Water Docket, Environmental Protection Agency
Mailcode: 28221T
Attention Docket ID No. EPA-HQ-OW-2011-0188
1200 Pennsylvania Ave., NW.
Washington, DC 20460

The Delaware Chapter of the Sierra Club is writing in strong support of EPA action to collect information on CAFOs (confined animal feeding operations). It is imperative that basic information be collected from all CAFOs nationwide to ensure that the goals of the Clean Water Act are being met.

CAFOs have become one of the greatest sources of pollution in our waterways, sometimes producing hundreds of thousands of tons of manure a year on a single site. But, unlike most other regulated industries within the United States, CAFOs do not routinely report facility-specific data, even though the operations pose severe risks to human health and the environment.
This must change. It is imperative that the EPA has the information needed to effectively implement the Clean Water Act permit systems by which U.S. waters are protected.
We strongly urge the EPA to use its authorities under the Clean Water Act, Section 308 to swiftly adopt a new reporting rule for all CAFOs. We support a rule that collects information about each of these operations, including the location of the production area, the number and type of animals, and the volume of manure produced. In addition, this data collection should be repeated at least every five years.

• Reporting information to the EPA will vastly improve the EPA’s ability to ensure that CAFOs comply with the Clean Water Act and do not contaminate our lakes and waterways.

In addition, antibiotics, one of the medical miracles of the 20th century, are becoming less effective in human medicine due to the rise of resistant bacteria. CAFOs crowd thousands or even hundreds of thousands of animals into tightly confined spaces. These industrial animal operations use antibiotics non-therapeutically—not to treat sick animals—but to compensate for overcrowded, unsanitary, and stressful conditions and to promote faster growth. The U.S. Centers for Disease Control (CDC) has declared antibiotic resistance one of its “top concerns.” Unfortunately, CAFOs routinely use massive amounts of antibiotics, including those important in human medicine, for non-therapeutic purposes. (Mellon, M. Ph.D., J.D., Director, Food and Environment Program and Susan Prolman, J.D., Washington Representative, Food and Environment Program at the Union of Concerned Scientists)

There is a growing recognition that industrial agriculture's contributions to antibiotic resistance must be addressed. On the Federal level, the Preservation of Antibiotics for Medical Treatment Act would end the routine, non-therapeutic use medically important antibiotics in animal agriculture. The American Medical Association, American Public Health Association, National Association of County and City Health Officials, The Humane Society of the United States, and Sierra Club are among the more than 380 health, consumer, agricultural, environmental, humane, and other organizations that have endorsed this bill. States are moving forward as well, with legislation addressing this issue currently pending in Maine and Ohio.
On a local level, citizens are asking their schools and restaurants to stop purchasing meats raised with the non-therapeutic use of antibiotics.

Thank you for your consideration of our comments on this much-needed rule to assess the extent to which CAFOs may be contributing to water pollution and affecting our communities.

Sincerely,

Nancy Moore, Chair, Executive Committee, Sierra Club, Delaware Chapter
Sarah Bucic, Board Member, Executive Committee, Sierra Club, Delaware Chapter
Jim Black, Member, Sierra Club, Delaware Chapter

CC: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attn: Desk Officer for EPA, 725 17th St., NW., Washington, DC 20503.