The Water Permit

In order for Lundy Russell (the neighbor building the chicken houses) to build a functioning CAFO, he must get a water permit from TDEC (TN Department of Energy & Conservation). This step in the process gave us the opportunity to weigh in with a state official- Paul Davis. By requesting this permit be categorized as an “individual permit”, open to public notice and comment in an appeal to the Division of Water Pollution Control, we have the chance to both slow the process down, as well as to make a case for the state not issuing the permit at all. That would prevent the necessity for litigation.

That case has to be addressed from a very narrow perspective: that the chicken houses pose a threat to the cleanliness of a waterway. Jeff’s spring, and the drainage from the hillside these chicken houses are planning to sit atop, flow into the Long Hungry Creek, from which Jeff derived the name of the farm. It was during this process that we learned that Long Hungry Creek had already been classified by the state as an “Exceptional Water of TN” (tier 2) for its “exceptional biological diversity” in December of 2006. Only three creeks in all of Macon County have this classification, and we believe it helps our cause, since the state is committed to protecting the diversity it recognized independently of this situation.

We have had the waters- both the spring and the creek- tested to set a baseline for comparison later on. This will allow us to see any changes that may occur as a result of the construction or operation of chicken houses, should we fail in our attempts to stop this project from moving forward and becoming reality. Cobb Vantress steadfastly claims these chicken houses will have ‘zero discharge’, which would mitigate the concerns the state may have about contamination of the creek. We find it impossible to believe that 40,000 birds just a few hundred feet above these “exceptional” waters, can manage to discharge nothing. If anyone out there knows of contamination from a no-discharge operation, anywhere in the US, it would really help to know the details.

Even if the day-to-day operation of this kind of chicken operation discharges nothing from the houses themselves, there are several other points along the way that raise concerns. Every 22 weeks or so, when they remove the chickens, they must clean out the accumulated manure. This will expose the dry, dusty, stinky, and potentially disease-laden material to the elements, increasing the chance of blowing or washing some amount down upon the farm and creek. We have no idea what Lundy or Cobb plans to do with this material. Legally, they can spread it on fields, compost it, put it in man-made ponds, or sell it to other farmers. All bring up additional concerns and possible points of contamination.

Further, after reading the “Biosecurity Standards” document that all Cobb contractors must adhere to, they make it very clear that they are concerned for the health of these large, dense, flocks, and require several measures to protect them. These measures include, but are not limited to (all bullet points are direct quotes):

Pre-Farm Entry

• No one entering a Cobb farm is to have any direct non-Cobb bird contact for the past 72 hours.
• All personnel must follow travel restrictions between farms and other facilities as outlined by the “Internal Visitation and Isolation” policy.
• Every effort should be made to restrict any visitors to the farms unless absolutely essential
• It is company policy that no Customer, Domestic, or International business visitor will be allowed into any GP farm unless prior approval has been granted. Approvals may be granted by Jerry Moye (Pres.), but only after consideration of the necessity and risk has been assessed

Farm Entry

• Shower facilities allowing persons entering a farm to take a complete shower.
• Showers are intended to remove dust and organic debris from the body surfaces (skin and hair). Complete shower and shampoo (Hair washing), is mandatory. People should use the “Buddy System” and watch one another after showering to determine if a complete shower has been taken.
• No personal clothing will be allowed onto the farm, nor should farm clothing be allowed to be taken off the farm.
• Personal items have been shown to transmit disease (cigarette lighters).
• All items brought onto the farm must completely [be] disinfected by aerosol spray or disinfectant hose, depending on the item

Vehicle & Vehicle Sanitation

• Any vehicle which is routinely used on a farm should remain on the farm at all times and not travel on and off

Poultry House Entry

• Vehicles: the wheels and wheel wells of all vehicles e.g spreader trucks, ‘chicken hawks’ must be effectively cleaned and disinfected before entering the houses (every time!) once houses have been signed off as salmonella free.
• Equipment: All equipment and materials that enters the house must be disinfected.
• Foot-pan Management: Foot-pans should be located at the door entry prior to footwear change and should contain a 4″ deep solution with an approved disinfectant

Vegetation Control

• Vegetation (grass) provides protection for rodents and insects to enter and exit chicken houses. Complete freedom from vegetation in a farm compound is the most desirable situation in any new or rebuilt facilities. Only approved herbicides provided by Cobb will be used.
• The fence line must be sprayed with Company-provided chemicals as directed by company personnel.

Rodent Control

• Bait stations should be located every 100 feet on the outside of poultry houses and against the footings.
• The company will provide all approved bait.

Wild Bird Control

• Wild birds may carry disease. Complete bird proofing is the goal.
• Backyard Flocks: Backyard flocks represent an extremely high biosecurity risk! Any backyard flock 1/2 mile or less of the farm compound should be reported to the Farm Manager and the QA Team. Efforts may be made to contact the owners for removal of birds.

Insect Control

• Insects can also be vectors for poultry diseases and must be controlled. Only approved pesticides and insecticides will be provided by the Company.

Farm Perimeters

• Fence lines must be clear of vegetation and overgrowth.

There are many causes for concern as we consider possible points of contamination to our farm- sanitizing liquids sprayed on vehicles, rodent bait, herbicides, pesticides, and insecticides. Given the very close proximity to our farm, the gardens, the spring, and the creek, it seems inevitable that these chemicals will be a source for contamination. Not to mention, reading Cobb’s standards is like reading the manifesto of a control-obsessed totalitarian regime. Not only do they rule their contractors with an iron fist , but their attempts to control the backyard flocks of their neighbors within 1/2 mile seems excessive and speaks to the vulnerability of their birds.

These strict standards, which I have no doubt Cobb would consider ample evidence of their thoughtful management of chicken houses, speaks to me of genetically inferior birds with high a susceptibility to the normal pathogens and diseases present on God’s green earth. I am guessing that antibiotics will be present in the feed, but have no documentation (yet) to back up that guess. We now know from years of overuse of antibiotics in both the human and industrial farm animal populations, that too many antibiotics weaken a body’s ability, be it fowl or human, to fight off disease. Overuse of antibiotics has also been named as the culprit for creating super-bacteria that develop resistance to antibiotics and become especially virulent and dangerous.

TDEC ‘s only concern as they consider this permit request, is for any possible or likely contamination to Long Hungry Creek. Below are the relevant points that must accompany any letter. If you choose to write, personalize it, make it your own, but please limit your statements to the relevant points, or you risk having your opinion dismissed. You can email or snail mail your letter in.

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Paul Davis, Director
Dept. of Environment and Conservation
Division of Water Pollution Control
7th Floor L&C Annex, 401 Church Street
Nashville, TN 37243
paul.estill.davis@tn.gov

Dear Mr. Davis,

I would like the CAFO permit [SOPC00061] applied for by Russell Poultry to be treated as an application for an individual permit with a public notice and a public hearing before TDEC considers issuing a permit.

This facility will drain directly onto Long Hungry Creek Farm, the spring that supplies the farm’s drinking water, and into the Long Hungry Creek, a very clear, clean stream.

TDEC has already classified Long Hungry Creek as an “exceptional water of Tennessee” (tier 2). The creek is threatened by the pullet houses, the disposal of manure and bedding, and the runoff from sanitizing agents, pesticides, and insecticides- all standard components of CAFO operations.

We would like a determination of the social and economic necessity for this facility permit, which is to be located 300 feet from the farm.

I’d like to hear back from you and be notified of any public hearing or other opportunity to present information and arguments about the injuries to our environment that may result if the permit is granted.

Thank you,
[your name, address, phone and email]