STRICTER REGULATIONS ARE NEEDED ON HOG CAFOS WASTE EMISSIONS

MEMORANDUM

TO:          REPRESENTATIVE SAM WATFORD

FROM:    CHRISTOPHER JOHNSON, UNDERGRAD AT DAVIDSON COLLEGE

RE:          STRICTER REGULATIONS ARE NEEDED ON HOG CAFOS WASTE EMISSIONS

DATE:     May 1st, 2015

Hog lagoons on pork farms are a hazard to the health and well being of citizens in the surrounding areas. Hog lagoons are large pits where hog waste is stored and treated. They are typically open-top pits that allow the hog waste to mix with water and treatment chemicals until the waste is used for fertilizer or else disposed. However, these lagoons have tremendous negative impacts on the surrounding areas in terms of environmental and human health.¹ In addition to their impact on health, the odor from the lagoons drastically impacts housing prices and the quality of life of surrounding neighborhoods.² These lagoons also disproportionately impact members of poor, primarily minority communities.³ Current measures of pollution control and current regulations on these lagoons are not effective enough to have a significant impact on the reduction of the negative consequences of the hog waste lagoons.¹ I propose that the N.C. government create an integrative strategy to hold pork producers responsible for protecting the surrounding area while also not preventing the pork producers from making profits similar to current levels.

Three solutions to reduce the negative impacts of hog lagoons.

1. Offer incentives for pork producers to clean up and maintain the hog lagoons. This is the current solution that is being used in North Carolina. This solution relies on offering financial incentives to hog farmers in an attempt to encourage the use of Environmentally Superior Technologies (ESTs). However, this solution has had very limited success and has not had a significant effect on hog waste management practices.⁴ To improve the existing program, the state could provide more educational opportunities for the farmers in order to encourage the use of the program.
2. Increase the strictness of regulations on the creation and maintenance of hog lagoons. This solution is the most top-down approach and would involve the most control and support from the state government. The regulations would mandate aspects of the lagoon such as: the material of the lining; the depth of which the lagoon must be built to; the type of spray that is used to treat the lagoon; how frequently the lagoon must be flushed out. This solution focuses on the physical aspects of the lagoon and will just bolster the current regulations that are already in place.⁴
3. Mandate and subsidize the implementation of Environmentally Superior Technologies (ESTs). This solution is the most integrative solution of the three options as it involves both regulation and financial incentives. Since there have been several ESTs that have been found to be effective in the state of North Carolina, this solution would still give farmers the freedom to choose which EST they deem is best suited for their farm.⁵

An analysis of each possible solution using the PEST model. The PEST (Political, Economic and Environmental, Social, Technological) model focuses primarily on analyzing five different factors of a decision. These five factors include the following: Administrative & Technological Feasibility, Environmental Impact, Social Impact, Economic Impact, and Political Feasibility. I have analyzed each of these factors and then scored them on a three-point scale. Each of these factors was then weighted based on my assessment of its importance to the issue. Administrative and Technological Feasibility (ATF) is weighted less because of the potential of technological improvements to mitigate the risks. Economic impact is weighted less because this proposal focuses primarily on the social and environmental impacts of hog lagoons.

Administrative and Technological Feasibility:

1. Incentives give the individual farm the power to dictate what it can or cannot do with current technology and their own resources. (High Feasibility)
2. Regulations are the least feasible option because they offer a wide generalization of what all farms should be able to do, which could seriously harm some smaller farms.⁶ (Low)
3. ESTs, while forcing farms to meet certain standards, gives each farm the ability to reach these standards in unique ways that are more custom fit to what their farm can handle.⁶ (Moderate)

Environmental Impact

1. Incentive based solutions have the potential for a big environmental impact if a majority of farms buy into them. However, based on current use of incentive programs in North Carolina and other states, this seems unlikely.⁴ (Low Impact)
2. Regulations can have an important impact on environmental degradation if the regulations are strict enough and enforced.⁷ (Moderate)
3. ESTs have the biggest potential for environmental benefits since they are systems designed specifically to protect the surrounding environment.⁸ (High)

Social Impacts:

1. Incentives offer the farms a chance to be proactive in protecting the surrounding neighborhoods, which could create a better relationship between the farm and the citizens. However, farms will typically only do this if pressured by organized citizens, which poor communities are often unable to do.⁹ (Low Impact))
2. Regulations have the most positive social impacts because, if utilized correctly, can protect underrepresented and poor communities.⁹ (High)
3. ESTs offer similar protections to the minority communities while also offering farms a chance to pick the more aggressive ESTs to gain a better reputation within those communities. However, if the community doesn’t pressure the farms, they most likely will not select the most aggressive options.³ (High)

Economic Impact:

1. The current incentive structure has a very little impact on the overall state budget since so few farms are participating. It has a very positive impact on the farms that choose to take advantage of the incentive programs since it makes the transition significantly less costly. (High Impact)
2. Regulations could have the most negative economic impact since a broad regulation could really harm smaller farms that can’t afford to transition or pay the fines for non-compliance. (Low)
3. Subsidized mandated ESTs will still put some mandatory cost on the farms, but it will provide them with the ability to choose the EST that best fits their budget. It will have higher costs for the states, but it will benefit the state economically from less health issues and higher property values.⁶ (Moderate-High)

Political Feasibility:

1. Since incentives are already the standard in NC, this option is the most feasible.⁴ (High)
2. Regulations are by far the least feasible option. Since the pork industry has such an influence in NC, any form of strict regulation will have an exceptionally difficult time being passed.⁴ (Low)
3. Because ESTs are a mandate, they could have trouble getting passed. But because of the flexibility they offer, it has a higher likelihood of being accepted. (Moderate)

Based on this analysis, mandating and subsidizing ESTs will have the most positive impact and is the most feasible option. Since ESTs are mandatory, there is a guarantee that there will be a positive environmental impact that protects underrepresented citizens. Furthermore, because it is subsidized, it will have less of a negative impact on farms profits. It will also reduce the number of lawsuits brought against the farms by communities. The funds from the government can come from the capital already put away for the current incentive program. This solution should be much better received than a standard regulation in the political sphere, as it makes concessions to the pork industry.

3=Highly feasible or very positive impact

2=Feasible or positive impact with several drawbacks

1=Low feasibility or more drawbacks than positive impacts

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2. Wing, S., PhD et al. Integrating Epidemiology, Education, and Organizing for Environmental Justice: Community Health Effects of Industrial Hog Operations. Am. J. Public Health 98, 1390–7 (2008).
3. Stretesky, P. B., Johnston, J. E. & Arney, J. Environmental inequity: An analysis of large-scale hog operations in 17 states, 1982-1997*. Rural Sociol. 68, 231–252 (2003).
4. Karan, A. Pigs, Profit, Planet: North Carolina Farmers’ Perspectives on Waste Lagoon Conversion. (Duke University, 2011).
5. Ying-Chien, C., Kuo-Ling, H. & Ching-Ping Tseng. Two-Stage Biofilter for Effective NH^sub 3^ Removal from Waste Gases Containing High Concentrations of H^sub 2^S. J. Air Waste Manag. Assoc. 57, 337–47 (2007).
6. Aneja, V. P. et al. Characterizing Ammonia Emissions from Swine Farms in Eastern North Carolina: Part 2-Potential Environmentally Superior Technologies for Waste Treatment. J. Air Waste Manag. Assoc. 58, 1145–57 (2008).
7. Butzer, S. & Hildyard, C. Murky waters: North Carolina wrestles to manage hog waste. The Pendulum (2014).
8. Regmi, S., Maneerat Ongwandee, Morrison, G., Fitch, M. & Rao Surampalli. Effectiveness of Porous Covers for Control of Ammonia, Reduced Sulfur Compounds, Total Hydrocarbons, Selected Volatile Organic Compounds, and Odor from Hog Manure Storage Lagoons. J. Air Waste Manag. Assoc. 57, 761–8 (2007).
9. Wendee Nicole. CAFOs and Environmental Justice: The Case of North Carolina. Environ. Health Perspect. Online 121, (2013).

About Christopher Johnson

Chris is a sophomore environmental studies and political science major at Davidson College. He is interested in pursuing research in environmental policy and law.

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