A coalition of poultry, meat processing, and rendering associations has filed hundreds of pages of public comments on the Environmental Protection Agency’s (EPA’s) proposed Effluent Limitation Guidelines (ELGs). The comments, submitted by the June 25, 2002, deadline, detailed many errors in EPA’s proposal and called for the rule to be withdrawn.
The Meat and Poultry Products Industry Coalition is comprised of the National Renderers Association, American Meat Institute, National Chicken Council, National Meat Association, National Turkey Federation, and U.S. Poultry and Egg Association. The coalition assembled a team of technical, legal, and economic consultants to review the proposed rule (see April 2002 Render) and many thousands of pages of supporting documents EPA used to justify its proposal and to draft the coalition’s comments.
The comments made it clear that the proposal will place an enormous economic and regulatory burden on the meat and poultry industry, with little benefit to the environment or human health. They also detailed the effectiveness and comprehensiveness of existing federal and state environmental regulations and cited several layers of existing regulatory oversight for the meat and poultry industry, including the National Pollutant Discharge Elimination System permit system, the developing Total Maximum Daily Load rule, and local regulation that fills in gaps in national oversight. Additionally, the industry is involved in voluntary efforts to promote technologies and process modifications to control discharge.
The comments also pointed out that EPA underestimated the rule’s cost by a factor of eleven, saying it will cost $80 million when it actually will cost nearly $1 billion to implement. The agency missed the mark because it failed to include the full range of wastewater treatment technologies necessary to achieve the proposed limits and underestimated the costs that facilities would have to incur in order to meet the limits consistently under all climatic and operational conditions.
To view a copy of the coalition’s submitted comments, click here (PDF file).
August 2002 Render