February 21, 2010

To the members of the Senate Agriculture and State Affairs Committees:

I.C.A.R.E. understands that there is an effort to resurrect two 2009 bills that would
transfer regulatory and enforcement authority over swine and poultry CAFOs to ISDA
and curb local control over CAFOs (S1223 and 1213). We urge you not to continue with
these efforts or allow the printing of any version of the bills in question—no matter how
well white-washed they may be. The attempt to resurrect S1213 is particularly troubling:
given the dairy and cattle associations’ threats to pursue legislative fixes to the
inconvenience of their recent loss at the state Supreme Court, a clearer example of overt
pandering to industry interests at the expense of public health and welfare would be
difficult to find. To allow lobbyists for the industry’s largest and wealthiest producers to
rewrite state law solely to suit their clients’ bottom lines and retroactively justify their
community-shattering litigiousness would be an unacceptable breach of the public trust.1

As written, these bills are first and foremost an insult to Idaho’s local governments,
voters, and an affront to the principles of local control. The bills assume that local
planning and zoning commissions and boards of county commissioners are incapable of
understanding water and air quality data and reports circulated by DEQ. This is not only
an insult to the intelligence of county commissioners, it is an insult to the voting citizens
of those counties. Furthermore, it assumes that these governments and the citizens they
work for are incapable of drawing rational conclusions about the effects of land use
within their own counties. If this were the case, what would be the purpose of having
local land use planning in the first place? After all, if the locals are incapable of
responsibly governing themselves, then the state may as well assume control over all
land-use planning; yet we do not see any proposals to assume this level of control over
residential or industrial zoning.

In a news report that covered the discussion over these bills at a recent Senate
Agricultural Affairs Committee meeting, CAFO lobbyist Ken McClure claimed that all of
the issues counties like Gooding wish to assert some control over are already covered by
federal laws—namely, the Clean Air (CAA) and Clean Water Acts (CWA)—and are
therefore duplicative and unnecessarily burdensome.2 In reality, Mr McClure’s statement
could not be much further from the truth.
1
Medium and Large CAFOs comprise a fraction of Idaho’s total dairy and beef cattle operations—between
7% and 14%—but house 86% of the state’s total cattle inventory (a total of 1.95 million cattle), and
produce a supermajority of the two industries’ waste. Statistics compiled using 2007 Idaho Livestock
Census data. Interestingly, National Agricultural Statistics Service (NASS) data show an even starker
divide, with Medium to Large CAFOs comprising between 1-24% of the state’s total operations and
generating 81.5-91% of the industries’ total waste. Because neither Idaho Livestock Census nor NASS data
are broken down exactly according to EPA definitions—these ranges include operations with inventories of
500+ and 200-499 head—the upper limit of the ranges listed here may include some operations that would
not meet EPA’s definition of a Medium or Large CAFO. However, as both data sets are based on numbers
reported in lengthy surveys that are entirely voluntary, it is also likely that the data itself underestimates the
number and concentration of Idaho’s livestock inventory.
2
See: Miller, John. “Dairy Industry Fights Idaho Counties.” Idaho Statesman. Published online February
11, 2010. Available at: http://www.idahostatesman.com/531/story/1076271.html
The facts about existing environmental and public health regulations governing CAFOs
are as follows:

Clean Water Act

The CWA does deal with some of the water-quality issues associated with CAFOs.
However, its scope is limited: the CWA regulates surface water quality only (it does not
govern ground water quality).

EPA’s CAFO enforcement authority is similarly limited. Under the CWA, CAFOs are
identified as point sources, and EPA’s primary tool for enforcing the CWA with respect
to point sources is the National Pollutant Discharge Elimination System (NPDES) permit
program. In Waterkeeper Alliance v. EPA, the US Court of Appeals for the Second
Circuit ruled that EPA did not have authority under the CWA to require all CAFOs to
apply for a NPDES permit solely based on a “potential” to discharge.3 This has narrowed
EPA’s CAFO enforcement authority to those facilities that choose to apply for a NPDES
permit.4 CAFO operators who choose not to apply for a NPDES permit effectively avoid
EPA oversight altogether.5

To understand the real-world implications of these facts, one need only visit EPA’s
Enforcement and Compliance History Online (ECHO) database.6 In 2007 Idaho had
between 765 and 1,505 cattle & calf facilities that met EPA’s definition of a medium or
large CAFO (and were therefore eligible to apply for NPDES permits). Yet, according to
ECHO, only102 Idaho CAFOs are currently regulated under the CWA’s NPDES
program.7 Of these 102 permitted facilities, EPA has inspected 13. Furthermore, it is
likely that even fewer facilities will seek coverage under the new NPDES CAFO permit
to be issued this year, making the prospective “burden” of federal CWA authority over
Idaho’s dairy CAFOs in the foreseeable future practically nil.8

3
Rogers, Barclay and Ellen Steen. “Waterkeeper Alliance, Inc. v. EPA: CAFO Water Regulations
Invalidated.” Water Quality and Wetlands Committee Newsletter, Vol. 6, No. 2 (August 2005). Available
online at http://www.crowell.com/NewsEvents/Article.aspx?id=322
4
CAFOs are eligible for coverage under a NPDES permit if they “discharge” or “propose to discharge” to
waters of the US. CAFOs “propose to discharge” if the facility is “designed, constructed, operated or
maintained such that a discharge will occur” (40 CFR 122.23(d)(1)).
5
It is true that non-permitted facilities can be fined for CWA violations (and for discharging without a
permit), but EPA’s ability to keep tabs on non-permitted facilities is extremely limited. Reports of
unpermitted facility discharges to surface waters are much more likely to be funneled through ISDA—an
agency with an extensive and sordid history of failure to enforce water quality standards (See “ISDA’s
Dismal CAFO Enforcement Record.”)
6
http://www.epa-echo.gov/echo/
7
Source: 2007 Idaho Livestock Census. Because the Livestock Census data are not broken down exactly
according to EPA definitions—the numbers listed here include operations with inventories of 500+ and
200-499 head—the upper limit of the ranges listed here may include some operations that would not meet
EPA’s definition of a Medium or Large CAFO. However, as ISDA data are based on numbers reported in
lengthy surveys that are entirely voluntary, it is also likely that the Livestock Census data itself
underestimates the number and concentration of Idaho’s livestock.
8
For example, Idaho Dairymen’s Association spokesman Bob Naerebout has stated that he expects no
more than a few dozen of Idaho’s numerous dairy CAFOs to apply for the newest instantiation of the
 Clean Air Act

Mr. McClure’s comment about the CAA is even less true than his assertions about the
CWA. Whereas under the CWA, CAFOs are considered “point-sources” and other
agricultural activities are considered “non-point sources,” the CAA groups CAFOs with
all other agricultural activities. Under the CAA “agricultural activities” are largely
unregulated. In reality, about the only “agricultural” emissions the CAA covers
effectively are those from burning, PM 10 and PM 2.5 (dust).9

CERCLA and EPCRA

Mr McClure did not mention the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA, aka Superfund) or Emergency Planning and
Community Right-to-Know Act (EPCRA) specifically, but because these are the only
other two federal environmental laws that have regulated CAFOs in the past it is
important to understand what they do and do not cover.

As of January 20, 2009, all livestock operations (including CAFOs) are exempt from
CERCLA reporting requirements, and all but Large CAFOs are exempt from EPCRA
reporting requirements.10 Large CAFOs are required to report if they emit 100 pounds of
ammonia or hydrogen sulfide in one 24-hour period. Until the results of the National Air
Emissions Monitoring Study are finalized, Large CAFO operators can fulfill this
requirement by submitting “good faith estimates” of their emissions.

Ground Water

Technically, DEQ has authority to promulgate and enforce rules governing the state’s
ground water quality. However, because of a giant loophole present in the current ground
water quality rule, two Memoranda of Understanding (MOU) with ISDA that turn
enforcement of the ground water quality rule at beef and dairy CAFOs over to ISDA, and
a lack of funding for ground water monitoring, DEQ has essentially been powerless to
stop the continued pollution of ground water by CAFOs.

As currently written, DEQ’s Ground Water Quality Rule features a loophole for
operations following “Best Management Practices”:

400.GROUND WATER CONTAMINATION.

1. Releases Degrading Ground Water Quality. No person shall
cause or allow the release, spilling, leaking, emission,

NPDES permit.
9
See “Agriculture-Specific Requirements” on EPA’s CAA webpage:
http://www.epa.gov/oecaagct/lcaa.html
10
See: EPA’s CERCLA/EPCRA Administrative Reporting Exemption for Air Releases of Hazardous
Substances from Animal Waste at Farms Final Rule Fact Sheet. Available online at:
http://www.epa.gov/emergencies/docs/chem/CAFO_rule_fact_sheet.pdf. The full text of the final rule is
available at: http://www.epa.gov/fedrgstr/EPA-AIR/2008/December/Day-18/a30003.htm.
 discharge, escape, leaching, or disposal of a contaminant
into the environment in a manner that: (3-20-97)
a. Causes a ground water quality standard to be exceeded;
(3-20-97)
b. Injures a beneficial use of ground water; or (3-20-97)
c. Is not in accordance with a permit, consent order or
applicable best management practice, best available
method or best practical method.
(DEQ Ground Water Quality Rule, pg. 13; my emphasis)

While the original intent of this caveat was no doubt to ease the burden on farmers doing
their best to be good stewards who inadvertently impact ground water quality—say
through the application of commercial fertilizer—in practice, the exemption has had the
effect of sanctioning blatant pollution by CAFOs. CAFO lagoons are allowed to leach
1,000 gallons of untreated effluent per acre per day, without concern for the relative
vulnerability of surrounding ground water to contamination; CAFO nutrient management
plans, largely used to determine whether producers are following “best management
practices,” utilize 15-year-old ASAE manure generation values for phosphorous that are
themselves based on 30-year-old data (this is in contrast to small producers, whose
nutrient management plans, composed with assistance from USDA, utilize the 2005
ASAE values); 11 CAFO operators have been known to exploit the unregulated status of
“third-party” waste application to allow the routine over-application of waste on nearby
fields, thereby facilitating the transport of nitrogen and other contaminants to ground
water.

Three separate DEQ reports released just this past year note that CAFOs have polluted
groundwater in Washington, Gooding, and Cassia Counties with livestock-only
antibiotics, steroid hormones and nitrates. Nitrate levels at one industrial dairy in Marsing
have recently reached as high as 170 ppm, yet nothing has been done.12

Ground water in the Magic Valley has a minimal layer of additional protection from
EPA’s Sole Source Aquifer program—the valley sits on top of the EPA-designated sole
source Eastern Snake River Plain Aquifer—but this program only requires that projects
utilizing federal funds with the potential to degrade the aquifer receive approval from the
SSA program.13 In recent years, the program’s Memoranda of Understanding with
11
See: Ron Sheffield, Ph.D. to Owyhee County Planning and Zoning Administrator Mary Huff, July 18,
2007 (attached). Information about nutrient management plans for small producers was obtained from a
phone conversation with Dick Johnson, NRCS.
12
Nitrate contaminated drinking water is most notorious for its link to “blue baby syndrome”—which
causes developmental deficiencies and even death in severe cases. However, more recent studies have tied
high nitrate levels to a number of other serious health problems including hyperthyroidism, cancer,
diabetes, non-Hodgkin’s lymphoma, and birth defects. For a summary of the research and references on
nitrates and drinking water, see: Ward, Mary H., et al. “Workgroup Report: Drinking-Water Nitrate and
Health—Recent Findings and Research Needs.” Environmental Health Perspectives 113(11) (November
2005): 1607–1614. Published online 2005 June 23. Available at
http://ehp.niehs.nih.gov/members/2005/8043/8043.pdf.
13
For an overview of the SSA program, you can visit EPA region 10’s SSA program web page at:
http://yosemite.epa.gov/r10/water.nsf/Sole+Source+Aquifers/Overview/
various federal agencies (including USDA) have hampered its ability to protect the
aquifer.

State air quality regulations

ISDA’s Rules Governing Agriculture Odor Management are the only non-federal air
quality requirements to which the state’s CAFOs are subject.14 These Rules, as anyone
unlucky enough to have had a CAFO implanted upwind of them will tell you, are a joke.
Apart from being extreme leniency of the Rules themselves, ISDA’s “method” of dealing
with odor complaints is completely unscientific, and the agency’s response times are
incredibly slow—several days or even a week may pass before an inspector arrives on the
scene. To I.C.A.R.E.’s knowledge, no CAFO has ever been penalized for violation of
these Rules.

ISDA’s Dismal CAFO Enforcement Record

ISDA has a dismal record of protecting Idaho’s surface and ground water from CAFO
pollution.15 Recent high-profile CAFO violations of the CWA alone include Double C
Farms (2005), Bruneau Cattle Co. (2006), and C Bar M (2008).16

In the past, industry and ISDA representatives attempted to use high-profile cases like
these and the figures reported in ISDA’s Beef Cattle Environmental Control
Memorandum of Understanding (“Beef MOU”) and Idaho Dairy Pollution Prevention
Initiative Memorandum of Understanding (“Dairy MOU”) Annual Reports as evidence
that the state’s CAFO enforcement programs were working and that more stringent
oversight of or changes in ISDA’s enforcement authority are unnecessary. Yet publicly
available water monitoring data and reports contradict this assertion.17 Further, the idea

14
As far as CAFOs are concerned, DEQ’s Rules for the Control of Air Pollution in Idaho do nothing more
than implement CAA requirements. DEQ can and has intervened when CAFO facilities fail to keep PM 10
and PM 2.5 at or below allowable levels and for unpermitted burning, but even these efforts are largely
toothless: they are not enough to keep CAFOs from regularly repeating the offense—a fact best
documented in the case of Sunnyside Feedlot. Should the ongoing efforts of a handful of Congressmen to
exempt CAFOs from the CAA succeed, even these minimal regulatory requirements will be void.
15
The same could be said of its enforcement record with regard to CAFO-caused air pollution; however, its
failures to protect water quality are better documented.
16
Source: US EPA Enforcement & Compliance History Online (ECHO).
17
For example, in its 2007 Dairy MOU Annual Report, ISDA freely admits that 126 of 397 fields tested
were over the P threshold (ISDA 2006 Dairy MOU Annual Report, 6). Importantly, these tests were run on
dairy farms whose well nitrates were “10 ppm or greater.” For 6 out of 7 of DEQ’s Upper Snake Rock
Surface Water Monitoring sites along the Snake River, total phosphorous exceeded the TMDL at
frequencies at and above 50%. Not surprisingly, the site with the highest total phosphorous exceedance rate
(83.6%) is immediately downstream of a cluster of Jerome and Gooding County CAFOs. See also: DEQ’s
Water Information Bulletin, No. 50, Part 7, “Trend Analyses for Idaho’s Nitrate Priority Areas 1994-2007,”
by Kenneth W. Neely (September 2008); DEQ’s December 2009 Ground Water Quality Technical Report
No. 38, “Possible Sources of Nitrate to the Springs of Southern Gooding County, Eastern Snake River
Plain, Idaho,” by Kerri Shorzman, Joe Baldwin and John Bokor; “Health Consultation: Sunnyside Area
Groundwater Contamination: Evaluation of Antibiotic, Steroid Hormone & Nitrate Compounds in
Groundwater Near a Confined Animal Feeding Operation (CAFO); Weiser, Washington County, Idaho,”
itself—that high-profile violations of a law are evidence that enforcement programs are
working—is a product of severely twisted logic: ordinarily, such blatant displays of
contempt for the law are indications that enforcement efforts are deeply flawed. There is
also evidence indicating that the much-touted results appearing in ISDA’s rosy Beef and
Dairy MOUs—purporting to show steady declines in CAFO noncompliance and
discharge violations—are largely illusory.

The Beef and Dairy MOU Annual Reports overlook several important facts. ISDA
inspections function more as a shield for CAFO operators than as a tool for enforcing
compliance: ISDA does not consider “evidence of past discharge” as evidence of
noncompliance, multi-day lag times between citizen complaints and ISDA inspections
are not uncommon, and ISDA protocol requires the agency to notify CAFO operators of
impending inspections—in the case of routine inspections (not prompted by complaints)
operators may have several weeks’ notice.18 Additionally, ISDA’s refusal to give
credence to evidence of noncompliance submitted by anyone other than an ISDA
inspector radically narrows the scope of actionable evidence; 19 ISDA and industry have a
record of resorting to intimidation to discourage citizens from reporting evidence of
noncompliance; 20 ISDA is well-known for revealing to producers the identity of citizens
who have complained and asked to remain anonymous; and Department employees have
a tendency to advise CAFO operators to utilize ethically questionable legal loopholes to
avoid noncompliance citations.21 Even when ISDA issues a notice of noncompliance,
operators can continue for months and (in several cases) years without being assessed a
fine.22
prepared by Idaho Department of Health and Welfare Division of Health under a cooperative agreement
with the US Department of Health and Human Services Agency for Toxic Substances and Disease
Registry, March 19, 2007; and DEQ’s Ground Water Quality Technical Report No. 39, “Nitrate and
Emerging Contaminants Evaluation of Springdale, Idaho: Cassia County Nitrate Priority Area,” by Kerri
Shorzman and Joe Baldwin (December 2009).
18
This reality was best summed up in a quote from ISDA spokesman Wayne Hoffman: “‘Until they’re
caught discharging they’re not out of compliance.’” Barker, Rocky. “Feds Question Idaho’s Efforts to Keep
Manure Out of Waterways.” The Idaho Statesman. November 14, 2005. Available at:
http://www.boisestate.edu/history/issuesonline/fall2006_issues/f1_news_pdf06fall/POLLUTION111405.pd
f . Further references to this article will be made parenthetically within the text.
19
At a public meeting on November 16, 2009, ISDA Dairy/CAFO Bureau Chief Marv Patten essentially
admitted that the agency’s reluctance to act on citizen tips about CAFO violations was in part due to its fear
of being sued by industry. ICARE’s recording of this meeting can be accessed and downloaded at:
http://idahocares.org/negotiated-rule-making.
20
ICARE’s Executive Director and several ICARE members have had first-hand experience with this, and
would be happy to provide affidavits of their experiences, if requested.
21
Two well documented incidences of the latter include a “third-party” waste application in a field
neighboring a Nampa dairy and paralleling Indian Creek (first reported in June 2005), and ISDA employee
John Chatburn’s advice to Double C’s operator that he could avoid regulation by simply opening a gate.
Sources: Idaho Press Tribune, “Waste Floods Into Pasture,” by Michael McAuliffe; Letter from Gary Bahr
(ISDA Agricultural Bureau Chief, Water Quality Programs) to Mike McGown (DEQ), June 13, 2005; and
Barker, 2005.
22
For example: High ‘N Dry Feeders/VL Livestock Inc. has continued to operate in noncompliance (for a
faulty lagoon) since 2002 and has never been assessed a fine. Prior to being foreclosed on, Seth Matthews
was allowed to operate his Sunnyside Feedlot in continual noncompliance. Despite polluting 22 private
neighboring wells (and probably the Snake River) with nitrate, livestock-only antibiotics Sulfamethoxazole
and Sulfamethizine, and the hormone 17-beta estradiol, Matthews was never fined. Nitrate levels at an
industrial dairy in Marsing have recently reach as high as 170 ppm—nothing has been done.
In the rare event that ISDA has taken substantive enforcement action, it has also, more
often than not, reduced whatever fines or penalties are handed down to pennies on the
dollar. For example: two Magic Valley dairy CAFOs caught discharging liquid waste into
irrigation ditches and deliberately spreading manure on a public roadway in 2007 were
initially assessed a combined fine of $55,000; by early 2008, ISDA had agreed to whittle
that sum down to a total of $6,000.23 When asked about the Department’s lenient
approach toward enforcement evinced by such cases at an October 16, 2009 meeting with
ICARE representatives, ISDA Deputy Director Brian Oakey had this to say:

[…] In my opinion, and in a lot of peoples’ opinions, this type of

enforcement program works. Because when you’ve got a $50,000 penalty
that’s held in probation for a year and says “we’re going to hold you to
this” you take remedial measures, and you ensure that it doesn’t happen
again, and if it does within the probationary period then we’re going to
take the other $49,000. That gives them a very strong incentive to comply
with the law, and to take extra effort—extra measures beyond what the
law requires—to ensure that these types of discharges do not occur.24

Oakey’s assumption may be correct in the short term—a producer assessed a fine that is
held in abeyance for a year has an monetary incentive to be on good behavior during the
probationary period—but it fails miserably as a long-term pollution abatement strategy.25
In fact, the evidence indicates this policy has made Idaho’s CAFO pollution problem
worse: on ISDA’s watch, operators have been given what amounts to a once-a-year free
pass on discharges. It is easy to see how even a handful of the state’s CAFOs taking
advantage of that free pass places the state’s ground and surface waters—to say nothing
of its air quality and the health of its soils—in peril.

These problems have been exacerbated by ISDA’s use of outdated science and industry
standards. The state’s nutrient management planning software (“Idaho One Plan”), Rules
Governing Beef Cattle Animal Feeding Operations (“Beef Rules”) and Rules Governing
Dairy Waste (“Dairy Rules”) utilize outdated standards and data that make CAFO
contamination of surface and groundwater virtually inevitable—even if producers are
attempting to be good environmental stewards. Former University of Idaho Assistant
Professor and Waste Management Engineer Dr. Ron Sheffield addressed this very issue
in a July 18, 2007 letter reviewing the proposed NMP for a large Owyhee County dairy
CAFO expansion. He wrote:

The proposed NMP was developed via the Idaho 1-Plan, and lacks several details
concerning the operation of the dairy’s manure handling system and activities
related to mitigating potential odors. […]

23
Christensen, Matt, “Jerome Dairies Fined for Waste Violations.” Times-News. March 6, 2008.
24
Brian Oakey, October 16, 2009, ISDA Boise headquarters.
25
Oakey implicitly admits as much: “if it [discharge] does [happen again] within the probationary period”
(ICARE’s emphasis).
 1. Phosphorous Excretion. The manure generation values used in the NMP are based
on 1991 manure generation values adopted by the USDA-NRCS. Several
advances in animal genetics, dairy management, and feeding strategies have taken
place since the late ‘80s; the time in which the studies were conducted to generate
the 1991 values. Subsequently, the American Society of Agricultural and
Biological Engineers and the Association for Professional Animal Scientists
developed new a manure generation standards (ASA 384.2 MAR2005) that was
adopted in 2005. Specifically, the standard raised the estimated phosphorous
excretion for a mature 1400 lb dairy cow from 0.21lbs P2O5/cow/day to 0.39 lbs
P2O5/cow/day, nearly doubling the amount of excreted phosphorous per day. The
use of the 1991 excretion values is in accordance with state rules. However,
given the current accepted science, the proposed NMP creates a false sense of
security for the producer that the management of phosphorous, through
following the NMP, will occur without excessive build-up of soil phosphorous
in the soil, when in reality, that will likely occur because only half of the
excreted manure phosphorous has been accounted for in the NMP.26

The Idaho One Plan’s manure generation values have not been updated since this letter
was sent.

Add to this the outdated NRCS 590 standard incorporated in the state’s Beef and Dairy
Rules, the power granted ISDA in the Beef and Dairy MOUs, and the widespread abuse
of the “safe harbor” provisions of the state’s Beef Cattle Environmental Control Act
(“BCECA”) and Dairy Rules, and it becomes difficult not to see the consequences—near-
perfect immunity from and evasion of enforcement under the state’s Ground Water
Quality Rule and the CWA—within the past several years as the result of a deliberately
planned and carefully executed coup on behalf of large producers by ISDA.27

In any case, there is no doubt that in the past several years ISDA has successfully
circumvented the intent of Congress (in creating the CWA) and the state legislature (in
creating the BCECA and Sanitary Inspection of Dairy Products Act)—much to the
detriment of the state’s waters.

Conclusion

The few federal and state regulations that attempt to limit the impacts of CAFO activities
on Idaho’s water and air quality are not a matter of legislation for legislation’s sake: they
are intended to protect the health of its citizens, the continued fertility of its working
irrigable lands, private property rights and values, and the viability of its tourism and
water-based recreational industries. Senator Corder’s attempt to resurrect S1213 and

26
Dr. Ron Sheffield to Mary Huff. July 18, 2007 (ICARE’s emphasis). A copy of the entire letter is
attached.
27
ISDA cites a “philosophical difference” as the basis of its decision not to incorporate the updated 590
standard (2007 Dairy MOU Annual Report, 6). Importantly, this “philosophical difference” does not apply
to small beef and dairy farms, whose nutrient management plans are developed by USDA and utilize the
2007 590 standard and updated manure generation values.
1223 would cripple the already weak protections these laws afford as well as undermine
the state’s long-standing tradition of local control.

Even when in receipt of a substantial operating budget, ISDA has routinely failed to
enforce the few state-level environmental rules and laws that govern beef and dairy
CAFOs. There is no reason to believe that it will do better with more responsibility and a
smaller budget. On the contrary, there is ample reason to believe that giving ISDA greater
authority over the state’s CAFOs in tandem with slashing its budget will spell disaster for
a number of Idaho families and communities. I.C.A.R.E. urges you not to print any bill
that would give ISDA unchecked authority over CAFO regulation and enforcement—
whether beef, dairy, swine, or poultry.

Sincerely,

Alma Hasse
Executive Director
Idaho Concerned Area Residents for the Environment (I.C.A.R.E.)
PO Box 922
Fruitland, ID 83619

Shavone Hasse
Board Member
Idaho Concerned Area Residents for the Environment (I.C.A.R.E.)
PO Box 922
Fruitland, ID 83619