July 30, 2001

EPA's National Pollutant Discharge Elimination System Permit Regulations and Effluent Limitation Guidelines and Standards for Concentrated Animal Feeding Operations

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National Pollutant Discharge Elimination System Permit Regulation and Effluent Limitations Guidelines and Standards for Concentrated Animal Feeding Operations

Stated Purpose:

EPA is proposing revisions to these regulations to address changes that have occurred in the animal industry sectors over the last 25 years, to clarify and improve implementation of CAFO permit requirements, and to improve the environmental protection achieved under these rules.

Summary of RSP Comment:

Most point sources of water pollution are highly regulated. Further tightening of point source discharge regulations would add substantial costs while providing only small marginal improvements in water quality. Therefore, it makes sense for EPA to address runoff from nonpoint sources such as CAFOs.

However, EPA's proposed approach to address runoff pollution from CAFOs is unlikely to yield cost-effective improvements in water quality. EPA's own analysis indicates the regulations, if promulgated, would impose net social costs of between $664.2 million-$803.9 million annually on the U.S. public, and even these figures may understate net social costs.

EPA's scientific data do not show confined animal feeding operations are major contributors to water pollution nationwide. The water quality data EPA uses to suggest that CAFOs are a significant nationwide problem are neither comprehensive nor accurate enough to support the conclusions EPA draws.

While EPA does report incidents that reveal CAFO-caused water quality problems in certain watersheds, these do not support uniform nationwide regulation. Rather, they reveal that EPA could achieve greater environmental and public health benefits at significantly lower costs if it facilitated community-based approaches that rely on site-specific analysis and market incentives to improve water quality in impaired watersheds.