EPA-HQ-OW-2005-0037
I strongly oppose your proposal to allow CAFOs to self select themselves for
regulation. I doubt very many will voluntarily apply for permits to discharge.
I think all CAFOs should be registered with EPA, just as blood facilities must
be registered with FDA. All CAFOs should have nutrient management plans. I
strongly support the proposed use of the zero discharge requirement, and the
use of Best Practicable Technology limits for coliform standards. The Clean
Water Act was intended to return our waters to swimmable fishable conditions.
Rampant unregulated animal waste discharges, either intentional or as "acts of
nature" in stormwater runoff, are completely contrary to the Clean Water Act.
These discharges are neither unexpected nor unpreventable. The huge volumes of
wastes generated by CAFO must be planned for via the NMP process, with zero
discharges into the environment as the goal. This process should apply to all
CAFOs, large or small. NO exception should be made for "agricultural
stormwater", and CAFOs that don't "plan" discharges. Thank you, T. Burns
Comment submitted by T. Burns
This is comment on Proposed Rule
Revised National Pollutant Discharge Elimination System Permit Regulation and Effluent Limitation Guidelines for Concentrated Animal Feeding Operations in Response to Waterkeeper Decision
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