Analysis Flawed and Not Transparent

Washington, DC – Today, a coalition of meat and poultry industry groups said the Environmental Protection Agency’s (EPA or the Agency) proposed wastewater guidelines will cost hundreds of millions more than Agency estimates, kill at a minimum tens of thousands more jobs and close many processing facilities, resulting in hardship for livestock and poultry producers.

“We believe that the proposed Effluent Limitations Guidelines (ELG) would thwart the Biden administration’s efforts and limit, or reverse, these outcomes for small processors, rural job creation, producer livelihoods and a resilient food supply chain,” the coalition said.

The Meat and Poultry Products Industry Coalition (MPP or the Coalition) made the remarks in comments submitted about the EPA’s proposed rule revising the ELGs for wastewater discharged by meat and poultry processing and rendering facilities Last amended in 2004, the meat and poultry ELGs currently apply to about 180 of the estimated 5,300 meat and poultry facilities nationwide. EPA estimates between 845 and 1,620 facilities would be subject to and incur costs should the proposed ELGs become final. The full comments are here.

The Coalition made the following key arguments in the comments:

• The Agency has grossly underestimated for many MPP facilities: 
  Industry analysis of the projected number of MPP facility closures for Option 1 without chlorides would jump from 16 sites that EPA estimates in the proposed rule to 74 sites.

  The projected number of near-term job losses associated with these facility closures would increase from nearly 17,000 that EPA estimates in the proposal to over thirty thousand to nearly 80,000 direct job losses from plant closures.

  The projected closures and job losses for the more stringent regulatory options would increase similarly. For Option 2 with chlorides, for example, the projected number of facility closures would increase to 139, 15 % of facilities that exceed the Option 2 threshold, or 340 closures for Option 3.

• The proposed rule harms the relationship between MPPs and publicly-owned treatment works (POTWs): 
  Indirect discharging MPP facilities often make significant financial investments in maintaining and upgrading the POTW or shouldering major surcharges for the POTW’s continued operation and maintenance, which reduce public treatment costs for residential ratepayers and improve the quality of local and downstream waters.
• EPA’s analyses of pollutant loadings are inconsistent with its cost analyses: 
  EPA is taking credit for pollutant removals that are already occurring.
• EPA has not timely provided complete information on its analysis: 
  EPA has not provided complete information for public and industry stakeholder verification in a timely way.

The Meat and Poultry Products Industry Coalition is made up of the American Farm Bureau Federation, the Meat Institute, National Chicken Council, National Pork Producers Council, National Turkey Federation, North American Renderers Association and the U.S. Poultry & Egg Association.

About the American Farm Bureau Federation

The American Farm Bureau Federation is the national advocate for farmers, ranchers and rural communities. Just as the work of feeding our nation begins on the farm, we believe that’s where the policy that shapes agriculture should begin as well. Every year, Farm Bureau members in more than 2,800 counties meet to discuss and vote on policies affecting their farms, ranches and communities. Those policies then set the agenda for their state Farm Bureaus and ultimately AFBF.

About the Meat Institute

The Meat Institute is the United States’ oldest and largest trade association representing packers and processors of beef, pork, lamb, veal, turkey, and processed meat products. Meat Institute members include over 350 meat packing and processing companies, the majority of which have fewer than 100 employees, and account for over 95 percent of the United States’ output of meat and 70 percent of turkey production.

About the National Chicken Council

The National Chicken Council (NCC) represents integrated chicken producer-processors, the companies that produce and process chickens. Member companies of NCC account for more than 95 percent of the chicken sold in the United States.

About the National Pork Producers Council

NPPC is the global voice for the U.S. pork industry, protecting the livelihoods of America’s pork producers who abide by ethical principles in caring for their animals; in protecting the environment and public health; and in providing safe, wholesome, nutritious pork products to consumers worldwide.

About the National Turkey Federation

The National Turkey Federation (NTF) is the national advocate for America’s turkey farmers and producers, raising awareness for its members’ products while strengthening their ability to profitably and safely deliver wholesome, high-quality and nutritious food to consumers worldwide. NTF is the sole national trade association exclusively representing the turkey industry; its members account for more than 95 percent of all U.S. turkey production.

About the North American Renderers Association

The North American Renderers Association (NARA) represents the interests of the North American rendering industry to regulatory and other governmental agencies, promotes the greater use of animal byproducts, and fosters the opening and expansion of trade between foreign buyers and North American exporters. In addition to its U.S.-based headquarters, the association maintains offices in Mexico and Hong Kong, and has market consultants in strategic locations around the world.

About the U.S. Poultry & Egg Association

U.S. Poultry & Egg Association (USPOULTRY) is the all-feather organization representing the complete spectrum of today’s poultry industry, whose mission is to progressively serve member companies through research, education, communication and technical assistance. Founded in 1947, USPOULTRY is based in Tucker, Ga.