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Balancing large farms and toll on environment

By Stacy Gittleman


Earl Butz, U.S. Secretary of Agriculture in 1973, told America’s farmers to “get big or get out,” ushering in decades of policies and incentives for the country’s agricultural industry to embrace farming at an industrial-sized scale as countless smaller family farms struggled and lost ground. According to the organization American Farmer, the United States between 1992 and 2012 lost 31 million acres of farmland to urban and suburban development.


While smaller, many family farms have been losing ground and jobs for decades, but for others, there is an area of growth in agriculture: the larger, industrial, or factory farm. Food and Water Watch estimates that there are now 25,000 factory farms in the country, accounting for 1.6 billion animals.


Anyone shopping at their local grocery store looking to get the best price on meat, dairy, or eggs should be aware that low prices come with a price to the environment.


“Everyone who eats food should care how it is raised, processed, and brought to market,” said Michigan State University Extension Environmental Management Educator Sarah Fronczak, who grew up on a Michigan hen and row crop farm and is passionate about helping farmers manage the environmental impact of their farms. “In Michigan, we are surrounded by water resources. We cannot separate farming practices from the food we consume. Without farmers, we do not have food. But we all must care about the quality of the water in the Great Lakes. It’s all intertwined.”


Over the last 30 years, strains on the agriculture industry brought on an age of industrial farming, where animals are not fed in a pasture but for the better part of their lives are housed and fed commodity crops like corn and soy in large warehouse-like confinements. Untreated waste from all of these animals, totaling up to millions of gallons a year, is stored in manmade waterways or vast holding containers until it is sprayed onto crops. When the ground becomes too saturated with nutrients like phosphorus, nitrogen, or potassium, or if manure is spread onto frozen ground or right before a soaking rain, this runoff of untreated animal waste winds up contaminating inland water tributaries, streams, rivers, and ultimately, the Great Lakes.


The Environmental Protection Agency (EPA) in 1976 coined the term Animal Feeding Operations, or AFOs, for this method of condensed farming, where animals are confined in an on-site building for more than 45 days per year.


When an AFO reaches an animal equivalent of 1,000 pounds of animal – which could be 1,000 beef cattle, 700 dairy cows, 2,500 swine weighing more than 55 pounds, 125,000 broiler chickens, or 82,000 laying hens or pullets – it is defined as a Concentrated Animal Feeding Operation, or CAFO. In the early 2000s, the EPA began to require permits of CAFOs under the National Pollutant Discharge Elimination System (NPDES) mandated by the Clean Water Act (CWA).


Whether they are classified as a CAFO or an AFO, there are nearly 300 of these industrial farms in Michigan, clustered in the lower peninsula in the thumb region around Lakes Huron, Erie, and Lake St. Clair, along the south central and southwestern coast of Lake Michigan.


The distinction between AFOs and CAFOs can be a matter of just a few cows or chickens. Unless they pollute, AFOS are not required to be regulated with an NPDES permit. However, that does not mean that livestock issues that affect surface water are not regulated. Possible violations can be reported to Michigan Environment, Great Lakes and Energy (EGLE), or Michigan Department of Agriculture and Rural Development (MDARD) through the Right to Farm Act.


Environmentalists contend that AFOs are a tricky non-point source of contamination to nail down and say it is a critical task for EGLE to create enforcements, given that many water quality impacts in Michigan are partly caused by these sources. But farmers are looking at the bottom line.


Laura Campbell, manager for the Agricultural Ecology Department for the Michigan Farm Bureau, said CAFO owners in the state do not accept the 2020 permit – which is in the midst of litigation – because it “goes too far” and will put an increase of compliance costs onto farmers, including costs to transport manure to other locations. She added that it also puts a pinch on the farming industry’s bottom line that has already been hit hard by the COVID-19 pandemic.


“It will be difficult to comply to the 2020 general permit’s newer nutrient maximum calculations and not spread manure in the winter. We feel these are arbitrary numbers not based on data or science.”


There is no question, though, that farming in Michigan is big business. According to the Michigan Department of Agriculture and Rural Development (MDARD), agriculture contributes more than $104.7 billion annually to our state's economy, with livestock and crop diversity that comes in second only to California.


Still, Campbell stresses that staying afloat for a family farm is a struggle. In the 1980s and 1990s, tight profit margins made some farmers look at their land as another commodity to sell. High-interest rates on loans for farmers put on more pressure, and more aging farmers saw less of the next generations wanting to work the land. Eventually, she said efficiency in large-scale and concentrated farming became the best way to stay in farming.


The pandemic saw the further consolidation of the meat processing industry. Over 80 percent of the country’s meat processing industry is run by four companies: JBS, Tyson, Cargill, and National Beef.


“These companies want to process meat in high volume,” said Campbell. “If you are running a farm with a low headcount of livestock, they do not want to talk to you. There are some farms that have found their niche marketing to the farm-to-table market and they can stay small. But the industry is telling you to have either a small, niche farm or a large commodity farm. There is not a lot of room for medium-sized farms.”


Campbell, who grew up on her family’s Ohio horse and hay farm, argues that concentrated farming has helped farmers hold onto land that their family has worked for generations. Because animals are fed a controlled diet, farmers can have better quality control of the final product, be it meat, dairy products, or eggs.


“CAFO farmers are looking for the most efficient way to use the land. On one property, they want to grow the crops for their animal feed, raise the animals for market, and then use the manure from the animals to fertilize their crops.”


Campbell said it is a farmer's primary responsibility to take care of their animals and the land so future generations of farmers – often their family members – can continue to work. And many see CAFOs as a highly efficient way to farm, protect animals from disease, maximize an animal's nutrition intake, and efficiently bring quality meat, egg, and dairy products to market.


“Raising animals inside protects them from disease. Just because a farm is big does not mean that a farmer does not care about the welfare of the animals they raise or the land that they raise them on. It makes the best business sense to care both about the animals as well as the land.”


According to the Sierra Club, animals living on even the smallest CAFO in a day produces as much urine and feces as 16,000 humans. The big difference, the Sierra Club said, is that human waste is processed at a municipal wastewater treatment plant. CAFO waste is not treated to reduce disease-causing pathogens, nor to remove chemicals, pharmaceuticals, heavy metals, or other pollutants in the waste. Instead, it is stored untreated in storage structures or watery pits called lagoons for up to six months. Following its storage, the liquefied manure is sprayed onto farm fields for disposal. When waste from too many animals is spread on a disproportionate parcel of land, or on top of snow or frozen ground in the winter, an excess of phosphorus can enter into the waterway system.


Sierra Club Michigan Chapter State Director Gail Philbin said the organization has been monitoring activities and advocating for increased regulations on CAFOs in the state for over 20 years. Philbin said even though people may not live in the regions where CAFOs are clustered in the state, everyone should be concerned about how these factory-style farms impact the water for recreation, fishing, and drinking water quality.


“No matter where you live in the Great Lakes, all our waters are connected,” said Philbin. “Wastewater that runs from CAFOs eventually will drain into a watershed that leads into Lake Huron and Lake Erie. You don’t have to live near a CAFO for it to impact your water quality.”


Philbin and other environmentalists point to the massive toxic algal bloom in Lake Erie in 2014 that choked the drinking waters for Toledo, Ohio, as a lesson for those living in Michigan as to what can happen when phosphorus from agricultural runoff goes unchecked.


Philbin explained that in 2018, there were toxic algal blooms caused by agricultural runoff in Lake St. Clair and Saginaw Bay that were as significant as the Lake Erie algal blooms. However, the locations of those blooms did not impact drinking water supplies.


Officials with the Great Lakes Water Authority (GLWA), which draws water from Lakes Erie, Huron, St. Clair, and the Detroit River watersheds to provide water and wastewater services to 127 municipalities in seven southeastern Michigan counties, said they do not do any studies on aquifers and inland waterways. GLWA said it is not concerned about algal blooms in Lake St. Clair or Lake Huron because water is drawn from deeper in the lakes and not close to the shore. GLWA is also participating in the Detroit River Watershed Project, which involves quantifying phosphorus loadings entering the watershed impacting algae growth. Partnering researchers will determine how the amounts of phosphorus in the St. Clair River, Lake St. Clair, and the Detroit River – all part of the Detroit River Watershed – contribute to algal blooms in Lake Erie.


In 2019, GLWA surpassed federal and state regulators’ goal of reaching a 40 percent reduction in phosphorus levels by 2025, six years ahead of its deadline. GLWA has said it has been able to reduce its phosphorus levels by approximately 60 percent in treated and discharged waters from its water resource recovery facility. It is the first treatment facility along the tributary to Lake Erie to achieve this milestone.


Under Michigan’s Water Quality Monitoring Strategy, EGLE inspects the state’s watersheds on a five-year rotating basis by studying the small tributaries, streams, and rivers that lead into the watersheds. EGLE’s last comprehensive study on waters of the Saginaw River Watershed, Bay, Saginaw, and Tuscola counties was in 2014. The study identified sources of pollution that could impact the integrity of the tributaries and rivers that lead to the watershed and found “in general, agricultural and urban development within these watersheds has overwhelming effects on hydrology and water quality.”


Meaghan Gass, who works for the MSU Extension and the Michigan Sea Grant Project said that Michigan State University, the Bay County Health Department, and Saginaw Valley State University are working together to study the connectivity and quality of the waterways that start inland around farms and end up in regional watersheds. They regularly sample the waters in surrounding counties for microbial activity and E. coli levels, especially in the summer when raised levels of E. coli and nutrients threaten to close beaches.


Gass said the shallow, warm waters of the Saginaw Bay are home to one of the world's most diverse nesting habitats for waterfowl.


Though there are indeed stressors to the water quality in these watersheds, including harmful algal blooms, Gass said there is a difference between water conditions in Lake Erie that make algal blooms there more threatening to drinking water compared to the ones that occur in the Saginaw Bay and Lake Huron.


Gass said that with this research, Michigan Sea Grant and MSU are creating weather and water condition modeling tools that can be used through a mobile app that can help farmers better predict runoff patterns so CAFOs can someday make quick recalculations on when – and how much – they can apply nutrients to their soil and crops.


“This is a free tool that can be used by anyone to better forecast runoff risk,” said Gass. “We hope it will be used by agricultural producers so they may use the data to be better informed on how to avoid nutrient runoff and to be better stewards of the Great Lakes.”


The issue farmers have with a lack of regulations or enforcement on CAFOs is that there is no centralized place either at the federal or state level where data is being collected on activity. The EPA in 2009 left monitoring and permitting up to the states, and state environmental agencies are stretched thin. As it stands now, there are just nine EGLE CAFO inspectors to perform routine inspections on the state’s 288 CAFOs once every five years.


That is where grassroots movements such as Environmentally Concerned Citizens of South-Central Michigan (ECCSM) have stepped in.


Group member Pam Taylor is a retired teacher and a descendant of farmers who have worked the land in Lenawee County since 1837. A believer in traditional and sustainable farming methods, Taylor is one of the leading authors of the 2017 report: A Watershed Moment, one of the first reports in the nation to create a fully digital, sortable interactive layered map and database that documents and inventories all permitted CAFOs in a single state.


The report’s digital maps account for any permit violations committed by a Michigan CAFO from 2003 through 2016.


Taylor said documentation in A Watershed Moment took a team of volunteers a year to compile working from countless state and federal documents unearthed with the help of 300 Freedom of Information Act (FOIA) requests. Through her research, she learned that the state only began to thoroughly document CAFO activity in 2010. In fact, another 2019 national study on CAFOs by the National Resources Defense Council said Michigan received the lowest transparency rating, judged with criteria such as permit status, CAFO location and ownership, animal type and count and manure storage.


Taylor said within proximity of the southwest Lake Huron, Saginaw and Lake St. Clair watersheds – where millions of GLWA customers depend upon for their drinking water – many CAFOs have cropped up. This is because there is low population density, land is inexpensive and abundant and there is little that smaller townships can do from a regulatory standpoint to stop their growth. Though many are run by families who have farmed in the area for generations, the area has attracted European agriculturalists who are buying up land and establishing CAFOs as well.


Within the Huron Valley watershed, there are 37 CAFOs with 728,949 animals producing 593,734,441 gallons of waste from January 1, 2016 through December 31, 2016. From 2010 through 2016, these CAFOS were charged by the state with 67 enforcement actions. The St. Clair watershed, also a drawing source for GLWA, is host to just four CAFOs with 6,215 animals producing an average of 33,883,702 gallons of waste between 2010 and 2016. These CAFOs received 10 permit violations in that time span.


Taylor said with CAFOs receiving government subsidies and smaller dairy farmers raising their cows on pastures getting none, there is not much incentive for the larger agricultural operations to continue traditional farming methods.


“It puts the smaller, traditional farmer at a risky place,” said Taylor. “They can grow fruits and vegetables and stand to lose the farm their family had for generations, or they can go bigger and dedicate their acreage to commodity crops. From a business standpoint, it is a rational decision, but if you live downstream or enjoy the natural resources of the Great Lakes, not so much.”


In addition to polluting the water, CAFOs can also pollute the air with dozens of noxious gasses including ammonia and hydrogen sulfide, causing ailments like asthma and chronic bronchitis, according to a 2019 National Resources Defense Council report: CAFOs: What We Don’t Know is Hurting Us. The report said that the EPA provides no regulation on air pollution emissions from CAFOs, nor do they have any data quantifying how much noxious gases they emit.


However, those living around CAFOs just need to rely on their nose to know that something is not right.


On the western side of the state, former Michigan state Representative Dave Maturen (R-Kalamazoo), who lives on Indian Lake in Vicksburg, said beginning in the 1990’s, a small poultry farm across the street from his home gave way to a 1,000 hog CAFO which featured a million-gallon lagoon to contain the animal waste. Maturen said opening a window on a breezy summer night was not an option.


Maturen and many others in Michigan learned that local voices, petitions and a six-year process of passing a local zoning ordinance against large scale farming in Brady Township was no match for the Michigan Right to Farm Act which in 2000 was revised to pre-empt any local ordinances that tried to control the size or regulate CAFOs in their jurisdiction.


Though the hog farm is no longer there, those living around other CAFOs, and even some larger AFOs that come just under the wire of this classification, say that there is little they can do from a local level. They argue that the small number of inspectors assigned to oversee regulations and activities for the hundreds of CAFOs in the state are not enough and EGLE’s permit requirements do not go far enough to protect the quality of life in protecting Michiganders from air and water pollutants emanating from these farms.


“The farming industry still wants to paint the picture of a small family farm with a red barn, but some of these larger farms produce more feces in one day (that go untreated) than the city of Kalamazoo,” said Maturen, who is president of the conservation group Michigan Lakes and Streams Association. “Farmers have every right to make a living, but once they reach an industrial size, they should be subject to the same rules and regulations like any polluting industry.”


In Michigan, EGLE stands as the regulating body for CAFOs. Right now, environmentalists and those in the large-scale agriculture industry are in a dead heat about just how far the state should go in stepping up regulations as CAFO permits are revised and updated.


The 2015 EGLE CAFO permits expired in April of 2020. The 2020 permits have yet to be issued or enforced because they are being held up in court by the Michigan Farmer’s Bureau, representing state agricultural organizations including the Michigan Milk Producers Association, Michigan Pork Producers Association, Michigan Allied Poultry Industries, Dairy Farmers of America, Select Milk Producers, Foremost Farms and more than 120 individual permit holders.


Rob Michaels, a senior attorney with the Environmental Law and Policy Center, did extensive work on how the growth of CAFOs in the Maumee River Valley region in Ohio led to Lake Erie’s 2014 toxic algal bloom, and how this should stand as a lesson for Michigan’s regulating bodies. Most recently, he worked with a coalition of Michigan environmental organizations, including the Michigan Environmental Council, ECCSCM, Alliance of the Great Lakes, Environment Michigan, and Tip of the Mitt Watershed Council, For Love of Water, Michigan League of Conservation Voters, Michigan Sierra Club, and Socially Responsible Agricultural Project to shape the new 2020 regulations in the EGLE CAFO permit, which is supposed to be revised and reissued every five years.


New stipulations in the 2020 permit call for a ban on spreading liquefied manure on frozen ground between January and March each year, as it can be the largest contributor to nutrient runoff. The new permit also calls for reducing the percentage of nutrients that can be calculated into a CAFO’s comprehensive nutrient management plan. The 2020 permit also calls for planting a 35-foot-wide vegetative buffer between waterway embankments as well as having a 100-foot easement between waterways and where manure is spread on crops to minimize agricultural runoff.


“The amount of animal waste produced at CAFOS poses a big threat to our water sources,” said Michaels. “The EPA has had such a success over the decades in cleaning up our country’s waterways from other industries. While we are pleased that EGLE added our suggestions (to end wintertime manure spreading on frozen ground), there are no hard and fast penalizations for non-point sources of pollution like the kind caused by agricultural runoff. EGLE needs to go much farther considering the threat they pose.”


Michaels said there are no “hard and fast caps against agricultural waste.”


“The best solution we see is to put a cap on the amount of waste that can be spread onto the land. We have found that many of the crops and the soil they are planted in cannot hold any more phosphorus. CAFOs need to expand their land base as well as invest in waste treatment technologies. History shows us that when proper regulatory functions go into place, the market will create a product or technology, and ultimately jobs, to meet compliance standards.”


EGLE spokesperson Nick Assendelft said while the 2020 permit is in litigation, Michigan CAFOs still need to adhere to 2015 permits. CAFO permits contain requirements for design, operation, and maintenance of manure storage structures, land application requirements, and a requirement to develop and submit a nutrient management plan that is expected to be adhered to for the life of the permit. Every time a farmer applies manure to their property, they must document the amount and the weather conditions of that day.


“EGLE is determining a CAFO’s compliance or non-compliance by the 2015 general permit until a new permit is in place,” said Assendelft. “EGLE staff responds to any complaints and discharges and performs one full onsite inspection every five years. They also perform cursory inspections in that same five-year period. CAFOs are required to file annual reports by April 1 of each year, which staff reviews. EGLE is following its normal procedures in making sure permit holders adhere to the current rules.”


Recognizing the environmental degradation of CAFOs, some in Congress, like Sens. Elizabeth Warren (D-Mass.) and Corey Booker (D-NJ), are going out on a limb against the agriculture lobby and calling for a phasing out of CAFOs by 2040, according to the Pew Research Institute.


But in Michigan, environmentalists and researchers – many of them with family roots in agriculture – are trying to provide CAFOs solutions to best manage their farm’s environmental impact.


When thinking about larger versus smaller farms and their environmental impact, Fronczak of the MSU Extension cautions that just because a farm is smaller does not mean that they cannot harm a watershed. In fact, she said that size does not matter just so long as the farmer manages the farm in an environmentally conscious way.


Fronczak points to the Michigan Agriculture Environmental Assurance Program as a national model for providing outreach and education to farmers on how to best adapt sustainability practices to their industry. Administered by MDARD, the program helps farms of all sizes and all commodities voluntarily prevent or minimize agricultural pollution risks. It has verified over 5,000 Michigan farms that have earned certifications for farmstead, cropping, livestock, and forest and wetland stewardship.


“Farms are a business, and like any business, they should be taking responsibility for their waste, care of their animals and care of the land entrusted to them.”


Some high-tech solutions that MSU has researched, developed, and put into production to lessen the impact of animal waste are anaerobic digesters. Anaerobic digesters can process large amounts of animal and food waste and turn them into fuel by capturing some of the gas emissions from animal waste. Since 2013, the anaerobic digester at MSU each year processes about 17,000 tons of organic waste from MSU and the greater Lansing area per year as feedstock to produce biogas to generate over 2.8 million kWh of electricity per year. The system is fed by the dairy manure from the MSU Dairy Teaching and Research Center, food waste from several campus dining halls, fruit and vegetable waste from the Meijer Distribution Center in Lansing, and fats, oil, and grease from local restaurants and provides enough energy to fuel several buildings at MSU’s south campus.


But the cost of digesters is steep – at an average of $5 million – and they are not foolproof. In 2018, a CAFO in Barry County using a digester had a malfunction causing a manure runoff spill of between 5,000 and 10,000 gallons.


ECCSCM member Taylor said farming cannot "high-tech" its way out of the problem of excessive manure production with things like anaerobic digesters.


“For 20 years, we have seen every kind of newfangled system digesters and other technologies come and go,” said Taylor. “They are just too expensive and only create more problems. If a farm must exist as a CAFO, there must be regulations that the waste is treated just like human waste is treated. The government has its finger on the scale weighing very much in favor of larger farms. We try as much as possible to advocate for more sustainable farming practices. You cannot 'technofix' your way out of the amount of nutrients that run off from CAFOs which cause harm to wildlife populations, close our beaches and threaten our air and water resources."

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