Just over
a year ago, opposite the editorial pages of the New York Times, Blake Hurst, a former hog farmer and current
president of the Missouri Farm Bureau, bemoaned the plight of livestock farmers. Mr. Hurst wrote of a market that signals
farmers to produce more for lower prices while diverting inputs to ethanol production
and imposing burdensome regulations. Others, he said, disparage the industry over animal welfare and pollution, calling for the abandonment
of practices that best provide cheap and plentiful meat and dairy.
Referencing
a Chipotle advertisement, he wrote, “Commercial farmers will have to decide
whether we can withstand public opprobrium while continuing to efficiently
produce the world’s most essential good, or join the entertainment industry,
selling expensive pork chops with heaping sides of nostalgia.”
While I
share some of Mr. Hurst’s distaste for the small-farm fetishism often used by
the sustainable agriculture community, his rather ad hominem caricature and dismissal of those who would seek
alternatives to the predominant livestock production system largely misses the
point – that there is a real need for both improved regulation and alternative
production practices (the NYTs fielded numerous responses to Mr. Hurst's op-ed linked here).
Hurst is
guilty of perpetuating an unnecessary duality, where animal agriculture is
either large and industrialized or small and pasture-based. This argument, myopic in scope, is an appeal
to ignorance and a distraction from the immediate need to improve regulation of
an industry that feeds the vast majority of Americans while simultaneously
poisoning their water.
Industrialized
livestock production is the driving
force of American agriculture. It is the
cornerstone of our agricultural policy, a key consumer of more than 150 million
acres of corn and soybeans. And, yes, consumers
reap the benefits of the remarkable economies of scale that play out on these Concentrated
Animal Feeding Operations or CAFOs.
The EPA regulates CAFOs that discharge or purpose to discharge pollutants requiring operators
to have permits to do so. For a sense of
both farm size and market share consider that 58% of all swine
production in 2011 occurred on a mere 135 industrialized farms, each home to
more than 50,000 hogs. A full 81% of all
hog production took place on 1,340 farms with over 5,000 head each.
The amount of
livestock waste produced on such farms is equally impressive. A large operation is capable of producing
more than 1.5 million tons of manure a year.
In total, the EPA estimates that CAFOs annually produce 3 times more
waste than humans with the amount of excrement produced on the largest
operations surpassing that of many U.S. cities. The geographic concentration of large
operations – hogs in northern Iowa and southern Minnesota for example –
compounds the issue, imposing a disproportionate burden on those living within
these production regions and their watersheds.
As a result, 43% of the population has had their drinking water quality compromised
by CAFOs.
The current
standard of regulation is inadequate in part because it fails to require that all
CAFOs with the potential to discharge apply for permits. The EPA previously sought to require
universal registration unless a farm could demonstrate “no potential to
discharge.” This proposed rule would
have provided basic information about all CAFOs, their locations, the waste
they produce, and how they manage it. However,
the Waterkeeper Alliance v. EPA decision
in 2005, found that the EPA lacked authority to mandate permits. Rather, a CAFO must be found to have
discharged pollutants before being required to obtain a permit.
Yet all CAFOs are
presumably polluters - a point that is absolutely critical to the EPA’s ability
to effectively regulate point source pollution.
Without mandatory permits, a CAFO must be caught in the act of polluting
before they are brought under the auspices of the EPA. The practicality of this strategy for mitigating
pollution is mindboggling, especially in the absence of a comprehensive
inventory of all CAFOs.
Upward of
90% of raw waste produced by CAFOs is applied to cropland. However, there is insufficient land on which
to apply it safely. This necessitates
the use of structures to store manure, wastewater, and contaminated runoff and
opens the door to catastrophic failures and overflows, especially in cases of
extreme precipitation. As a result,
there are more large-scale discharges and significant increases in nutrient and
pathogen runoff.
A concern
over excessive runoff has led many to call for improved ecosystem monitoring in
proximity to large CAFOs. Again, without
a comprehensive inventory and requirement that CAFOs obtain discharge permits,
any monitoring will be severely gap-laden.
To achieve maximum efficacy, the EPA must have all CAFOs under their
purview.
What Waterkeeper made clear is that this
likely cannot be accomplished through the rule making process alone. Legislation increasing the scope of the EPA’s
regulatory power is needed. Requiring
all CAFOs to have discharge permits and to be held accountable seems as much a
matter of conscience as it is an ecological necessity.
Please feel free to contact me for additional information or direction to resources. Below is the Chipotle video Mr. Hurst referenced in his op-ed. I will go on the record as a fan of the video and its sentiments:
