From Marc Yaggi, Waterkeeper Alliance <[email protected]>
Subject Waterkeeper Alliance and Other Groups Petition EPA to Improve Oversight of Water Pollution from Concentrated Animal Feeding Operations
Date October 28, 2022 9:00 PM
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Dear Friend,

Gloria Reuben, President of Waterkeeper Alliance, penned this oped for Truthout ([link removed]) arguing that Concentrated Animal Feeding Operations (CAFOs) - also known as industrial factory farms - must be reigned in for the sake of clean water protection and environmental justice. She writes, "The most effective way to legislatively confront the CAFO crisis would be for the U.S. Environmental Protection Agency (EPA) to use the Clean Water Act to prevent uncontrolled discharges of untreated animal waste into our nation’s water by requiring these facilities to obtain permits that contain real limits."

As part of our ACT50 campaign celebrating the 50th Anniversary of the Clean Water Act and advocating for the next 50 years, ([link removed]) Waterkeeper Alliance and a nationwide coalition of 50 citizens’ groups and community advocacy, environmental justice, and environmental advocacy organizations, together representing tens of millions of people petitioned EPA on Wednesday to improve its oversight of water pollution from industrial-scale concentrated animal feeding operations. The groups argue that improved oversight of large CAFOs is necessary to satisfy the federal Clean Water Act and executive orders intended to advance environmental justice. Waterkeeper Alliance and the groups are represented by Earthjustice and of the 51 organizations filing this petition, 14 are Waterkeeper groups, including Waterkeeper Alliance.

The petition summarizes decades of well-established scientific research showing that CAFOs ([link removed]) — and large CAFOs, in particular — routinely discharge water pollution that threatens public health and the environment, including nitrogen, phosphorus, disease-causing pathogens, and pharmaceuticals. In addition, they include personal stories from people who live in communities harmed by CAFO pollution across the country. These community members report that CAFOs create serious water contamination problems, degrade drinking water, and impair opportunities for fishing, boating, and engaging in other forms of recreation. Larry Baldwin, NC CAFO Coordinator for Waterkeeper Alliance, Kemp Burdette, Cape Fear Riverkeeper, Sandy Bihn, Lake Erie Waterkeeper, and Buck Ryan, Snake River Waterkeeper all made declarations for the petition.

The petition also includes a new report detailing racial, ethnic, and other disparities in exposure to CAFO pollution. CAFOs cause disproportionate harm to communities of color, low-income communities, and under-resourced rural communities in North Carolina, Iowa, and California’s Central Valley — all areas in which CAFOs are densely concentrated. To our knowledge, this report is the first to describe the unequal harm that CAFOs impose on environmental justice communities in the Central Valley.

If granted, the petition would require EPA to adopt a rebuttable presumption that large CAFOs using wet manure management systems actually discharge water pollution and, thus, must obtain water pollution discharge permits under the Clean Water Act. According to EPA, there are more than 21,000 large CAFOs nationwide. EPA admits that many CAFOs discharge water pollution, but fewer than 6,300 large CAFOs (30%) have Clean Water Act permits. Although some large CAFOs operate under state-law permits, those permits typically are less protective of water quality, offer less transparency, and provide fewer opportunities for public participation, as compared with federal permits.

Please support our work to ensure greater EPA oversight of CAFOs by donating today. ([link removed]) It is critical to properly implement and enforce the Clean Water Act to protect disproportionately impacted communities and the waterways we use for drinking, swimming, and fishing. Help us be part of the solution.

We appreciate your support and dedication to drinkable, swimmable, fishable water.
To Clean Water,
Marc Yaggi
CEO
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