Action Alert: Public Input Sought for Agricultural Procedures Impacting Michigan Streams
The Michigan Department of Agriculture (MDA) is seeking public input on three GAAMPS by August 18, 2008. GAAMPS are Generally Accepted Agriculture Management Practices and these are the guidelines that farms and agribusinesses must follow in order to keep the protections provided by the Right to Farm Act. Two of the GAAMPS under review are critical to protecting our coldwater resources and Schrems West Michigan Chapter of Trout Unlimited with the help of the Kalamazoo Valley and Lansing-Bob Perrin Chapters of Trout Unlimited have developed the following recommendations:
Site Selection and Odor Control for New and Expanding Livestock Production Facilities GAAMP
The procedure starts out by laying out 3 primary objectives: Environmental Protection; Social Considerations (neighbor relations); and Economic Viability. The procedure then goes on to contradict this statement by saying, “Groundwater and surface water quality issues regarding animal agriculture production are currently addressed in the “Generally Accepted Agricultural and Management Practices for Manure Management and Utilization”, and are not duplicated here”. By deferring most discussion about potential impacts of production facilities on groundwater and surface water to the GAAMP for Manure Management and Utilization, water resources are relegated to a matter of secondary importance after other issues. Fish and wildlife resources should be considered as well during site selection. We feel that this procedure needs to have the following protection added:
1. New or Expanded operations should not be allowed within the 100 year flood plain or within 1,000 feet of any public surface water.
Manure Management and Utilization GAAMP
The current procedure calls for incorporation (mixing) of manure into fields where it is spread within 48 hours. We feel this time limit does not adequately protect our lakes and streams from run-off if a heavy rain should occur. A more protective time frame would be to require incorporation within 24 hours, but this is not likely to be supported by the agricultural community. With these factors in mind, our recommendation is:
2. Inject or immediately incorporate any manure spread within 300 feet of public surface water, or on any sloped field that directly drains into public surface water. Immediate incorporation shall be defined as within 6 hours. Any manure spread within 300 feet of public surface water should have appropriate buffers installed to prevent run-off.
Many southern Michigan streams suffer from high E-Coli bacteria levels, but very little is being done to control or improve this situation. As you may recall, a major fish kill occurred a few years ago on Tyler Creek when a significant amount of manure entered the stream. The source of the manure was never conclusively proven, but continuing high levels of E-Coli in these agricultural areas point to the need to improve some of our agricultural practices.
3. Any operation located within 1,000 feet of a public lake or stream, where that body of water is currently not meeting the DEQ standards on water quality for E. Coli on partial or total body contact shall be required to obtain an external assessment of their Conservation Practices similar to that of the MAEAP program. The operation will also submit to the County Drain Commission an updated survey of the drain tiles on any fields where manure is being spread, or where livestock is grazing.
Please write the to MDA and express your concerns with the current agricultural practices and include these three specific recommendations to protect our streams and rivers.
Written comments may be submitted to MDA’s Environmental Stewardship Division, P.O. Box 30017, Lansing, MI 48909, or via e-mail to email@example.com by 5 p.m. on August 19, 2008. MDA will forward all comments received by the due date to the respective GAAMPs Task Force chairpersons for consideration prior to final review and adoption.
For a copy of any of these GAAMPs including the proposed revisions, please visit www.michigan.gov/gaamps, or contact the MDA’s Environmental Stewardship Division at (517) 373-9797, or toll free at (877) 632-1783.