Directors Hyde and Schlichter,
It has come to my attention that Dee Matthews intends to lease farmland on Jones Road to Mr. John Surber and Mr. John Heinz of Premier Grain – Sabina Farmers Exchange, Inc. for a medium-sized CAFO (Concentrated Animal Feeding Operation). While I tend to side with Libertarian values (people should be allowed to do what they want unless it infringes upon rights of others), it appears this is a VERY bad location for a CAFO and would infringe upon local land-owners’ right to fresh air and clean water. I STRONGLY ENCOURAGE YOU TO UPGRADE THE FACILITY TO A LARGE-SIZED CAFO SO THE OWNERS WILL ADHERE TO HIGHER ENVIRONMENTAL STANDARDS.
In full disclosure, I have family on Jones Road, and the benefits of visiting them in Bloomingberg (rather than having them visit us in Columbus) is the fresh air, picturesque countryside and clear skies to see the stars at night. I would also like to clarify that argument against building a CAFO on Jones Road is both ethical and legal. I have seen several open letters to the Record-Herald (the local paper) addressing many of the ethical issues, and before I address the scientific, I would like to remind everybody that just because something might be legal does not mean it’s ethical.
While medium-CAFOs (300-2499 hogs) are not held to quite as strict standards as large-CAFOs (2500+), there are still regulations to ensure water quality. First of all, let’s look at the number of hogs. In order to properly house 2,400 hogs, a facility would need to be roughly 84,000 ft^2 (http://www.righteousbacon.com/space-for-swine/). That equates to a building roughly 420ft x 200ft (or something similar…I’ve heard two buildings with similar area). I do not know where the proposed building is going (once again, I’ve heard on the site of the former barn), but I have placed such a building on the topo map of the area as far away from both nearby streams as possible. A direct line to either stream is about 600 feet (not much more than the length of the building) or following possible water flow contours, up to 1,100 feet (not even a quarter mile).
According to the Clemson study, a hog might produce 1 ft^3 of manure per day (or if you think 6 inches deep, about 14,400ft^2 for 2,400 pigs a day or about 100,000 ft^2/week). I don’t know how often collection will be coming (I’ve heard only every six months), but 100,000ft^2 is roughly a 300 x 300 ft square grid.
Looking at the topographic map, there is not much grade to the farm. Good news…low erosion. Bad news, any flooding incidents (of which there are likely to be 3-4 yearly), while likely have manure infested waters feeding into both creeks. Furthermore, the loam soil would facilitate dissolved nutrient run-off into the local water tables.
In all fairness, I’ve had limited time to look at the location, but I do not think it is suitable for a CAFO. I realize that because this is an agricultural building, Mr. Matthews, Surber, & Heinz don’t need to go through similar channels for contraction of a non-agricultural facility which would include site drawings from an engineering firm. However, I would encourage them to do so if they truly believe there will be no damage to the two nearby creeks to set the community at ease.
One other thing I would caution them about site drawings is that while engineers may use old data for 50-year and 100-year floods, “stationarity” is a dangerous assumption. Most that know the land and the weather (as well as those of us that have studied scientific data), know that was once a 100-year flood is now a 20 or 25-year flood, a 20-year flood is a 4 or 5-year flood, etc… and the land we are looking at floods multiple times/year.
I’ve heard Mr. Surber and Heinz have an exemplary record with his other CAFOs, however, the location of those is VERY different than the current proposed sight. I once again encourage you to upgrade the proposed site to a large-sized CAFO. It would be a real shame if this lease…for short term gain led to huge lawsuits and paybacks that ultimately created a break-even for the Mr. Matthews & Mr. Surber or even a loss, due to fines, civil lawsuits, loss of respect in the community etc…. as well as unfixable damage to the area when the warning flags are clearly there and have been articulated.
M.S. Environmental Science, 2001
M.S. Civil Engineering, 2016
This letter is addressed to Tinka Hyde, Director of the Water Division at US EPA Region 5, and John Schlichter, Deputy Director of the Ohio Department of Agriculture.