OVERSIGHT ILLUSION
The Institute’s investigation, however, reveals the Michigan Model is an illusion.

• In 1997, for example, a 3,000-cow dairy with sites in Kentand Barry counties was responsible for five spills intocoldwater trout streams. The spills came after at least six years of MDA closing complaints when the producershowed superficial compliance with the voluntaryguidelines, or took some action to "abate" a specificcomplaint but none to solve the basic problem.
  
  
• Another case involves a moderate-size dairy operationresponsible for a large fish kill in 1994 to IsabellaCounty’s Salt River. The spill came one day afteragriculture inspectors responded to a complaint about anoverflowing waste lagoon. They left satisfied with the producer’s plan to lower the lagoon level by spreadingsome of the manure. After the fish kill, an MDEQ reportidentified serious problems that should have been obviousto MDA: Manure application at that time was dangerousbecause the ground was saturated by rains, the lagoon wastoo small for the herd, and storm water runoff frombuildings overloaded the lagoon.

CONCLUSION
These cases point to serious problems with Michigan’s current and proposed program for protecting the environment and rural communities from hazards inherent to large-scale, concentrated animal feeding operations. As federal regulators conclude in the USDA-EPA Draft Unified Strategy, from which Michigan is seeking exemption: "Large facilities (those with more than 1,000 animal units) produce quantities of manure that are a risk to water quality and public health whether the facilities are well managed or not."

Industrial-scale operations are increasing in Michigan as both industry and state-government promoters encourage farmers to adopt high-volume production. But, as the Institute’s review proves, Michigan is not prepared to ensure the shift to industrial agriculture is environmentally responsible.

RECOMMENDATIONS
It is incumbent upon state policy makers to recognize the flaws in the Department of Agriculture’s complaint response program, acknowledge the industry’s accelerating trend to larger livestock operations, and protect Michigan’s rural communities, groundwater, clear streams and clean air.

It is also essential that Michigan’s livestock producers receive clear and consistent guidance from state officials. Individual farmers pay a heavy price when the Department of Agriculture responds to a complaint but fails to identify problems that may exist or specify corrective measures required to prevent the problem from happening again.

Five of the state’s largest public interest and environmental policy groups, listed below, now call on the Michigan Department of Agriculture to immediately comply with its existing obligations under the law.

This coalition also calls on state policy makers to:

• Initiate an independent, interdisciplinary, field audit of the Right-to-Farm complaint response program.
  
  
• Establish a task force, made of public interests and professional experts, to respond to the audit’s findings and develop an appropriate, effective regulatory response to industrial-scale livestock agriculture.
  
  
• Appoint an ombudsman for communities and residents of areas where large-scale industrial agriculture operations are affecting property values and quality of life.
  
  
• Reject new public policy (such as the current S.B. 205) that would amend the Right to Farm Act to preempt local zoning of industrial agriculture. Michigan townships and counties are the most appropriate bodies to develop ordinances that reflect local conditions and concerns, especially in light of the state’s failure to adequately monitor industrial livestock operations.

United in this call for corrective and responsible action are:

The Michigan Land Use Institute

The Michigan Environmental Council

The West Michigan Environmental Action Council

The Sierra Club, Mackinac Chapter

Clean Water Action