Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
Virginia Pollution Abatement Regulation and General Permit for Poultry Waste Management [9 VAC 25 ‑ 630]
Chapter is Exempt from Article 2 of the Administrative Process Act
Action Develop requirements that will address concerns regarding transfer and off-site management of poultry waste in the Commonwealth.
Stage Proposed
Comment Period Ended on 8/21/2009
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8/14/09  4:31 pm
Commenter: Peter Pfotenhauer (Supporting Shenandoah Riverkeeper)

Please Pass The Poultry Litter Regulation

Peter Koehler-Pfotenhauer
10604 Wakeman Drive
Fredericksburg, VA 22407

I used to spend a good bit of time, and money, over in the Shenandoah Valley because of fishing trips on the South Fork of the river. Since 2005, I can count my trips on one hand. That translates into lost enjoyment fishing a beautiful river, and lost money for hotels, restaurants, guides, and other local businesses as I have stayed away. I am certainly not the only fisherman to go to healthier rivers.

Now, because the chicken manure is being shipped out of the Valley to other regions of the state, several other rivers I love face potentially the same fate as the Shenandoah. The Upper James is a national treasure, but recently it's fish have suffered the same fate as those in the Shenandoah. I don't think it's coincidence that fish in that river and some of its tributaries started showing the exact same problems fish in the Doah experienced almost immediately after shipments of poultry manure increased.  I know that shipments of this manure are also finding their way into my home river, the Rappahannock, and worry greatly that the guiding business I am starting this year may fall apart on me, if the Rapp is allowed to be contaminated with unregulated poultry run off like the James and Shenandoah. I've already seen anecdotal evidence in my own observations of more fish with sores and parasites in the last two summers on the Rapp, though it's not enough evidence to lay blame anyplace. The enjoyment of the beauty of a day on the water is spoiled by catching fish so sickly and disfigured that their beauty is lost beneath lesions, fungal growths, and a lack of energy to provide a decent fight.

As my grandpa used to say though, if it smells like poop, it probably is poop. No need to taste it. I worry not only about the health of the fish, but also my own. I drink water drawn from that river. I don't want to find out 20 years from now that the heavy metals, hormones, and other additives (especially arsenic) in the poultry feed that the chickens excrete has caused irreparable harm to the drinking water supply. Currently, we don't know what's in the water, because many of these emerging contaminants are not tested for by municipalities. Millions of Virginians are being recklessly exposed to unknown hazards because we are not protecting the drinking water supply as well as we should. A friend who worked the Peace Corp in Africa told me the first thing they did in a village was get the cows out of the creek to protect the drinking water supply, yet we allow them free access to the river, and let the manure from millions of chickens be spread so recklessly that it fouls the creeks and streams that bring irreplaceable drinking water to our cities and towns. Even a dog knows not to poop where it eats and drinks.

I worry that without stronger controls in place, more rivers will suffer the Shenandoah's fate. The ones free from impacts will become more crowded with fishermen looking for less damaged watersheds to enjoy, bringing more ills to the streams we haven't polluted yet. And ultimately, I do not think Virginia can meet it's commitments to clean the Chesapeake Bay  without regulating the uncontrolled application of chicken manure. The state has an interest in knowing where every ton of that crap winds up.

From what I know the purpose of the existing regulations was to limit the impact of this industrial by product on our environment. Industry, as it often does, found a way around the intent of the controls. Anyone raised on a farm with a chicken house as I was back in the 70's knows that chicken manure is a poor fertilizer because you have to over apply it to get enough nitrogen, allowing the phosphorus content to burn up the garden. We need regulatory changes that reflect the common sense and intelligence we have about this product. Please change the regulations to eliminate the (pardon the pun) chicken manure "poophole" that the poultry industry is exploiting to dispose of a hazardous waste in a totally uncontrolled manner. If these farmers were spreading commercial fertilizers they would have to follow more guidelines than they do when they spread this free manure.

Please act this year to solve a simple problem. I don't want to continue to live downstream from piles of poop that destroy river health, send tourism dollars to other states, and reduce jobs in our recreation industry, which is about as green as a field as you can find.


Peter Koeher-Pfotenhauer

CommentID: 9559