In comments submitted today, the U.S. poultry industry voiced several concerns with the Environmental Protection Agency’s (EPA) proposed National Pollutant Discharge Elimination System (NPDES) Concentrated Animal Feeding Operation (CAFO) Reporting Rule. The rule, proposed on October 21, 2011, would require owners and operators of CAFOs to submit certain information to EPA. Specifically, EPA is requesting detailed location information and farm demographics for virtually every family farm engaged in the production of commercial poultry and egg products in the United States.
EPA claims the Clean Water Act provides them with the authority to require CAFOs to submit the information sought, and this information will help them determine if a violation of the Clean Water Act has occurred. In reality, none of the information sought would provide any understanding as to whether the facility is discharging or violating the Clean Water Act. Mike Brown, president of the National Chicken Council, remarked, “We’re convinced the authority EPA claims under Section 308 of the Clean Water Act to collect information from non-discharging CAFOs oversteps what Congress intended when the law was written.”
In their comments, the poultry industry pointed out the very serious threat of making every CAFO location publicly available. “Making this kind of information readily available to the public puts the safety of the food chain at an even higher risk for acts of bioterrorism, not to mention the concern for the safety and privacy of the thousands of family farmers who often live at the same location,” said John Starkey, president of the U.S. Poultry & Egg Association.
In the rule, EPA also requested comment on the development of alternative mechanisms for promoting environmental stewardship and compliance. The industry pointed out its long history of environmental stewardship and indicated its commitment for continued improvement. Addressing this issue, Joel Brandenberger, president of the National Turkey Federation, commented, “We are pleased EPA recognizes the benefit of developing programs that can assist poultry and egg producers with further tools to extend their stewardship efforts. We urge EPA to follow this course rather than initiate an information collection exercise that will do nothing to enhance water quality.”
The comments can be viewed on the U.S. Poultry & Egg Association website at www.uspoultry.org/positionpapers.
