An Important Message About CAFO From President Logan Bower | Dairy Industry CAFO Ad Hoc Workgroup Response | PDMP Letter to DEP | Sample Letter for Individual Dairy Producers

April 4, 2007

Mr. Robert T. Gibson
Department of Environmental Protection
Bureau of Watershed Management, 10th Floor
Rachel Carson State Office Building
Harrisburg, PA 17105

Re: CAFO Draft Implementation Guidance Document

Dear Mr. Gibson:

I am Logan Bower, President of the Professional Dairy Managers of Pennsylvania (PDMP). I am also a dairy farmer, as are most of the members of our organization. PDMP appreciates the opportunity to provide the attached response to DEP on the CAFO Draft Implementation Guidance document published by DEP on March 10, 2007 (technical guidance #5390-2100-001).

Dairy producers are committed to responsible environmental stewardship – every day is Earth Day on our farms. We welcome the chance to work with DEP to achieve our goal of improved dairy and milk production for Pennsylvania while implementing management practices which protect our natural resources.

PDMP’s response on behalf of our dairy industry members was a collaborative effort of the Dairy Industry CAFO Ad Hoc Workgroup. I participated in the Workgroup, as did several leading dairy producers and PDMP members. From my perspective, our statement is a positive and constructive response to the CAFO Draft Guidance document, and we hope it encourages a positive and constructive working relationship between DEP and Pennsylvania dairy producers.

The CAFO permitting process, and how CAFO guidelines will be implemented, will have tremendous impact on dairy producers and dairy farm operations. It is important that the guidelines are easily understood, that they be based on solid engineering and sound science, and that they give clear direction on what is and what is not required of farm operations to obtain CAFO and water quality permits.

Of equal importance to dairy producers – the guidelines should clearly identify how DEP officials will measure and apply standards in the CAFO and water quality permit process and should identify the limitations on discretion of reviewing officials and the boundaries on conditions and requirements that may be imposed as conditions of approval.

Finally, we hope that the guidelines will be consistently and evenly applied by all DEP officials in each region of our commonwealth. gain, thank you for the opportunity to submit our response. I am happy to answer any questions you have. PDMP remains willing to engage in this discussion with DEP for the betterment of the dairy producers and all Pennsylvanians.

Sincerely yours,

Logan Bower
President

cc: Secretary Dennis Wolff
Senator Mary Jo White
Senator Mike Brubaker