NCC Comment on Proposed Exemption From Reporting Requirements for Poultry Farmers

The rule proposed by EPA in 2007 would give poultry farmers a narrowly tailored exemption from rules that would otherwise require them to make emergency reports of “emissions” that are actually nothing more than the normal consequences of livestock and poultry operations. The fact is that chickens and turkeys, like cattle, regularly produce ammonia in small concentrations as their wastes biologically degrade.

Subjecting these types of emissions to CERCLA/EPCRA emergency reporting requirements would needlessly burden the 40,000 family farmers who would need to make emission calculations and consider whether to file reports. Further burden would be placed on local fire and rescue services, the Coast Guard, and the state agencies that would receive and process such reports – and then do nothing about them. There is no need to send fire trucks and other emergency equipment and personnel to respond to “emissions” that consist of the natural and normal breakdown of animal excretion.

The proposed rule was limited to a very specific segment of the animal agriculture industry, one that has low-level, dispersed ammonia emissions, and which is operated primarily by small scale family farmers. They would be heavily burdened by the imposition of regulatory requirements that are difficult or impossible to fulfill and that serve no purpose of public health or welfare. Indeed, as a report from the University of Georgia demonstrated, ammonia concentrations near the poultry houses studied were extremely low and pose no risk to human health.

EPA was on the right track with its proposed rule, and we hope the final rule will be published very soon.

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Address media inquiries to: Tom Super

Senior Vice President of Communications

[email protected] 202-443-4130