WASHINGTON — An alliance of meat and poultry industry associations said the Environmental Protection Agency (EPA) has underestimated the cost of its proposed wastewater guidelines.

The Meat and Poultry Products Industry Coalition (MPP), 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 US Poultry & Egg Association, believes the guidelines will cost hundreds of millions more than the estimate, eliminate tens of thousands of 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,” MPP said.

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

In the comments, MPP argued that the agency has grossly underestimated closures for many MPP facilities citing:   

• Industry analysis of the projected number of MPP facility closures for Option 1 without chlorides would rise from the 16 sites estimated in the proposed rule to 74 sites. 
• The projected number of near-term job losses associated with these facility closures would jump from nearly 17,000 estimated in the proposed rule 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.
• EPA’s analyses of pollutant loadings are inconsistent with its cost analyses and the agency is taking credit for pollutant removals that are already occurring.
• EPA has not provided complete information on its analysis for public and industry stakeholder verification in a timely way.      

Also, MPP said the proposed rule injures relationships between meat and poultry production facilities and publicly owned treatment works (POTW) by straining production businesses that often make significant financial investments to maintain and upgrade POTWs and often take on major surcharges for the POTW’s continued operation and maintenance. Investments that reduce public treatment costs for residential ratepayers and improve the quality of local and downstream waters.

The American Association of Meat Processors (AAMP) supported MPP with a statement posted on its Facebook page:

“AAMP remains committed to environmental sustainability and encourages our members to operate in a way that is best for the environment. However, the strictest option could result in massive contraction in the meat industry. Small, rural communities could lose significant employers and a primary source of groceries. Food prices could dramatically increase, and the local meat movement could disappear. The EPA is attempting to regulate an industry that it doesn’t understand and hasn’t properly researched, and this one-size-fits-all approach to regulatory compliance could have devastating consequences. While we remain hopeful that the EPA will delay implementation in order to collaborate with the meat industry, we are asking for the Agency to adopt Option 1, as it is the one that harms the meat and poultry industry the least.”