Comments re: Large Poultry CAFO Work Group Meeting August 31, 2022 due at 2pm


Did you get our email this week about The Large Poultry CAFO working group asking for feedback from the community? We want to work closely with family scale farmers and rural residents to ensure that their property values, rural businesses, waterways, personal health and quality of life are protected from the air and water pollution that result from concentrating thousands of animals and their waste, in one location. We invite you to take this opportunity to make your voice heard! The Large Poultry CAFO workgroup is holding a meeting TODAY Wednesday, August 31st and wants to hear from YOU. Complete the form below to register to speak via video or phone at the Large Poultry CAFO workgroup meeting TODAY (8/31) by 2pm. 

Register for public comment via phone or video –

You can also submit written comments to



Dear Large Poultry CAFO Work Group Members:

Thank you for giving so much time and attention to this critical issue. Your work is vital in preserving the unique agricultural legacy of Oregon and ensuring we are a state where community minded family farms can thrive. Friends of Family Farmers (FoFF) has decided not to give comments in person to be sure there is enough time for all the impacted community members and concerned farmers who are distressed about this issue to have time to speak to the work group. We appreciate the opportunity to provide written comments and we would like to pass on the feedback we’ve received from our community on this issue.

FoFF was founded in 2005 by a group similar to the one championing this issue in Scio: a group of local farmers, concerned rural residents, and food systems advocates who see the interests of industrial agriculture being held over the will of the plurality of farmers and communities. After 17 years, our community has not changed their stance on Oregon’s prioritization of industrial farming over those using regenerative and organic practices. We have been hearing from our community on a regular basis, through our biennial survey, our 12 focus groups this year and the 10-20 emails/month we receive regarding the facility in Scio (and Foster Farms facilities planned for other parts of Oregon). The 1,600 active farmers in our network are greatly concerned about the impact that these facilities (as currently planned, under current permit conditions) will impact their ability to farm in the future.

First and foremost, our farmers are concerned about resource use and pollution from these facilities. Although we understand that there are the best intentions to keep the waste from this facility strictly contained, this has not proven completely possible in other industrial agricultural scenarios. When accidents happen and systems fail, the community bears the brunt of the problem. This concern centers around possible pollution of the Santiam River which many farmers use for irrigation and the possible groundwater contamination that will impact agricultural and residential wells alike in the area. There is also concern that the currently unregulated air pollution, in the form of particulate matter and ammonia will be a health burden to the other farmers and their crews in the area working in their fields, and will dampen the agritourism activities (farm stands and u-pick operations) that are springing up in the area, providing fellow farmers with a diversified income stream. We support the right to farm, but this facility (and those like it elsewhere) is much larger than other farms in the vicinity and will drastically change the character of this already agricultural area.

This is also a concern when it comes to the amount of water that is used by these facilities under the stock water exemption. Farmers we work with manage their limited water carefully and have continually faced early irrigation shut offs before the end of the season. It is therefore unreasonable that a large CAFO with hundreds of thousands of animals can use as much water for those animals as they need without a water right. We are in a multi-year drought and water is becoming more scarce, even in the Willamette Valley. Large CAFO operators with many hundreds of thousands of birds (or for that matter tens of thousands of cows or swine) should not be exempt from water statute. Facilities of this size should have to obtain a water right for the amount of water that they use in order to make sure it is congruent with the carrying capacity of the ecosystem and does not threaten the permitted water use of other farmers in the area. We also support a previously proposed 5,000 gallon per day limit on the stock water exemption as this is more than enough for the average existing farm in Oregon (according to animal water needs calculations from OSU) and would represent a lower burden on the water system. It is our collective duty to conserve water as Oregon becomes more arid. 

There is also concern that facilities like these are misusing high value soils and making it harder for other farmers to access the premium farmland we depend on for land based agricultural production. Facilities like the Large CAFO systems under consideration in this work group do not need high value soils to operate. In fact, by establishing CAFOs like these on designated high value soils, those soils are being degraded through compaction and construction and will take decades to return to their former structure and fertility. These parcels should be reserved for farmers who intend to use the soils to grow crops or pasture forage. With the pressure of development encroaching and farmland prices rising, there is enough competition for viable farmland in our state without allowing confinement based operations to use land that is designated as priority farmland. Confinement facilities like the ones proposed would be just as successful in an industrial area as they would on high value soils, while the same cannot be said for other farming operations. High value soils and EFU zoned land are vital and limited resources. Oregon would be better served by taking a realistic look at the nature of these facilities and not permitting them on land incongruent with their use. 

No farmer that we work with begrudges a fellow producer for making a living. But all farmers have the right to stand up and fight for a system where their farm is allowed to thrive. Oregon needs to prioritize the long term viability of our farmland when considering these permits. They should not negatively impact other farms in their area, their resource use should not be allowed to endanger other farms’ viability, and they should not be permitted on high value soils. The impact to the system as a whole needs to be considered when siting and permitting these facilities. No farm is truly a closed loop, and the ecosystems around them must be able to withstand their impact or we endanger Oregon’s identity as an agricultural state in the future.  Thank you for your thought and consideration in this matter.


Alice Morrison

Organizational Director

Friends of Family Farmers