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Guest Column: Fight Industrial Farms now!

For related articles and more information, please visit OCA's Environment and Climate Resource Center page and our Factory Farming & Food Safety page.

Please circulate this far and wide. It's an action alert for comments USEPA is seeking on the impacts of their concentrated animal feeding operation (CAFO) Clean Water Act regulations on small businesses, etc. There are rumors that the comment period will be extended for another month or two, but as of today no extension notice has been issued. As such, we're proceeding as if the deadline is Dec. 31 and are encouraging people to submit comments by then. Below are some talking points prepared by our friends at the Environmental Integrity Project and the Humane Society that we're trying to get out there to generate public interest before the deadline. Please consider submitting comments and circulate to your CAFO contacts! Thank you!!

ACTION ALERT

The Environmental Protection Agency is currently accepting public comments on the economic impact of its clean water regulations for factory farms on small businesses. Please take a minute to send a short message to EPA telling them that strong oversight of concentrated animal feeding operation ("CAFO") or factory farm pollution is good for family farmers and other small businesses that rely on healthy rural communities and clean water.

You can send your comment to EPA by e-mail at rfa-sbrefa@epa.gov by midnight on Dec. 31st. In your comments, let EPA know that you are commenting on the "CAFO 610 Review, Docket ID No. EPA-HQ-OW-2012-0813."

As required by the "Regulatory Flexibility Act," EPA must review the economic impact of its rules on small businesses within 10 years of finalizing them. EPA is currently reviewing regulations it established in 2003, which strengthened requirements for factory farm water pollution permits. The Regulatory Flexibility Act's definition of "small businesses" includes many large factory farms.

EPA considers 5 factors when evaluating the economic impact of its rules:

1) the continued need for the rule

2) the nature of complaints or comments received concerning the rule from the public

3) the complexity of the rule

4) the extent to which the rule overlaps, duplicates or conflicts with other Federal rules, and, to the extent feasible, with State and local governmental rules

5) the length of time since the rule has been evaluated or the degree to which technology, economic conditions, or other factors have changed in the area affected by the rule.


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