Many of us consume chicken. The Charlotte region is a densely populated consumer hub for meat, but surrounding counties in the region get densely blanketed with the waste generated as the animals are raised.
North Carolina has more waste from poultry than from swine and cattle combined.
Poorly managed, the waste can run downstream from ‘out-of-sight, out-of-mind’ to the Catawba River and its lakes – also drinking water reservoirs.
But for the first time since 2005, we all have an opportunity to comment on updating the waste regulations – the “2T” rules (15A NCAC 02T) – we have learned to be grossly inadequate.
We need you to speak up and be heard. The current 2T rules have failed to protect communities and water quality. Do you want to enjoy waterways without concern for bacteria or algae blooms? Should waste handling have common-sense safeguards?
You can submit comments one of three ways:
- Attend and speak at the public hearing in Hickory at 6 PM on Tuesday, October 17, at 6:00 PM at the Northview Middle School Auditorium, 302 28th Avenue NE, Hickory, NC 28601.
- Email comments to 15ANCAC2T2URule_Comments@ncdenr.gov (Deadline: November 22)
- Bonus points: mail written comments to Department of Environmental Quality, Division of Water Resources, Attn: 2T 2U Rule Comments, Water Planning Section, 1611 Mail Service Center, Raleigh, NC 27699-1611 (Deadline: November 22)
Use the information provided here to learn more about the issue and submit comments. Of course feel free to contact firstname.lastname@example.org if you have any questions while formulating comments!
What Are the Problems with How Chicken Waste Is Managed?
Short answer: Too much in too small an area with practically zero accountability — even less than what is required of hog and dairy CAFOs.
The North Carolina (upstream) part of the Catawba River basin has approximately 1,000 poultry CAFO houses. South Carolina, with better regulations, has only about 10% of that number.
Integrators like Tyson and Case Farms aim to maximize production and profit by processing as many chickens as possible as close as possible to their large processing plants. Consequently, a lot of waste generated is spread in a small area, too.
Poultry CAFOs have flocked to North Carolina, where they fly under the radar. They don’t have to get a permit from the State, and N.C. Department of Environmental Quality (DEQ) doesn’t know where they are, how many birds they’re growing, or how much waste they’re producing. How are already understaffed enforcement officials supposed to be able to adequately monitor and inspect so many poultry CAFOs?
Riverkeepers statewide have been diligently documenting and reporting poultry CAFO problems for years. DEQ has taken note, too, and recently reported on the industry’s explosive growth and related pollution issues.
From 2006 to 2014, the Catawba River basin in NC has seen a 78% increase in poultry. Nowhere in the state’s 100 counties is poultry as densely populated as in Alexander County, immediately upstream of Lake Hickory and Lake Norman.
When poultry operations concentrate their waste spreading, relatively little precipitation has a chance to fall on land without waste and run off clean to waterways.
Because of the current calculations for how much waste to spread, phosphorous ends up over-applied. At the same time, the Catawba River basin has the state’s second-highest phosphorous concentrations. The Lower Catawba has seen the greatest increases of any sub-basin in the state.
Nutrient overloading has decimated waterways like the Chesapeake Bay and Lake Erie, fueling harmful algal blooms that have gone so far as to shut down drinking water for a half-million people in the Toledo area. Eastern North Carolina experiences similar toxic blooms. The Charlotte region has been lucky – so far – but water utilities have cited it as a concern.
Poultry waste also contains pharmaceuticals, metals and bacteria. Fun fact: the Catawba River basin has the second-most fecal coliform bacteria of any basin in the state.
These are just environmental problems. Neighbors around poultry CAFOs have complained of difficulty breathing. Waste and feathers coat cars and structures downwind. Imagine living with that every single day.
What Are the Problems With the Proposed 2T Rule Changes?
Permit Terms: (See 2T. 0108 & .0111)
- The terms of non-discharge permits should not be extended from 5 to 8 years
- This proposal would decrease opportunities for public input, which is especially problematic when the public can’t comment on individual applications for coverage under general permits
- The State’s general permit for swine operations was challenged under Title VI due to its disproportionate impact on communities of concern. DWR should seek more, not less, input from communities in these circumstances
Setbacks: (2T .0506, .0606, .0706, .1108; 2U .0600)
- Rights to protection from pollution should not depend on whether one leases or owns the property next to a waste disposal field. Setbacks should still apply if the permittee leases neighboring property to another
- The rules should maintain the requirement for a 100-ft setback from swimming pools instead of assuming all pools are “places of public accommodation”
- Critical information regarding the fate of waste generated by agricultural operations should not be shielded from the public (See 2T .1403 & .1404)
- Governmental transparency should be a priority for DEQ. Depriving citizens of access to manure hauler records showing where waste is disposed limits the ability of the public to educate and protect communities from polluters
- Prior to permitting the land application of bulk animal waste residuals, DWR should give neighbors the same notice and opportunity for comment as it does prior to the land application of other bulk residuals (See 2T .1310)
- Poultry operations, the largest and fastest growing source of nutrients from animal agriculture in NC, should not be deemed permitted. DWR should consider location and waste management practices when permitting a CAFO (See 2T .1303)
- The EMC should follow the command of the NC General Assembly and create a violation points system to reduce the threat posed by serial polluters operating swine facilities (See N.C.G.S. 143-215.6E)
- CAFO permits should include cost-effective surface water quality monitoring obligations informed by, and responsive to, a permittee’s compliance record.
The rules and changes themselves can be accessed at https://files.nc.gov/ncdeq/Environmental%20Management%20Commission/Rule-Readoption-2T/Webpage/2T%20Rules%20all%20with%20comments.pdf
More information from the state is available at https://deq.nc.gov/public-hearing-proposed-actions-15a-ncac-02t-waste-not-discharged-surface-waters-rules-and-15a-0
Read Riverkeeper Sam Perkins’ op-ed in the Charlotte Observer at http://www.charlotteobserver.com/opinion/op-ed/article178290771.html