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Greg Scannell, CSP •

EPA vs. Small Farms

We all want clean water to drink, clean air to breathe, and clean land to produce from. The best means for achieving this is investment in small, local farms that believe in sustainability.

Sustainability has evolved from a media buzz word to an all encompassing movement concerning not just ecology but also economy and equity for people of all backgrounds. No organization has more regulatory influence in this arena than the Environmental Protection Agency (EPA). Small farms may assume they are free from such regulatory entities, guess again! The EPA employs inspectors that are responsible for managing the water, air and soil of every county in the United States in every economic sector—including agriculture. The following is a break down of how the EPA works, and how you can best protect your farm from violating their rules and regulations.

Farms are required to meet the compliance rules of their local, state and federal environmental laws. Any farm that confines animals for at least 45 days out of the year are defined as an Animal Feeding Operation (AFO). AFOs can be further categorized as Concentrated Animal Feeding Operations (CAFOs) if they meet certain requirements—mainly the number on animals on the farm and waste water discharge criteria (should their waste discharge directly to surface water, or an open water source runs through their property). See the table below for the CAFO requirements of horse farms. CAFOs are required to apply for permits and manage their facility in accordance with specific, professionally engineered design criteria. It’s important to recognize that an AFO can be designated a CAFO by the permitting authority despite low numbers of animal units. Typically AFOs are designated, and thus held accountable to CAFO design and operation criteria, by violating local, state and federal environmental laws. One example of this may be as minimal as discharging manure solids into your properties road side ditch—a conveyance means for water and thus an EPA regulated entity.

EPA inspectors are required to preform due diligence at both CAFOs and AFOs for the counties they oversee. An inspector may open a case on your farm by means of a complaint, a local emphasis program, or by random observance of a problem. Once an inspector is on site, they will document the means and methods of your nutrient management plan and look for any unlawful contaminations of water (surface and ground), air or soil. They will inform you of any violations, which if corrected promptly through a compliance commitment agreement, will not warrant monetary fine or legal processing. Violations that are not addressed immediately, or are significant, will be referred to the state’s attorney general for issuance of fines and potential legal action. Once issued a violation, your farm will now be designated as a CAFO, and subject to more strict regulation and permitting through the National Pollutant Discharge Elimination System.

Although most equestrians I know proclaim to be stewards of the environment, no longer can we hide behind words and decrees. Domestic farm animals contradict the balance of an ecosystem if left unchecked. The abundance of animal waste a farm produces can have a negative impact on the very soil, water and air the farm is sustained by. Comply with all federal, state and local environmental legislation, regulations and requirements including the Clean Water Act and the National Pollutant Discharge Elimination System. Manage rain water runoff away from open feed lots or manure holding areas. Runoff collecting directly in these areas should be designed so as not to contaminate any conveyance to local waterways. A good practice is to divert contaminated water, by means of gravity, through a vegetative filter strip.

The importance of preventative environmental health and safety remains paramount. Daily inspection of the environment your horses live in serves to prevent losses. The professionals at Safety Check Inc. are trained in environmental health and safety hazard analysis and accident prevention, specializing in EPA and OSHA compliance. For an equine consultation or barn walkthrough, please feel free to contact us at (815) 475-9991.

Works Cited
  • Producers’ Compliance Guide for CAFO’s: Revised Clean Water Act Regulations for Concentrated Animal Feeding Operations (CAFOs). Washington, DC: EPA, 2003. Web.

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