Round hay bales near Cambridge, IA. Image credit:Flickr,cwwycoff1
Search on the terms "hay pollutant epa" and you'll see hundreds of recent links with statements inferring that USEPA has 'declared hay to be a pollutant.' The source most often cited is indirect and provides no attribution within the Agency. A website covering a ranching industry meeting cites the following answer given in response to a question asked by an unidentified audience member: "Now that EPA has declared hay a pollutant, every farmer and rancher that stores hay, or that leaves a broken hay bale in the field is potentially violating EPA rules and subject to an EPA enforcement action,..." With that shot fired, the echo chamber is making hay out of what looks to be nothing of substance.
I searched extensively online and all I could find are some fairly old EPA pollution prevention guidance for managing concentrated animal feedlot (CAFO) runoff. Note: Pollution prevention guidance per se is not enforceable. Practices listed in an EPA guidance document could be incorporated in a CAFO discharge permit and thereafter would enforceable (simply by observing: are they they present or not?) but that would not be a surprise to the CAFO operator. Below are some excerpts from the old EPA guidance (pdf file).Selected excerpts from USEPA pollution prevention guidance document.
...Livestock feed may include hay, grain (sometimes supplemented with protein, vitamins, mineral supplements and antibiotics), and silage -- with grain and hay being the most common feeds...The proposed pollution prevention methods include such obvious measures as providing secondary containment to catch leachate, diverting runoff so it does not saturate the hay pile, and putting the hay under a shed to keep the rain off. Nothing whatsoever is included which infers that hay, per se, is a pollutant and no mention is made of regulatory status.
Potential Pollution Outputs and Environmental Impacts
The primary pollution outputs include unusable feed; dust emissions from loading, unloading, and grinding activities; air emissions from transportation to and from sites; and leachate from silage. A minor pollution output is contamination of storm water from spilled feed. Dust emissions pollute the air that agricultural workers and animals breathe and can cause respiratory problems in instances of prolonged exposure. Research indicates that silage materials stored at 65 percent moisture content or higher can produce leachate.
Needle in a haystack challange.
So here are two challenges for all you EPA-hating internet gossips, Tea Partiers, and fearful ranchers.
- See if you can find an authoritative source within EPA which classifies hay as a regulated pollutant in any context: either on open pasture land or on concentrated animal feed lots. IF you do, please post a link to it with your comments. I will modify my post accordingly and promise to repost it again, as an update, so it directs plenty of attention to your cited source.
- Name one rancher or animal broker who has been busted for leaving hay bales out in a field. Same offer holds with the update
Severe drought is a real problem for the ranching industry. Floods are a real problem for the ranching industry. Increased costs for animal feeds and for fuel also are real problems.
Voluntarily diverting some runoff from the uphill side of your feed pile can be done with a tractor or a front end loader. Its a one time action that prevents loss of the feed you put out - keeping it where the animals can get at it.
In a drought, leachate runoff is not a problem (obviously).
In a flood, everything is ruined and nobody cares about leachate.
What's the problem here people? Are we needing to blame EPA because business sucks or what?
Should have mentioned this in my initial post but the obvious slipped my mind. For many years EPA had recommended hay bale placement along a property perimeter as a non-point source pollution control method, when soils were disturbed (by hoofs or construction equipment, for example). EPA recently changed that recommendation because hay has become too expensive and was judged too difficult to keep in place, in comparison to alternative materials.
Facts can easily be twisted by people who are unfamiliar with current field practices and Agency guidance. It is not a stretch to imagine someone turning 'hay is no longer an EPA-recommended pollution control device' into 'EPA will fine you if you use hay to control pollution' (which is absolutely untrue).
Moral of the story: cite current, authoritative sources or keep still.
A commenter posted a link to a CAFO pollution control citation which, he pointed out, had been submitted to a Kansas CAFO owner by USEPA. I read the EPA notice letter from start to finish and "hay" was not mentioned even once.
The main CAFO objections beyond animal welfare generally are either odors bothering neighbors - an unrelated issue for this post - or manure getting into roadside ditches, percolating into groundwater and contaminating public and/or private wells, spilling onto public roadways, and even getting onto private yards, which is pretty inexcusable but it does happen when rainfall is intense like it can be with a tropical storm.
Have you ever heard of CAFO neighbors complaining about hay floating onto their lawns? I didn't think so. Not to say it never happens but it's just not going to be an agency focus given all the crap they have to take from internet gossips fed talking points by industry lobby groups. Sorry for the venting, but it really does get exasperating to see how close people are nudging their elected officials toward a 'get EPA' lynch-mob mentality based on thoughtless gossip.