November 19, 2008
Mr. Matthew Gluckman
US EPA Region 5
NPDES Programs Branch
77 West Jackson Blvd.
Chicago, Illinois 60604
State Program Requirements; Application To Administer the National Pollutant Discharge Elimination System (NPDES) Program for Concentrated Animal Feeding Operations (CAFOs); Ohio
Extension of Comment Period
Additional Public Hearing
Dear Mr. Gluckman,
The Ohio Farm Bureau Federation, the state of Ohio’s largest general farm organization with more than 234,000 members, sincerely appreciates U. S. EPA Region 5 completing its review of the state of Ohio’s application to revise its NPDES program to allow the Ohio Department of Agriculture to administer parts of the program pertaining to concentrated animal feeding operations (CAFOs) and storm water associated with construction activity at animal feeding operations (AFOs) in Ohio.
In its public notice printed in the Federal Register on October 15, 2008, U. S. EPA announced that the comment period for this proposal for which it is seeking public comment would close on December 16, 2008, and that one public hearing would be held for the purpose of receiving public comment.
Given that this action has been on-going for a number of years, we believe that the originally announced 60-day comment period is more than sufficient for this process. We also wish to bring to your attention that several additional opportunities have been afforded to the public regarding this process, which include but are not limited to the Department of Agriculture’s CAFF advisory committee meetings where proposed rules pertaining to the proposed transfer of delegation authority have been thoroughly discussed for the past several years, but also public hearings where all stakeholders have been provided with the opportunity to comment on rules proposed by the Department of Agriculture pertaining to this respective proposal.
Furthermore, we believe one public hearing, as was held in centrally-located Columbus, Ohio, on the evening of November 18th, is sufficient for this process. Those who wish to comment on the proposal but for some reason were unable to attend the November 18th public hearing can still file comments regarding the proposed transfer of NPDES authority from Ohio EPA to the Ohio Department of Agriculture with US EPA in writing by December 16th, so an additional public hearing is not necessary.
Upon reviewing the sign-in sheet from the November 18th public hearing, you will also learn that it was attended by citizens from all regions of the state, including farmers from as far away as northwest Ohio’s Williams County. Please consider this is an issue that affects the entire state of Ohio, not just one particular area or region. There are nearly 170 livestock farms in Ohio that have state permits with the Department of Agriculture, and almost every region of the state has at least one permitted livestock farm. As far as we’re concerned, if an additional public hearing is held, it should not result in the public comment period being extended, and it should be held in the west central area (Celina, Greenville, Wapakoneta or Sidney) of Ohio where an overwhelming majority of the state’s permitted livestock farms are located.
We thank you for positively considering our input regarding this very important matter.
John C. Fisher