Concentrated Animal Feeding Operations, or CAFOS, can create a lot of cow manure and liquid waste. Per the EPA, excess cow poop from CAFOs can contribute toxic and potentially deadly amounts of compounds like nitrates, as well as pathogens, antibiotics and hormones, to our rivers and groundwater. For example, in Yakima, many private drinking water wells are so contaminated with nitrates that residents cannot drink from them, and the largest source of that pollution is manure from dairy cows. That’s why it’s so important that the Washington Department of Ecology (Ecology) protect our communities, water, and wildlife from excess nitrates, bacteria, and other pollutants that can be discharged from unregulated and poorly regulated factory farms.

Protect Our Communities and Our Waterways

Puget Soundkeeper is part of a coalition, including Friends of Toppenish Creek, Waterkeeper Alliance, Western Environmental Law Center, Sierra Club, and the Center for Food Safety, that won a historic case in 2021 when the Washington Court of Appeals unanimously invalidated Ecology’s Clean Water Act permit for CAFOs. The permit violated state and federal law by failing to control the discharge of pollutants from CAFOs.

Now, Ecology has to write a new permit to regulate pollutants from CAFOs, just like it does for other industrial facilities. Ecology is currently soliciting feedback on the first draft of its new permit. Unfortunately, the new draft fails to address the issues that the Court ordered Ecology to fix, back in 2021.

The draft permit allows CAFOs to apply manure on land as fertilizer, in excess of what plants actually need. The draft permit also does not require sufficient water quality monitoring to determine whether pollution is taking place, does not require the use of up-to-date technologies to prevent manure leakages, and does not require adequate protections to prevent surface water pollution—such as through the use of science-based riparian buffers. It’s impossible to prevent pollution without sufficient technologies, monitoring and accountability.

The Washington State Department of Ecology is taking comments on the draft permit now until August 17. If improperly regulated, waste from CAFOs can harm the environment and public health.

We need you to tell the Department of Ecology that you oppose this permit and want to see science-based protections for Washington’s public health and environment.

Submit a Comment: Write to Ecology

Looking for ideas for your comment letter? We prepared a sample to help you include the key changes Ecology should make to the draft permit. Just copy and paste this sample into a document of your choice, edit it to reflect your priorities and values, and then copy and paste it into the field at the bottom of Ecology’s Public Comment Form. You can access Ecology’s form via the blue button below this sample comment.

Dear Department of Ecology,

I am a Washington resident and I am writing to share my concerns with you regarding the Draft Concentrated Animal Feeding Operation (CAFO) General Permits proposed in June 2022 (the “draft permit”), currently open to public comment. 

I’m greatly concerned  that the draft permit does not require sufficient protections to prevent pollution from entering our waterways, including but not limited to: adequate technology to prevent leaks from manure storage, best management practices for fields such as science-based riparian buffers, sufficient controls for land-based manure application, or sufficient water quality monitoring and reporting. These concerns have been raised by members of the public in the past, and the Appellate Court’s recent opinion affirms that these issues must be addressed. I am also concerned that Ecology has not adequately addressed or mitigated the climate impacts that can be caused by CAFOs, nor the impacts CAFOs can have on nearby communities—including communities impacted by environmental injustices.

Published science documents that excess nitrates, E. coli, fecal coliform bacteria, and various other pollutants coming from unregulated and poorly regulated CAFOs have damaged Washington’s waterways and harmed communities. As a Washingtonian it is important for me that Ecology leverage the best available science and known modern technologies—as required by the Clean Water Act—to protect the environment and people from water pollution coming from CAFOs. It is also important to me that Ecology live up to its obligations and commitments to Tribes and Indigenous persons, including by protecting salmon from water pollution that can be caused by CAFOs.

In the final permit, Ecology should at least make the following major changes: (1) implement modern technologies to prevent leakage from waste storage facilities and lagoons; (2) implement stronger soil, surface, and groundwater monitoring requirements that will sufficiently detect pollution; (3) safeguard against the overapplication of manure to land; and (4) implement meaningful discharge limitation standards and best management practices based on science—such as riparian buffers—to comply with water quality standards and keep our waterways fishable, swimmable, and drinkable.  In short, I urge Ecology to comply with the recent court order to implement reasonable, science-based protections for people, water, and aquatic life from pollution from CAFOs. 



How do I submit my comment to Ecology?

You don’t have to use the sample comment letter to submit a comment, but you’re welcome to! Click the “Submit your comment” button above, once you’re happy with your comment. Fill in your contact information on Ecology’s Public Comment Form, and then paste your comment into the field at the bottom of the page.