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The Environmental Quality Incentives Program (EQIP) was established in the Federal Agricultural Improvement and Reform Act of 1996 (the 1996 Farm Bill) "to provide a voluntary conservation program for farmers and ranchers who face serious threats to soil, water, and related natural resources" (USDA EQIP Fact Sheet). EQIP allows agricultural and livestock operators to enroll in 5-to 10-year contracts to manage natural resource concerns. The program offers financial (cost share and incentive payments) and technical assistance in the design and installation of practices to improve water quality, wildlife habitat, wetlands and grazing lands and other locally-designated natural resource priorities.

Current eligibility requirements for enrollment in EQIP prohibit the use of cost share funds for construction of animal waste storage and treatment facilities at large confined animal feeding operations (CAFOs). The USDA defines "large" CAFOs as operations containing over 1000 animal units, except where amended by the NRCS state conservationist. Some groups are lobbying to remove this restriction and allow CAFOs to use EQIP cost-share assistance to manage their livestock waste and mitigate the water and air pollution these operations create. Defenders of Wildlife believes that the 1000 animal unit restriction should remain in place for the following reasons:

Taxpayers should not be asked to fund the destruction of family farms. Across America, concentration of livestock production into fewer, larger, industrial operations has been rampant over the past 20 years, driving small producers out of business. For instance, the number of hog farms has fallen precipitously over the past 20 years, with 443,000 producers going out of business from 1982 to 1997, while the number of hogs stayed the same (Minority Staff of Agriculture Committee Report, 1997). The huge operations, which are often affiliated with meat-packing companies, can suppress commodity prices and drive smaller producers out of business. Providing subsidies to these mega-producers to clean up their waste will increase their profitability and their advantage over smaller producers, hastening the decline of the small livestock producers.

Large CAFO Operators should be held responsible for cleaning up after themselves. One of the ways these large animal feeding operations that have gained such an edge over small producers is that they have benefited financially by externalizing to the public the environmental costs of maintaining large numbers of animals in confined operations. Current waste-management practices, such as the giant open-air lagoons, have resulted in millions of gallons of urine and feces entering streams and groundwater through leakage, flooding and bursting of lagoons. The air pollution and stench of the CAFOs has sickened neighboring children, forced residents indoors and decreased neighborhood property values. These operators should be held financially responsible for the cost of properly managing their waste, not rewarded with government subsidies. The federal government should not be subsidizing the industry that is creating the pollution.

Taxpayers should not have to fund flawed manure handling technology. The most widespread technology used to manage livestock waste, manure lagoons and sprayfields, are fundamentally flawed. The lagoons are prone to flooding and leakage, which has resulted in algal blooms, fish kills, illness outbreaks in humans, groundwater contamination and lost opportunities for downstream recreation and water use. Both types of waste facilities emit toxic hydrogen sulfide, ammonia and methane into the air.

CAFOs can still receive technical assistance and advice under EQIP. EQIP’s restrictions do not prohibit large operations from seeking technical assistance for the improvement of their manure management practices. Defenders of Wildlife believes that giving advice and assistance to large operators is a fair use of public funds, but that the actual construction and operation of management facilities should be paid for by the CAFO operator who is profiting from the operation, not by the public.

Taxpayer dollars should fund conservation practices above and beyond the requirements of the law. Given limited budgets for conservation practices, and the fact that nearly all agricultural conservation programs are under-funded and over-subscribed, taxpayer dollars should go to those operators who are already meeting their legal obligations and want to take extra measures to enhance natural resources. Taxpayers should not have to pay to help huge, highly profitable corporations to quit polluting and obey the law.

In summary, large confined animal feeding operations have forced hundreds of thousands of small livestock owners out of business. They have been able to do this in part because they have forced their associated costs – in air and water pollution – on to surrounding communities and downstream residents. It is time for these operators to shoulder the financial burden of handling their waste in a responsible manner – not to force it onto the taxpayers at large. Please maintain EQIP restrictions that prohibit cost-share assistance and incentives to large livestock operations.

For more information, please contact Aimee Delach at 202-682-9400 x271 or adelach@defenders.org