Cattlemen Comment on CAFO Rules

August 2, 2001

The Environmental Protection Agency's concentrated animal feeding operations (CAFO) initiative is impractical for the diverse United States cattle industry, the National Cattlemen's Beef Association (NCBA) says. "The cattle industry supports efforts to protect the environment," said Faith Burns, NCBA associate director, environmental affairs. "However, environmental initiatives work best when they are scientifically based, site specific and economically viable. The EPA CAFO proposal is broad and confusing."

Since the early 1970s, the Clean Water Act (CWA) has defined CAFOs as point sources. The newly proposed CAFO regulations would broaden the number of operations that are considered point sources. The proposal sets out various "options" for defining a CAFO. A "two-tiered option" would define a CAFO as any farm or ranch with 500 beef cattle. A "three-tiered option" would define a CAFO as any farm or ranch with 300 beef cattle that failed to meet certain risk factors.

In comments delivered to the EPA, NCBA made several recommendations to improve the complex proposed regulation, including allowing states the flexibility to develop programs that achieve goals and recognizing that manure management procedures should take into account regional environmental differences.

"EPA has the authority to delegate certain Clean Water Act functions to individual states," Burns said. "Cattlemen believe that programs in many of these states are achieving positive environmental results. These state programs take into account regional and local variations that require different types of environmental protections." The EPA proposals would require states to alter their current programs.