A sprayfield at an industrial hog operation (courtesy of Waterkeeper Alliance).
On October 24, CCR Attorney Fellow Allen Buansi delivered comment on the NC Department of Environmental Quality (DEQ)’s proposed Waste Not Discharged to Surface Waters rules (15A NCAC 02T) (“2T rules”), which expire in 2019. Importantly, these include rules governing animal waste management systems of CAFOs. The NC Environmental Management Commission sought public comment on these proposed rules in three hearings in different parts of the state, with the third held in Raleigh on October 24, 2017. The last public hearing on the 2T/2U rules was on Wednesday, October 24.
At the hearing, the vast majority of speakers advocated for changes in the proposed rules to better protect the environment and residents living near CAFOs. As alleged in the pending Title VI complaint filed with EPA, those residents are disproportionately African American, Native American and Latino. CCR emphasized at the hearing the need for (1) an equity analysis as a condition of permitting swine operations; (2) creation of a violation points system pursuant to statutory obligations under N.C.G.S. 143-215.6E; (3) application of increased setbacks to property leased or owned by the permittee and (4) removal of deemed permitted designation for poultry operations. CCR highlighted DEQ’s obligations under Title VI (as set out in the EPA’s January 2017 Letter of Concern to DEQ) to prevent racially discriminatory impacts from its permitting and oversight practices and policies.
Although there are no more scheduled public hearings on the proposed 2T rules, the public can submit written comments through November 22, 2017.
Posted by Allen K. Buansi on Fri. October 27, 2017 2:55 PM