Today, at TDEC offices across Tennessee, there are two public hearings to discuss rule changes.
Sometimes rule changes are innocuous. These are not.
The net effect of these rules is that "medium" CAFOs will henceforth be exempt from regulations that would protect Tennesseans from the millions of gallons of waste they generate.
You may know CAFOs from more common nomenclature: factory farms.
After this rule change,
A dairy with 699 cows? No permit.
A hog farm with 2,499 fully-grown swine? No permit.
124,999 chickens? No permit.
No permit? No problem.
Just how much manure is that?
To get an idea of how much waste that is, imagine a packed Neyland Stadium at UT vs Alabama. If those fans were trapped in there for 24 hours, they would generate more than 200,000 lbs of waste.
The same amount of swine in that stadium? Over a million pounds in one day.
One hog = over 10 lbs waste per day
One NEWLY UNREGULATED factory farm with 2,499 swine = over 9 million lbs of waste per year
What do they do with all that manure?
If you look at an aerial view of one of these factory farms, you'll likely find a big roundish dark spot on the terrain. It looks similar to a waterbody on the satellite image because it's big and dark. You can't tell how deep it is or what's in there, but I'll give you a hint: it ain't Shinola.
You're probably looking at a manure lagoon. Those Olympic-pool-sized craters hold - literally - tons of manure. They should be lined so that contaminants don't enter our groundwater. They should be secured against mass precipitation events so all that fecal coliform doesn't wash into our drinking water sources. And the waste should be accounted for. If a truck comes and vacuums up 6 tons of manure and drives away, shouldn't we have some idea of where it's dumping? These concerns do not disappear when you downgrade from 125,000 chickens to 124,999. What now? TCWN feels that the opportunity exists for better cooperation between Tennessee's Departments of Environment and Agriculture. There must be a way for TDEC to work with the Ag Dept (and within our current legislative framework) to better secure our water quality around factory farms. Department of Agriculture staff work tirelessly on USDA and NRCS compliance issues. The Agency is experienced with best management practices for farmers to protect soil and water health. And it is a much better conduit for communicating environmental concerns to farmers in language they speak, making note of their concerns, and working with them for a mutually beneficial result.
Why would TDEC voluntarily reduce water quality protections?
It’s not doing it voluntarily. TDEC’s hands are virtually tied on this matter due to the 2018 passage of Senate Bill 2217 and House Bill 1017, the so-called "Loophole Legislation." Combined, both bills were three pages. Those three pages forced TDEC to roll back clean water protections for medium CAFOs. It was Tennessee’s own House and Senate representatives that not only allowed this to happen, but rather they caused it to happen.
Why? To attract business to the state. All across the nation, producers like Tyson are finding it increasingly difficult to hide the detrimental impacts of their operations. Issues of animal welfare notwithstanding, water quality issues related to CAFOs are getting more attention, and states are reacting to make it more difficult for CAFOs to pollute. Not in Tennessee. It appears our state legislature wants to attract business that other states have deemed too dangerous to public health to continue without regulation. That’s backwards, eh? The Last Say TDEC may have the last say when it comes to executing these laws, but TCWN will put its thoughts to paper first - for any Tennessean to read. TCWN will issue a comment letter about these rules to TDEC by their deadline date of July 25. If you would like to see your name added, or if you would like some help drafting your own letter, let me know at email@example.com. As an individual Tennessean, you rely on TDEC to keep your water clean. And you rely on TCWN and other conservation groups to ensure the Agency does its job. Please do your part to support the work of water quality advocates in Tennessee by donating here.