Barrett Farms
Donald and Judi Barrett
Rt 5 Box 126
Idabel, OK 74745
Phone (580)286-6776 Fax: (580)2865829 Email: barrett@pine-net.com
February 13, 1999
The Honorable Dennis Howard
Commissioner of Agriculture
Oklahoma Department of Agriculture
2800 North Lincoln Boulevard
Oklahoma City, OK 73105-4298
VIA FACSIMILE: 405.522.0909
As I am sure that you are aware (and may have been involved in, through joint agencies' meetings), that the Oklahoma Water Resources Board has been in engaged in an interim revision to the Oklahoma Water Quality Standards. This has been brought on by water labels in SB1170 to denote nutrient impairment, of which no waters had been so labeled in Oklahoma.
The interim revision informal meeting of December 14, 1998, revealed the proposed label of "nutrient limited" be placed on surface water of which a process would be used to decide if it was nutrient impaired. The "nutrient vulnerable" label for groundwater is proposed to be placed on groundwater that is believed to be moderately affected by nitrates. The key words here are "if " and "believed".
SB1170 allows ODA to prohibit the application of poultry litter in nutrient limited watersheds and over nutrient vulnerable groundwater. In that context, even though the bill does not contain a scientific definition for those labels, the legislature implied that these labels should be placed on water that is impaired by poultry litter, not water that is to be tested to see if it is impaired. The "nutrient limited watershed" label should have been used for water that has been proven to be impaired by nutrients. The label of "nutrient vulnerable" is proposed for groundwater that does not have adequate sampling and data collection. It is also based upon nitrates and you and I both know that phosphorus is the excess nutrient in poultry litter. The ratio of the two, (phosphorus and nitrogen) in poultry litter allows nitrogen to be used up completely by the surface forage with excess phosphorus being stored in the soil until the holding capacity is reached. It would be unjust for poultry farms to suffer hardship based upon a nutrient vulnerable labeled groundwater, based upon nitrogen, even if the agency had adequate data to back up the label, of which they do not.
ODA may choose to not prohibit the application of poultry litter in these areas so labeled by OWRB, but staff and authorities change. It is only right to get these labels correctly and fairly placed on these waters, since it has the potential to unjustly affect the poultry industry now and in the future.
Commissioner Howard, as our advocate for agriculture, I know that you are as concerned about this as I am. Will you be visiting with OWRB to get these labels fairly placed on waters that the senate bill intended for them to be placed? Oklahoma Farmers depend upon you to speak out and defend their interests. Regardless of what some people may think, the poultry industry is vital to the economy of Oklahoma and when something negatively affects it, other industries will also be caught in the wave of loss.
We faxed to you on December 16, our comments on the proposed surface water revisions. If you did not get those please let me know. I am faxing today with this letter, comments on ground water revisions. We would like to receive any comments made by ODA, (by anyone at that agency) to OWRB on this process. Can you see that we get copies?
The final and formal meeting of this process is Thursday, January 21. We will attend. We are hopeful that OWRB will have made the just changes that we have requested. If not, what can be done and what will you be doing, to attempt rectification? The poultry industry appreciates your efforts on our behalf. We look forward to hearing from you.
Sincerely,
Donald and Judi Barrett
Barrett Farms,
Member Broiler Producers Council
cc: Senator Jeff Rabon
Representative Terry Matlock