Chicken Industry Response to EIP Report

Statement of Delmarva Poultry Industry, Inc. on the More Phosphorus, Less Monitoring report by the Environmental Integrity Project

With just a little bit of time to read, understand, and analyze the More Phosphorus, Less Monitoring “report” by the anti-chicken industry group Environmental Integrity Project, it is impossible to offer complete comments on it. However, these points are worth making.

As with any industry, updated and modern facilities are required to keep businesses competitive, including farm family-owned chicken farms. The new chicken houses include the latest technology and have landscape designs and environmental protection systems that exceed existing chicken housing. Water quality improvements are likely to be enhanced with the new chicken houses and their stormwater management plans.

Under the state of Maryland’s Concentrated Animal Feeding Operations program that covers most of the Eastern Shore’s chicken houses and newly constructed ones, chicken houses, through this federally-approved U.S. Environmental Protection Agency permit system, are allowed zero discharge of nutrients to waters of the state except for discharges during a 24-hour, 25 year storm which is about 6 inches of rain in a 24 hour period. So under normal weather conditions, there will be no discharges of nutrients to the waters of the state from the hundreds of chicken houses covered by the state permit.

The authors of the report conclude that a 1 to 2 percent annual growth in chicken meat production in the last 30 years on the Delmarva Peninsula is dangerous trend. That is nonsense.

The report uses 1985 as a baseline for some its data. According to data produced by Delmarva Poultry Industry, Inc., the capacity of all chicken houses on Delmarva from 1985 until 2014 went up by 37% in those 30 years; about 1 percent per year.

From 1995 until 2014, the number of chicken houses on Delmarva went down by 25%.

In the last 10 years, the capacity of all the Delmarva chicken houses went down about 3% while the number of operating chicken houses went down 12%. This is hardly an explosive growth that needs to be stopped by government actions.

After several years of economic sluggishness and regulatory hurdles, chicken house construction throughout Delmarva is catching up to the more normal level. For several years until last year, only a handful of chicken houses were built on Delmarva. Now, the pent-up demand for new houses is resulting in new construction.

A moratorium on new house construction until 2024 is ridiculous. The oft-cited Maryland Phosphorus Management Tool regulation in Maryland will limit manure applications on some farmland in the state and during the early phase-in period soil phosphorus levels will be computed and analyzed.

Opponents of the chicken industry who favor the moratorium on chicken house construction until full implementation of the Phosphorus Management Tool regulation in 2024 are hoping that by killing construction they will kill the chicken industry.

The report, though focused on the chicken industry and chicken manure, says nothing about the growth of the human being population in the Chesapeake Bay Watershed and the growth of houses, businesses, and impervious surfaces that contribute to water pollution.

Delmarva’s chicken industry has examined more than 70 proposed technologies that seek to do something with the manure other than direct farmland application as a locally produced organic fertilizer. For a variety of reasons, there are no commercially operating alternative use facilities on Delmarva, except the Perdue AgriRecycle plant in southern Delaware.

Delmarva’s chicken growers and farm families that handle chicken manure are making progress in water quality protection and more progress will be made. A moratorium on chicken house construction will not be part of the solution.