Threats to Georgia's Water Quality: An Analysis of E.P.D.'s Proposed C.A.F.O. Rules
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Experiences in North Carolina as well as many other states in the southeast region have demonstrated that prevailing waste management systems for animal feeding operations - lagoons and sprayfields - are directly contributing to the pollution of our nation's waters. As a result of public concern . and increased awareness of this problem, states throughout the southeast have responded by strengthening regulations and enacting legislation designed to protect the environment from the threats posed by animal feeding operations. Georgia appeared to be following the lead of other states when the Environmental Protection Division of the Department of Natural Resources ("EPD") announced its plan to promulgate regulations to address animal feeding operations. Shortly thereafter, EPD convened a Stakeholders Committee comprised of members of the environmental community, the agricultural community, EPA, U.S. Fish and Wildlife Services and academia. At the request of EPD, this Committee developed recommendations for regulations for animal feeding operations which were completed in October 1998. In December 1998, EPD released proposed rules which amend Georgia's Rules for Water Quality Control, Chapter 391-3-6. While EPD's decision to convene a stakeholders committee and promulgate regulations seemed to indicate that it recognized the importance of adequately addressing the problems posed by animal feeding operations, the rules as proposed indicate otherwise. The rules as proposed fail to regulate the vast majority of animal feeding operations in Georgia and do not contain specific requirements such as regular monitoring, annual inspections, and recordkeeping that are integral parts of an effective regulatory scheme. Moreover, the rules bear little resemblance to the recommendations submitted by the Stakeholders Committee and, in many respects, provide less regulatory oversight than current standards. Thus, the rules should be amended to reflect the consensus reached by the Stakeholders Committee and should be strengthened to include specific requirements with respect to siting, monitoring, and enforcement.