URGENT REQUEST FOR OZARK SOCIETY COMMENTS: C & H HOG FARM PERMIT MODIFICATION
WHAT IS AT RISK?
Water quality in the Buffalo National River
WHAT IS THE THREAT?
Untreated hog waste released from the C & H hog farm in Mt. Judea, Arkansas. Untreated, land applied-hog waste from the C & H hog farm located in Mount Judea, Arkansas runs off into Big Creek. Big Creek supplies much of the surface water flow into the Buffalo River. Runoff from hog waste applied to fields at C & H will enter Big Creek and then flow into the Buffalo National River.
WHAT YOU CAN DO: Comment by email or regular mail on the C & H Hog Farm Permit Modification
C & H Hog Farm (factory) has applied to ADEQ for a permit modification to allow use of a vac-tanker truck to spread untreated hog waste from storage Pond 2 on surrounding fields. Ultimately, we would like the entire permit to be re-opened for public comment. Please send a brief comment to ADEQ based on the information provided by regular mail or email. The deadline for written comments via email or regular mail is April 17th by 4:30 PM, Central Time. A short example comment letter is also included. If possible, please try to prepare your own written message using the example as a guide.
SEND WRITTEN COMMENTS TO:
Email: Water-Draft-Permit-Comment@adeq.state.ar.us; OR
Mail: Water Division Permits Branch, 5301 Northshore Drive, North Little Rock, AR 72118-5317 Attention: ADEQ Permit Branch
The public may also provide comments in person at a public hearing in Jasper, AR on April 20th, 2015. The announcement by the ADEQ is provided at the end of this request.
SHORT EXAMPLE FOR SENDING WRITTEN COMMENTS:
I request that the C & H Hog Farm proposed modification of their Nutrient Management Plan to allow land application of hog wastewater from Waste storage Pond 2 by tanker-wagon be denied.
It is not appropriate and it should not be permitted for C & H to use a vac-tanker truck to apply hog wastewater to any of the fields from Pond 2 without reliable, accurate information about the content of the waste – the amount of Phosphorus, Nitrogen and other nutrients and without reliable data on the level of nutrients, Phosphorus and Nitrogen already applied to some of the fields.
Thank you for the opportunity to comment.
Your name, mailing address, email and/or telephone number should be included.
ADDITIONAL TALKING POINTS YOU MAY WANT TO INCLUDE IN YOUR PERSONALIZED COMMENTS:
The C & H Hog Farm proposal to modify their permit to allow land application of hog waste water from storage Pond 2 by tanker wagon should be denied for the following reasons:
1. Documents submitted by C & H to justify modifying the permit contain incorrect maps, specifically ownership of field 5 and parts of fields 12 and 16. There are no new maps in the revised nutrient management plan. These continuing map errors, inaccurate leases and land ownership errors must be corrected before any wastewater sewage is applied by Vac-Tanker from Pond 2. Who owns the fields/parts of fields and who may lease these fields? Which fields will receive the Pond 2 waste?
2. Field application areas have changed from 630.7 acres to 335 acres without explanation. The modification request indicates an increase in waste production by about 500,000 gallons with only 750 pigs (down from around 4000), begging the question of why is waste production up from 2,090,081 gallons to 2,614,059?
It is critically important for C & H to eliminate errors, misrepresentations and unexplained changes in data when requesting a modification of their permit to remove waste from Pond 2 by Vac-Tanker. How much waste? How is the waste spread? Is it distributed evenly over a field?
3. There is not adequate information on the amount of Phosphorus, Nitrogen and other nutrients in Pond 2 that would be spread on fields by vac-tanker truck. Most people are not trained in soil science but may notice from the Best Management Practices in the modification section that the P index data is provided for less than half of the fields and is listed as low, another unexplained deviation from the revised nutrient management plan (NMP). This lack of information makes it difficult to provide specific comments.
The permit modification should be denied because of errors and miscalculations in P index data, of the acreage for field application, changing hog population numbers, and gallons of hog waste produced.
It is understood that only comments directly pertaining to the modification will be considered. It is an unfortunate situation that the public is invited to comment on a very narrow portion of the General Permit and request by C & H to modify the permit, when a large part of the document is replete with continuing errors, miscalculations, unexplained changes and deviations in the NMP. Because of the misinformation, the entire permit should be reopened to the public for comment.
ADEQ ANNOUNCEMENT & REQUEST FOR COMMENTS:
LITTLE ROCK – An Arkansas Department of Environmental Quality public hearing for the proposed modification of coverage for C&H Hog Farm in Mount Judea under the Concentrated Animal Feeding Operation General Permit is set for 6 p.m. April 20 in the Jasper School District Cafetorium. Those attending the hearing should enter the school building, located at 600 School St. in Jasper, at the clock tower.
The proposal involves modifying the Nutrient Management Plan to allow land application of wastewater from Waste Storage Pond 2 via tanker wagon. The public notice of the Nutrient Management Plan and Notice of Intent are on the Department’s website at http://bit.ly/1BbrCSJ. [This document is about 80 pages]
Written comments will be accepted during the public comment period, which began on March 18 and ends at 4:30 p.m. April 17. Those who wish to comment on ADEQ’s draft permitting decision must submit written comments to the agency, along with their name and mailing address, during the public comment period.
Written or oral comments will be accepted at the April 20 public hearing. Written comments are preferred in the interest of accuracy. No additional comments will be accepted upon adjourning the hearing.
Written comments should be mailed to Water Division Permits Branch, 5301 Northshore Drive, North Little Rock, AR 72118-5317 or by emailing Water-Draft-Permit-Comment@adeq.state.ar.us. Telephone inquiries on the Notice of Intent and Nutrient Management Plan should be directed to (501) 682-0648.
After the public comment period and public hearing, ADEQ will issue a final decision on the request to modify the Nutrient Management Plan. Only comments directly pertaining to the modification will be considered. ADEQ will notify each person who has submitted written comments or requested notice of the final decision.