Twenty-five years after passage of the Clean Water Act, Vice President Al Gore praised it as one of the U.S.'s most important environmental laws and launched a new strategy to address clean water issues of the next generation. The following statement delivered at an Environmental Protection Agency hearing by Roger Allison, executive director of the Missouri Rural Crisis Center, argues in favor of strong enforcement of the Clean Water Act in the face of repeated violations by factory farms corporations.

Date: 11/21/97

My name is Roger Allison. I'm a grain and livestock farmer from Howard County and executive director of the Missouri Rural Crisis Center (MRCC) which is comprised of over 3600 farm 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 MRCC's ag policy task force which is made up 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 factories in their midst -- manure spills, fish kills, contaminated groundwater and toxic gases like hydrogen sulfide and ammonia.

The growth of corporate industrialized agriculture has far outpaced our ability to protect our water.We have a wonderful law in the Clean Water Act but as our state environmental regulator admits, 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."

Therefore we applaud the Vice-President's directive for government agencies to implement an action plan in the next 90 days to more effectively prevent water pollution including runoff from factory farms. Expediting the regulatory process is a start in getting a handle on a crisis that is gripping the country from Maryland and North Carolina to Missouri to Colorado.

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, groundwater 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) meeting the animal unit requirements. These 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 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. The animal unit threshold should be 500 animal units to reflect the enormous amount and toxicity of the waste generated in these mid-sized facilities. In addition, livestock factory owners also must be held responsible for their operation's wasteincluding how it's applied to land. A no-discharge permit should mean no discharges into the waters of this state, including runoff from overapplication. They 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 based on the needs of their communities.

The Vice-President's initiative is commendable for its head-on approach to identifying sources of pollutants and developing strategies to control them. Point #10, USDA strategy for providing producers with technical and financial assistance to comply with standards, must be flagged for its potential for giving corporate subsidies to the large-scale corporate producers that have caused most of the problems. We send the wrong message to corporate producers when we reward them with money after they continually break existing laws. The offer of technical and financial assistance should be targeted to independent family farmers instead of corporations.

The crafters of the Clean Water Act and the Congress that passed it could not forsee 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.

I am here to tell the Vice-President and the EPA that family farmers are not afraid of an 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 devastate our land that has been stewarded and carefully passed on by our families for generations. These initiatives if refined to reflect our above concerns will help ensure that our generation has something to pass on to the next.