosphere. (136)
• Encourage the development and use of composting systems that help eliminate odor and break down animal waste into a safe and useful agricultural product. (137)
• Investigate systems that reuse animal waste for energy or fertilizer production. (138)
• Promote alternatives to antibiotics, with the eventual goal of eliminating the use of antibiotic feed additives in livestock production.
• Develop educational strategies to promote alternatives to antibiotic use, such as improved animal hygiene and less overcrowding, which can enhance animal growth and well-being without the need for intensive drug therapy.
• Develop a standard, consumer-friendly label for sustainably produced meat and dairy products that may not be "organic" but represent significant production reforms over the industrial model (for example, animals that may have ingested some non-organic feed but ingested no antibiotics and did not grow in close confinement). Such an "eco-label" might include a checklist of well-defined sustainable production practices-for example "no antibiotics used ever"-which would easily inform the consumer about the specific production practices that were utilized on the farm.
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NOTES:

130 Penny Loeb, "Do the Big Guys Play Fair?" U.S. News and World Report, May 24, 1999, p. 26.

131 Recommendations based in part on Clean Water Network's Feedlot Work Group "Clean Water Network General Recommendations for EPA's Model Individual NPDES Permit for CAFOs," Clean Water Network, Washington, D.C., 1999.

132 Huffman, R.L. and P.W. Westerman, "Estimated seepage losses from established swine waste lagoons in the lower coastal plain of North Carolina," Transactions of the American Society of Agricultural Engineers, Vol. 38, No. 2 (1995), pp. 449-453; McCurdy, M. and K. McSweeney, "The origin and identification of macropores in an earthen-lined dairy manure storage basin," Journal of Environmental Quality, Vol. 22 (1993), pp. 148-154.

133 Carroll, J.J., J. R. Dunbar, R. L. Givens, et al., "Sprinkling for dust suppression in a cattle feedlot," California Agriculture (March 1974), pp. 12-14.

134 Sweeten, J.M., et al., "Odor control from poultry manure composting plant using a soil filter," Applied Engineering in Agriculture, Vol. 7, No.4 (1991), pp. 439-449.

135 Thu, Kendall M, Laura DeLind, et al., "Social Issues," in: Understanding the Impacts of Large-Scale Swine Production: Proceedings from an Interdisciplinary Scientific Workshop (Des Moines, Iowa, June 29-30, 1995).

136 Vanotti, M.B. and P.G. Hunt, "Solids and nutrient removal from flushed swine manure using polyacrylamides," Transactions of the ASAE, Vol. 42, No. 6 (1999), pp. 1833-1840. Vanotti, M.B., et al., "Encapsulated Nitrifiers Research," USDA research summary at internet location: http://www.florence.ars.usda.gov/efd_1/vanotti/mtv13a.htm (printed April 7, 1999).

137 Environmental Products & Technologies, "EPTC's Agricultural Waste Treatment Technology Well Received at International Equipment Show," News release, February 16, 1999. Internet location: http://eptcorp.com/nr990216.html.

138 Harper, Scott, "Perdue Farms to Reform Chicken-Manure Disposal Practices," Norfolk Virginian-Pilot, March 10, 1999 (LEXIS-NEXIS online news service). In Virginia, the state's director of soil and water conservation issued an invitation to the largest chicken producers to discuss waste innovations for the industry. The cooperative effort resulted in a joint venture between Perdue Farms and a recycling business to build a $6 million complex that will convert chicken waste into fertilizer pellets. The state expects to convert up to 120,000 tons of manure a year-almost half of what the region's farms generate-and even pay growers for each load of manure that they bring to the complex.