7 January 2002
 
The EPA is accepting comments on proposed changes to the regulations concerning Concentrated Animal Feeding Operations (CAFOs), commonly known as “factory farms.” One point the agency is considering is the population size at which operations will be classified as CAFOs and the environmental performance standards they are to meet. Of particular concern is whether “dry lot” duck operations should be given favorable regulatory status over “wet lot” operations. The duck industry has weighed in heavily in favor of this and we need to counter them.
 
Dry lot operations deprive ducks of all but drinking water. Ducks are aquatic birds who thrive in water. A European Union farmed animal protection committee stated: “Access to an outside run and water for bathing are necessary for ducks, as water birds, to fulfill their biological requirements.” Serious welfare problems, including blindness, can result if ducks are not able to immerse their heads. Ducks in these systems are debeaked and kept crowded together by the thousands in noxious sheds. Many suffer ammonia burns from waste accumulations. They also suffer injuries to their webbed feet from the wire they are forced to stand on.
 
Please contact the EPA and let them know that factory farming is environmentally destructive, inhumane and unnecessary. Dry lot duck systems are even more inhumane than wet lot systems and should not be rewarded with favorable environmental regulatory status. Let EPA know you are opposed to the proposed alternative options for dry lot duck operations and want the agency to set the lowest population thresholds and impose the strictest regulations possible for animal agriculture.
 
Comments can be submitted by e-mail to: CAFOS.comments@epa.gov Please be certain to specify docket number W-00-27 and submit as an ASCII, Word or WordPerfect file.
 
Comments must be submitted by January 15th.
 
The EPA notice can be accessed at: http://www.epa.gov/npdes/regulations/noda_fr.txt .
 
Thank you for all you do on behalf of farmed animals, today and every day.
 
- Kim Sturla & Ned Buyukmihci, Cofounders
 
Animal Place is a nonprofit sanctuary for abused and discarded farmed animals and other domestics. We're located in Solano County, California, but our interest in improving the lives of farmed animals knows no boundaries. Our E-Alerts address animal issues that need your immediate action: letters, phone calls, or lifestyle change. We'll also share the latest news about animals here at Animal Place. For information about us visit http://AnimalPlace.org.