Wednesday, September 25, 2013

Big Creek Hog Farm Near Buffalo National River

Update 1/22/2015:   According the an article on ParkAdvocate: "U.S. District Judge D. Price Marshall found two federal agencies liable for illegally guaranteeing portions of approximately $3.6 million in loans applied for by C&H Hog Farms, a 6,500-animal factory farm that began operating on a tributary of the river in 2013. The two federal agencies—the Small Business Administration (SBA) and the Farm Service Agency (FSA)—guaranteed these loans despite failing to conduct adequate environmental reviews."

Update 5/3/2014:  The Arkansas Pollution Control and Ecology Commission passed a 6-month moratorium on hog farms in the Buffalo River Watershed.  They also initiated a rule-making process to consider a permanent ban on medium and large hog operations in the watershed.  This is a good start, but there is lots of work to be done to protect water quality in the Buffalo River and around the state.

I've now attended multiple talks by UA professors on the state's monitoring plan.  Two questions arise that I don't think have been answered adequately:
1.  Why did the researchers not disclose the fact that nutrient application fields were mislabeled/misrepresented in the permitted plan?  They claim they didn't view it as their scientific duty, but science (I'm a scientist among other things) is about discovering the truth.  In not disclosing this information to the public they were knowingly perpetuating a falsehood and that isn't what science is about.

2.  Is the current, funded, monitoring plan adequate to definitively determine if the Cargill Hog Farm has negative impacts on Big Creek and the Buffalo River?  I don't think it is and two professors I've heard from on both sides of the issue have said as much.  The major flaws are that no funding is in place for accurate groundwater flow or nutrient sourcing studies.  The research team wants funding for dye-tracer studies.  There should be isotopic or other studies done to determine the source of nutrients found in the Buffalo.  There should also be more monitoring and karst mapping on fields where application is actually taking place.  Due to funding and landowner concerns, very few actual application fields are being monitored.

Update 2/12/14: Read this incredible letter from Earthjustice to ADEQ showing how C&H has been intentionally misrepresenting facts about its nutrient management plan to ADEQ, UA researchers, and others.  The letter also accuses C&H of spending and wasting taxpayer dollars via multiple sources despite their connection to Cargill, a private company with annual revenues over $100 billion.

Original Article:
The USDA and Arkansas Dept. of Environmental Quality issued permits to C&H Hog Farm to operate a CAFO (Concentrated Animal Feeding Operation) along Big Creek near Mt. Judea. The perceived weakness of the permit applications, and the permitting process in general, in addition to the fact that the farm is located in the Buffalo River Watershed roughly five miles from the Buffalo, have alarmed paddlers, environmentalists, and locals concerned with air and water quality impacts in their community. From the hog farm landowners' perspective, they followed all the rules, got their permits, took out large loans and have already begun bringing in hogs.

Due to water quality concerns and the importance of the Buffalo River (our nation's first National River and a major tourism draw), the Arkansas legislature approved the use of ~$340,000 of rainy day funds to study impacts of the hog farm and its proposed application of hog waste to nearby fields. Many of the proposed application fields border Big Creek and are in its floodplain. The fields will likely reach nutrient saturation within a short period of time and will probably contribute nutrients and biological contaminants to Big Creek and the Buffalo River. Ideally, the testing that will be performed by University of Arkansas researchers would take into account all possible routes for pollution to travel from the farm into the Buffalo River, however some of the university's professors already argue that isn't the case. I attended a presentation by Dr. Van Brahana, a Prof. Emeritus at UA, during which he argued that monitoring plans were insufficient as they didn't even mention karst or karst-related groundwater transport. This area of the state happens to have lots of karst (see map below), which allows for rapid transportation of water underground. This also means that pollutants aren't attenuated before they reach surface waters, such as the Buffalo or Big Creek in this case.

A lawsuit has been filed against the "U.S. Department of Agriculture Farm Service Agency (FSA) and the U.S. Small Business Administration (SBA) for their inadequate review and improper authorization of loan guarantee assistance to C&H Hog Farms". "Earthjustice, Earthrise Law Center, and local attorney Hank Bates are representing the Arkansas Canoe Club, Buffalo River Watershed Alliance, National Parks Conservation Association, and The Ozark Society".

One of the least discussed aspects of this story is that CAFOs fall under the General Permit system at ADEQ. General Permits are designed to be quick and easy to get and it is very difficult for ADEQ to deny a general permit application without risking a lawsuit. Few if any environmental organizations testified when ADEQ was deciding to place CAFOs under the general permitting system. If we want to prevent other CAFOs from popping up, this is something structural we need to change. Many states already ban CAFOs or specific practices often used by CAFOs. North Carolina, a huge pork producer, after having horrific spills from hog waste lagoons following a hurricane, has banned the construction of any new lagoons.

Let me know if I'm missing any important aspects of this issue or if I've gotten something wrong.

Links to More Information:
Lots of Documents and Background via Buffalo River Watershed Alliance
Hog Farm Near Buffalo Raises Concerns
Legislature Approves Funding for Water Testing at Hog Farm - ArkTimes
TNC Karst Program
ADEQ Site Inspection Report

How You Can Help:

Elect people who want to strengthen environmental protection and enforcement. Weak enforcement of existing laws is a big issue in AR.

Lobby legistlators and ADEQ to remove CAFOs from the general permit system or to ban CAFOs entirely (other states have already taken this step).

Encourage NPS, US Forest Service, State Parks, etc. to acquire entire Buffalo River watershed

Join the organizations mentioned above or here. Or at least get on their mailing lists.

Blue and Green Show Karst Areas.  Red Star - Location of Hog Farm

Green Arrow - Hog Operation Site.  Red - Waste Application Fields
View Hog Farm in a larger map

Proximity of CAFO to Big Creek and Buffalo National River.
View Hog Farm in a larger map

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