Comments Submitted to the Environmental Protection Agency

At AGPROfessionals, our mission is to advocate for our clients. As a part of this, we follow the regulatory landscape and step in to participate when needed. Most recently, we stepped in on the EPA Region 10's request to provide comments regarding their modified National Pollutant Discharge Elimination System (NPDES) General Permit for Concentrated Animal Feeding Operations located in the State of Idaho. For this comment period the EPA is accepting comments exclusively on changes made to the General Permit since the previous comment period.

All too often, agencies pass regulations without thought to the bigger picture and their ripple effect. Below is a high-level overview of the comments/recommendations made by our AGPROfessionals team:

• Updating language regarding seepage rates from impoundments to align with industry standards and practical considerations.
• Evaluation methods should not look to other states for guidelines, instead they should follow NRCS standards tailored to Idaho, utilizing existing testing parameters that are widely accepted and used across the United States.
• Discard the proposed requirement for subsurface discharge monitoring plan (SDMP) since it adds unnecessary complexity and cost. We propose that the requirements for a SDMP be based on evidence of risk rather than a one-size fits all blanket requirement.
• Liner specifications should not look to other states for guidelines. Requirements for liner specifications should adhere to industry-accepted NRCS standards.

For more details and specifics, see below or click HERE to view the complete comment submitted on July 2nd, 2024.