March 15, 2001
The Honorable Christine Todd Whitman
Administrator
Environmental Protection Agency
Ariel Rios Federal Building
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20004
Dear Administrator Whitman:
The National Association of State Departments of Agriculture (NASDA), representing the commissioners, secretaries, and directors of agriculture in the fifty states and four territories, requests that the Environmental Protection Agency (EPA) extend the comment period on the agency's proposed regulations for Concentrated Animal Feeding Operations (CAFOs). We request an additional 120 days beyond the current final comment date of May 14, 2001.
EPA published the "Proposed Revisions to the NPDES Permit Regulation and Effluent Guidelines and Standards for CAFO's" on January 12, 2001. This exceedingly lengthy and complex rule would extend water quality regulation to tens of thousands of farm operations. We have serious questions about how the numerous requirements outlined in this proposal would impact animal agriculture, including the additional economic costs that will be imposed on states and producers. In addition, we have ongoing concerns about the quality and completeness of the data EPA has used to show water quality impacts from animal agriculture and the need for this proposed rule.
We ask you to thoroughly examine the proposed rule and allow the agricultural community sufficient time to assess and respond to this major regulatory proposal.
Sincerely,
<signed>
Leon Graves
President, NASDA
Commissioner, Vermont Department of Agriculture
Frank DuBois
Chairman, Natural Resources & Environment Committee
Secretary, New Mexico Department of Agriculture