RECEIVED
    CLERK’S OFFrCF
    MAY
    2
    -
    2001
    Written Testimony ofthe Illinois Milk Producers’ Association
    STATE OF ILUNOIS
    Jim Fraley,
    Manager
    Po~IutIon
    Control Board
    Pollution Control Board Hearing
    Monday, April
    30, 2001
    ~
    ~
    Construction Standards
    Our organization represents more than 80% ofthe state’s milk throughour five
    member cooperatives and two independent producer groups. We have been involved in the
    development ofthe Livestock Management Facilities Act (LMFA), since its inception.
    The need for some type ofvehicle to help support the state’slivestock industry is
    desperately needed
    —
    it needs to allow forresponsible growth and not discourage producers
    with burdensome regulations that are too expensive to implement. We have lost one-third
    of our dairy farms in Illinois, just since
    1996, and our cow numbers threaten to drop below
    100,000 within a few years.
    Illinois is on the verge oflosing a significant portion of its
    number-one agricultural economic resource.
    In the five years since the LMFA has beenenacted, 23 persons have indicated an
    interest in building a dairy in Illinois by filing a Notice of Intent to Construct with the
    IDOA, yet only six have actually moved forward and have been built.
    Why haven’tthese
    been built? A variety ofreasons, I’m sure. But I have heard from many producers about
    the onerous cost ofregulation that has come along with the developmentofthe LMFA.
    Groundwater monitoring, engineering assistance, nutrient management plan development,
    and construction standards
    are all examples ofadditional-c~stsAhat are borne by the
    producer
    —
    a person who is a price-taker and cannot pass along these added costs.
    We specifically would like to address the areas oflagoon construction and
    construction standards.
    Lagoons are an integral part ofmanaging nutrients from a dairy operation.
    Most of
    the dairies in the state utilize a lagoon or holding pond system for the storage or treatment
    ofmanure.
    By mandating a blanket guideline that requires producers to install “...rigid
    material such as concrete or steel (in areas ofkarst topography)”these rules discourage the
    construction ofany new lagoons or expansion of existing facilities. The dairy areas ofthe
    state happen to be located in the areas that happen to have karst topography. By
    discouraging the dairy industry,
    more producers will switch to row crop farming in lieu of
    alfalfa, oats, and other conservation crops.
    These crops are not well-suited for these
    sections ofthe country.
    It has been shown that a minimum hydraulic conductivity of 1
    x
    1
    ~7
    cm/second for a
    properly-installed clay liner will prove to be virtually impermeable. The movement of
    waterthrough this type ofliner is about one inch per decade.
    By requiring these additional
    —
    and unnecessary measures
    —
    it greatly adds to the cost oflagoon construction and would
    further erode the producer’sbottom line with little or no
    environmental benefit.
    Our state is blessed with an
    abundance of feed, excellent locations
    in which to
    expand current dairies and
    establish new ones, and a solid transportation system. Please
    help keep our state economically competitive with other states in the nation.
    Do not
    implement these restrictive mandates for lagoon construction.

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