I have seen public notice and letters in the local newspapers that on February 29 the Ohio Department of Agriculture (ODA) is accepting comments and will hold an open house and public meeting on the draft Permit to Install (PTI) and the draft Permit to Operate (PTO) that has been issued to the Arnold Road Farm.
I am very familiar with this process, having been involved in one way or another with these events for the past 33 years. I feel compelled to share my thoughts with the public so that you’re not misled as to the purpose of this meeting. For the record, I do not know the Drew family who have applied for this permit and do not provide consulting services to them.
The open house is your opportunity to look at the application that has been submitted to ODA, to ask ODA staff questions concerning the review of the application, and to understand the process through listening to those who are in charge of examining and approving the permit and will be regulating the farm. Following the open house will be the opportunity to make comments for the public record.
Within the notice there is something very important to take note of: ODA is seeking “to obtain additional information limited to the criteria applicable to the permit”. They are not looking for opinions, just facts that they may have failed to consider before approving the permit. A “draft” permit, which this is, means that the application has met all of the standards required by Ohio and federal law and the last step is to see if the public might have information that they have overlooked in their review process. And those facts (criteria) must pertain to those items that are controlled by Ohio law and pertain to this farm only.
Permitting livestock farms is not a popularity contest – it is based solely on science and facts and Ohio law. You may not like many things associated with large-scale livestock production, and your opinions are certainly your right to have. But unless you have “additional information limited to the criteria applicable to the permit” (i.e., what is regulated under Ohio law) your information at the meeting will be politely accepted by ODA and carefully considered but will have no impact on the issuance of the permit.
I’ve always compared the permit process to obtaining an Ohio driver’s license. When I go to get my license or have it renewed, I am subject to a test administered by the state and must pass that to get my license. My neighbors are not consulted as to whether I deserve a license or not. But with a state license, I am subject to every state law that governs my driving abilities and there are police who make sure I obey those laws. When I don’t, or have an accident, there are consequences including fines and losing my license. It is the same with an ODA farm permit, only more stringent in that the permitted farms must keep records that are reviewed and verified by ODA inspectors at least twice per year to stay in compliance. The background of the individual applicants is also thoroughly vetted to ensure past compliance with environmental laws in order to be issued a permit.
I hope if the public understands the public meeting process and its intent and function, it will help eliminate further frustration about feeling you are not being heard. By the way, written comments are considered just as valid as oral comments from ODA’s perspective. Sometimes it is easier to write your thoughts down than to stand up and say them.