United Poultry Concerns January 14, 2002
Comments to EPA on Dry Lots for Ducks Submitted By UPC
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.)


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
FAX: 757-678-5070

(Comments to EPA on Dry Lots for Ducks Submitted By UPC)

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