ACTION ALERT: Submit a Comment for CAFO General Permits Reissuance draft
The public comment period is open for the Department of Ecology’s Concentrated Animal Feeding Operation (CAFO) General Permits Reissuance draft through 11:59pm (PST) on Wednesday, August 17, 2022.
Orca Conservancy has submitted a comment letter encouraging the Department of Ecology to enact effective CAFO waste regulations that will protect vital habitats that salmon and endangered orcas depend on, while also promoting the well-being of Washington State residents.
To comply with the recent court order and to fulfill its legal obligations, the Department of Ecology must make the following changes to the CAFO General Permit Reissuance:
Implantation of best management practices based on science which includes mandatory riparian buffers;
Implementation of “all known, available, and reasonable methods of prevention, control, and treatment” (AKART) for existing manure lagoons and compost areas;
Completely prevent violations of surface water quality standards and groundwater quality standards as outlined in Ch. 173- 201A WAC and Ch. 173-200 WAC, respectively;
Implement monitoring practices (visual inspections and soil sampling) sufficient to ensure compliance;
Provide public participation in the development of site-specific nutrient management plans, as required by the Clean Water Act;
Consider the effects of climate change, as required by Washington State Environmental Policy Act (SEPA)
Click here to read Orca Conservancy’s Comment Letter
Click here to read the draft and other reports submitted by the Department of Ecology
What is the Draft and Why is it Important?
The Department of Ecology issues CAFO General Permits to operations that confine livestock for long periods of time. These permits allow the livestock operations to discharge pollution to surface or groundwater. The permits require that specific pollution preventative measures be in place such as collecting runoff, storing manure, and adopting practices based on soil tests to protect water quality.
With the draft CAFO General Permits Reissuance, the Department of Ecology has the ability to take meaningful action to address climate change impacts here in Washington by reducing the amount of nutrient pollution that reaches, and acidifies, our marine waters. Toxic pollution is one of the major threats that impact the critically endangered Southern Resident killer whales (SRKWs), while other threats such as climate change and ocean acidification places additional threats on an already struggling
How will it impact whales?
Climate change is placing tremendous stress on coastal and marine ecosystems. Ocean acidification, paired up with other climate impacts like warming waters, deoxygenation, melting ice, and coastal erosion, pose real threats to the survival of many marine species including the SRKWs and salmon on which they depend.
CAFOs are a major contributor to harmful algal blooms nationwide. These blooms occur when an overgrowth of algae takes over a body of water and produces toxins that can threaten environmental and public health. So-called “nutrients” (phosphorous and nitrogen), major constituents of CAFO waste, fuel these algae outbreaks. CAFOs hold massive amounts of manure at their facilities, and they spread it onto land. During heaving rain, the holding facilities can overflow, or manure applied to fields can runoff into natural water systems. CAFO waste that enters into waterways is a major contributor to nutrient pollution, which feeds these harmful algae blooms.
Nutrient pollution also causes local acidification through feedback loops involving biological growth, metabolism, and decay, over and above that which would occur in the absence of nutrient input from humans. These processes use more oxygen than they produce, causing oxygen minimum zones, more commonly known as ‘dead zones’, and resulting in locally acidified waters. More acidic, lower-oxygen waters are likely to undergo both chronic and acute environmental changes, including a decline in biomass productivity, a factor important to fisheries. Studies over the past several years suggest that acidification could negatively impact salmon due to the lower pH balance that can cause a condition called acidosis (too much acid in body fluids), and could inhibit their ability to detect or “smell” danger, making them more susceptible to health risks and danger.
How and Where to Submit a Comment:
The draft will be available for review and public comment through 11:59pm PST on August 17, 2022. Comments can be submitted online (preferred method), by mail, or in person (comments are recorded during public hearings).
Online comments can be submitted through the online Public Comment Form here
Tips for how to submit a public comment:
Be respectful and polite in your comment.
Get personal, share your experiences and why you care. Personal messages carry more sentiment and weight which are more meaningful and can have a bigger impact on policymakers.
Avoid pre-written copy and paste templates. New practices have passed that make it so pre-written templates only get counted once. Meaning if multiple people submit the same exact comment, it will only be recorded once. Make it personal and unique to make sure it is counted.
Cite relevant data that supports your comment
Suggested talking points:
Killer whales are at the top of the food chain. Pollution caused by CAFOs will work its way into the ecosystem, causing irreversible damage and contributing to the ongoing issues facing the endangered Southern Resident killer whales.
Harmful algae blooms not only pose a risk to the ecosystem and wildlife, they also pose a health risk to humans and local communities
Pollutants discharged without permitted regulations will directly violate Washington State Law, the federal Clean Water Act, and pose a threat to multiple species protected under the Endangered Species Act.
Salmon and steelhead trout depend on cold, clean, and oxygenated water to survive. Harmful algae blooms and acidification caused by pollutants from CAFOs can negatively impact water quality and conditions.
Pathogens, excess nutrients, and other contaminants present in animal waste further endanger salmon by creating hypoxic and/or toxic environments that kill off their food sources.11 This, in turn, hurts other species depending on salmon as a food source, impacting marine and aquatic life all along the food chain.
Effective CAFO waste regulation would promote the well-being of Washington residents who depend on groundwater for drinking, as well as all those who depend on Washington’s waterways and natural resources for recreation, economic prosperity, education, and quality of life.
The tiny-shelled marine snail (Pteropods) are among the marine creatures most vulnerable to ocean acidification. Pteropods are an important food source for Pacific salmon, therefore the loss of pteropods means fewer Chinook salmon which the endangered SRKWs need to survive.