Oklahoma Cattlemen Submit Comments on Bacteria Levels of Red River in Southern OklahomaTue, 08 Mar 2016 18:15:36 CST
The Oklahoma Cattlemen's Association submitted written comments this week to the Oklahoma Department of Environmental Quality- in regards to work that the DEQ is doing on draft bacterial TMDLs in the lower Red River area. In the comments, the cattle organization expressed concern that the DEQ is putting too much blame on domesticated animals, like beef cattle, for high levels of bacteria in the river system.
The comments were submitted on Monday, the final day for comments to be offered to the state agency. Here are the comments as submitted by OCA to DEQ:
"On behalf of the members of the Oklahoma Cattlemen's Association (OCA), I appreciate the opportunity to provide comments on the Public Notice entitled "Availability of Draft Bacterial TMDLs for the Lower Red River Study Area - Proposed Modification to Incorporate Lower Red River Study Area Bacterial TMDLs into Oklahoma's Water Quality Management Plan." OCA is a membership based organization of cattle producers and landowners in Oklahoma. Our membership is committed to the production of safe, wholesome and high quality beef while maintaining high standards for responsible stewardship of the natural resources needed for beef production.
"First, OCA sincerely appreciates the Oklahoma Department of Environmental Quality's (DEQ) willingness to extend the comment period by 30 days to March 7th. OCA hosted a cattle producer meeting in Wapanucka, Oklahoma on the evening of February 2nd to discuss the Public Notice and encourage cattle producers to provide comments. Of the 80 participants in the meeting, only one individual indicated that they were aware of the Public Notice before receiving the invitation to the meeting. Based upon this, OCA requested a comment extension of 30 days to which DEQ generously responded. OCA respectfully requests DEQ evaluate their communication strategy of future announcements, public notices and rule modifications. Perhaps a task force of regulatory and industry individuals could review the current communication strategies and propose modifications.
"The Public Notice acknowledges the lack of data to estimate populations of wildlife and avian species other than deer. OCA believes this to be a significant deficiency that needs to be considered before summary statements can be made. At the producer meeting in early February, all participants indicated that the numbers of feral swine on their property and surrounding areas have significantly increased in the past decade. Further, feral swine are known to concentrate in creek and water areas during summer months, the primary sampling time period, in order to find relief from heat. This may compound their contribution to bacteria load. Further, several producers have indicated that waterfowl, specifically geese, have used their improved forage systems as food sources. One producer indicated that well over 100 geese congregate on his rye forage on a frequent basis. High fecal bacteria levels in the Oklahoma River in the past, while initially blamed on cattle, have been found to be human and geese.
"Table 3-13 of the TMDL report is, in the opinion of OCA, badly skewed toward commercially raised farm animals. OCA appreciates the statement on page 3-20 "...a number of bacterial source tracking studies around the nation demonstrate that wild birds and mammals represent a major source of the fecal bacteria found in streams." OCA agrees! OCA suggests that before any potential non-point sources are implicated, sufficient effort to gather and estimate data from each potential source be made. New DNA technologies can accurately determine the source of the fecal bacteria. In the very least, comments in the summary of the Public Notice should be more clear that data from specific wildlife sources while unavailable are likely to be strong contributors to elevated bacteria counts. This would be consistent with comment policy as page 3-13 of they DRAFT 2015 Bacterial Total Maximum Daily Loads for Oklahoma Streams in the Lower Red River Area says "Despite the lack of specific data, for the purpose of these TMDLs, land application of commercially raised farm animal manure is considered a potential source of bacterial loading to the watersheds in the Study Area."
"OCA is also concerned about the individual data sets from each of the waterbodies. While a geometric mean is calculated, several of the waterbodies have single or two entries that are well outside the other data points. For example, in the Caney Boggy Creek data set for Enterococci, the range is 10 to 2,900 (page A-3). Further, the second highest data point is 325, 2,575 points below the highest. Additionally, in the Bokchito Creek data set, the range is 5 to 2,000 with eight of the eleven data points being 1,730 points less the second highest number. These high ranges of data can skew the results significantly. Why were these data points, so far outside the significant portion of the data set, not excluded or samples retaken? Single data entires like these cause question of sampling technique including timing, potentional contimantion or other inconsistencies. OCA urges that sample sets be scrutinized for data inconsistencies.
"We sincerely appreciate the opportunity to provide comments on this important rule."
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