The Minnesota Farm Bureau Federation submitted comments last week on behalf of Farm Bureau members from Minnesota to the U.S. Environmental Protection Agency on the proposed Concentrated Animal Feeding Operation reporting rule.
In the comments, MFBF president Kevin Paap stated that the proposed rule's two primary options are significantly flawed because they exceed the EPA's authority under the Clean Water Act while creating intense security, safety and privacy concerns for farmers.
He noted that there is ample public information already available that EPA can gather for CWA purposes. FB urges EPA to pursue that approach instead.
Paap also stated that MFBF objects to the proposed rule's two primary options for the following four reasons.
First, many of today's livestock and poultry farms are designed and operated so as not to have any discharges. As no-discharge facilities, they merit such a presumption under Section 308 and should not be required to report unless information applicable specifically to them indicates otherwise, he said.
Second, these two options would effectively create a publicly available "national registry" of the approximately 20,000 farms, EPA says, that would be subject to this rule.
This greatly raises the risk that these farms and many farm families will experience malicious acts of violence and intimidation by extremists, Paap said. Two such unlawful and violent incidents recently took place in California.
Third, such a national registry also creates unacceptable national biosecurity risks inconsistent with federal policy under the 2004 presidential directive "Defense of United States Agriculture and Food" and the 2007 National Infrastructure Protection Plan that treats livestock and poultry facilities as critical infrastructure to be protected from terrorist acts.
Lastly, when people come onto FB members' farms unauthorized (even without malicious intent) and fail to follow their animal health protocols, those visitors increase exponentially the risk of spreading disease.
Paap also stated that EPA's third approach would use information already publicly available. MFBF does not oppose this approach, but would oppose EPA compiling that information into some kind of central registry because it to raises security and privacy concerns.
Source: MN Farm Bureau