Comments on NC Dept of Environmental Quality’s Swine General Permit, Submitted on Behalf of REACH, NCEJN, Waterkeeper Alliance, Crystal Coast Waterkeeper and the North Carolina Conference of the NAACP

On March 4, the Chambers Center, Earthjustice, and the Yale School of Forestry & Environmental Studies and the Yale School of Public Health submitted comments to the North Carolina Department of Environmental Quality (“DEQ”) on the Draft  Swine Waste Management Permit currently under consideration. These comments were submitted on behalf of the North Carolina Environmental Justice Network (NCEJN), the Rural Empowerment Association for Community Help (REACH) and Waterkeeper Alliance, Inc., Crystal Coast Waterkeeper, and the North Carolina State Conference of the NAACP.

While these comments conisdered all aspects of the draft permit, our focus was on the racially discriminatory impacts of the industrial swine operations and DEQ’s failure to fulfill its obligations under Title VI of the Civil Rights Acr of 1964 in permitting these operations. As noted in the introduction of our comments:

Those impacts include air and water pollution emanating from the open pits of waste and sprayfields in which DEQ-permitted swine operations store and disperse billions of gallons of feces, urine and other waste. The consequences of this system are not just environmental, but also racially discriminatory, because they disproportionately burden non-white North Carolinians.

DEQ continues violating Title VI because the agency has failed to exercise its authority to provide adequate protections for the health and welfare of surrounding communities and, knowing the risks and impacts of the lagoon and sprayfield system in eastern North Carolina, failed to exercise its duty to include terms to identify and protect those communities in the draft Swine General Permit. We urge DEQ to begin planning now for the transition of North Carolina’s swine industry from the antiquated lagoon and sprayfield system to a more sustainable foundation for farming in the state.

Read the full text of the comments, and the attached exhibits:

In addition to signing on to these comments, the NC NAACP also submitted a separate comment letter.