Hearing held today on EPD’s proposed changes to CAFO pollution – we need your help!

_{Your voice will make a difference. Read the below, cut and paste it, rework it however you want. But DO email EPD before March 2oth 4:30pm.  EPDComments@dnr.state.ga.us}

EPD’s proposed modifications further threaten the economic viability of small farmers, human health and the environment, as well as federal clean water protections, in Georgia.  We request significant reconsideration and revision of EPD’s proposed Animal Feeding Operations Permit Requirements.

_{In Georgia, on any one given day, there are:}

• _{205 million broiler chickens,}
•  _{9 million egg-laying hens,}
• _{235,000 hogs,}
• _{35,000 dairy cows}
• _{producing as much untreated manure as 85 million people — nearly 9 times the population of Georgia.}

_{Annually GA raises and slaughters some 1.4 billion meat chickens, the largest producing state in the country. In fact if we were a country, we’d be the sixth largest producing country in the world. The 17.5 million broilers in Franklin County, Georgia produce as much waste as the greater Philadelphia metro area (equivalent of 5.9 million people). The more than 10.7 million broiler chickens on factory farms in Gilmer County, Georgia produce as much untreated manure as the sewage from the Seattle metro area. Annually, the broilers farms of GA produce 2 million tons of untreated poultry litter annually, which is 20% of the US total. I say this so that we understand the scale of the untreated waste we are talking about.}

_{Georgians for Pastured Poultry, an alliance made up of farmers, chefs and advocates including Compassion in World FArming, Seirra Club and Georgia Organics,  recently conducted an intensive study into what impact the industrial chicken meat production model is having on our state. The conclusive evidence, supported by over 300 references, including scientific journals, was that it has  an unchallenged detrimental impact, including with regard to the environment. Surely the answer with such high volumes of waste is not to scale back, but rather to enforce existing regulation and look to increase control.}

_{The report, Out of Sight, Out of Mind, concluded that there is another business model, a new market emerging in the state, that should be supported. In just 5 years, Georgia’s farmers markets have grown by 600%. The national average is around 16% for the same time period. Georgians are exploding with the desire to support small scale humane and sustainable farmers. Pasture poultry farming is one example, detailed in our report,  of a higher welfare, higher environmental models.}

_{However, if the industrial model continues to be allowed to externalize its pollution costs, that is to force someone else, i.e. taxpayers, to pick up the bill for any clean-up costs that are needed to keep our recreational and drinking waters clean for, the small farmer, who does not cause such extensive environmental impact, does not stand a chance.}

_{In fact, the clear competitive advantage to the small sustainable farmer is that he or she is more environmentally friendly and does not have to pay for extensive environment control mechanism. The very system of farming that they have adopted does this naturally because it works with nature and has less of an impactful on the surrounding environment. This is the competitive advantage of this model of farming. If industrial farms are not required to pay for control for the environmental impacts, small farmers are being unfairly stripped of perhaps their only advantage in the market and they will not flourish. It will not be a level playing field by any stretch of the imagination if GA CAFOs are not required to limit and pay for the pollution, which is inherent to this system of farming.} 

_{CAFOs, which are not farms, but factories, must be required to plan and report what exactly is going to happen to the enormous amount of waste produced by farm animal factories -  the equivalent of 85 million people’s untreated waste on a daily basis – and how they plan to control the impact of this waste on our collective environment.   If not for the sake of the environment, for the sake of creating a level playing field for the emerging small scale humane and sustainable farmers.}

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