Mark your calendar...November 22nd is the deadline for comments on proposed new rules on animal waste management in NC that will affect our rural communities and our waterways. Here are some talking points. Don't hesitate to contact us at Winyah Rivers for more information. Send comments by e-mail to: 15ANCAC2T2URule_Comments@ncdenr.gov (Put “2T 2U Comments” in the subject line)
Proposed Changes to Rules in 15A NCAC 2T and 2U
Permit Terms (See 2T. 0108 & .0111):
The terms of non-discharge permits should not be extended from 5 to 8 years.
- This proposal would decrease opportunities for public input, which is especially problematic when the public can’t comment on individual applications for coverage under general permits
- The State’s general permit for swine operations was challenged under Title VI due to its disproportionate impact on communities of concern. The NC agency responsible for water quality protections should seek more, not less, input from communities in these circumstances.
Setbacks (2T .0506, .0606, .0706, .1108; 2U .0600):
Rights to protection from pollution should not depend on whether one leases or owns the property next to a waste disposal field. Setbacks should still apply if the permittee leases neighboring property to another.
The rules should maintain the requirement for a 100-ft setback from swimming pools instead of assuming all pools are "places of public accommodation".
Critical information regarding the fate of waste generated by agricultural operations should not be shielded from the public (see 2T .1403 & .1404).
Government transparency should be a priority for the state agency. Depriving citizens of access to manure hauler records showing where waste is disposed limits the ability of the public to educate and protect communities from polluters.
Prior to permitting the land application of bulk animal waste residuals, the agency should give neighbors the same notice and opportunity for comment as it does prior to the land application of other bulk residuals (see 2T .1310).
CAFOs (Concentrated Animal Feeding Operations):
Poultry operations, the largest and fastest growing source of nutrients from animal agriculture in NC, should not be deemed permitted. The agency should consider location and waste management practices when permitting a CAFO in order to protect the public and our waterways (see 2T .1303).
A violation points system to reduce the threat posed by serial polluters operating swine facilities should be created to protect the rights of the public (see N.C.G.S. 143-215.6E).
CAFO permits should include cost-effective surface water quality monitoring obligations informed by, and responsive to, a permittee’s compliance record.