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EPA'S Proposed Effluent Guidelines Will Be Costly With Little Benefit to the Environment, AMI Says

Tuesday, June 25, 2002

Washington, DC - The Environmental Protection Agency's (EPA) proposed Effluent Limitation Guidelines will place an enormous economic and regulatory burden on the meat and poultry industry, with little benefit to the environment or human health, the American Meat Institute (AMI) said in comments filed with EPA today. AMI asked EPA to withdraw the proposed rule, published February 25, 2002.
In hundreds of pages of comments submitted individually and as part of the Meat and Poultry Products Industry Coalition, AMI provided extensive details about the effectiveness and comprehensiveness of existing federal and state environmental regulations, which make the proposed rule unnecessary. AMI said that the National Pollutant Discharge Elimination System (NPDES) permit system administered by EPA and the states, as well as federal effluent guidelines where appropriate, have been one of the nation’s top environmental success stories in recent decades and continue to effectively protect and improve the nation’s water quality.
The Institute also commented that EPA is well into the process of developing a program to address water quality issues nationwide through the Total Maximum Daily Load (TMDL) rule. Furthermore, local authorities, with a focus on water quality concerns not readily addressed on national scale, provide yet another layer of regulatory oversight for the meat and poultry industry. Finally, the industry is actively involved in voluntary efforts to promote innovative technologies and process modifications to control discharges.
The EPA proposal is fundamentally flawed and riddled with serious sampling, analytical and engineering errors, AMI said. These errors have not only produced faulty and unreliable data, but have generated untenable and unjustified conclusions by the Office of Water. According to AMI, under the Clean Water Act, EPA must set new discharge limits based on the best available technology (BAT) that is economically achievable. Yet EPA modeled pollutant removals for the industry and derived new discharge limits using plants whose technologies exceeded EPA’s proposed technology requirement for meat and poultry facilities.
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AMI also criticized EPA for failing to give credit in its pollutant removal “model” for wastewater treatment currently in place at existing red meat and poultry facilities. This flaw, together with sampling errors, caused EPA to vastly overestimate the level of pollutants currently being discharged from MPP facilities.
"In many cases, EPA inappropriately assumed that facilities were discharging raw, untreated wastewater," said AMI Senior Vice President of Regulatory Affairs and General Counsel Mark Dopp. "Given that facilities must comply either with federal standards, NPDES permits or local discharge limits, EPA's conclusions are mystifying...In essence, EPA has severely inflated the benefits from this rule by assuming pollutant removals without proper foundation."
Finally, EPA underestimated the rule's cost by a factor of eleven, saying it will cost $80 million when it actually will cost nearly a billion dollars 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.
“Not only has the agency failed to include all of the additional treatment processes, units and equipment at these facilities in its compliance cost estimates, it also failed to include the costs associated with additional treatment chemicals necessary to even approach the new limits, and in turn the cost of generating additional sludge from this process. In fact, EPA estimated that sludge associated with more intensive wastewater treatment would actually be reduced, a conclusion that defies engineering logic,” Dopp said. “EPA's cost estimates are about as accurate as a description of Bill Gates' wealth as 'above average.’”
A complete copy of AMI's individual comments and those of the Meat and Poultry Industry Coalition are available on http://www.meatinstitute.org.
AMI represents the interests of packers and processors of beef, pork, lamb, veal and turkey products and their suppliers throughout North America. Together, AMI's members produce 95 percent of the beef, pork, lamb and veal products and 70 percent of the turkey products in the U.S. Headquartered in Washington, DC, the Institute provides legislative, regulatory, public relations, technical, scientific and educational services to the industry. Its affiliate, the AMI Foundation, is a separate 501(c)3 organization that conducts research, education and information projects for the industry.

For more information contact:
Janet Riley
Vice President, Public Affairs
Josee Daoust
Manager, Public Affairs

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