"Family farmers, communities and the environment
lose when we let these companies have an unfair competitive advantage."

My name is Roger Allison. I'm a grain and livestock farmer from Howard County, Missouri and executive director of the Missouri Rural Crisis Center which is comprised of over 3600 farm and rural families. I am here today representing the consensus points that have been developed by the Campaign for Family Farms and the Environment, a multi-state coalition of environmental and farm groups, the Clean Water Network and the MRCC ag (agriculture) policy task force which is made up of rural community groups from throughout Missouri who have been working to protect their families, communities and the environment from corporate hog factories.

Many of our members have first-hand experience with livestock factories in their midst - manure spills, fish kills, contaminated ground water and toxic gases like hydrogen sulfide and ammonia. Because corporations have attempted to pre-empt local control on the state level, we have had to be vigilant in protecting the ability of county governments to control their destinies by passing health ordinances.

It's important to make a distinction here between family farmers like our members and the new-style factory farms. Traditional agriculture, with its diversity of crops and animals, spreads waste over a much larger area in much smaller amounts. Real family farmers, unlike corporations, see our land as a place to grow crops and pasture their livestock, not just as a place to spray manure. We have a vested interest in not overapplying nutrients and not introducing toxic concentrations of heavy metals like copper, zinc and arsenic which are in the manure. We are in it for the long haul, unlike boom-and-bust, slash-and-burn companies. Far from being efficient, these corporations rely on heavy infusions of capital to control the market.

The awful truth is: Family farmers, communities and the environment lose when we let these companies have an unfair competitive advantage through lax environmental enforcement, tax advantages, taxpayer-funded research and other corporate welfare. It has been shown that 28 jobs get lost whenever nine jobs are created at factory farms. In contrast, a rural economy built on family farmers sustains itself as farmers' business expenditures get recirculated through feed and seed stores, machinery dealers and hardware stores.

Our work as a family farm organization close to the ground confirms: the most important issue in agriculture today is the industrialization of agriculture. The growth of corporate industrialized agriculture has far out-paced our ability to protect our water. We have a good law in the Clean Water Act but as our state environmental regulator admitted, it has no authority to prevent fish kills, only the ability to fine companies that pollute. Our experience with factory farms is that they follow the old adage of "it's better to apologize than to ask permission.''

While we have been encouraged that the federal government has finally recognized the problem of factory farm water pollution by releasing a Clean Water Action Plan, it remains quite a few hay bales short of a truckload. With a crisis spiraling out of control, with watersheds endangered from Maryland to Utah, we desperately need an emergency convoy of trucks sent immediately. Last year's pfiesteria outbreak from factory farm runoff that caused the death of millions of fish should have stood as a shrill wake-up call.

We recognize that the nature of the federal government has not been to spring into fast action. But the federal Action Plan confirms that notion so well it should be renamed the Federal Foot-dragging Plan. We simply can't wait until 2005 for the EPA to finally issue discharge permits for CAFOs. We can't wait until 2002 for land application standards. We can't wait to protect our waterways and ground water from corporate bandits that have no stake in protecting water.

It is clear that the EPA must declare an immediate moratorium. It needs to stop construction and permitting of these facilities until there are regulations in place to prevent spills, ground water and air contamination. This moratorium is absolutely necessary until adequate testing is completed on the waters surrounding already existing factory farms, and to develop alternatives to the cesspool storage system that most factory farms employ.

Federal laws must include required permits for all CAFOs (concentrated animal feeding operations) at an animal unit level that reflects when their environmental impacts become a problem. The animal unit threshold should be 500 animal units to reflect the enormous amount and toxicity of the waste generated in these facilities. This would include the massive growth in corporate contract operations that are blanketing the country in the 500-999 animal unit category. All permits should be individual rather than general permits to reflect site-specific conditions. We need to eliminate the 24-hour, 25-year loophole that allows too many facilities to go unpermitted.

Permits must include detailed designs for waste storage and land application based on the most limiting factors whether it's nitrogen, phosphorus or heavy metals. Permits should also require facilities to be sited away from floodplains, drinking water wells, public lands, and other ecologically sensitive watershed areas.

The use of lagoons by CAFOs for waste storage should be phased out because it is outmoded and should be determined not to be "the best available technology'' as defined by the Clean Water Act. This is one point pushed for in legislation introduced by Rep. George Miller (D-CA). Miller's timetable for the phase-out is also slow - 10 years - but it recognizes that these larger-than football-field-sized cesspools are a menace that should no longer be allowed. We can no longer tolerate the nitrate contamination of our ground water which harms livestock and humans.

In addition, livestock factory owners also must be held responsible for their operation's waste including how it's applied to land. A no-discharge permit should mean no discharges into the waters of this state, including runoff from over-application. Corporations should also be held accountable for the pollution caused by their contract producers. A national minimum standard should be established with an explicit understanding that states and local governments have the authority to pass "stricter than federal'' environmental regs (regulations) based on the needs of their communities.

Local governments need this latitude because frankly these companies that masquerade as agriculture are quite a different animal. In Missouri they were responsible for more fish kills in one month's time than what had been caused by all of agriculture in the previous 10 years. At the same time they foul our air with poisonous gases that make neighbors ill. One test in Renville Co., Minnesota found that one-quarter of 32 tests taken near manure cesspools exceeded Minnesota air quality standards for hydrogen sulfide. More than half of the people living within two miles of mega-hog sites reported an increase in allergies, sinus infection, nasal blockage and a lack of energy, according to a survey done in Putnam County, Missouri. Under the federal Emergency Planning Right to Know Act, livestock factories should have to notify state and local emergency planning committees that they are releasing excessive amounts of ammonia and hydrogen sulfide or face hefty fines.

The crafters of the Clean Water Act and the Congress that passed it could not foresee this intensive move to industrialized livestock production 25 years ago. We need to enforce this law to its fullest extent. This requires an EPA that recognizes our health and our environment depend on them. We must regulate these industrial-sized livestock factories that create industrial-sized waste like the industry they are. It's high time that corporations stop hiding behind family farmers to avoid regulation. They must be held accountable. We must be assured that human health, the environment and animal welfare do not get lost in the race for corporate profits.

I am here to tell the the EPA that family farmers are not afraid of a strengthened and enforced Clean Water Act. We welcome these laws that protect the environment and rural communities. We are afraid though of companies that have no connection to our land who feel that they can degrade the land that has been passed on by our families for generations. An expedited action plan if refined to reflect our above concerns will help ensure that our generation has something to pass on to the next generation.

Also read:

• A rural economy built on family farmers sustains itself
  by Roger Allison
  
  
• Hog Wars.