Wheat farmers in Kansas, dairy farmers in Wisconsin, and corn farmers in Iowa, along with millions of employers and employees who rely on a strong agricultural industry for prosperity, all have reason to be deeply concerned by the EPA’s implementation of draconian water mandates in Florida. That’s the word from national agriculture leaders. In a letter sent to EPA administrator Lisa Jackson, 36 leading national agriculture groups expressed concern about the new EPA mandates for numeric nutrient criteria (NNC) in Florida’s waters.
If enacted, these mandates would establish a template of how NNC could be structured nationwide and would result in economic harm for the regulated community, for the economy as a whole and for the public sector that must develop and administer the NNC.
In the letter, the organizations urge the EPA to:
- Delay further NNC policymaking until it has engaged with all relevant stakeholders in a thorough and transparent review of the strategic direction of NNC policies.
- Revisit and update the 1998 “National Strategy for the Development of Regional Nutrient Criteria” (National Strategy).
- Not finish the NNC for Florida’s lakes and streams this fall and instead work on those in concert with the NNC that EPA is planning to finalize in August 2012 for all other Florida waters – and in the process answer the numerous and significant scientific, economic and policy questions about these NNC in an open and transparent manner.
- Reject policymaking by settlement agreement, with its inherent opaqueness and the distrust that creates.
The first set of EPA mandates is scheduled to take affect in Florida on Oct. 15. If that occurs, the new mandates will have an immediate, chilling impact on Florida’s economy, because the federal mandates will be the “law of the land” in Florida. Every water discharge permit that comes up for renewal will be subject to the new federal mandates, and EPA regulators will consider water bodies that do not meet the new federal mandates to be impaired.
“The Florida Department of Agriculture estimates that the total initial cost for agricultural producers to comply with the NNC for lakes, rivers, and streams to be between $855 million to $3.069 billion, and the subsequent annual compliance costs to be $902 Million to $1.605 billion. As a result, they estimate that the size of the Florida economy will be reduced by $1.148 billion a year and that 14,545 full and part-time jobs would be lost,” cited the agricultural leaders in the letter.
In addition to concerns about the heavy economic burden the EPA water mandates will place on Florida’s agricultural community, there are also significant questions regarding the scientific validity of the new mandates.
The letter goes on to say, “In the case of Florida, there are significant questions about the statistical, modeling and biological science used by EPA. By EPA’s own admission in the proposed rulemaking, there is no scientifically established correlation between these proposed NNC and the desired biological conditions in these waters. In general, we believe there is a serious lack of rigorous, generally accepted science that justifies the particular methods EPA adopted to generate these NNC in Florida.”
Source: Ron Sachs Communications