CAFO - NPDES Permit Compliance
October 2021 - there has been little published progress on the Michigan, EGLE Draft 2020 CAFO permit re-insurance. The reissued permit is currently under litigation and the litigation is pending, with no published proceedings at this date. MI Farm Bureau will continue to keep all Michigan CAFO farms up to date on any changes to that litigation status. Michigan CAFO's must continue to follow the current COC they are operating under until further notice from EGLE.
For our clients and all CAFO’s in Michigan, everyone should be aware of the changes the state is proposing to the CAFO Permit. All CAFO’s in Michigan are permitted under the states existing CAFO General Permit, which expired on April 1, 2020 – and all CAFO’s now need to be reissued a new COC after once the draft reissued CAFO permit becomes final. The state has proposed many changes to the existing permit that will have to be met to obtain continued coverage.
Please give us a call with any questions or concerns. Many proposed changes could impact your farm, your management and other decisions you make moving forward.
About our CAFO services:
FCS has been helping farms meet their CAFO-NPDES permit requirements for over 15 years. From our first few farms in New York and Vermont to our larger foot-print now expanding to the Midwest, our focus has been on our clients economic & agronomic goals while meeting or exceeding all water quality permit requirements.
Each state has a unique NPDES - CAFO permit enforcement structure, and FCS has the knowledge and experience to help you wade through the regulatory obstacle course that you confront as your farm grows. We have helped many CAFO sized livestock farms develop a CNMP, expand existing operations, complete required annual reporting/NMPs, and helped develop new permits for new large farm operations.
We believe that the annual reporting process for all CAFO's (NMP updates) can help the farm develop base line data that can greatly improve decision making on the farm. Decisions made with real farm data can improve potential economic success on the farm while complying with all CAFO permit record keeping requirements.
FCS always will have a representative at your farm during any CAFO inspection unless you request otherwise. We can be as present and involved in your permit process and relation with your local regulatory agency as you would like. Members of our staff have been part of National EPA CAFO inspections in addition to being on site for all of our clients state DEC/EGLE state annual inspections.
We have no doubt we can help keep you in compliance with all annual requirements. Each Fall FCS will get in touch to begin the annual update process. We visit the farm to see collect record and results fro the growing season, what sampling may be needed for the upcoming update, and what infrastructure may have been implemented. The farm data becomes the baseline for your farms annual CAFO update report, and the next seasons NMP uses the previous seasons actual farm data to plan ahead. As yield data is collected year to year we can begin to utilize the required records for additional, production efficiency and environmentally focused farm analytics.
We have seen hundreds of livestock waste management systems over the years, we can provide blunt & honest feedback about proposed infrastructure changes and the relation to CAFO permit/CNMP compliance. The dollars gained or lost on an ill-advised new structure, retro-fit, or change in management can be devastating for a farms bottom line. It is crucial that you hear honest pro's and con's related to various ideas for someone who has no incentive to promote any particular practice or system. All we ever focus on is you, your farm, and how changes effect the success of your farm.
