United Poultry Concerns, Inc.
12325 Seaside Road PO Box 150
Machipongo, VA 23405
Phone (757) 678-7875
Docket Number W-00-27
Environmental Protection Agency
40 CFR Parts 122 and 412
Public Comments can be submitted by email to: CAFOS.comments@epa.gov.
Specify Docket Number 2-00-27. Submit as an ASCII, Word or
WordPerfect file. Submit by Tuesday Evening, January 15, 2002. EPA
Notice: http://www.epa.gov/npdes/regulations/noda_fr.txt
Detailed Report on the Duck Industry:
http://www.vivausa.org/Campaigns/Ducks/Viva!USADuckReport.htm
Proposed Rule: Notice of data availability. National Pollutant
Discharge Elimination System Permit Regulation and Effluent
Limitation Guidelines and Standards for Concentrated Animal Feeding
Operations.
The Environmental Protection Agency (EPA) proposes to revise and
update two regulations to ensure that manure, wastewater, and other
process waters generated by concentrated animal feeding operations
(CAFOs) do not impair water quality.
United Poultry Concerns is a 501c(3) organization that addresses the
treatment of chickens, turkeys, ducks, and other domestic fowl.
United Poultry Concerns promotes the humane treatment of domestic
fowl. On behalf of our national membership, we appreciate the
opportunity to comment on the Proposed Rule. Our comments concern
whether dry lot duck operations should receive favorable regulatory
status over wet lot duck operations. United Poultry Concerns opposes
giving dry lot duck operations favorable regulatory status for the
following reasons.
1. Dry lot operations deprive ducks, which are waterfowl, of all
water but drinking water-drinking water that is typically dispensed
only in one-drop-at-a-time nipple drinkers. To deprive ducks of a
clean water-based environment is to ignore the basic nature,
behavior, and hygiene of these aquatic birds. Ducks are skilled
enthusiastic swimmers from birth. Ducks must swim in order to
maintain good plumage and to maintain a healthful distribution of
preen-gland oil over their skin at all times. Ducks require a steady
supply of clean water in order to wash their nostrils, eyes, and
bills frequently throughout the day to maintain hygiene and
well-being. Ducks denied water to swim in develop lice and mites. In
their natural habitat, ducks have constant access to clean bathing
water. Provided only with shallow water containers, and on dry lots
with no water containers, ducks are susceptible to ophthalmia, or
"sticky eye." Sticky eye mats the feathers around the eye with a
yellowish discharge and can cause a duck's eyelids to stick shut. If
sticky eye is not promptly cured, the infection can persist through
the duck's life and cause blindness. Add sticky eye to
keratoconjunctivitis, the painful eye disease to which ducks are
susceptible when forced to live in dry lot sheds permeated with
excretory ammonia fumes from the decomposing uric acid in their
accumulated droppings, and the painful chronic eye infections that
can cause ducks to go blind are compounded.
2. Dry lot duck operations typically force ducks to stand and walk on
wire floors without relief, thereby encouraging painful and infected
foot problems to develop, including abrasions, bruises, lameness, and
torn skin in the hock joint, shank, and foot pad inviting
staphylococcus boils and abscesses. The anatomy and physiology of a
duck's foot are designed for swimming, not walking on wires. Ducks
need pasture and bathing water to avoid foot problems and to maintain
healthy feet. Clean swimming water can actually help a duck to
recover from a serious leg or foot injury.
3. Dry lot duck operations debill ducks by cutting or burning off a
portion of the duck's upper bill as a substitute for proper
husbandry. The bill of a duck, like the beak of a chicken or turkey,
is filled with highly sensitive nerves. These sensitive nerves enable
ducks to eat the way ducks eat naturally-by dabbling, or straining,
plankton and other microorganisms in mud and water through their
bills. Debilling is a painful, debilitating mutilation. Debilled
ducks are susceptible to bill infections, and because they cannot
preen properly with a mutilated bill stump, they are more likely to
become infested with lice, mites, and other external parasites. Dry
lot operations ignore the duck's bill-related biological requirements
in two important ways: they prevent ducks from dabbling, and they
mutilate the bill, thereby preventing ducks from maintaining bodily
hygiene by preening. Debilling actually encourages abnormal feather
pulling as does chronic stress, pain, boredom, nutritional
deficiency, and a biologically impoverished, filthy environment,
i.e., a dry lot operation.
EVERY SINGLE DUCK HUSBANDRY MANUAL EMPHASIZES THAT WHEN FORCED TO
SURVIVE IN A FILTHY ENVIRONMENT, ON IMPROPER FOOD, AND WITHOUT CLEAN
WASHING WATER, DUCKS DEVELOP HEALTH AND HYGIENE PROBLEMS. E.g., "The
most common causes of health problems in ducks are improper diet [a
diet lacking succulent greens and composed of too much protein and
corn], ingestion of toxic substances [including excretory ammonia
gases and mold toxins], overcrowding [less than a minimum of 2 square
feet of floor space per medium-or large-size ducks, who really need a
minimum of 10 to 25 square feet of ground space per duck], filthy
pens, and injuries. . . . [W]hen ducklings are overcrowded, brooded
on damp litter, or kept in filthy quarters, they can suffer serious
coccidiosis infestations. . . . Feather-eating is usually the result
of boredom, but can also be triggered by excessively high brooding
temperatures, intense light, overcrowding, an unbalanced diet, or the
lack of green feed. Clean bathing water for ducks prevents and
reduces susceptibility to lameness, sticky eye, worms, lice, mites,
and the boredom and irritation that can lead to feather-pulling and
other abnormal behaviors in ducks." (Storey's Guide to Raising Ducks,
2001, by Dave Holderread.)
Recommendations:
1. Clean fresh water for swimming, for total head and body immersion,
and for drinking.
2. Succulent vegetation. Ducks and ducklings need a constant supply
of tender greens such as fresh lettuce, grass, and dandelions.
3. Clean dry bedding.
4. Access to a clean outdoor environment with appropriate forage
including water to dabble in.
5. No debilling. Debilling is an inhumane substitute for proper
husbandry. This painful mutilation can actually increase
feather-pulling and other destructive behaviors that develop when
ducks are forced to live in crowded, sterile environments that ignore
their biological requirements.
6. A minimum of 10 square feet of ground space per duck.
7. Gentle handling. The legs and wings of ducks are easily injured.
Ducks should never be grabbed by their wings or legs. When a duck is
lifted from the ground, the duck's weight should rest on your
forearm, the duck should be upright, and the wings should be held
firmly but gently against your side.
Conclusion The EPA should not give favorable regulatory status to dry
lot duck operations. Consider the following:
For the past two years, residents living near West Creek in north
Langley, British Columbia, have endured a recurring stench that one
resident likens to "sticking your head in a cesspool." The stench
comes from a manure pit built under an intensive duck farm in North
Langley, 7455 256th Street, where Bert Vane keeps up to 10,000 ducks
in a 10,000 square foot dry lot shed. The ducks are debilled. They
live without fresh air, natural light, or water to bathe or swim in
for six to seven weeks until they are slaughtered. They stand and
walk on a wire floor through which their mainly liquid manure drops
into a 66-meter long, 2.5 meter-deep concrete pit for six months
before being hauled away by tanker truck. One duck produces .06 kilos
of waste every day, 219 kg per year; or .33 lbs per day, .05 tons per
year. Waterfowl fecal matter contains as much as 33 million fecal
coliform bacteria. The average contribution of coliform bacteria from
a single bird in a 24-hour period is 5 to 40 times greater than that
of a single human being. (Compiled from The Vancouver Sun, 20
December 2001, p. B3; "Waterfowl feeding at Heckscher Pond,"
Huntington Department of Environmental Control; and "Livestock Manure
Production Rates and Nutrient Content," J.C. Barker et al., 2002
North Carolina Agricultural Chemicals Manual).
Comments Submitted by United Poultry Concerns, 14 January 2002 Docket
Number: W-00-27
For more information, contact Karen Davis, PhD, President at (757)
678-7875, or visit
http://www.UPC-online.org/environment
United Poultry Concerns, Inc.
PO Box 150
Machipongo, VA 23405-0150
757-678-7875
FAX: 757-678-5070
www.upc-online.org
(Comments to EPA on Dry Lots for Ducks Submitted By UPC)
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