NPPC Comments on EPA's CAFOs, Welcomes Improvements

January 16, 2002

The National Pork Producers Council (NPPC), commenting on the Environmental Protection Agency's (EPA) proposed changes to regulations governing concentrated animal feeding operations, said the agency "has embraced much of our broad vision for how the Clean Water Act should work for pork producers." The concentrated animal feeding operations (CAFOs) will cover all species of livestock and poultry and are scheduled to become final in December 2002.

NPPC's comments highlighted many improvements proposed in the proposal that will help pork operations make major and continual improvements in their environmental performance. NPPC President Barb Determan made special note of the emphasis EPA placed on comprehensive nutrient management plans and the use of environmental management systems (EMSs). Determan said, "In particular, we are pleased to see continued support for the wide-scale adoption and implementation of (nutrient management plans) by all producers, the appropriate use of environmental management systems and efforts to ensure the responsible application of manure under all circumstances." The pork industry "has earned a reputation for developing proactive environmental improvement programs that achieve results without placing unnecessary financial or technical burdens on producers," Determan continued. "We believe that CNMPs and EMSs meet this test, and we support them. Our concern is that EPA's final rule be based on sound science and is affordable, achievable and sustainable for pork producers of all sizes and geographical locations."

NPPC continues to insist that cost effective and workable alternatives be found for mandates in the proposed rule that are either technically or financially impossible to achieve. Determan pointed to the zero-discharge standard as one example. "EPA's 'zero-discharge' standard is prohibitively expensive and impractical and will likely lead to further concentration by forcing family hog farms out of business," Determan said. "We think this is bad public policy because it closes the door on other practical, cost effective, and environmentally sound technologies. The proposed zero-discharge standard is impractical because there is no livestock waste management system that can have zero-discharge under all conceivable rainfall conditions. Farmers will be forced by this policy to risk permit violations due to the vagaries of weather, even when they are properly managing systems designed to provide great environmental protection. It simply makes no sense."

Independent economic analysis done by the Food and Agricultural Policy Research Institute (FAPRI) showed that the zero-discharge standard in the proposed regulations would dramatically increase the probability that significant numbers of hog operations of all sizes in the Midwest and mid-Atlantic regions would be driven out of business.

"The Environmental Protection Agency estimates that it will cost $281,328 over 10 years for a midwestern pork operation with 1,460 hogs to comply with its proposed CAFO rule," Determan said. "For a 3,444 head farrow to finish swine operation in the Midwest, capital costs alone would total $332,000."