Before starting an on-the-ground investigation of a CAFO, you need to gather information to help you understand what you see at or around the facility. For example, knowing whether you are upstream or downstream of the CAFO, and knowing who owns the land, are critical for making sure your observations relate to the facility you are concerned about. Plus, you will need to explain your concerns to MDEQ staff at some point in the process, and you will need to be thorough in your explanation.
You may want to begin with organizing your community to assist you. You'll no doubt find others nearby who are also concerned about clean safe air, water, and land, and some of the tasks below are easier if you have others helping keep track of activities in the community.
Example: The Lenawee County Plat Map shown at right was very useful to identify fields used by area CAFOs for spreading manure. The fields are colored in yellow.
Creating a Layout, Step by Step
A. Identify names and locations of CAFOs
If you already know the name and address of the CAFO, go to the layout section below. If not, you can identify the names and locations of CAFOs in your state by obtaining a list of CAFOs from the state agency responsible for regulating water pollution from CAFOs. This list may be easily available by contacting the agency or it may need to be requested through an open records search or a FOIA (Freedom of information Act) request. The list you want should provide information about all CAFOs that have been identified by the state so far, including the name, location, owners, size, species of livestock, and status of permitting.
B. Get a copy of the CAFOs Comprehensive Nutrient Management Plan
Ask your state agency for a copy of the CAFO's Comprehensive Nutrient Management Plan, the CNMP, if it's available. It may be called a Nutrient Management Plan instead. You may only be able to get an executive summary, but even that can be useful. This document contains the CAFO operator's plans for managing, actually for disposing, all the manure from the animals, including a list of the fields to be used for land-application of the manure, and how much at each field. You'll want to read the document carefully.
C. Collect area maps
Use the facility address to begin creating a complete layout of the facility and all the lands under their control. Collect any maps you can find of the area: road maps, topographic maps, and aerial or satellite photographs. Google Earth or Google Maps, YellowPages.com, or subscription services such as Terraserver are excellent online resources. (Note use of Google Earth is best if you have a high-speed Internet connection.) For example, once you have the address of the existing CAFO, go online to Terraserver to verify the actual location of the main facility. Sometimes CAFO owners will use a business or even home address instead of the address of the main facility where animals are housed. The imagery available on Terraserver is recent enough that the CAFO should be visible, so you can verify its location, any nearby waters, etc.
Plat maps contain public information that will help to identify lands and fields owned by the CAFO, or owned by others that the CAFO may have leased for land-application (spreading) of waste. Plat maps are often available for sale or sometime are available on line through your county offices. If you are unsure of the owner, your county clerk, Register of Deeds or equivalent official will have information you can obtain to help understand who owns what property.
Topographic maps use lines to represent a general image of the earth's surface, including both natural and human-made features. You can purchase paper copies (the most useful because you can write on them), or you can go to Trails.com to see them online. Brown contour lines give indication of direction of flow of water and of shapes and heights of landforms. Blue lines are used for water, displaying connections between ditches, streams, and larger rivers, inland lakes, Great Lakes, and the oceans. Many states also have drain or ditch authorities at the county or state level that may have maps of these surface waters.
Other hydrology maps, including those from watershed councils or groups, fishing groups, state natural resource agencies or on public Geographic Information Systems (GIS) would also help. If you use or know someone who can use GIS, the State of Michigan has a huge library of GIS files available for free download. Many states' resource agencies are now using GIS, as well as many universities and even volunteer groups. Alabama's Jacksonville State University has created online systems for several states.
D. Identify all the waterways near the CAFO
- Look at all the maps and aerial images that you've collected to identify all of the waterways near the CAFO, including county drains, streams or creeks, wetlands and intermittent waterways.
- Look for the direction of flow of the waterways and the receiving waters around the CAFO (there may be more than one receiving water at a single operation, so note all of them).
- Draw or sketch a map showing roads and waterways to keep track of the information you've gathered so far and as a place to record locations your field observations. Using a Global Positioning System (GPS) device helps assist with accurately locating the observations when you're on the road. (The link goes to How Stuff Works, that will hopefully clearly explain how GPS devices work to find an exact location upon the Earth, usually using latitude and longitude.) When you call or send email to the MDEQ to report any observations of concern, they want to know exactly where to look, and using a GPS helps with that.)
E. Start on-the-ground observations at the CAFO
When making any on-the-ground observations, you should plan to bring a Monitor Buddy, so one of you can drive and the other can take photos and make notes. Take one of the investigation toolboxes, and especially the map you've compiled to make notes on.
When you conduct field observations at the facility, never leave the public road right-of-way. Do not trespass on private property.
- Start by driving in a one-mile radius around the facility and note your observations on the map. (You may also want to make another pass or more driving in the opposite direction.)
- From the road, identify all open ditches, tile risers, catch basins, gate valves or other hardware associated with drainage of water.
If you can see them, keep track of the number of buildings at the site, and if possible the types of buildings and structures seen (barns, milkhouses, residences, silage or compost storage bins).
- Note the location of any waste storage lagoons relative to creeks or drains.
- Identify the flow direction of drains, creeks or other waterways within the one mile radius.
- Identify upstream waters, if they exist, for comparison of water quality.
Take photographs to document your observations, noting the location and what you are observing, and using landmarks in the photos if possible.
- If there is any CAFO waste land application occurring when you are there, or if there is evidence of recent applications, take photographs of the activity.
- If land applied wastes appear close to open waterways, are extremely thick, or are draining into ditches or waterways, photograph these sites.
- Follow the two-minute rule when you're making your observations and testing water.
- Do not stay at a site any longer than necessary. You do not want to draw attention to what you are doing.
- Avoid confrontation if at all possible (driving away is always best, as you can come back later).
- Take pictures if they follow you, or if they come at you, etc.
- Keep your cell phone handy in case you need to call for help, and you may want to put an emergency number into speed dial, including the police.
Note that local roads in Michigan are 33 feet from the center of the road for road right of way, state highways vary from 50 to 100 feet from the center of the road. You should obtain a map from Michigan Department of Transportation (MDOT) for the location you will be monitoring on a state highway as areas vary. No trespassing, and obey the laws.
F. Make and record your observations about the land, operation, and activities
- Location: have map showing section numbers, crossroads (e.g., US 127 east side north of Donnelly Road)
- Drains: open drains, tile risers, creeks, ditches, streams, etc.
- Are they applying liquid or solids?
- Are they surface applying or incorporating the material into the soil?
- What crop is in the field? Corn, wheat, soybeans, hay, rye oats: is it a growing crop or harvested crop?
- Are they plowing, and if so, are they disking, plowing, or chisel plowing?
- Have there been any new field tiles installed? New ditches, or cleaning of existing ditches?
- What type of equipment are they applying with? (tractor and tanker, semi, terragator, solids spreader?)
- What type of manure handling equipment, how many of each, manure semis, liquid haulers, solids haulers?
- Weather forecast - what's the prediction for precipitation? Check NOAA, then copy or email the forecast to yourself (you won't be able to retrieve the forecast at a later date. It's the forecast that's important here, not the weather report.) In Michigan, "large CAFO waste application shall be delayed if rainfall exceeding 1/2 inch, or less if a lesser rainfall event is capable of producing an unauthorized discharge, is forecasted by the National Weather Service within 24 hours of the planned application." See the Large Concentrated Animal Feeding Operation General Permit MIG019000, page 7 D for details.
- What is the weather at the time of manure application (rain, snow, melt, etc.)?
- How many times have they applied to this field? (This is when it's important to have allies also watching activities.)
- How many houses, orchards, businesses, houses for sale, etc. are in this block?
- Take pictures!
G. Make and record your observations about the waterways around the CAFO
- Smell the water. Is there an odor? A strong odor, particularly of manure, is an immediate trigger for concern and filing a complaint with the DEQ, however not all pollutants from CAFOs smell bad.
- What is the color of the water? Compare particularly with any upstream waters flowing into the CAFO, if there are any. Contaminated water from Michigan CAFOs has ranged in color from white (milkhouse wastes) to black (manure), with brown (manure), green from silage leachate (with algae from nutrients), pink (diesel fuel) and yellow (chemical treatments), all found based on the contaminants.
- Is the water turbid or cloudy or foamy? (Causing an increase in turbidity in waterways is illegal.)
- What does the sediment look like if the water is clear? The bottom may be covered with brown or other sediments, indicating a prior discharge.
- What direction does the water flow? Is there water or liquid flowing in this waterway when no other waterways are flowing? This might indicate an illegal connection into surface water from the facility.
- Take your pictures, samples, measured DO readings before you call your state agency about a discharge.
- Is there any housing near this drain?
- Are there dead fish or other aquatic organisms? Are there bloodworms or other indicators of ongoing contamination?
- If you have a DO meter, take a picture of the meter reading with the tested water in the background. (This will give you evidence of water temperature, DO, and water appearance with the time and date on your camera.)
- If you suspect a discharge take a picture of your water samples at the location (preferably with a white piece of paper or snow in the background to really show the color of the sample).
H. Compile your complete layout package on the CAFO facility
What to include in your complete layout package:
- Assemble one map showing everything you find: draw and label everything you saw, preferably on the topographic map
- CAFO Name, address, phone number, county, township, section number
- Topo maps and drain maps, with all drains leaving the property within a one-mile radius clearly marked
- Location of any open drains or ditches, creeks, streams, lakes, etc. that you found in your drive around
- Aerial images/map from web if you have them, and Global Positioning System (GPS) coordinates
- Plat Book, with relevant info noted/highlighted
- Register of Deeds information on properties bought, name and address on record for facility, if the property has been signed up for agricultural agreements, development rights, name changes, tax liens
- County treasurer tax records, descriptions of properties
- Comprehensive Nutrient Management Plan if available
- Number of wells at the location, and what the septic system is like (the Health Dept will have this info)
- Location of all tile risers, gate valves, buildings on property, type of irrigation (pivot or travel), drag lines, hoses, pipes, and digging or excavation (you can find these by driving around the block of the facility)
- Soil type (you can find it out from the county Soil Survey, available from County Extension office)
- Topographic map with all your notes
- Your recorded field and water observations, and that day's official weather & rainfall prediction from NOAA website
When you've created a layout of the CAFO, now you're ready to move on to Conduct Water Sampling near the CAFO.