Final Report of the Small Business Advocacy Review Panel on EPA's Planned Proposed Meat and Poultry
Products Effluent Limitations Guidelines Rulemaking
APPENDICES
Appendix Al: Materials Shared with Small Entity Representatives for the
Pre-Panel Outreach Meeting held on May 2, 2023
Appendix A2: Materials Shared with Small Entity Representatives for the
Panel Outreach Meeting held on July 17, 2023
Appendix Bl: Written Comments Submitted by Small Entity
Representatives following the May 2, 2023 Pre-Panel Outreach Meeting
Appendix B2: Written Comments Submitted by Small Entity
Representatives following the July 17, 2023 Panel Outreach Meeting
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Final Report of the Small Business Advocacy Review Panel on EPA's Planned Proposed Meat and
Poultry Products Effluent Limitations Guidelines Rulemaking
Appendix Al: Materials Shared with Small Entity Representatives for
the Pre-Panel Outreach Meeting held on May 2, 2023
Table of Contents
Pre-Panel Meeting Agenda Al-2
SBAR Panel Process Presentation Al-4
Pre-Panel Rulemaking Presentation Al-14
Pre-Panel Questions for SERs Al-42
A1-1
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Pre-Panel Meeting Agenda
A1-2
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EPA's SBAR Pre-Panel Outreach Meeting with Small Entity Representatives on
Proposed Amendments to the Meat and Poultry Products Effluent Limitations
Guidelines Rulemaking
May 2, 2023, l:00pm-3:30pm, Eastern time zone
Agenda
1:00 Welcome and Opening Remarks
Bill Nickerson (EPA Small Business Advocacy Chair (SBAC) / Office of Policy)
Rob Wood (Director, Engineering and Analysis Division, EPA Office of Water)
David Rostker (Small Business Administration, Office of Advocacy)
Steph Tatham (Office of Management and Budget, Office of Information and Regulatory
Affairs)
1:15 SER Introductions
1:25 Presentation on Panel process (Bill Nickerson, EPA SBAC)
1:35 Presentation on Proposed Amendments to Meat and Poultry Products Effluent
Limitations Guidelines Rulemaking (Office of Water)
2:05 Discussion Proposed Amendments to the Meat and Poultry Products Effluent Limitations
Guidelines Rulemaking
2:40 Break
2:50 Discussion (continued)
3:15 Closing session
Closing remarks from EPA, SBA, and OMB
Wrap up and next steps (what to expect next)
3:30 Adjourn
A1-3
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SBAR Panel Process Presentation
A1-4
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An Overview of the Small Business Advocacy
Review (SBAR) Panel Process
May 2023
Bill Nickerson, EPA's Small Business Advocacy Chair
k Office of Regulatory Policy and Management
Office of Policy
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Why does EPA convene an SBAR Panel?
The Regulatory Flexibility Act (RFA) as amended
by the Small Business Regulatory Enforcement
Fairness Act (SBREFA), requires agencies to:
"assure that small entities have been given an opportunity to
participate in the rulemaking process" for any rule "which will
have a significant economic impact on a substantial
number of small entities/'
A1-6
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What is an SBAR Panel?
An EPA Small Business Advocacy Review (SBAR) Panel is
made up of four managers from three federal agencies:
EPA's Small Business Advocacy Chair (EPA's SBAC is from OP)
A manager from the EPA program responsible for writing the rule
O rj A U.S. Small Business
i\ Administration
J
fa.
. c'l
. £i>.
The Small Business Administration's Chief Counsel for Advocacy
The Administrator of the Office of Management and Budget's
(OMB's) Office of Information and Regulatory Affairs (OIRA)
A1-7
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What does an SBAR Panel do?
The RFA tasks the Panel with reviewing the material the Agency
has available concerning the rulemaking, and collecting advice
and recommendations from small entity representatives (SERs)
on issues related to the following four elements:
Who are the small entities to which the proposed rule will apply?
What are the anticipated compliance requirements of the upcoming proposed
rule?
Are there any existing federal rules that may overlap or conflict with the
regulation?
Are there any significant regulatory alternatives that could minimize the impact
on small entities?
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SERs Participation in the Pre-panel and Panel process
SERs are invited to 2 meetings: Pre-panel Outreach meeting and
Panel Outreach meeting
At each meeting, SERs participate in the discussion about how the rule
might impact them and provide suggestions about how to minimize that
impact.
Panel Outreach meeting will focus on further refining SER advice and
recommendations from the Pre-panel Outreach
SERs are invited to supplement the verbal meeting discussions with
written comments (due 2 weeks after each meeting)
A1-9
SER FAQwebpage https://www.epa.gov/reg-flex/frequent-questions-small-entities.
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Where does the Panel process fit within the rulemaking process?
EPA's Pre-
Panel Outreach
Meeting with
SERs
Panel Outreach
Meeting with
SERs
Panel Report
to EPA's
Administrator
Notice of
Proposed
Rulemaking
Public
Comment
Period
Final Rule
It is EPA's goal to host SBAR Panels well before a proposed rule
is written so there is adequate time to incorporate Panel
recommendations into senior management decision-making about
the proposed rule
SER participation in the Pre-panel and Panel Outreach meetings
does not preclude or take the place of participation in the normal
public comment period at the time the rule is proposed
A1-10
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What does the Panel do with the information,
advice, and recommendations from SERs?
The Panel prepares a Panel Report
SER comments are summarized, and written comments are
included as an appendix
SER information, advice, and recommendations are synthesized
into a set of Panel recommendations
Submitted to the EPA Administrator
Considered during senior-management decision-making prior to
the issuance of the proposed rule
Placed in the rule's docket when the proposed rule is published
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Thank You
We realize that small entities make significant
sacrifices to participate in this process
Thank you for taking time and effort away from
your business or organization to assist the Panel in
this important work
A1-12
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Contact Information for SBAC Staff
Lanelle Wiggins, RFA/SBREFA Team Leader
EPA Office of Policy
202-566-2372
wiqqins.lanelle@epa.gov
A1-13
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Pre-Panel Rulemaking Presentation
A1-14
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Meat & Poultry Products Effluent Limitations Guidelines
Rulemaking
SBREFA Pre-Panel Outreach
May 2,2023
United States
Environmental Protection
Agency
A1-15
Office of Water
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Overview
* Background
* Applicable Small Entity Definitions
'Small Entities Potentially Subject to Regulation
* Rulemaking Scope
'Wastewater Treatment Option Development
'Potential Economic Impact on Small Entities
* Questions and Next Steps
United States
Environmental Protectio
Agency
A1-16
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Key Terms Used in this Briefing
Effluent Limitations - Discharge standards, typically expressed as numeric pollutant limits (e.g., 10
mg/L of Nitrogen). May also include "non-numeric" requirements such as management practices or
process changes to reduce pollution (pollution prevention)
Direct Discharger - An industrial facility that discharges industrial process wastewater directly to a
surface water
Publicly Owned Treatment Works (POTW) - A municipal wastewater treatment plant that treats
domestic waste (sewage) along with any industrial wastewaters that are discharged to the collection
system
Indirect Discharger-An industrial facility that introduces pollutants into a POTW from any non-
domestic source regulated under section 307(b), (c) or (d) of the Act.
Pretreatment Standards - Effluent limitations that apply to indirect discharging facilities
Conventional Pollutants-Oil and grease, total suspended solids (TSS), biochemical oxygen demand
(BOD), and fecal coliform
Nutrients - Various forms of nitrogen and phosphorus
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Background: Effluent Limitations Guidelines (ELGs)
ELGs are national standards developed under the Clean Water Act (CWA) that apply to
industrial wastewater discharges
These standards are based on available treatment technology and pollution control
measures
The technology selected must be economically achievable for the industry as a whole
ELG pollutant limits are incorporated into National Pollutant Discharge Elimination System
(NPDES) and pretreatment permits
NPDES permits provide pollutant-specific limits that direct dischargers are required to meet
before sending their wastewater to a surface water
Pretreatment permits provide pollutant-specific limits that indirect dischargers are required
to meet before sending their wastewater to a publicly owned treatment works (POTWs).
There are currently no industry specific pretreatment standards for the MPP industry
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Background: Meat and Poultry Products ELG
The original MPP ELGs rule was issued in 1974
The MPP ELGs were last revised in 2004
In September 2021 (Preliminary Effluent Guidelines Program
Plan 15), EPA announced a rulemaking to revise the existing
discharge standards for the meat and poultry products industry
United States
Environmental Protectio
Agency
A1-19
Office of Water
5
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MPP Questionnaire - Thank you!
All facilities should have received a questionnaire
Census or detailed
Questionnaire status
Received about 2,800 short (census) questionnaires
Received about 830 detailed questionnaires
Reviewing response data and following up for clarification
Response data is used in the engineering, environmental, and economic
analyses
United States
Environmental Protectio
Agency
A1-20
Office of Water
6
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Small Entity Definitions
NAICS
Industry Description
Monthly Average # of Full/Part time
Employees over last 24 months*
311611
Animal (except Poultry) Slaughtering
1,000
311612
Meat Processed from Carcasses
1,000
311613
Rendering and Meat Byproduct
Processing
750
311615
Poultry Processing
1,250
The definitions of small entities for the MPP industry are listed in SBA's regulations at 13 CFR 121.201
(SBA's method of calculation can be found in 13 CFR 121.106). The SBA definitions for small
businesses vary by NAICS category and are regularly updated.
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Small Entities Potentially Subject to Revisions
NAICS
Industry Description
Number of Small Firms
with in-scope facilities
(preliminary analysis)
Number of Large Firms
with in-scope facilities
(preliminary analysis)
311611
Animal (except Poultry)
Slaughtering
469
18
311612
Meat Processed from
Carcasses
592
12
311613
Rendering and Meat
Byproduct Processing
33
3
311615
Poultry Processing
276
23
Other
362
75
Total
1732
131
United States
Environmental Protectio
Agency
A1-22
Office of Water
8
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Consultation with Small Entity Representatives
EPA is interested in information, advice, and recommendations from
the small entity representatives (SERs)
This information will be used to develop a regulatory flexibility analysis,
which becomes part of the record for the potential regulation
For rules that may have a significant economic impact on a substantial
number of small entities, the Regulatory Flexibility Act (RFA) requires
agencies to evaluate regulatory alternatives that may minimize the
burden on small entities expected to be regulated.
Your feedback can help shape selection of regulatory alternatives
United States
Environmental Protectio
Agency
A1-23
Office of Water
9
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Consideration of Regulatory Alternatives
The RFA notes that the regulatory alternatives must be consistent with
the stated objectives of applicable statutes (i.e., the Clean Water Act
(CWA)), and suggests significant alternatives such as:
the establishment of differing compliance or reporting requirements or
timetables that take into account the resources available to small entities
the clarification, consolidation, or simplification of compliance and reporting
requirements under the rule for such small entities;
the use of performance rather than design standards; and
an exemption from coverage of the rule, or any part thereof, for such small
entities.
United States
Environmental Protectio
Agency
A1-24
Office of Water
10
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CWA 301(b) and 304(b) - Statutory Factors for Revising ELGs:
The industry processes, raw materials, products, and byproducts
Locations, age of equipment and plant size
Types and amounts of pollutants discharged
Control technology performance and cost
Financial status of the industry
Impacts of the regulations on other media such as air pollution and
solid waste (sludge disposal)
United States
Environmental Protectio
Agency
A1-25
Office of Water
11
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Current ELG Applies To Direct Dischargers Only
Subparts
Facility Type
Facility Size
# of facilities
Currently Regulated Pollutants
A-D
Meat Slaughterhouses and
Packinghouses
>50M Ib/yr
39
Conventional, Ammonia, Total Nitrogen
<50M Ib/yr
13
Conventional
E
Small Processors of finished meat
products
<6000 lb/day
18
Conventional
F-l
Meat Cutters, sausage & luncheon
meats, ham, and canned meat
processors
>50M Ib/yr
20
Conventional, Ammonia, Total Nitrogen
<50M Ib/yr
14
Conventional, Ammonia
J
Renderers*
>10M Ib/yr
19
Conventional, Ammonia, Total Nitrogen
K
Poultry First Processors**
>100M Ib/yr
79
Conventional, Ammonia, Total Nitrogen
L
Poultry Further Processors***
>7M Ib/yr
1
Conventional, Ammonia, Total Nitrogen
Conventional Pollutants = BOD, Fecal Coliform, Oil & Grease, Total Suspended Solids
*Renderers processing <10M Ib/yr are not subject to ELGs. Estimate there are 4 such direct discharge facilities.
**Existing Poultry First processers processing <100M Ib/yr are not subject to ELGs. Estimate there are 4 direct discharge
facilities.***Existing Poultry Further processers processing <7M Ib/yr are not subject to ELGs. Estimate there are no direct
discharge facilities.
United States
Environmental Protection
Agency
A1-26
Office of Water
12
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Rulemaking Scope: Potential Revisions to the ELG
1. Update nutrient effluent limits for nitrogen (TN) and phosphorus
(TP) - Part of EPA's strategy to reduce nutrient discharges to the
nation's waters
2. Evaluate and consider setting effluent limits for other pollutants
including: conventionals and chlorides
3. Add pretreatment standards for facilities that discharge to POTWs.
Considering: conventionals, nitrogen, phosphorus, chlorides
4. Revise production size thresholds and subcategories
United States
Environmental Protectio
Agency
A1-27
Office of Water
13
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Wastewater Treatment Options Development
* Considerations for Direct Dischargers to update limits to reflect current technology:
Phosphorus removal
More complete denitrification to reduce TN
Chlorides removal
E. coli
Considerations for Indirect Dischargers to protect POTWs from passthrough and
interference:
Screening, oil and grease removal, and equalization
Phosphorus removal
Nitrogen removal including denitrification to address nitrate
Chlorides removal
Conditional limits to allow off-ramp from pretreatment standards for nutrients where
POTW already removing nutrients.
Reduces costs for indirect dischargers and eliminates redundant treatment
United States
Environmental Protectio
Agency
A1-28
Office of Water
14
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Example Treatment Technologies
Pretreatment - Screens, grit removal, DAF
Anaerobic lagoon
Bio = Biological treatment with Nitrification/Denitrification
Activated sludge
Anoxic, aerobic basins (4-5 stage or SBR)
Secondary clarifier
Solids - Belt filter press, gravity thickening, hauling and landfilling
Phosphorus Removal - Alum or ferric chloride chemical addition
Disinfection - Chlorination/dechlorination
Chlorides for specific waste streams - evaporation, haul off-site, deep-well injection
^Facilities may comply with effluent limits using any technologies they choose.*
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Economic Analysis: Data Sources
2022 MPP Detailed and Census questionnaires
Hoovers Dun & Bradstreet - estimates for revenue and employment
Economic census data
USDA-Food Safety and Inspection Service (FSIS) data
Facility employment information
Facility production information
USDA-Economic Research Service (ERS) data
Meat and poultry prices
Sales volumes
Market trends
United States
Environmental Protectio
Agency
A1-30
Office of Water
16
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Economic Analysis
* The Economic Analysis will assess:
Facility-level Impacts
Firm-level Impacts
Market-1 eve I Impacts
Societal Benefits
* Considerations for the analysis:
Potential revisions to the ELGs may expand regulations to cover small facilities and indirect
dischargers, which may impact small entities.
This emphasizes the importance of Regulatory Flexibility Analysis requirements
to consider impacts to small businesses.
United States
Environmental Protectio
Agency
A1-31
Office of Water
17
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Example: Indirect Meat Slaughterhouse *other:capital-sitePreP,
engineering, contingency, etc.
Beef slaughter, 30 million Ibs/yr, discharges to POTW Annual - auxiliary functions,
lab/admin staff, etc
Not currently covered by the MPP ELGs
Treatment in Place (TIP): Pretreatment
Capital Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other*
Add C
$0
$0
$0
$0
$0
$0
Add C, N, P
$0
$52,000
$720,000
$22,000
$1,090,000
$800,000
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other*
Monitoring
Add C
$0
$0
$0
$0
$0
$0
$6,000
Add C, N, P
$0
$10,000
$230,000
$40,000
$79,000
$44,000
$110,000
United States
Environmental Protectio
Agency
A1-32
Office of Water
18
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Example: Indirect Poultry Slaughterhouse
Poultry slaughter, 42 million Ibs/yr, discharges to POTW
Not currently covered by the MPP ELGs
TIP: Pretreatment
Capital Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add C
$0
$0
$0
$0
$0
$0
Add C, N, P
$0
$110,000
$1,370,000
$22,000
$1,100,000
$1,120,000
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Monitoring
Add C
$0
$0
$0
$0
$0
$0
$6,000
Add C, N, P
$0
$10,000
$302,000
$29,000
$192,000
$64,000
$110,000
United States
Environmental Protectio
Agency
A1-33
Office of Water
19
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Example: Indirect Meat Further Processor
Beef deboning/marinating, 25 million Ibs/yr, discharges to POTW
Not currently covered by the MPP ELGs
TIP: Pretreatment
Capital Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add C
$0
$0
$0
$0
$0
$0
Add C, N, P
$0
$26,000
$428,000
$22,000
$1,160,000
$705,000
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Monitoring
Add C
$0
$0
$0
$0
$0
$0
$6,000
Add C, N, P
$0
$6,000
$142,000
$43,000
$70,000
$31,000
$110,000
United States
Environmental Protectio
Agency
A1-34
Office of Water
20
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Example: Indirect Renderer
Beef and chicken rendering, 60 million Ibs/yr, discharges to POTW
Not currently covered by the MPP ELGs
TIP: Pretreatment
Capital Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add C
$0
$0
$0
$0
$0
$0
Add C, N, P
$0
$88,000
$2,000,000
$22,000
$995,000
$1,340,000
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Monitoring
Add C
$0
$0
$0
$0
$0
$0
$6,000
Add C, N, P
$0
$10,000
$403,000
$38,000
$154,000
$54,000
$110,000
United States
Environmental Protectio
Agency
A1-35
Office of Water
21
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Example: Direct Poultry Slaughterhouse
Chicken slaughter and cutting/seasoning, 190 million Ibs/yr, discharges to river
40 CFR 432 subpart K and L
TIP: Pretreatment, BOD removal, nitrification, partial denitrification, disinfection
Capital Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add partial N, P
$0
$0
$0
$94,000
$0
$41,000
Add full N, P
$0
$225,000
$1,290,000
$22,000
$1,380,000
$1,270,000
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Monitoring
Add partial N, P
$0
$0
$0
$31,000
$0
$3,000
$6,000
Add total N, P
$0
$16,000
$457,000
$45,000
$256,000
$92,000
$110,000
United States
Environmental Protectio
Agency
A1-36
Office of Water
22
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Implementation schedule
Existing Direct dischargers limits will be implemented as permits are renewed
according to their 5-year permitting cycle.
Existing Indirect dischargers must comply with pretreatment standards no later than
3 years after the final rule is published.
Required to submit to the Control Authority a report which contains the information listed in
paragraphs 40 CFR 403.12 (b)(l)-(7) within 180 days after the effective date of a categorical
Pretreatment Standard
New Facilities/Sources (direct and indirect dischargers) must comply with the
limitations and standards on the date they begin discharging after promulgation of
the rule.
New Sources shall be required to submit to the Control Authority a report which contains the
information listed in paragraphs 40 CFR 403.12 (b)(l)-(5) at least 90 days prior to
commencement of discharge.
United States
Environmental Protectio
Agency
A1-37
Office of Water
23
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Outreach and Schedule
Small Business Regulatory Enforcement Fairness Act
Sent news releases Jan. 18 requesting small entity representative volunteers
Pre-Panel meeting May 2023
Formal Panel meeting June 2023
Proposed Rule: December 2023
United States
Environmental Protectio
Agency
A1-38
Office of Water
24
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Questions for Small Entity Representatives
How may proposed amendments affect your business?
Revised limits; new limits on additional pollutants
Pretreatment Standards
What recommendations do you have for small business flexibilities to
reduce burden?
Do you anticipate any unique legal, administrative, or recordkeeping
burdens associated with this action? Any issues not addressed?
Are there other federal regulations that apply to small entities that may
overlap with this EPA action?
Any other feedback for EPA on the MPP ELG
*This information will be used to develop a regulatory flexibility analysis, which becomes part of the record
for the potential regulation
United States
Environmental Protectio
Agency
A1-39
Office of Water
25
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Closing Session
Closing remarks from EPA, SBA, and OMB
Next Steps:
Written comments submitted to Lanelie Wiggins by May 16, 2023
United States
Environmental Protectio
Agency
A1-40
Office of Water
26
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Contact Information
EPA SBAR Contact:
EPA MPP Contact(s)
SBA Advocacy:
OMBOIRA:
Lanelle Wiggins (WiRRins.Lanelle@epa.Rov)
Steve Whitlock (Whitlock.Steve@epa.Rov)
Erica Mason (Mason.Erica@epa.Rov)
Todd Doley (Doley.Todd@epa.Rov)
Dave Rostker (David.Rostker@sba.Rov)
Steph Tatham (Stephanie.J.Tatham@omb.eop.Rov)
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Pre-Panel Questions for SERs
A1-42
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Pre-Panel Outreach Meeting - May 2, 2023
Pre-Panel Outreach Small Entity Representative (SER) Questions for Discussion on the Meat and
Poultry Products Effluent Limitations Guidelines Rulemaking
The input and feedback EPA receives will be used to inform the Small Business Advocacy Review
(SBAR) Panel Outreach meeting materials. The input will also be used to inform proposed
amendments to the Meat and Poultry Products Effluent Limitations Guidelines (MPP ELGs).
For rules that may have a significant economic impact on a substantial number of small entities, the
Regulatory Flexibility Act (RFA) requires agencies to evaluate regulatory alternatives that may
minimize the burden on small entities expected to be regulated. The RFA notes that the regulatory
alternatives must be consistent with the stated objectives of applicable statutes (i.e., the Clean
Water Act (CWA)), and suggests significant alternatives such as:
the establishment of differing compliance or reporting requirements or timetables that take
into account the resources available to small entities;
the clarification, consolidation, or simplification of compliance and reporting requirements
under the rule for such small entities;
the use of performance rather than design standards; and
an exemption from coverage of the rule, or any part thereof, for such small entities.
To that end, these informal questions on your work practices and your experiences with meat and
poultry processing operations are aimed at guiding our discussion today, and your later written
feedback, towards ideas for minimizing the economic impact on your business while remaining
within the constraints of the CWA. We are not seeking a structured response on each question;
rather, we are interested in any feedback or details you can provide, and hope that these questions
let you know what type of information would be most useful as we consider advice from the small
entity representatives concerning this proposed action.
If you are interested in providing this or other information in writing, please see the contact
information below.
We ask that you refrain from providing Confidential Business information (CBI) during the
discussion or in email to EPA. If you choose to provide CBI, we will provide special instructions.
Contact Information:
Lanelle Wiggins
Office of Regulatory Policy and Management
Office of Policy
Phone:(202) 566-2372
E-mail: wiggins.lanelle(S>epa.gov
A1-43
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Overarching Topics
1. How do you anticipate any proposed amendments to the MPP ELG would affect your business?
For example, would it impact the service you provide, require the hiring of additional staff,
require process changes, or require the purchase and installation of new equipment?
2. What recommendations do you have for small business flexibilities that may reduce burden? In
what way can these flexibilities be structured to better aid small entities in reducing potential
burdens? Are there any specific flexibilities that would help your business?
3. What are the characteristics of a small business in your industry that make it different from a
large business?
4. Is there any information that would improve EPA's understanding of the number of small
entities that may be affected by this proposed rulemaking?
5. Do you anticipate any significant issues or circumstances not addressed in the materials
provided?
6. Do you have any other feedback for EPA related to MPP ELG?
Meat and Poultry Products Industry
1. How would an amended ELG impact investments and new projects?
2. Are there any sector-unique business or competitive issues that EPA should understand? Are
there any specific business or competitive issues associated with your business?
3. How often do you currently conduct wastewater sampling at your facility?
a. What is the cost of the analysis per sample (including lab and labor)?
b. What pollutants do you currently sample?
4. Are there any production or processing operations that are unique to small businesses that EPA
should consider as it develops the proposed rule?
Pretreatment Standards
1. Do you discharge wastewater to a POTW? Do you have a pretreatment permit or control
agreement?
a. What pollutants does the POTW require your facility to monitor?
b. Does the POTW require management practices, such as segregation of waste streams or
use of pollution prevention best management practices to limit discharge of pollutants
to the POTW?
2. Do you have concerns with how pretreatment standards may affect your relationship with the
POTW? For example, costs or new or updated permits?
3. Are there any constraints unique to small entities, such as available space at your facility, that
may present challenges to installing wastewater treatment technologies?
4. What flexibilities would you recommend that EPA consider when developing pretreatment
standards for small MPP facilities?
5. Are there specific production thresholds or wastewater flow thresholds that EPA should
consider when developing pretreatment standards for MPP facilities to minimize impacts to
small entities?
A1-44
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Reporting and Recordkeeping
1. What recommendations do you have for reducing the recordkeeping and reporting burden on
small businesses?
2. Do you anticipate any unique legal, administrative, or recordkeeping burdens associated with
compliance with the proposed action?
Other Federal Regulations
1. Are there regulations from other federal agencies that apply to small entities that may overlap
with this EPA action? Do you have suggestions on how to minimize conflicting requirements?
A1-45
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Final Report of the Small Business Advocacy Review Panel on EPA's Planned Proposed Meat and Poultry
Products Effluent Limitations Guidelines Rulemaking
Appendix A2: Materials Shared with Small Entity Representatives for the
Panel Outreach Meeting held on July 17, 2023
Table of Contents
Agenda A2-2
Rule Presentation A2-4
A2-1
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Agenda
A2-2
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SBAR Panel Outreach Meeting with Small Entity Representatives for
EPA's Upcoming Proposed Rulemaking,
"Meat & Poultry Products Effluent Limitations Guidelines"
Monday, July 17, 2023 - 1:00 pm to 3:00 pm (Eastern)
AGENDA
1:00 Welcome and Introductions
Introductory Remarks
o Bill Nickerson, EPA's Small Business Advocacy Chair, Office of Policy (OP)
o Rob Wood, Director, Engineering and Analysis Division, EPA's Office of
Water (OW)
o Nick Goldstein, Office of Advocacy, Small Business Administration (SBA)
o Steph Tatham, Office of Information and Regulatory Affairs (OIRA), Office of
Management and Budget (OMB)
Roll Call of SERs - Lanelle Wiggins, EPA's RFA Team Leader, OP
1:20 Presentation on Rulemaking - Erica Mason, Engineering and Analysis Division, OW
1:45 Discussion/Consultation with SERs - All
2:45 Closing Remarks and Next Steps
Closing Remarks
o EPA: Bill Nickerson, Rob Wood
o SBA: Nick Goldstein
o OMB: Steph Tatham
Next Steps and Reminders - Lanelle Wiggins
3:00 Adjourn
A2-3
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Rule Presentation
A2-4
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Meat & Poultry Products Effluent Limitations Guidelines
Rulemaking
SBREFA Formal Panel Meeting
July 17,2023
United States
Environmental Protection
Agency
Office of Water
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Overview
* Background
* Applicable Small Entity Definitions
'Small Entities Potentially Subject to Regulation
* Rulemaking Scope
'Wastewater Treatment Option Development
'Potential Economic Impact on Small Entities
* Questions and Next Steps
United States
Environmental Protectio
Agency
A2-6
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Key Terms Used in this Briefing
Effluent Limitations - Discharge standards, typically expressed as numeric pollutant limits (e.g., 10
mg/L of Nitrogen). May also include "non-numeric" requirements such as management practices or
process changes to reduce pollution (pollution prevention)
Direct Discharger - An industrial facility that discharges industrial process wastewater directly to a
surface water
Publicly Owned Treatment Works (POTW) - A municipal wastewater treatment plant that treats
domestic waste (sewage) along with any industrial wastewaters that are discharged to the collection
system
Indirect Discharger-An industrial facility that introduces pollutants into a POTW from any non-
domestic source regulated under section 307(b), (c) or (d) of the Act.
Pretreatment Standards - Effluent limitations that apply to indirect discharging facilities
Conventional Pollutants-Oil and grease, total suspended solids (TSS), biochemical oxygen demand
(BOD), and fecal coliform
Nutrients - Various forms of nitrogen and phosphorus
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Background Terms
Pretreatment - Treatment technologies that may include screens, oil and grease traps, equalization, DAF.
Used to remove grit, large solids, oil and grease.
Dissolved Air Flotation (DAF) - Wastewater clarification process, often used in pretreatment to remove oil
and grease and solids. Air bubbles released in the treatment unit attach to oils and solids, bringing them
to the surface where they are skimmed off.
Anaerobic Lagoon - A lagoon or basin that undergoes anaerobic digestion, where organic matter is
broken down by bacteria without oxygen. Wastewater stays in the lagoon for days to months before
continuing to the next treatment stage. Solids settle at the bottom and eventually need to be dredged.
Biological Treatment - Organic matter is broken down by bacteria. Contaminants are destroyed or
removed, leaving cleaner water. Biomass will need to be removed. May include aerobic and anaerobic
basins.
Nitrification - Reduced nitrogen compounds are oxidized to nitrite and nitrate by autotrophic nitrifying
bacteria.
Denitrification - Nitrates are reduced to gaseous nitrogen with anaerobes.
Gravity Thickener/Belt Filter Press - Technologies used to condense biosolids/remove water to produce a
more concentrated solid product. Used to reduce the amount of sludge.
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Background Terms
In-Scope - Facilities in the MPP industry that discharge wastewater and may be regulated by the current
or revised MPP ELGs.
Out-of-Scope - Facilities that are not regulated by the current MPP ELGs and are not going to be regulated
by proposed changes to the MPP ELGs. For example, facilities that do not discharge wastewater are out-
of-scope. Facilities that have closed are out-of-scope.
Firm - A business that may include one or more facilities.
United States
Environmental Protectio
Agency
A2-9
Office of Water
5
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Background: Effluent Limitations Guidelines (ELGs)
ELGs are national standards developed under the Clean Water Act (CWA) that apply to
industrial wastewater discharges
These standards are based on available treatment technology and pollution control
measures
The technology selected must be economically achievable for the industry as a whole
ELG pollutant limits are incorporated into National Pollutant Discharge Elimination System
(NPDES) and pretreatment permits
NPDES permits provide pollutant-specific limits that direct dischargers are required to meet
before sending their wastewater to a surface water
Pretreatment permits provide pollutant-specific limits that indirect dischargers are required
to meet before sending their wastewater to a publicly owned treatment works (POTWs).
There are currently no industry specific pretreatment standards for the MPP industry
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Background: Meat and Poultry Products ELG
The original MPP ELGs rule was issued in 1974 and they were last revised in
2004
There are about 5,300 MPP facilities that generate wastewater
180 facilities have NPDES permits and discharge wastewater directly to
receiving waters
5,100 facilities indirectly discharge wastewater via POTWs or have no
discharge
The current MPP ELGs
Apply only to large, direct dischargers
Do not have limits for phosphorus
Are not based on the most stringent technologies available for removing
nutrients
United States
Environmental Protectio
Agency
A2-11
Office of Water
7
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Background: Meat and Poultry Products ELG
In 2019 as part of effluent guidelines preliminary plan 14, EPA published
results of its cross-cutting review of nutrients in industrial wastewater, where
EPA showed that MPP direct discharge effluents contained the highest
phosphorus loads and the fifth highest nitrogen loads of all the industrial point
source categories.
In 2020, EPA announced a detailed study of the MPP industry and found:
There are existing, affordable technologies that can reduce nutrient
concentrations in MPP wastewater
Pretreatment standards may be needed as publicly available data shows
pollutants from MPP facilities may passthrough and cause interference for
some POTWs
In September 2021 (Preliminary Effluent Guidelines Program Plan 15), EPA
announced a rulemaking to revise the existing discharge standards for the
meat and poultry products industry
United States
Environmental Protectio
Agency
A2-12
Office of Water
8
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Pollutants and Environmental Impact (Context)
Excess nutrients contribute to harmful algal blooms and areas of low oxygen
("dead zones").
Nitrates contaminate waters used as sources for drinking water and
recreation while negatively impacting farming and ranching uses, aquatic life,
and ecosystem health.
58% of the nation's rivers and streams and 45% of our lakes have excess levels
of phosphorus.
43% of the nation's rivers and streams and 46% of our lakes have excess levels
of nitrogen.
Communities near MPP facilities are likely to experience multiple
environmental stressors, and in these communities, minority and low-income
percentiles exceed U.S. averages.
United States
Environmental Protectio
Agency
A2-13
Office of Water
9
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MPP Indirect Dischargers and POTWs
Nationally, POTWs are not required to treat wastewater for nutrients.
Nutrients from MPP facilities passthrough to the environment
Some POTWs have no pretreatment programs for Industrial Users
An initial analysis of 100+ POTWs found 73% of the POTWs receiving MPP
wastewater have violation(s) for pollutants found in MPP wastewater
including: conventional pollutants, nutrients, and chlorides
33 U.S. Code § 1317 (b) (1) Pretreatment standards shall be established to
prevent the discharge of any pollutant through treatment works which are
Dublicly owned, which pollutant interferes with, passes through, or otherwise is
ncompatible with such works.
40 CFR 403.3 (p) Pass Through means a Discharge which exits the POTW into
waters of the United States in quantities or concentrations which, alone or in
conjunction with a discharge or discharges from other sources, is a cause of a
violation of any requirement of the POTW's NPDES permit
United States
Environmental Protectio
Agency
A2-14
Office of Water
10
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Current ELG (direct dischargers)
Subparts Facility Type Facility Size Ib/yr production
# of Facilities Currently Regulated Pollutants
A-D
Meat Slaughterhouses and Packinghouses
>50M Ib/yr
39
Conventional, Ammonia, Total Nitrogen
<50M Ib/yr
13
Conventional
E
Small Processors of finished meat products
<6000 lb/day
18
Conventional
F-1
Meat further processors
>50M Ib/yr
20
Conventional, Ammonia, Total Nitrogen
<50M Ib/yr
14
Conventional, Ammonia
J
Renderers
>10M Ib/yr
19
Conventional, Ammonia, Total Nitrogen
K
Poultry First Processors
>100M Ib/yr
79
Conventional, Ammonia, Total Nitrogen
L
Poultry Further Processors
>7M Ib/yr
1
Conventional, Ammonia, Total Nitrogen
Current General Pretreatment Regulations (indirect dischargers)
Subparts
Facility Size
Ib/yr production
Prohibitions
Currently Regulated Pollutants
All
All
All
General
A User may not introduce into a POTW any pollutant(s) which cause Pass Through or Interference.
Specific
Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW
resulting in Interference
Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow
rate and/or pollutant concentration which will cause Interference with the POTW.
United States
Environmental Protectio
Agency
Office of Water
11
A2-15
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Small Entity Definitions
NAICS
Industry Description
Monthly Average # of Full/Part time
Employees over last 24 months*
311611
Animal (except Poultry) Slaughtering
1,000
311612
Meat Processed from Carcasses
1,000
311613
Rendering and Meat Byproduct
Processing
750
311615
Poultry Processing
1,250
The definitions of small entities for the MPP industry are listed in SBA's regulations at 13 CFR 121.201
(SBA's method of calculation can be found in 13 CFR 121.106). The SBA definitions for small
businesses vary by NAICS category and are regularly updated.
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Small Entities Potentially Subject to Revisions
NAICS
Industry Description
Number of Small Firms
with in-scope facilities
(preliminary analysis)
Number of Large Firms
with in-scope facilities
(preliminary analysis)
311611
Animal (except Poultry)
Slaughtering
469
18
311612
Meat Processed from
Carcasses
592
12
311613
Rendering and Meat
Byproduct Processing
33
3
311615
Poultry Processing
276
23
Other
362
75
Total
1732
131
United States
Environmental Protectio
Agency
A2-17
Office of Water
13
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Consultation with Small Entity Representatives
EPA is interested in information, advice, and recommendations from the
small entity representatives (SERs) to minimize impacts to small entities
This information will be used to develop a regulatory flexibility analysis,
which becomes part of the record for the potential regulation
For rules that may have a significant economic impact on a substantial
number of small entities, the Regulatory Flexibility Act (RFA) requires
agencies to evaluate regulatory alternatives that may minimize the burden
on small entities expected to be regulated.
Your feedback can help shape selection of regulatory alternatives
United States
Environmental Protectio
Agency
A2-1
Office of Water
14
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Consideration of Regulatory Alternatives
The RFA notes that the regulatory alternatives must be consistent with
the stated objectives of applicable statutes (i.e., the Clean Water Act
(CWA)), and suggests significant alternatives such as:
the establishment of differing compliance or reporting requirements or
timetables that take into account the resources available to small entities
the clarification, consolidation, or simplification of compliance and reporting
requirements under the rule for such small entities;
the use of performance rather than design standards; and
an exemption from coverage of the rule, or any part thereof, for such small
entities.
United States
Environmental Protectio
Agency
A2-19
Office of Water
15
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CWA 301(b) and 304(b) - Statutory Factors for Revising ELGs:
The industry's processes, raw materials, products, and byproducts
Locations, age of equipment and plant size
Types and amounts of pollutants discharged
Control technology performance and cost
Economic achievabiiity for the industry
Impacts of the regulations on other media such as air pollution and
solid waste (sludge disposal)
United States
Environmental Protectio
Agency
A2-20
Office of Water
16
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Rulemaking Scope: Potential Revisions to the ELG
1. Consider updating nutrient effluent limits for nitrogen (TN) and establishing
limits for phosphorus (TP) - Part of EPA's strategy to reduce nutrient discharges
to the nation's waters
2. Evaluate and consider setting effluent limits for other pollutants including:
conventional pollutants and chlorides
3. Consider adding pretreatment standards for facilities that discharge to POTWs.
Considering: conventional pollutants, nitrogen, phosphorus, chlorides
4. Consider revisions to production size thresholds and subcategories. The
proposed rule may have production thresholds where facilities below that
threshold may be subject to less stringent ELGs, best management practices,
or no limitations at all
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Engineering Analysis: Data Sources
Questionnaire - Thank you! Sent out to all MPP facilities identified by EPA
Sampling events at 6 facilities
Discharge Monitoring Report data, permits, fact sheets, facility process
and wastewater flow diagrams
Presentations and Discussions with facilities, POTWs, industry groups and
leaders, stakeholders, vendors
Discussions with EPA regions, permit writers
Discussions with USDA
CAPDET modelling - wastewater treatment plant design and cost
estimation
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Engineering Analysis: Wastewater Treatment Options Development
* Considerations for Direct Dischargers to update limits to reflect current technology:
Phosphorus removal
More complete denitrification to reduce TN
Chlorides removal
E. coli
Considerations for Indirect Dischargers to protect POTWs from passthrough and
interference:
Screening, oil and grease removal, and equalization
Phosphorus removal
Nitrogen removal including denitrification to address nitrate
Chlorides removal
Conditional limits to allow off-ramp from pretreatment standards for nutrients where
POTW already removing nutrients.
Reduces costs for indirect dischargers and eliminates redundant treatment
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Treatment Technologies
Conventional Pollutant Removal: Oil & Grease, TSS, BOD, fecal coliforms
Screens, grit removal
DAF (Dissolved Air Flotation) - removes oil & grease, solids, BOD
Chemical Phosphorus Removal: (Total Phosphorus)
Alum or ferric chloride chemical addition. Generally added before the DAF or secondary
clarifier
Nitrogen Removal: (Total Nitrogen)
Anaerobic lagoon
Bio = Biological treatment with Nitrification/Denitrification
Effectively - 5 stage Bardenpho Process
United States
Environmental Protectio
Agency
A2-24
Office of Water
20
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Treatment Technologies
Pathogen Removal - Disinfection
Chlorination/dechlorination
Applies to direct dischargers only
Chlorides Removal - hides, Kosher slaughter, curing, brining, water softening, etc
Separation, evaporation system or haul off-site
Solids Handling
Facilities with flows >10,000 GPD - Belt filter press, gravity thickening
All Facilities: hauling and landfilling
^Facilities may comply with effluent limits using any technologies they choose.*
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Economic Analysis: Data Sources
2022 MPP Detailed and Census questionnaires
Hoovers Dun & Bradstreet - estimates for revenue and employment
Economic census data
USDA-Food Safety and Inspection Service (FSIS) data
Facility employment information
Facility production information
USDA-Economic Research Service (ERS) data
Meat and poultry prices
Sales volumes
Market trends
United States
Environmental Protectio
Agency
A2-26
Office of Water
22
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Economic Analysis
* The Economic Analysis will assess:
Facility-level Impacts
Firm-level Impacts
Market-1 eve I Impacts
Societal Benefits
* Considerations for the analysis:
Potential revisions to the ELGs may expand regulations to cover additional facilities and
indirect dischargers. This may include some small entities (firms).
This emphasizes the importance of Regulatory Flexibility Analysis requirements
to consider potential impacts to small entities and alternatives to minimize those impacts.
United States
Environmental Protectio
Agency
A2-27
Office of Water
23
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Example Regulatory Structure: Indirect Meat Further Processor
Production (million lbs/yr)*
<1
1-20
>20
Regulated Pollutants
No numeric discharge
standards
Oil & Grease, TSS, BOD
Nitrogen, Phosphorus, TSS,
BOD, Oil & Grease, Ammonia
Technology Basis
Pollution Prevention
Dissolved Air Flotation (DAF)
DAF, Chemical P Removal,
Nitrification/Denitrification
High-Chloride Waste Streams
No requirements
Pollution Prevention
Segregation and management
via zero discharge
Example Facility Size (Mlb/yr)
0.5
10
30
Wastewater flow (gal/day)
1,500
8,500
80,000
Capital Cost (one time)
$5,000
$800,000
$3.2 M
Annual O&M
$5,000
$41,000
$400,000
Annual Monitoring Cost**
No requirements
$4,000
$6,000
*Examples for illustration - production thresholds in proposed rule will be based on statutory factor analysis
**Assumes monthly samples for all regulated pollutants
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Example: Indirect Poultry Further Processor
Chicken deboning/marinating, 6 million Ibs/yr, discharges to POTW
Flow: 7,000 GPD
TIP: None
Capital Costs (one time capital costs)
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add C
$147,000
$0
$0
$0
$255,000
$330,000
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Monitoring
Add C
$13,000
$0
$0
$0
$44,000
$4,000
*Other: Capital - site prep,
engineering, contingency
Annual - auxiliary
functions, lab/admin staff
United States
Environmental Protectio
Agency
A2-29
Office of Water
25
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Example: Indirect Meat Slaughterhouse
Beef slaughter and hides processing, 30 million Ibs/yr, discharges to POTW
24,000 GPD, hides processing: 200 GPD, evaporation system**
TIP: None
Capital Costs (one time capital costs)
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Chlorides**
Other*
Add C
$140,000
$0
$0
$0
$1 M
$74,000
$1 M
Add C, N, P
$170,000
$35,000
$700,000
$534,000
$1 M
$74,000
$1.9 M
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Chlorides**
Monitoring
Add C
$35,000
$0
$0
$0
$35,000
$18,000
$4,000
Add C, N, P
$35,000
$10,000
$200,000
$80,000
$75,000
$18,000
$6,000
United States
Environmental Protectio
Agency
A2-30
Office of Water
26
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Example: Indirect Poultry Slaughterhouse
Poultry slaughter, 42 million Ibs/yr, discharges to POTW
Flow: 150,000 GPD
Treatment in Place (TIP): Pretreatment
Capital Costs (one time capital costs)
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add C
$0
$0
$0
$0
$0
$0
Add C, N, P
$0
$45,000
$1.45M
$600,000
$400,000
$2 M
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Monitoring
Add C
$0
$0
$0
$0
$0
$4,000
Add C, N, P
$0
$10,000
$290,000
$210,000
$130,000
$6,000
United States
Environmental Protectio
Agency
A2-31
Office of Water
27
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Example: Indirect Renderer
Beef and chicken rendering, 28 million Ibs/yr, discharges to POTW
Flow: 22,000 GPD
TIP: Pretreatment
Capital Costs (one time capital costs)
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add C
$0
$0
$0
$0
$0
$0
Add C, N, P
$0
$36,000
$860,000
$22,000
$310,000
$1 M
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Monitoring
Add C
$0
$0
$0
$0
$0
$6,000
Add C, N, P
$0
$10,000
$230,000
$36,000
$34,000
$6,000
United States
Environmental Protectio
Agency
A2-32
Office of Water
28
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Example: Direct Meat Further Processor
Beef deboning/marinating, 8 million Ibs/yr, discharges to a river
Flow: 30,000 GPD
TIP: Pretreatment, partial biological treatment, disinfection
Capital Costs (one time capital costs)
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add C
$0
$0
$0
$0
$0
$0
Add full N, P
$0
$0
$550,000
$260,000
$110,000
$760,000
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Monitoring
Add C
$0
$0
$0
$0
$0
$6,000
Add total N, P
$0
$0
$180,000
$80,000
$25,000
$8,000
United States
Environmental Protectio
Agency
A2-33
Office of Water
29
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Example: Direct Poultry Slaughterhouse
Chicken slaughter and cutting/seasoning, 190 million Ibs/yr, discharges to river
Flow: 700,000 GPD
TIP: Pretreatment, partial biological treatment, disinfection
Capital Costs (one time capital costs)
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Other
Add partial N, P
$0
$0
$0
$890,000
$200,000
$900,000
Add full N, P
$0
$0
$1.5 M
$890,000
$550,000
$2.4 M
Annual O&M Costs
Pretreatment
Anaerobic
Lagoon
Bio
Chem P
Removal
Solids
Monitoring
Add partial N, P
$0
$0
$0
$850,000
$180,000
$6,000
Add total N, P
$0
$0
$130,000
$850,000
$480,000
$7,000
United States
Environmental Protectio
Agency
A2-34
Office of Water
30
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Implementation schedule
Existing Direct dischargers limits would be implemented as permits are renewed
according to their 5-year permitting cycle.
Existing Indirect dischargers would have to comply with pretreatment standards no
later than 3 years after the final rule is published.
Would be required to submit to the Control Authority a report which contains the information
listed in paragraphs 40 CFR 403.12 (b)(l)-(7) within 180 days after the effective date of a
categorical Pretreatment Standard
New Facilities/Sources (direct and indirect dischargers) would have to comply with
the limitations and standards on the date they begin discharging after promulgation
of the rule.
New Sources would be required to submit to the Control Authority a report which contains the
information listed in paragraphs 40 CFR 403.12 (b)(l)-(5) at least 90 days prior to
commencement of discharge.
United States
Environmental Protectio
Agency
A2-35
Office of Water
31
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Outreach and Schedule
Small Business Regulatory Enforcement Fairness Act
Sent news releases Jan. 18 requesting small entity representative volunteers
Pre-Panel meeting May 2023
Formal Panel meeting July 2023
Proposed Rule: December 2023
United States
Environmental Protectio
Agency
A2-36
Office of Water
32
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Questions for Small Entity Representatives
Your oral or written feedback on these questions will help inform EPA's proposed rule,
consideration of feasibility, requirements, alternatives, and impact estimates. We
welcome your expert input.
What is the production size of your facility?
Do you know how much wastewater your facility generates?
Do you discharge directly into a surface water or do you send your wastewater to a POTW?
What is your relationship with your POTW?
What technical assistance does the POTW provide you?
Has the POTW discussed with you potential issues with the pollutants in your wastewater? Slug loads,
quality/quantity of wastewater discharged, inconsistent flows, oil and grease issues
Does your facility have any limits from your POTW?
Are there other MPP facilities in your region you could work cooperatively with along with
your POTW to address pollution (e.g. hauling waste water to another facility)? Are there
other opportunities for cooperation or cost-sharing related to wastewater treatment?
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Questions for Small Entity Representatives
How does your facility currently manage or treat wastewater?
Best management practices can include dry clean up practices, grease and solids
removal, segregate waste, minimize water usage, by-product recovery, animal pen
waste management, blood handling, training, etc.
Does your facility employ any of these best management practices? If so, what
type(s)?
Treatment technologies can include screens, oil & grease traps, equalization,
dissolved air flotation, anerobic lagoons, etc. Does your facility have any
treatment technologies in place? If so, which ones?
Some treatment technologies require space. For example, the size of an anerobic
lagoon should be greater the more waste is treated. Does your facility have space
it could use for treatment technologies? If so, how much?
United States
Environmental Protectio
Agency
A2-38
Office of Water
34
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Questions for Small Entity Representatives
In thinking about the best management practices and treatment
technologies discussed are there any that would be easier or more
challenging for you to implement? Why?
Are there practices or technologies where cost may be an issue?
Are there other challenges that would make it difficult for you to adopt
any of the best management practices or treatment technologies
discussed?
Have you had difficulty finding vendors to take by-products and blood?
Are there other options for management of these by-products?
United States
Environmental Protectio
Agency
A2-39
Office of Water
35
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Questions for Small Entity Representatives
Are there specific concerns your facility has with the ability to comply with
potential ELG revisions? For example: available space, lack of expertise, access
to funding/borrowing to cover the cost of the capital equipment
What type of technical assistance would your facility need?
Is this ongoing rulemaking affecting how your facility makes decisions on
current plans? How can EPA mitigate this?
What recommendations do you have for small business flexibilities to reduce
burden? For example: delayed implementation schedule
Are there other federal regulations currently under development that apply to
small entities in this industry that may overlap with this EPA action?
United States
Environmental Protectio
Agency
A2-40
Office of Water
36
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Closing Session
Closing remarks from EPA, SBA, and OMB
Next Steps:
Written comments submitted to Lanelie Wiggins by July 31, 2023
United States
Environmental Protectio
Agency
A2-41
Office of Water
37
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Contact Information
EPA SBAR Contact:
EPA MPP Contact(s)
SBA Advocacy:
OMBOIRA:
EPA
Lanelle Wiggins (WiRRins.Lanelle@epa.Rov)
Steve Whitlock (Whitlock.Steve@epa.Rov)
Erica Mason (Mason.Erica@epa.Rov)
Todd Doley (Doley.Todd@epa.Rov)
Nick Goldstein (Nick.Goldstein@sba.Rov)
Dave Rostker (David.Rostker@sba.Rov)
Steph Tatham (Stephanie.J.Tatham@omb.eop.Rov)
United States
Environmental Protection
Agency
A2-42
Office of Water
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Final Report of the Small Business Advocacy Review Panel on EPA's Planned Proposed Meat and Poultry
Products Effluent Limitations Guidelines Rulemaking
Appendix Bl: Written Comments Submitted by Small Entity
Representatives following the May 2, 2023 Pre-Panel Outreach Meeting
Table of Contents
Blue Grass Quality Meats Bl-2
Boone's Butcher Shop / Kentucky Association of Meat Processors Bl-4
Missouri Association of Meat Processors Bl-11
U.S. Poultry and Egg Association Bl-14
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Blue Grass Quality Meats
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From:
To:
Subject:
Date:
Dan Rice
Lanelle Wiggins
RE: EPA"s Pre-Panel Outreach Meeting: Meat and Poultry Products Effluent Limitations Guidelines
Tuesday, May 16, 2023 5:29:49 PM
Hi Lanelle,
Thank you for including me in the pre panel outreach. I was able to listen in on the meeting
and, though I am definitely not our wastewater expert here at Blue Grass Quality Meats, I do
own the business and function as the Chief Financial Officer. The past several years have been
very difficult for our small business. In addition to the normal complexities of the meat
business including substantial capital needs, narrow margins and highly volatile raw material
costs, the last several years have had serious added difficulties caused by a shortage of
available qualified labor, serious raw material supply chain disruptions and difficulties related
to the Covid Pandemic. We have struggled to make capital improvements that are necessary
for the operation of our business. If we were forced to make capital expenditures at this time
without a financial return it would be disastrous for our business and for our employees who
depend on it for their livelihood.
Meeting feedback from my small business would be please avoid any regulation that pushes a
financial burden on small and very small businesses in our industry. Events of the past several
years have left our businesses in a very fragile state.
Thank you ,
Dan
Dan Rice
2648 Crescent Springs Pike, Crescent Springs, KY 41017
drice@bluegrassqualitymeats.com
www.bluegrassqualitvmeats.com
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Boone's Butcher Shop / Kentucky Association of Meat Processors
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Bardstown, KY 40004
Tel (502) 348-3668
allison@boonesbutchershop.com
Boone's Butcher Shop
100 Old Bloomfield Pike
Lexington, KY 40503
Kymeatprocessors.org
Kentucky Association of Meat
Processors
176 Pasadena Drive
KAMP
www.boonesbutchershop.com
US Environmental Protection Agency
Washington, DC
MAY 16, 2023
RE: SER Comments - Meat & Poultry Products Effluent Limitations Guidelines Rulemaking
To whom it may concern,
My name is Allison Boone Porteus. I am a third-generation owner/operator of a slaughterhouse and meat processing plant,
Boone's Abattoir, Inc. (DBA Boone's Butcher Shop), in Bardstown, KY. We employ approximately 40 people in our plant
and engage in slaughter and processing of cattle, hogs, sheep, and goats, process deer meat for hunters, and have a retail
store. We do minimal poultry processing for our retail store, so I am speaking as a red meat processing plant rather than
poultry. I am also a founding member and Treasurer of the Kentucky Association of Meat Processors (KAMP), a trade
organization representing approximately 100 very small and small meat processors in the state of Kentucky. I've also served
as a Board Director of the Indiana Association of Meat Packers and Processors (IMPPA) for approximately 5 years. My
experience as an owner of a small meat processing plant and my roles with KAMP and IMPPA have allowed me to interact
with many small processors, and I have a deep understanding of the types of challenges and financial hardships small
processors face.
Data Gathering and Questionnaire
I would like to start my comments on the presentation of the Meat & Poultry Products Effluent Limitations Guidelines
Rulemaking with the process by which the EPA gathered their information on meat and poultry processors. I was a recipient
of the EPA's Meat and Poultry Products Detailed Questionnaire. This was the first communication I've received from the
EPA, and I had very little knowledge of how or why the EPA could regulate my business. Based on the questionnaire I
received, I would respectfully submit that the EPA does not have significant knowledge or understanding of the meat
processing industry. The detailed questionnaire was 60 pages of questions requiring a level of detail that is not required for us
to track, nor is it easily obtained.
Section 3 of the detailed questionnaire not only asked for pounds of meat processed going back 5 years from when we
received the questionnaire but went so far as to request the number of pounds we processed, and wanted that number broken
down into fresh cuts, smoked product, cured product, sausage, luncheon meat, canned meat, and Kosher meat products. I
have low confidence in the information I provided. USDA FSIS (Food Safety Inspection Services) inspected plants are only
required to provide a range of quantities produced within their facilities and only for products that bear our legend of
inspection. We must provide to the USDA estimated average daily product volumes by type (i.e. slaughter, raw intact, raw not
intact, etc., and then by species) and the number of days per month produced on average. The range of pounds for each type
of product and species in is large; the ranges are 1-100, 101-1,000, 1,001-3,000, 3,001-6,000, 6,001-50,000, 50,000-250,000,
250,001-600,000, 600,001-1,000,000. Detailed record keeping is not required for the number of pounds produced under
USDA. Furthermore, there is no requirement to track retail exempt or custom exempt pounds processed, both products that
do not bear our USDA legend of inspection. Therefore, most small processors do not have the ability to report the
information requested.
Section 3 and Section 11 included 2021 within the scope of understanding our processing volumes and finances. I would urge
the EPA to carefully consider how much weight it gives to 2021 and how that year impacted processors financial viability.
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For most processors, including me, 2020 and 2021 were unprecedented years in terms of volumes and profits. As some large
processors were forced to suspend operations for periods of time due to COVID outbreaks, consumers were forced to seek
out alternatives to their chain grocery and big box stores, and many turned to smaller processors to either purchase meat in
bulk or shopped in the small processors' stores or bought animals or cuts from farmers that resulted in more animals
processed in small plants. The addition of significant stimulus money pushed out to families across the country allowed
consumers to spend more money on higher priced meat and to purchase larger quantities at once than they had in the past.
EBT funds for families who received that benefit were increased during the pandemic, providing families with funds to cover
their meat and grocery purchases. Additionally, the state of Kentucky provided families with school age children, who would
not normally be eligible for EBT, with EBT funds. Other states may have done the same. In that light, our EBT sales more
than tripled from 2019 through 2021, and we lost almost half of that growth in 2022. We expect to see those numbers, as well
as sales, further decline in 2023 as pandemic era spending comes to an end and EBT benefits are reduced to pre-pandemic
levels. Although we hope to continue to see sales and profits outpace 2019 and prior numbers, there is significant uncertainty
as to whether consumers will revert to their pre-pandemic buying patterns.
Sections 5, 6, and 7 of the detailed questionnaire used vocabulary and asked questions that seemingly required a level of
knowledge regarding wastewater, that I do not have and would assume other processors do not have either. Terms like DAF,
outflow (diagrammed with latitude and longitude to three decimal places), design influent flow, average influent flow, design
residence time, etc., are not terms that I am familiar with, nor did I know how to respond to the questions. I do know that a
helpdesk was available to consult with while working through the survey. Flowever, I had to complete this application during
evenings and weekends, when we were not producing or operating our retail store. Most small processors, including myself,
do not have staff available to work on projects like the questionnaire, so the owners were trying to figure out the answers in
their limited amount of available time.
My comments on the questionnaire are to demonstrate that I found the questionnaire to be intimidating and very difficult to
respond to with any degree of confidence. I am certain that other processors felt the same way and may not have responded.
To understand how robust the data gathering effort was on the questionnaire and how representative the data being used by
the EPA is, I would like to make the following inquiries:
1. Flow many detailed and how many short questionnaires were sent out? You provided the number of responses
received in the presentation, but what is the response rate?
2. Flow did you determine the pool of processing plants to send the questionnaires to?
3. Did your population of questionnaire recipients include retail exempt or custom exempt plants? Are those plants
considered in the number of small entities you included on slide 8 as potentially impacted by the revisions?
4. Why are grocery stores and other facilities that process boxed meat not considered within the scope of the revisions?
The purge released from opening beef and pork primal cuts would be a source of nitrogen and phosphorous. Is there
evidence that the impact from those types of processors is not significant vs. breaking down carcasses?
5. Did the EPA review the questionnaire with any entities (i.e. USDA, trade organizations, state inspection services)
that may have provided feedback as to whether the questionnaire was written in a way that small processors would
be able to answer the questions with accuracy?
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Small Business Definition within the Meat and Poultry Processing Industry
The second topic I would like to address is the definition of a small business within the meat processing industry. The
presentation listed small businesses within NAICS codes for animal slaughtering and meat processed from carcasses as 1,000
employees or less. The meat processing industry is a highly consolidated industry; per a White House Fact Sheet published
on January 3, 2022 (https://www.whitehouse.gov/briefing-room/statements-releases/2022/01/Q3/fact-sheet-the-biden-harris-
action-plan-for-a-fairer-more-competitive-and-more-resilient-meat-and-poultrv-supplv-chain/). "Four large meat packing
companies control 85 percent of the beef market. In poultry, the four top processing firms control 54 percent of the market.
And in pork, the top four processing firms control about 70 percent of the market." The result of such high consolidation in
the industry has resulted in there being 4 very large processors in this country and the vast majority of the remaining
processors are very small.
Of the approximately 100 processors in the state of Kentucky, excluding plants owned by the Big Four processors, I am
aware of only two processors who have more than 100 employees. Most of the rest have less than 50 employees, and a large
portion of those are less than 20 employees. As I noted in the section regarding the questionnaire, most processors do not
track the number of pounds processed in their facilities, so looking at full-time employee equivalents is typically a
meaningful number to determine size. The USDA uses employees as a means for determining size and identifies large
establishments as having greater than 500 employees, small establishments as having more than 10 but less than 500
employees, and very small establishments as having fewer than 10 employees or annual sales of less than $2.5 million
(https://www.fsis.usda.gov/sites/default/files/media file/2021-03/Docket No.93%E2%80%93016F.pdf).
I submit the following questions to the EPA regarding how it views small meat processors:
1. Can the EPA or Small Business Administration further refine the definition of a small business within the meat
processing industry?
2. Can the EPA use a more readily available statistic to measure processor size and reevaluate the industry with that
information?
3. Has the EPA considered where the majority of the wastewater issues stemmed and whether regulating small
processors has a significant impact on water quality?
Economic Impact to Small Meat Processing Facilities Capital Costs
I can only describe my reaction to the financial burden to processors described within the presentation on slides 18-22 as
shock and awe. The capital costs described on those slides range from $2.3M to $4.5M to regulate conventional, nitrogen,
and phosphorous in wastewater. The only asset any small processor has that comes even close to that level of investment is
the building from which we operate. We operate out of a 20,000 square foot building: I would estimate that to cost $3M-$4M
to build this same building with current prices. We would not even consider spending that level of money on non-revenue
generating equipment and construction. There is no financial analysis that would support making that kind of investment.
My business is fortunate in that it is located right in the middle of a small, growing community and we have a thriving retail
store. If this kind of investment were required, we would stop our slaughter and processing activities and source all our meat
from other processors. Unfortunately, most processors in Kentucky do not have the level of retail business we do to sustain
their businesses: they rely heavily on their slaughter and processing revenues, if not exclusively, to continue operations.
Regulations that would require such high capital costs would cause those processors to cease operations. I would then likely
have to source my retail meats from one of the Big Four meat processors exclusively. Pushing more processing to the Big
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Four processors has significant economic and societal impacts for both farmers and consumers, which I will expand on in a
later section.
Another area in which I am fortunate is that, as a third-generation business owner and with the investment by the state of
Kentucky in expanding small scale meat processing, we are financially sound. Even with that, we do not generate enough
cash flow to be able to spend over $2M without borrowing money. Many first- and second-generation small meat processors
carry significant debt as they try to scale their operations. They would not have the cash flows to support taking on more debt
to invest in wastewater treatment. The capital costs of this regulation alone would be a death blow to almost the entire small
meat processing industry, with very few exceptions.
When financially logical, my business typically invests anywhere from $50,000 to $200,000 a year in facility upgrades,
equipment, and technology. These are necessary investments to keep our plant running, especially considering the lack of
skilled workers available in our industry. Technology and equipment are crucial to account for the challenges we face in
finding employees. The capital costs described in the presentation would be the equivalent of what we spend in revenue-
generating assets for at least a 10-year period.
Space is another challenge that some small processors, and perhaps some larger processors, will face if these regulations are
implemented. My plant sits on a one-acre lot, and we have used every bit of available space. We purchased a lot across the
street for overflow employee parking, and our parking lot is still not big enough. We have customers parking on grassy areas
that adjoin our property when our parking lot is full, which occurs multiple days during the week. There is a steep hillside on
one side and behind our building and a powerplant on the other side. There is no property to purchase that could be used for a
lagoon or to install equipment. All square footage inside of our building is also maxed out with production equipment and
cold storage. We simply do not have the space for additional equipment, and certainly have no space for a lagoon.
One other area where these regulations will impact small processors is in the relationship between the processors and
Tenderers. Small meat processors are already paying Tenderers to pick up their solid waste. The capital costs described in the
presentation for Tenderers would likely result in a further reduction of Tenderers, making disposing of solid waste even more
expensive.
I submit the following questions regarding the capital costs:
1. What specific equipment would be required to treat wastewater at a small processing plant?
2. Is any of the equipment scalable to small processing plants?
3. How would the EPA regulate plants that do not have the space to implement all the necessary wastewater
treatments?
Economic Impact to Small Meat Processing Facilities - Operation and Maintenance of Wasterwater Treatment
Equipment
The annual operating and maintenance costs noted on slides 18-22 were equally mind-boggling. The estimated annual costs
are between $402,000 and $769,000.1 estimate that the addition of those annual costs could increase my wages and
repairs/maintenance expenses by over 50%. Those costs alone would be the entirety of annual profits for me as a thriving
small meat processor and would likely result in a loss. Businesses that are not thriving would not have the cash to pay such
costs. I would not have the cash to pay those costs if I had to borrow money to implement the capital costs to meet regulatory
requirements.
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I am also concerned about how processors would find and retain the expertise needed to operate and maintain the equipment
needed to comply with the regulations. I am not familiar with most of the equipment listed within the presentation. Based on
the discussion during the meeting and the fact that the estimate to operate and maintain the equipment hovers around half of a
million dollars, it did not sound like the equipment would be easy to learn how to operate and maintain. Of the 40 people
employed at Boone's Butcher Shop, three of us have college degrees, and none of those degrees are in microbiology or water
management. Many small processors have no employees who have college degrees. Meat processing equipment is designed
to be operated and maintained by people who are trained within the plant and is not overly complicated. I do not believe that
many plants would have staff who have the availability or the skill to operate and maintain what sounds like complex
equipment. Small meat processors are already struggling with staffing and how to train people for the skilled manual labor of
slaughtering and cutting meat; there are very few resources for training available to us.
I submit the following questions regarding the operation and maintenance of the treatments needed to comply with potential
wastewater regulations:
1. What level of training or knowledge specifically is needed to operate and maintain the water treatment equipment
with the understanding that nearly all small plants would have very little prior understanding of the treatments
proposed? A 4-year degree, a 2-year degree, a 6-month course, a two-week course?
2. Does a workforce exist that can fill these roles?
3. To what degree does the EPA plan to provide technical assistance to small meat processors to comply with these
requirements?
Societal Impact of Regulating Wastewater in Small Meat Processing Plants
As I've outlined in my preceding comments, regulating wastewater in small meat processing plants would be detrimental to
the industry and would result in a widespread shuttering of hundreds of small meat processing plants across the country. I've
also provided comments on how highly concentrated the meat processing industry already is. In a capitalist market, such a
high concentration of the market is bad for both the producers (i.e. farmers) and for consumers. President Biden made
remarks to this exact effect on January 3, 2022, saying the following about the four big processers in the United States:
"Without meaningful competition, farmers and ranchers don't get to choose who they sell to. Or put
another way, our farmers and ranchers have to pay whatever these four big companies say they have to pay,
by and large. But that's only half of it. These companies can use their position as middlemen to overcharge
grocery stores and, ultimately, families ... I've said it before and I'll say it again: Capitalism without
competition isn't capitalism: it's exploitation ... To bring down - to bring in more competition and dignity
and more farmers, ranchers, and customers, we're going to invest in new and innovative small businesses
and meat processors the lifeblood of our economy. And when we do this, we'll give farmers and
ranchers more options beyond giant processing conglomerates, shore up the weak points in our food supply
chain."
Those remarks were made during a virtual meeting President Biden held to announce a $1 billion investment in new and
expanded meat and poultry processing (https://www.whitehouse.gov/briefing-room/speeches-remarks/2022/01/Q3/remarks-
bv-president-biden-during-a-virtual-meeting-to-discuss-boosting-competition-and-reducing-prices-in-the-meat-processing-
industry/). Unfortunately, we are at the tail end of the distribution of those funds. As I mentioned during the meeting on May
2nd, the last $75 million of grants is open for applications now through July 19, 2022. As small processors consider
expansion plans, they will not know that another massive amount of money may be needed two years from now to treat their
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wastewater. For larger grants, a 50% matching of funds is required. Many processors will take on debt to match the grant and
may not have the ability to borrow additional funds to implement this regulation.
The timing of proposed wastewater treatment regulations appears to be in direct conflict with the Biden-Harris
administration's efforts to expand meat processing capacity. This country is in the position where we are relying so heavily on
four main processors due to many factors - high barriers to entry, both economic and in knowledge and skill, high regulatory
compliance hurdles from both USDA's FSIS and OSHA, and a lack of workforce to support the industry- to name a few, that
the federal government is stepping in to level the playing field. Additional regulations of the magnitude discussed by the EPA
will cripple the small meat processing plants, putting the US back in the position we are trying to avoid - complete
dominance by a handful of meat and poultry processors. As we saw during 2020 and 2021, reliance on only those large
processors resulted in sky-high meat prices and near crippling of our food supply chain.
Small meat processors already struggle to compete with the large processors. We cannot slaughter and process meat on a
small scale nearly as efficiently as the large processors can on an enormous scale. We compete by adding the value to
consumers of allowing them to know where their meat comes from and in allowing farmers to market their meat directly to
consumers at farmer's markets, small independent grocery stores, and online. If we attempt to pass these costs on to our
customers, our products will no longer be competitive. The costs described in the presentation are pennies on the pound for
large processors. Those same costs are dollars on the pound for small processors. As much as American families want to
support their small, local farmers and processors, they will not be able to afford to pay those additional costs. The small
processors will go out of business and the farmers will be forced to accept whatever price the Big Four processors want to
pay for their livestock. The Big Four processors will get stronger, and we will be left with only the biggest processing plants
and the largest ranches to provide the animal protein American consumers demand.
I urge you to read the two articles I cited directly from The White Flouse's website describing the challenges this country is
facing in the meat processing industry. Obviously, clean water has a positive societal and global impact. Flowever, I hope you
will consider how harmful these regulations would be to the American public if their small, local processors no longer exist.
I submit the following questions regarding the societal impact of these regulations:
1. Would the EPA consider setting limits on who is impacted by the regulations (i.e. processing plants with less than
1,000 employees would be exempt from these regulations)?
2. Can changes be made to existing water treatments and/or water treatment facilities that would lessen the impact of
small meat processors' wastewater without requiring the small processors to pre-treat the water?
I appreciate your consideration of my comments and look forward to discussing this further in the formal panel discussion in
June. I am available to answer any questions or clarify comments prior to the meeting.
Sincerely,
Vice President and Co-Owner
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Missouri Association of Meat Processors
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PO Box 518 * Carthage, MO * 64836
417-237-0410 phone/text
niki@mamp.co * www.mamp.co
May 16, 2023
In response to the zoom meeting on May 2 in regards to potential regulatory action.
To start, thank you for allowing me to participate as a small entity representative. I
appreciate this opportunity as this potential action could significantly impact members of
the Missouri Association of Meat Processors (MAMP).
MAMP represents 145 small and very small meat processors in Missouri and
surrounding states. We define "small and very small" as less than 100 employees.
Some of our processors have 2 employees. Less than 2 dozen have more than 50
employees. In addition, with this small of a workforce equals a small amount of
processing levels. The levels discussed in the presentation are nowhere near the level
that MAMP members produce. MAMP urges the EPA to reconsider their definition
of "small and very small."
MAMP members have been exceedingly busy since spring 2020 due to the pandemic.
On top of that, the workforce is sparce. There is so much business, but not nearly
enough workers to do the work. MAMP members are struggling significantly to meet
their local community needs. Add to their already full plate this impending action and
this could greatly impact many aspects of their business that need immediate attention.
MAMP urges the EPA to reevaluate the implementation timeline of these potential
regulatory actions.
In addition to the potential this could happen quickly, the comprehension and
understanding of "what" the processor will need to do is overwhelming. They are going
to need significant technical support on understanding these rules and procedures. Is
the EPA willing to assist with this support? MAMP urges the EPA to highly consider
providing substantial technical support in understand and upholding these
actions.
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When meat processors received the surveys late summer/fall 2022, many were
confused by the questions and thought process behind the questions. MAMP does not
believe a true representation of processors sent in their results, therefore not giving the
EPA a fair and balanced viewpoint of small and very small processors. Furthermore,
looking at these businesses and reviewing the potential expected costs of the
implementation of the potential regulatory action is downright scary. EPA is talking
huge amounts that small businesses cannot feasibly finance in this short amount of
time. Processors have been blessed with many state and federal grant programs since
the pandemic to assist with further processing, but this potential action will be a
substantial financial burden. I speculate that some may even decide being in business
is not worth it. Implementation costs will be financially devastating to many of our
members resulting in the shutting of multi-generational small businesses. This will hit
home when local communities who support these businesses have to go elsewhere.
4H and FFA kids won't have a local meat processor to help them with projects and
educational experiences. Local food banks will not be able to rely on assistance from
programs such as Share the Harvest here in Missouri. MAMP urges the EPA to
reevaluate the cost to implementation.
MAMP appreciates the EPA considering these items while in this process. If MAMP can
be of any more assistance, please contact me.
Sincerely,
^ecfmicU
Niki Mahan-Cloud
Executive Director
Mark Reynolds
MAMP President
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U.S. Poultry and Egg Association
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"Pinpointing the Opportunities - Concentrating the Efforts"
USP1ULTRY
U.S. POULTRY & EGG ASSOCIATION
May 11, 2023
U.S. Poultry & Egg
Association
1530 Cooledge Road
Tucker, GA 30084-7303, USA
Telephone: 770.493.9401
Facsimile: 770.493.9257
www.uspoultry.org
Lanelle Wiggins
RFA/SBREFATeam Leader
US EPA - Office of Policy (1803A)
1200 Penn Ave NW
Washington DC 20460
RE: EPA Pre-Panel Outreach Meeting on Meat and Poultry Products Effluent
Limitations Guidelines Rulemaking
Ms. Wiggins,
Chairman
Jarod Morrison
Farbest Foods
Jasper, IN
Vice Chairman
Mikell Fries
Claxton Poultry Farms
Claxton, GA
Treasurer
Jonathan Cade
Hy-Line International
Des Moines, IA
Secretary
Bill Griffith
Peco Foods
Tuscaloosa, AL
Immediate Past Chairman
Mike Levengood
Perdue Farms
Salisbury, MD
On behalf of the U.S. Poultry & Egg Association's (USPOULTRY) members who are
classified as small entities, I would like to thank the US EPA Office of Policy for
convening a Small Business Advocacy Review Panel to address the Agency's potential
revision to Effluent Limitation Guidelines (ELGs) and development of pretreatment
standards (PTS) for the Meat and Poultry Products (MPP) Industry.
I also want to thank EPA for holding the Pre-Panel Outreach meeting on Tuesday
May 2, 2023 to provide an update on the ELG revision progress and accepting verbal
comments on how the potential revisions would affect small business entities. As
suggested during the May 2nd meeting, I am submitting the comments below as both
a follow-up to discussions that were held during the meeting and to reiterate issues
of concern for small businesses that would be affected by the development of PTS
and revisions to the ELGs.
As a general comment, you recall from the response of participants in the meeting
that the ramifications of the potential ELG revisions and development of PTS will be
significant. The financial investment scenarios presented during the meeting are
substantial and, in some cases, may be so prohibitive they would force a business to
close their doors.
President
John Starkey
U.S. Poultry & Egg Association
Tucker, GA
Our more detailed comments are as follows:
1) The Likely ELG Burden on Small Processors is Contrary to the Goal of the
Administration's Action Plan for Expanding Small Meat & Poultry Processors
- As underscored during the meeting, the current estimated costs for
wastewater treatment systems under the ELG would be unobtainable by
many smaller processors. One of the top priorities of the administration is
providing funding for and supporting the nationwide expansion of small
meat and poultry processors. However, the estimated costs associated with
the ELG for small processors' wastewater treatment systems could present a
major obstacle to achieving the administration's goals.
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2) Additional Small Processor Engagement - Additional outreach is needed to
get more small processors engaged and educated on the ELG process and
the potential impacts the revisions will have on business operations and
finances. As noted in the general comment above, the consequence of the
final revisions is substantial on many levels. This ELG revision process is being
expedited by the Consent Decree at an accelerated pace. The compressed
timeframe poses significant challenges for EPA and small entities...
3) POTW Community Engagement - Additional outreach to publicly owned
treatment works (POTWs) is needed to get a better understanding of the
potential impacts of small processor discharges, if any, on municipal
wastewater treatment systems. Our own industry discussions with the
National Association of Clean Water Agencies confirm that POTWs in their
membership largely have not identified the MPP industry as a primary cause
for their facilities failure to meet their discharge limitations, contrary to
statements to that effect in Program Plan 15. While it is possible there may
be concerns in some localities, these cases would not appear to be the
typical experience for POTWs across the nation.
4) POTW Relationship with MPP Facilities - Municipal wastewater treatment
plants are generally designed and operated to handle the pollutants
associated with MPP plants. As we have explained to the team leading the
ELG revision process, many municipal plants have strong and mutually
beneficial relationships with MPP plants, especially "small" MPP plants. It is
not uncommon for municipal wastewater treatment plans to rely on
surcharge fees they obtain from MPP plants to expand plant efficiencies and
simply cover expenses associated with daily operation. Eliminating these fees
may trigger higher water and sewer rates taxes for the citizens of these
communities.
5) EPA's Current Cost Estimates Must be Revised to Reflect Current
Engineering and Construction Trends - Information is needed pertaining to
EPA's estimated cost estimates for treatment system options to meet ELGs
for small processors. Costs for water and wastewater treatment systems
have significantly increased over the last several years and are continuing to
increase at a rapid pace. Do the EPA cost estimates sufficiently take these
increases into account? Other regulatory initiatives (e.g., PFAS, new lead and
copper rule, other new federal and state water pollution rules and
regulations, federal grants for water treatment system upgrades, etc.) are
also putting, and will continue to put, significant upward pressures on costs
for water treatment systems. The March 20/27, 2023, Engineering News-
Record magazine indicated an annualized total construction cost for "Sewage
and Water Disposal" and "Water Supply" projects increased by 15.6% and
16.0%, respectively (January 2022-January 2023) in the past year.
6) Outreach and Education for Small Processors - Additional outreach and
education are needed for small processors on wastewater treatment
technology, pollutants of concern, operational issues, residuals/waste
management, chloride waste stream management, etc. related to the
proposed ELGs. This recommendation was expressed by a member of the
Panel during the May 2nd meeting.
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7) Consideration of Other Environmental Factors - Deep well injection of
chloride waste streams is prohibited in certain areas (e.g., Minnesota) and
not practical in many others (a very challenging permitting process at best).
Practicality of the other options listed for chloride wastes (segregation and
management offsite and evaporation) are also questionable given costs
and/or availability in various areas. What about the air emission from
burning to evaporate high chloride waste streams? Shouldn't these other
environmental factors be included into the "equation"?
8) Determination of Actual POTW Impacts - EPA should perform mass
balances for chloride and other pollutants of concern (TN, TP) for small MPP
plants to determine if impacts on POTWs and associated effluent is
significant. If not, new ELG requirements and limitations should not be
required. This would provide the flexibility that was discussed during the
May 2nd meeting.
9) Analysis of Small Processors and "Further Processing" - Many of the small
processors are "further processing" meat products generated at other
plants. These different "further processed" products can result in a wide
range in wastewater characteristics. We are concerned that EPA may not
fully understand this aspect of the industry.
10) Analysis of Downstream Treatment Processes - EPA listed various
treatment trains to meet ELGs. Use of certain treatment units can have
impacts on downstream treatment processes and costs. Examples include:
Anaerobic processes will remove significant BOD/COD without any
total nitrogen removal. This can result in insufficient carbon for total
nitrogen removal in downstream activated sludge treatment
processes requiring purchase of external carbon sources.
Requirements for pretreatment systems to remove ammonia
nitrogen or total nitrogen (TN) requires advanced wastewater
treatment systems. The effluent from these systems will commonly
contain very low effluent BOD and TSS levels. This can cause
compliance (many POTWs have minimum removal requirements for
BOD and TSS) and/or operational issues for downstream POTWs.
Alkalinity and/or pH neutralization is required for biological
treatment systems, which can require the use of water treatment
chemicals that increase chloride, TDS, sodium, conductivity, etc.
levels in treated effluent.
Our concerns in this area prompt several questions, including:
Whether current EPA assumptions take these factors into account;
and
Whether EPA estimates for wastewater treatment systems include
costs for additional land acquisition or pump stations/pipelines to
transport wastewater to another site for treatment.
B1-17
-------
11) EPA Should Solicit Expertise from Other Federal and State Agencies - EPA
should reach out to other federal agencies on the ELG to address multiple
analytical and related issues:
USDA-FSIS/FDA - food safety requirements (water softeners for
hardness removal use of chlorinated food safety and sanitation
chemicals).
USDA provides grants/loans for wastewater treatment systems and
may be able to provide current cost data for water treatment
projects.
Other agencies that should be engaged include:
State Departments of Agriculture, USDA-NRCS [2023 EQUIP unit cost
payment rates - see attached), extension agencies.
12) Availability and Capacity of WWT Design and Operator Resources -
Advanced biological treatment systems require design professionals and
sophisticated operators. The ability of small processors to secure applicable
technical resources can be challenging at best. Various states require
licensing of operators, and we hear there are shortages of licensed operators
in many areas.
13) Closer Attention Must be Given to Small Flow Treatment Unit Costs -
Treatment unit costs ($/gallon) for small flows can be significantly higher
than those for the larger flows at the bigger processors. Do the EPA
economic assumptions take this into account?
14) Technical Support - Small processors need technical support and outreach
on environmental issues, which should be a major component of any
regulatory initiative for ELGs aimed at these small processors.
On behalf of USPOULTRY's members who are classified as small entities, I again
would like to thank the EPA Office of Policy for convening a Small Business Advocacy
Review Panel to address the Agency's potential revision to Effluent Limitation
Guidelines and development of pretreatment standards for the Meat and Poultry
Products Industry. Likewise, I would like to thank the EPA for seeking comments and
considering the observations and questions listed above.
Sincerely,
Paul J. Bredwell III, P.E.
Executive Vice President - Regulatory Programs
pbredwell@uspoultry.org
B1-18
-------
USDA United States Department of Agriculture
Natural Resources Conservation Service
Environmental Quality Incentives Program
Nebraska - Fiscal Year 2023
Code
Practice
Component
Units
Unit Cost
101
CNMP Design and
Implementation Activ
ty
Design- Dairy greater than 300 AU and less than 700 AU with Land Application
No
$8,462.63
101
CNMP Design and
Implementation Activ
ty
HU-Design- Dairy greater than 300 AU and less than 700 AU with Land Application
No
$10,155.15
101
CNMP Design and
Implementation Activ
ty
Design- Dairy greater than or equal to 700 AU with Land Application
No
$9,429.21
101
CNMP Design and
Implementation Activ
ty
HU-Design- Dairy greater than or equal to 700 AU with Land Application
No
$11,315.05
101
CNMP Design and
Implementation Activ
ty
Design- Dairy less than 300 AU Land Application
No
$7,975.95
101
CNMP Design and
Implementation Activ
ty
HU-Design- Dairy less than 300 AU Land Application
No
$9,571.14
101
CNMP Design and
Implementation Activ
ty
Design- Livestock Operations greater than 300 AU without Land Application
No
$5,606.78
101
CNMP Design and
Implementation Activ
ty
HU-Design- Livestock Operations greater than 300 AU without Land Application
No
$6,728.13
101
CNMP Design and
Implementation Activ
ty
Design- Livestock Operations greater than 300 AU without Land Application and Minimal
Engineering
No
$3,697.35
101
CNMP Design and
Implementation Activity
HU-Design- Livestock Operations greater than 300 AU without Land Application and Minimal
Engineering
No
$4,436.82
101
CNMP Design and
Implementation Activity
Design- Livestock Operations less than or equal to 300 AU without Land Application and
Minimal Engineering
No
$4,995.15
101
CNMP Design and
Implementation Activity
HU-Design- Livestock Operations less than or equal to 300 AU without Land Application and
Minimal Engineering
No
$5,994.18
101
CNMP Design and
Implementation Activity
Design- Non Dairy Operation greater 700 AU with Land Application
No
$9,584.67
101
CNMP Design and
Implementation Activity
HU-Design- Non Dairy Operation greater 700 AU with Land Application
No
$11,501.60
101
CNMP Design and
Implementation Activity
Design- Non Dairy Operation greater than 300 AU and less than 700 AU with Land Application
No
$7,989.48
101
CNMP Design and
Implementation Activity
HU-Design- Non Dairy Operation greater than 300 AU and less than 700 AU with Land
Application
No
$9,587.38
101
CNMP Design and
Implementation Activity
Design- Non Dairy Operation Less than 300 AU with Land Application
No
$7,127.69
101
CNMP Design and
Implementation Activity
HU-Design- Non Dairy Operation Less than 300 AU with Land Application
No
$8,553.22
101
CNMP Design and
Implementation Activity
Design- Small Livestock Operations greater than 300 AU with Land Application and Minimal
Engineering
No
$6,546.44
101
CNMP Design and
Implementation Activity
HU-Design- Small Livestock Operations greater than 300 AU with Land Application and
Minimal Engineering
No
$7,855.72
101
CNMP Design and
Implementation Activity
Design- Small Livestock Operations less than 300 AU with Land Application and Minimal
No
$5,157.38
Environmental Quality Incentives Program
B1fifge 1 of 29
Nebraska - Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
-in-i ji i 4.4.- a 4.- *. HU-Design- Small Livestock Operations less than 300 AU with Land Application and Minimal .. &r.loool-
101 CNMP Design and Implementation Activity r . . ^ ^ No $6,188.85
& ^ ' Engineering
101 CNMP Design and Implementation Activity Design- Small Livestock Operations less than 300 AU without Land Application No $5,150.54
101 CNMP Design and Implementation Activity HU-Design-Small Livestock Operations less than 300 AU without Land Application No $6,180.65
101 CNMP Design and Implementation Activity Design-CNMP Revision No $3,633.15
101 CNMP Design and Implementation Activity HU-Design-CNMP Revision No $4,359.78
102 Comprehensive Nutrient Management Plan Planning Dairy Greater than 300 AU, less than 700 AU with Land No $7,050.75
102 Comprehensive Nutrient Management Plan HU-Planning Dairy Greater than 300 AU, less than 700 AU with Land No $8,460.90
102 Comprehensive Nutrient Management Plan Planning Dairy Greater than 700 AU with Land No $8,849.55
102 Comprehensive Nutrient Management Plan HU-Planning Dairy Greater than 700 AU with Land No $10,619.46
102 Comprehensive Nutrient Management Plan Planning Dairy Less than 300 AU with Land No $5,957.03
102 Comprehensive Nutrient Management Plan HU-Planning Dairy Less than 300 AU with Land No $7,148.43
102 Comprehensive Nutrient Management Plan Planning Livestock Greater than 300 AU, less than 700 AU with Land No $6,589.88
102 Comprehensive Nutrient Management Plan HU-Planning Livestock Greater than 300 AU, less than 700 AU with Land No $7,907.85
102 Comprehensive Nutrient Management Plan Planning Livestock Greater than 300 AU, No-Land No $5,251.95
102 Comprehensive Nutrient Management Plan HU-Planning Livestock Greater than 300 AU, No-Land No $6,302.34
102 Comprehensive Nutrient Management Plan Planning Livestock Greater than 700 AU with Land No $8,000.03
102 Comprehensive Nutrient Management Plan HU-Planning Livestock Greater than 700 AU with Land No $9,600.03
102 Comprehensive Nutrient Management Plan Planning Livestock Less than 300 AU with Land No $4,897.70
102 Comprehensive Nutrient Management Plan HU-Planning Livestock Less than 300 AU with Land No $5,877.23
102 Comprehensive Nutrient Management Plan Planning Livestock Less than 300 AU, No-Land No $3,841.80
102 Comprehensive Nutrient Management Plan HU-Planning Livestock Less than 300 AU, No-Land No $4,610.16
106 Forest Management Plan FMP101 to 250 acres No $2,898.00
106 Forest Management Plan HU-FMP101 to 250 acres No $3,477.60
106 Forest Management Plan FMP 21 to 100 acres No $1,764.00
106 Forest Management Plan HU-FMP 21 to 100 acres No $2,116.80
106 Forest Management Plan FMP 251 to 500 acres No $4,284.00
106 Forest Management Plan HU-FMP 251 to 500 acres No $5,140.80
106 Forest Management Plan FMP 501 to 1000 acres No $5,229.00
106 Forest Management Plan HU-FMP 501 to 1000 acres No $6,274.80
Environmental Quality Incentives Program
BiP2gge2of 29
Nebraska -
Fiscal Year 2023
-------
Code Practice
106 Forest Management Plan
106 Forest Management Plan
106 Forest Management Plan
106 Forest Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
110 Grazing Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
116 Soil Health Management Plan
Environmental Quality Incentives Program
Component
FMP Greater Than 1000 acres
HU-FMP Greater Than 1000 acres
FMP Less Than or Equal to 20 acres
HU-FMP Less Than or Equal to 20 acres
Conservation Plan for Grazed Lands <100 acres.
HU-Conservation Plan for Grazed Lands <100 acres.
Conservation Plan for Grazed Lands >10,000 acres
HU-Conservation Plan for Grazed Lands >10,000 acres
Conservation Plan for Grazed Lands 1,501 to 5,000 acres
HU-Conservation Plan for Grazed Lands 1,501 to 5,000 acres
Conservation Plan for Grazed Lands 101 to 500 acres
HU-Conservation Plan for Grazed Lands 101 to 500 acres
Conservation Plan for Grazed Lands 5,001 to 10,000 acres
HU-Conservation Plan for Grazed Lands 5,001 to 10,000 acres
Conservation Plan for Grazed Lands 501 to 1,500 acres
HU-Conservation Plan for Grazed Lands 501 to 1,500 acres
Crops, <5
HU-Crops, <5
Crops, 5 or more
HU-Crops, 5 or more
Crops+Livestock, <5
HU-Crops+Livestock, <5
Crops+Livestock, 5 or more
HU-Crops+Livestock, 5 or more
Organic Crops + Livestock, <5
HU-Organic Crops + Livestock, <5
Organic Crops + Livestock, 5 or more
HU-Organic Crops + Livestock, 5 or more
Organic Crops, <5
Units
No"
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Unit Cost
$6,804.00
$8,164.80
$1,197.00
$1,436.40
$1,841.04
$2,209.25
$4,142.34
$4,970.81
$3,221.82
$3,866.18
$2,301.30
$2,761.56
$3,682.08
$4,418.50
$2,761.56
$3,313.87
$1,392.27
$1,670.72
$1,771.98
$2,126.38
$1,518.84
$1,822.61
$1,898.55
$2,278.26
$2,151.69
$2,582.03
$2,278.26
$2,733.91
$1,645.41
B1R^ge 3 of 29
Nebraska
- Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
116 Soil Health Management Plan HU-Organic Crops, <5 No $1,974.49
116 Soil Health Management Plan Organic Crops, 5 or more No $2,025.12
116 Soil Health Management Plan HU-Organic Crops, 5 or more No $2,430.14
116 Soil Health Management Plan Small Farm No $1,265.70
116 Soil Health Management Plan HU-Small Farm No $1,518.84
120 Agricultural Energy Design High Complexity, 1 Design No $4,439.66
120 Agricultural Energy Design HU-High Complexity, 1 Design No $5,327.59
120 Agricultural Energy Design High Complexity, 2-3 Designs No $5,650.46
120 Agricultural Energy Design HU-High Complexity, 2-3 Designs No $6,780.55
120 Agricultural Energy Design High Complexity, 4-5 Designs No $6,861.26
120 Agricultural Energy Design HU-High Complexity, 4-5 Designs No $8,233.51
120 Agricultural Energy Design High Complexity, 6+ Designs No $8,072.06
120 Agricultural Energy Design HU-High Complexity, 6+Designs No $9,686.47
120 Agricultural Energy Design Low Complexity, 1 Design No $2,233.46
120 Agricultural Energy Design HU-Low Complexity, 1 Design No $2,680.15
120 Agricultural Energy Design Low Complexity, 2-3 Designs No $3,444.26
120 Agricultural Energy Design HU-Low Complexity, 2-3 Designs No $4,133.11
120 Agricultural Energy Design Low Complexity, 4-5 Designs No $4,655.06
120 Agricultural Energy Design HU-Low Complexity, 4-5 Designs No $5,586.07
120 Agricultural Energy Design Low Complexity, 6+Designs No $5,865.86
120 Agricultural Energy Design HU-Low Complexity, 6+Designs No $7,039.03
120 Agricultural Energy Design Medium Complexity, 1 Design No $3,336.56
120 Agricultural Energy Design HU-Medium Complexity, 1 Design No $4,003.87
120 Agricultural Energy Design Medium Complexity, 2-3 Designs No $4,547.36
120 Agricultural Energy Design HU-Medium Complexity, 2-3 Designs No $5,456.83
120 Agricultural Energy Design Medium Complexity, 4-5 Designs No $5,758.16
120 Agricultural Energy Design HU-Medium Complexity, 4-5 Designs No $6,909.79
120 Agricultural Energy Design Medium Complexity, 6+ Designs No $6,968.96
120 Agricultural Energy Design HU-Medium Complexity, 6+Designs No $8,362.75
Environmental Quality Incentives Program
B1P2fge4of 29
Nebraska -
Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
138
Conservation Plan Supporting Organic Transition
Conservation Plan Supporting Organic Transition CAP Crops and Livestock
No
$4,746.38
138
Conservation Plan Supporting Organic Transition
HU-Conservation Plan Supporting Organic Transition CAP Crops and Livestock
No
$5,695.65
138
Conservation Plan Supporting Organic Transition
Conservation Plan Supporting Organic Transition CAP Crops or Livestock
No
$4,050.24
138
Conservation Plan Supporting Organic Transition
HU-Conservation Plan Supporting Organic Transition CAP Crops or Livestock
No
$4,860.29
138
Conservation Plan Supporting Organic Transition
Transition to Organic- Crop and Livestock, High Complexity
No
$6,933.83
138
Conservation Plan Supporting Organic Transition
HU-Transition to Organic- Crop and Livestock, High Complexity
No
$8,320.59
138
Conservation Plan Supporting Organic Transition
Transition to Organic- Crop and Livestock, Low Complexity
No
$4,746.38
138
Conservation Plan Supporting Organic Transition
HU-Transition to Organic- Crop and Livestock, Low Complexity
No
$5,695.65
138
Conservation Plan Supporting Organic Transition
Transition to Organic- Crop, High Complexity
No
$4,746.38
138
Conservation Plan Supporting Organic Transition
HU-Transition to Organic- Crop, High Complexity
No
$5,695.65
138
Conservation Plan Supporting Organic Transition
Transition to Organic- Crop, Low Complexity
No
$4,113.53
138
Conservation Plan Supporting Organic Transition
HU-Transition to Organic- Crop, Low Complexity
No
$4,936.23
138
Conservation Plan Supporting Organic Transition
Transition to Organic-Livestock, High Complexity
No
$6,617.40
138
Conservation Plan Supporting Organic Transition
HU-Transition to Organic-Livestock, High Complexity
No
$7,940.88
138
Conservation Plan Supporting Organic Transition
Transition to Organic-Livestock, Low Complexity
No
$4,429.95
138
Conservation Plan Supporting Organic Transition
HU-Transition to Organic-Livestock, Low Complexity
No
$5,315.94
140
Transition to Organic Design
High Complexity, 1 -4 CPS
No
$9,328.22
140
Transition to Organic Design
HU-High Complexity, 1 -4 CPS
No
$11,193.86
140
Transition to Organic Design
High Complexity, 5+ CPS
No
$12,032.16
140
Transition to Organic Design
HU-High Complexity, 5+ CPS
No
$14,438.59
140
Transition to Organic Design
Low Complexity 1-4 CPS
No
$3,628.34
140
Transition to Organic Design
HU-Low Complexity 1-4 CPS
No
$4,354.00
140
Transition to Organic Design
Low Complexity, 5+ CPS
No
$7,207.14
140
Transition to Organic Design
HU-Low Complexity, 5+ CPS
No
$8,648.57
144
Fish and Wildlife Habitat Design
Fish & Wildlife Habitat DIA
No
$2,401.38
144
Fish and Wildlife Habitat Design
HU-Fish & Wildlife Habitat DIA
No
$2,881.66
144
Fish and Wildlife Habitat Design
Fish & Wildlife Habitat DIA (2 Land Uses)
No
$2,935.02
144
Fish and Wildlife Habitat Design
HU-Fish & Wildlife Habitat DIA (2 Land Uses)
No
$3,522.02
144
Fish and Wildlife Habitat Design
Fish & Wildlife Habitat DIA (3 or More Land Uses)
No
$3,468.66
Environmental Quality Incentives Program
BiP2fge5of 29
Nebraska -
Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
144 Fish and Wildlife Habitat Design HU-Fish & Wildlife Habitat DIA (3 or More Land Uses) No $4,162.39
148 Pollinator Habitat Design Pollinator Habitat Enhancement Plan CAP No $2,801.61
148 Pollinator Habitat Design HU-Pollinator Habitat Enhancement Plan CAP No $3,361.93
148 Pollinator Habitat Design Pollinator Habitat Enhancement Plan CAP - No Local TSP No $4,069.01
148 Pollinator Habitat Design HU-Pollinator Habitat Enhancement Plan CAP - No Local TSP No $4,882.81
157 Nutrient Management Design and Implementation Activity Design Nutrient Management for 101 to less than 300 Acres and No Manure No $3,244.50
157 Nutrient Management Design and Implementation Activity HU-Design Nutrient Management for 101 to less than 300 Acres and No Manure No $3,893.40
157 Nutrient Management Design and Implementation Activity Design Nutrient Management for greater than 101 Acres and less than or equal to 300 Acres No $5,677.88
Fertilizer and Manure
157 Nutrient Management Design and Implementation Activity HU-Design Nutrient Management for greater than 101 Acres and less than or equal to 300 No $6,813.45
Acres Fertilizer and Manure
157 Nutrient Management Design and Implementation Activity Design Nutrient Management for greater than 300 Acres and No Manure No $4,055.63
157 Nutrient Management Design and Implementation Activity HU-Design Nutrient Management for greater than 300 Acres and No Manure No $4,866.75
157 Nutrient Management Design and Implementation Activity Design Nutrient Management for greater than 300 Acres Fertilizer and Manure No $6,894.56
157 Nutrient Management Design and Implementation Activity HU-Design Nutrient Management for greater than 300 Acres Fertilizer and Manure No $8,273.48
157 Nutrient Management Design and Implementation Activity Design Nutrient Management for less than or equal to 100 Acres and No Manure No $2,433.38
157 Nutrient Management Design and Implementation Activity HU-Design Nutrient Management for less than or equal to 100 Acres and No Manure No $2,920.05
157 Nutrient Management Design and Implementation Activity Design Nutrient Management for less than or equal to 100 Acres Fertilizer and Manure No $4,055.63
157 Nutrient Management Design and Implementation Activity HU-Design Nutrient Management for less than or equal to 100 Acres Fertilizer and Manure No $4,866.75
158 Feed Management Design Feed Management Plan No $3,244.50
158 Feed Management Design HU-Feed Management Plan No $3,893.40
159 Grazing Management Design Design and Implementation Activities for Grazed Lands <100 acres No $1,227.36
159 Grazing Management Design HU-Design and Implementation Activities for Grazed Lands <100 acres No $1,472.83
159 Grazing Management Design Design and Implementation Activities for Grazed Lands >10,000 acres No $2,761.56
159 Grazing Management Design HU-Design and Implementation Activities for Grazed Lands >10,000 acres No $3,313.87
159 Grazing Management Design Design and Implementation Activities for Grazed Lands 1,501 to 5,000 acres No $2,147.88
159 Grazing Management Design HU-Design and Implementation Activities for Grazed Lands 1,501 to 5,000 acres No $2,577.46
159 Grazing Management Design Design and Implementation Activities for Grazed Lands 101 to 500 acres No $1,534.20
159 Grazing Management Design HU-Design and Implementation Activities for Grazed Lands 101 to 500 acres No $1,841.04
159 Grazing Management Design Design and Implementation Activities for Grazed Lands 5,001 to 10,000 acres No $2,454.72
Environmental Quality Incentives Program
B1P2^ge 6 of 29
Nebraska - Fiscal Year 2023
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Code Practice Component Units Unit Cost
159 Grazing Management Design HU-Design and Implementation Activities for Grazed Lands 5,001 to 10,000 acres No $2,945.66
159 Grazing Management Design Design and Implementation Activities for Grazed Lands 501 to 1,500 acres No $1,841.04
159 Grazing Management Design HU-Design and Implementation Activities for Grazed Lands 501 to 1,500 acres No $2,209.25
160 Prescribed Burning Design Prescribed Burning Plan (DIA) greater than 1,000 acres No $3,780.00
160 Prescribed Burning Design HU-Prescribed Burning Plan (DIA) greater than 1,000 acres No $4,536.00
160 Prescribed Burning Design Prescribed Burning Plan (DIA) greater than 101 acres and less than 250 acres No $1,575.00
160 Prescribed Burning Design HU-Prescribed Burning Plan (DIA) greater than 101 acres and less than 250 acres No $1,890.00
160 Prescribed Burning Design Prescribed Burning Plan (DIA) greater than 21 acres and less than 100 acres No $1,260.00
160 Prescribed Burning Design HU-Prescribed Burning Plan (DIA) greater than 21 acres and less than 100 acres No $1,512.00
160 Prescribed Burning Design Prescribed Burning Plan-DIA greater than 251 acres and less than 500 acres No $1,890.00
160 Prescribed Burning Design HU-Prescribed Burning Plan-DIA greater than 251 acres and less than 500 acres No $2,268.00
160 Prescribed Burning Design Prescribed Burning Plan DIA less than or equal to 20 acres No $945.00
160 Prescribed Burning Design HU-Prescribed Burning Plan DIA less than or equal to 20 acres No $1,134.00
160 Prescribed Burning Design Prescribed Burning Plan-DIA greater than 501 acres and less than 1,000 acres No $2,520.00
160 Prescribed Burning Design HU-Prescribed Burning Plan-DIA greater than 501 acres and less than 1,000 acres No $3,024.00
161 Pest Management Conservation System Design High Complexity, 1 -4 CPS No $5,063.84
161 Pest Management Conservation System Design HU-High Complexity, 1 -4 CPS No $6,076.60
161 Pest Management Conservation System Design High Complexity, 5+ CPS No $6,243.78
161 Pest Management Conservation System Design HU-High Complexity, 5+ CPS No $7,492.54
161 Pest Management Conservation System Design Low Complexity 1-4 CPS No $2,384.66
161 Pest Management Conservation System Design HU-Low Complexity 1-4 CPS No $2,861.59
161 Pest Management Conservation System Design Low Complexity, 5+ CPS No $3,564.60
161 Pest Management Conservation System Design HU-Low Complexity, 5+CPS No $4,277.52
162 Soil Health Management System Design Crops + Livestock, <5 No $3,244.50
162 Soil Health Management System Design HU-Crops + Livestock, <5 No $3,893.40
162 Soil Health Management System Design Crops + Livestock, 5 or more No $4,055.63
162 Soil Health Management System Design HU-Crops + Livestock, 5 or more No $4,866.75
162 Soil Health Management System Design Crops, <5 No $3,082.28
162 Soil Health Management System Design HU-Crops, <5 No $3,698.73
Environmental Quality Incentives Program
BiPjge7of 29
Nebraska -
Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
162
Soil Health Management System Design
Crops, 5 or more
No
$3,731.18
162
Soil Health Management System Design
HU-Crops, 5 or more
No
$4,477.41
162
Soil Health Management System Design
Organic Crops + Livestock, <5
No
$5,191.20
162
Soil Health Management System Design
HU-Organic Crops + Livestock, <5
No
$6,229.44
162
Soil Health Management System Design
Organic Crops + Livestock, 5 or more
No
$6,489.00
162
Soil Health Management System Design
HU-Organic Crops + Livestock, 5 or more
No
$7,786.80
162
Soil Health Management System Design
Organic Crops, <5
No
$3,568.95
162
Soil Health Management System Design
HU-Organic Crops, <5
No
$4,282.74
162
Soil Health Management System Design
Organic Crops, 5 or more
No
$4,866.75
162
Soil Health Management System Design
HU-Organic Crops, 5 or more
No
$5,840.10
162
Soil Health Management System Design
Small Farm
No
$2,433.38
162
Soil Health Management System Design
HU-Small Farm
No
$2,920.05
163
Irrigation Water Management Design
1-2 Designs - With Pump Test
No
$6,104.01
163
Irrigation Water Management Design
HU-1-2 Designs - With Pump Test
No
$7,324.81
163
Irrigation Water Management Design
1-2 Designs - Without Pump Test
No
$5,131.17
163
Irrigation Water Management Design
HU-1-2 Designs - Without Pump Test
No
$6,157.40
163
Irrigation Water Management Design
3 or More Designs - With Pump Test
No
$9,695.90
163
Irrigation Water Management Design
HU-3 or More Designs - With Pump Test
No
$11,635.07
163
Irrigation Water Management Design
3 or More Designs - Without Pump Test
No
$8,372.06
163
Irrigation Water Management Design
HU-3 or More Designs - Without Pump Test
No
$10,046.47
164
Improved Management of Drainage Water Design
1-2 Designs - No Tile Map Available
No
$6,833.97
164
Improved Management of Drainage Water Design
HU-1-2 Designs - No Tile Map Available
No
$8,200.76
164
Improved Management of Drainage Water Design
1-2 Designs - Tile Map Available
No
$5,015.61
164
Improved Management of Drainage Water Design
HU-1-2 Designs - Tile Map Available
No
$6,018.73
164
Improved Management of Drainage Water Design
3 or More Designs - No Tile Map Available
No
$8,589.68
164
Improved Management of Drainage Water Design
HU-3 or More Designs - No Tile Map Available
No
$10,307.61
164
Improved Management of Drainage Water Design
3 or More Designs - Tile Map Available
No
$7,887.68
164
Improved Management of Drainage Water Design
HU-3 or More Designs - Tile Map Available
No
$9,465.21
165
Forest Management Practice Design
DIA 101 to 250 acres
No
$756.00
Environmental Quality Incentives Program
B1P2fge8of 29
Nebraska -
Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
165 Forest Management Practice Design HU-DIA101 to 250 acres No $907.20
165 Forest Management Practice Design DIA 21 to 100 acres No $504.00
165 Forest Management Practice Design HU-DIA 21 to 100 acres No $604.80
165 Forest Management Practice Design DIA 251 to 500 acres No $1,008.00
165 Forest Management Practice Design HU-DIA 251 to 500 acres No $1,209.60
165 Forest Management Practice Design DIA 501 to 1000 acres No $1,197.00
165 Forest Management Practice Design HU-DIA 501 to 1000 acres No $1,436.40
165 Forest Management Practice Design DIA Greater Than 1000 acres No $1,449.00
165 Forest Management Practice Design HU-DIA Greater Than 1000 acres No $1,738.80
165 Forest Management Practice Design DIA Less Than or Equal to 20 acres No $315.00
165 Forest Management Practice Design HU-DIA Less Than or Equal to 20 acres No $378.00
199 Conservation Plan High Complexity Plan, <200 acres No $6,085.44
199 Conservation Plan HU-High Complexity Plan, <200 acres No $7,302.53
199 Conservation Plan High Complexity Plan, >1,000 acres No $8,557.34
199 Conservation Plan HU-High Complexity Plan, >1,000 acres No $10,268.80
199 Conservation Plan High Complexity Plan, 200-1,000 acres No $7,415.69
199 Conservation Plan HU-High Complexity Plan, 200-1,000 acres No $8,898.82
199 Conservation Plan Low Complexity Plan, <200 acres No $3,100.50
199 Conservation Plan HU-Low Complexity Plan, <200 acres No $3,720.60
199 Conservation Plan Low Complexity Plan, >1,000 acres No $6,085.44
199 Conservation Plan HU-Low Complexity Plan, >1,000 acres No $7,302.53
199 Conservation Plan Low Complexity Plan, 200-1,000 acres No $4,566.60
199 Conservation Plan HU-Low Complexity Plan, 200-1,000 acres No $5,479.92
199 Conservation Plan Medium Complexity Plan, <200 acres No $4,566.60
199 Conservation Plan HU-Medium Complexity Plan, <200 acres No $5,479.92
199 Conservation Plan Medium Complexity Plan, >1,000 acres No $7,415.69
199 Conservation Plan HU-Medium Complexity Plan, >1,000 acres No $8,898.82
199 Conservation Plan Medium Complexity Plan, 200-1,000 acres No $6,085.44
199 Conservation Plan HU-Medium Complexity Plan, 200-1,000 acres No $7,302.53
Environmental Quality Incentives Program
B1P2^ge 9 of 29
Nebraska -
Fiscal Year 2023
-------
Code Practice
199 Conservation Plan
199 Conservation Plan
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
201 Edge-of-Field Water Qua
Evaluation
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
ity Monitoring-Data Collection and
Environmental Quality Incentives Program
Component Units Unit Cost
Small Farm - less than or equal to 10 acres No $2,445.53
HU-Small Farm - less than or equal to 10 acres No $2,934.63
Data Collect Surface Last Year No $21,123.68
HU-Data Collect Surface Last Year No $25,348.42
Data Collect Surface Last Year with two treatment sites No $30,643.34
HU-Data Collect Surface Last Year with two treatment sites No $36,772.01
Data Collect Surface Year 1 plus - NO QAPP No $17,768.48
HU-Data Collect Surface Year 1 plus-NO QAPP No $21,322.18
Data Collect Surface Year 1+ less QAPP (pre-install information) with two treatment sites No $25,610.54
HU-Data Collect Surface Year 1+ less QAPP (pre-install information) with two treatment sites No $30,732.65
Data Collect Surface Year 1-QAPP No $24,143.36
HU-Data Collect Surface Year 1-QAPP No $28,972.03
Data Collect Surface Year 1-QAPP with two treatment Sites No $33,495.26
HU-Data Collect Surface Year 1-QAPP with two treatment Sites No $40,194.32
Data Collect Tile Last Year No $47,027.09
HU-Data Collect Tile Last Year No $56,432.50
Data Collect Tile Last Year with two treatment sites No $67,761.49
B1P2gge 10 of 29
Nebraska - Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
201
Edge-of-Field Water Qual
Evaluation
ty Monitoring-Data Co
lection and
HU-Data Collect Tile Last Year with two treatment sites
No
$81,313.79
201
Edge-of-Field Water Qual
Evaluation
ty Monitoring-Data Co
lection and
Data Collect Tile Year 1 plus - NO QAPP
No
$43,671.89
201
Edge-of-Field Water Qual
Evaluation
ty Monitoring-Data Co
lection and
HU-Data Collect Tile Year 1 plus - NO QAPP
No
$52,406.26
201
Edge-of-Field Water Qual
Evaluation
ty Monitoring-Data Co
lection and
Data Collect Tile Year 1+ less QAPP (pre-install information) with two treatment sites
No
$62,728.69
201
Edge-of-Field Water Qual
Evaluation
ty Monitoring-Data Co
lection and
HU-Data Collect Tile Year 1+ less QAPP (pre-install information) with two treatment sites
No
$75,274.43
201
Edge-of-Field Water Qual
Evaluation
ty Monitoring-Data Co
lection and
Data Collect Tile Year 1-QAPP
No
$50,046.77
201
Edge-of-Field Water Qual
Evaluation
ty Monitoring-Data Co
lection and
HU-Data Collect Tile Year 1-QAPP
No
$60,056.12
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Above And Below
No
$30,026.08
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
HU-System Installation-Above And Below
No
$36,031.29
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Above And Below cold climate
No
$32,913.42
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
HU-System Installation-Above And Below cold climate
No
$39,496.11
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Retrofit 1
No
$3,781.18
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
HU-System Installation-Retrofit 1
No
$4,537.42
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Retrofit 2
No
$8,190.82
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
HU-System Installation-Retrofit 2
No
$9,828.98
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Retrofit 3
No
$10,894.61
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
HU-System Installation-Retrofit 3
No
$13,073.54
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Retrofit Above 3
No
$17,949.67
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
HU-System Installation-Retrofit Above 3
No
$21,539.60
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Retrofit Above and Below 1
No
$4,280.26
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
HU-System Installation-Retrofit Above and Below 1
No
$5,136.31
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Surface
No
$22,003.01
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
HU-System Installation-Surface
No
$26,403.62
202
Edge-of-Field Water Qual
ty Monitoring-System
nsta
ation
System Installation-Surface Cold Climate
No
$22,581.94
Environmental Quality Incentives Program
BiPjgellof 29
Nebraska - Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
202 Edge-of-Field Water Quality Monitoring-System Installation HU-System Installation-Surface Cold Climate No $27,098.32
202 Edge-of-Field Water Quality Monitoring-System Installation System Installation-Tile No $29,962.69
202 Edge-of-Field Water Quality Monitoring-System Installation HU-System Installation-Tile No $35,955.23
202 Edge-of-Field Water Quality Monitoring-System Installation System Installation-Tile Cold Climate No $29,962.69
202 Edge-of-Field Water Quality Monitoring-System Installation HU-System Installation-Tile Cold Climate No $35,955.23
207 Site Assessment and Soil Testing for Contaminants Activity Site Evaluation and Soil Testing for Contaminants No $10,065.60
207 Site Assessment and Soil Testing for Contaminants Activity HU-Site Evaluation and Soil Testing for Contaminants No $12,078.72
207 Site Assessment and Soil Testing for Contaminants Activity Site Evaluation for Potential Contaminants No $3,355.20
207 Site Assessment and Soil Testing for Contaminants Activity HU-Site Evaluation for Potential Contaminants No $4,026.24
207 Site Assessment and Soil Testing for Contaminants Activity Soil Testing and Subsurface Investigation No $6,710.40
207 Site Assessment and Soil Testing for Contaminants Activity HU-Soil Testing and Subsurface Investigation No $8,052.48
207 Site Assessment and Soil Testing for Contaminants Activity Soil Testing for Contaminants on Low Risk Sites kSqFt $131.93
207 Site Assessment and Soil Testing for Contaminants Activity HU-Soil Testing for Contaminants on Low Risk Sites kSqFt $158.32
209 PFAS Testing in Water or Soil PFAS Testing: Complicated (High Complexity) Sampling - Multiple Samples No $789.65
209 PFAS Testing in Water or Soil HU-PFAS Testing: Complicated (High Complexity) Sampling - Multiple Samples No $947.58
209 PFAS Testing in Water or Soil PFAS Testing: Simple (Low Complexity) Sampling - Single Sample No $923.86
209 PFAS Testing in Water or Soil HU-PFAS Testing: Simple (Low Complexity) Sampling - Single Sample No $1,108.63
209 PFAS Testing in Water or Soil PFAS Testing: Simple (Low Complexity) Sampling - Multiple Samples No $655.44
209 PFAS Testing in Water or Soil HU-PFAS Testing: Simple (Low Complexity) Sampling - Multiple Samples No $786.53
216 Soil Health Testing Basic Soil Health Suite No $112.29
216 Soil Health Testing HU-Basic Soil Health Suite No $134.75
216 Soil Health Testing Basic Soil Health Suite - No Labor No $98.93
216 Soil Health Testing HU-Basic Soil Health Suite - No Labor No $118.72
216 Soil Health Testing Basic Soil Health Suite + Chemical No $154.21
216 Soil Health Testing HU-Basic Soil Health Suite + Chemical No $185.05
216 Soil Health Testing Basic Soil Health Suite + Comprehensive Chemical - No Labor No $140.85
216 Soil Health Testing HU-Basic Soil Health Suite + Comprehensive Chemical - No Labor No $169.02
216 Soil Health Testing Single Indicator - No Labor No $40.55
216 Soil Health Testing HU-Single Indicator - No Labor No $48.66
Environmental Quality Incentives Program
BiP3gge 12 of 29
Nebraska - Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
216
Soil Health Testing
Soil Health and Dynamic Soil Properties
No
$2,021.28
216
Soil Health Testing
HU-Soil Health and Dynamic Soil Properties
No
$2,425.54
217
Soil and Source Testing for Nutrient Management
Manure or Compost Only
No
$783.33
217
Soil and Source Testing for Nutrient Management
HU-Manure or Compost Only
No
$940.00
217
Soil and Source Testing for Nutrient Management
Small scale - Soil and Nutrient Source Test
No
$340.06
217
Soil and Source Testing for Nutrient Management
HU-Small scale - Soil and Nutrient Source Test
No
$408.07
217
Soil and Source Testing for Nutrient Management
Soil and Source Material Test
No
$2,692.44
217
Soil and Source Testing for Nutrient Management
HU-Soil and Source Material Test
No
$3,230.92
217
Soil and Source Testing for Nutrient Management
Soil Test Only
No
$667.91
217
Soil and Source Testing for Nutrient Management
HU-Soil Test Only
No
$801.49
217
Soil and Source Testing for Nutrient Management
Soil Test Only Garden Plots/Raised Beds
No
$430.78
217
Soil and Source Testing for Nutrient Management
HU-Soil Test Only Garden Plots/Raised Beds
No
$516.93
217
Soil and Source Testing for Nutrient Management
Soil Test- pH Emphasis
No
$186.60
217
Soil and Source Testing for Nutrient Management
HU-Soil Test- pH Emphasis
No
$223.92
217
Soil and Source Testing for Nutrient Management
Source Water Nutrient Test
No
$594.24
217
Soil and Source Testing for Nutrient Management
HU-Source Water Nutrient Test
No
$713.09
217
Soil and Source Testing for Nutrient Management
Zone or Grid Soil Test
No
$1,346.73
217
Soil and Source Testing for Nutrient Management
HU-Zone or Grid Soil Test
No
$1,616.07
218
Carbon Sequestration and Greenhouse Gas Mitigation
Assessment
High Complexity
No
$1,342.08
218
Carbon Sequestration and Greenhouse Gas Mitigation
Assessment
HU-High Complexity
No
$1,610.50
218
Carbon Sequestration and Greenhouse Gas Mitigation
Assessment
Low Complexity
No
$671.04
218
Carbon Sequestration and Greenhouse Gas Mitigation
Assessment
HU-Low Complexity
No
$805.25
218
Carbon Sequestration and Greenhouse Gas Mitigation
Assessment
Medium Complexity
No
$1,006.56
218
Carbon Sequestration and Greenhouse Gas Mitigation
Assessment
HU-Medium Complexity
No
$1,207.87
221
Soil Organic Carbon Stock Measurement
Carbon Stock Monitoring
No
$1,251.51
Environmental Quality Incentives Program
B1P$ge 13 of 29
Nebraska - Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
221 Soil Organic Carbon Stock Measurement HU-Carbon Stock Monitoring No $1,501.82
222 Indigenous Stewardship Methods Evaluation ISME 1001 to 3,000 Acres No $16,686.57
222 Indigenous Stewardship Methods Evaluation HU-ISME1001 to 3,000 Acres No $20,023.89
222 Indigenous Stewardship Methods Evaluation ISME 11 to 300 Acres No $6,750.30
222 Indigenous Stewardship Methods Evaluation HU-ISME 11 to 300 Acres No $8,100.36
222 Indigenous Stewardship Methods Evaluation ISME 301 to 1,000 Acres No $12,535.91
222 Indigenous Stewardship Methods Evaluation HU-ISME 301 to 1,000 Acres No $15,043.09
222 Indigenous Stewardship Methods Evaluation ISME Less Than or Equal to 10 Acres No $5,057.29
222 Indigenous Stewardship Methods Evaluation HU-ISME Less Than or Equal to 10 Acres No $6,068.75
223 Forest Management Assessment CEMA101 to 250 acres No $2,268.00
223 Forest Management Assessment HU-CEMA101 to 250 acres No $2,721.60
223 Forest Management Assessment CEMA 21 to 100 acres No $1,197.00
223 Forest Management Assessment HU-CEMA 21 to 100 acres No $1,436.40
223 Forest Management Assessment CEMA 251 to 500 acres No $3,402.00
223 Forest Management Assessment HU-CEMA 251 to 500 acres No $4,082.40
223 Forest Management Assessment CEMA 501 to 1000 acres No $4,284.00
223 Forest Management Assessment HU-CEMA 501 to 1000 acres No $5,140.80
223 Forest Management Assessment CEMA Greater Than 1000 acres No $5,733.00
223 Forest Management Assessment HU-CEMA Greater Than 1000 acres No $6,879.60
223 Forest Management Assessment CEMA less than or equal to 20 acres No $630.00
223 Forest Management Assessment HU-CEMA less than or equal to 20 acres No $756.00
224 Aquifer Flow Test Aquifer Flow Test No $1,369.23
224 Aquifer Flow Test HU-Aquifer Flow Test No $1,643.08
228 Agricultural Energy Assessment Large size, 1 Enterprise No $3,753.11
228 Agricultural Energy Assessment HU-Large size, 1 Enterprise No $4,503.73
228 Agricultural Energy Assessment Large size, 2 Enterprises No $4,982.01
228 Agricultural Energy Assessment HU-Large size, 2 Enterprises No $5,978.41
228 Agricultural Energy Assessment Large size, 3 Enterprises No $6,210.92
228 Agricultural Energy Assessment HU-Large size, 3 Enterprises No $7,453.10
Environmental Quality Incentives Program
B1P3fge 14 of 29
Nebraska -
Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
228
Agr
cultural Energy Assessment
Large size, 4+ Enterprises
No
$7,439.82
228
Agr
cultural Energy Assessment
HU-Large size, 4+ Enterprises
No
$8,927.78
228
Agr
cultural Energy Assessment
Medium size, 1 Enterprise
No
$2,855.93
228
Agr
cultural Energy Assessment
HU-Medium size, 1 Enterprise
No
$3,427.11
228
Agr
cultural Energy Assessment
Medium size, 2 Enterprises
No
$4,084.83
228
Agr
cultural Energy Assessment
HU-Medium size, 2 Enterprises
No
$4,901.80
228
Agr
cultural Energy Assessment
Medium size, 3 Enterprises
No
$5,313.74
228
Agr
cultural Energy Assessment
HU-Medium size, 3 Enterprises
No
$6,376.48
228
Agr
cultural Energy Assessment
Medium size, 4+ Enterprises
No
$6,542.64
228
Agr
cultural Energy Assessment
HU-Medium size, 4+ Enterprises
No
$7,851.17
228
Agr
cultural Energy Assessment
Small size, 1 Enterprise
No
$2,114.21
228
Agr
cultural Energy Assessment
HU-Small size, 1 Enterprise
No
$2,537.05
228
Agr
cultural Energy Assessment
Small size, 2 Enterprises
No
$3,343.11
228
Agr
cultural Energy Assessment
HU-Small size, 2 Enterprises
No
$4,011.73
228
Agr
cultural Energy Assessment
Small size, 3 Enterprises
No
$4,572.02
228
Agr
cultural Energy Assessment
HU-Small size, 3 Enterprises
No
$5,486.42
228
Agr
cultural Energy Assessment
Small size, 4+ Enterprises
No
$5,800.92
228
Agr
cultural Energy Assessment
HU-Small size, 4+ Enterprises
No
$6,961.10
313
Waste Storage Facility
Bedded Pack - Concrete Floor and Concrete Walls
SqFt
$10.15
313
Waste Storage Facility
HU-Bedded Pack - Concrete Floor and Concrete Walls
SqFt
$12.18
313
Waste Storage Facility
Bedded Pack - Earth Floor and Concrete Walls
SqFt
$4.61
313
Waste Storage Facility
HU-Bedded Pack - Earth Floor and Concrete Walls
SqFt
$5.53
313
Waste Storage Facility
Bedded Pack - Earth Floor and Wood Walls
SqFt
$3.04
313
Waste Storage Facility
HU-Bedded Pack - Earth Floor and Wood Walls
SqFt
$3.65
313
Waste Storage Facility
Bedded Pack - Earth Floor with Concrete Walls and Concrete Apron
SqFt
$6.35
313
Waste Storage Facility
HU-Bedded Pack - Earth Floor with Concrete Walls and Concrete Apron
SqFt
$7.63
313
Waste Storage Facility
Buried Concrete Tank, Between 15,000 to 110,000 c.f. of storage
Cu-Ft
$2.08
313
Waste Storage Facility
HU-Buried Concrete Tank, Between 15,000 to 110,000 c.f. of storage
Cu-Ft
$2.50
313
Waste Storage Facility
Buried Concrete Tank, Greater than 110,000 c.f. of storage
Cu-Ft
$2.02
Environmental Quality Incentives Program
BiP3fge 15 of 29
Nebraska - Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
313
Waste Storage Facil
ty
HU-Buried Concrete Tank, Greater than 110,000 c.f. of storage
Cu-Ft
$2.42
313
Waste Storage Facil
ty
Buried Concrete Tank, Less than 14,999 c.f. of storage
Cu-Ft
$3.20
313
Waste Storage Facil
ty
HU-Buried Concrete Tank, Less than 14,999 c.f. of storage
Cu-Ft
$3.84
313
Waste Storage Facil
ty
Dry Stack - Concrete floor and concrete walls
SqFt
$8.61
313
Waste Storage Facil
ty
HU-Dry Stack - Concrete floor and concrete walls
SqFt
$10.33
313
Waste Storage Facil
ty
Dry Stack - Concrete floor and no walls
SqFt
$6.30
313
Waste Storage Facil
ty
HU-Dry Stack - Concrete floor and no walls
SqFt
$7.57
313
Waste Storage Facil
ty
Embankment Storage Pond
Cu-Ft
$0.06
313
Waste Storage Facil
ty
HU-Embankment Storage Pond
Cu-Ft
$0.07
313
Waste Storage Facil
ty
Excavated Storage Pond
Cu-Ft
$0.10
313
Waste Storage Facil
ty
HU-Excavated Storage Pond
Cu-Ft
$0.12
313
Waste Storage Facil
ty
Steel or Concrete Above Ground Storage Structure
Cu-Ft
$3.09
313
Waste Storage Facil
ty
HU-Steel or Concrete Above Ground Storage Structure
Cu-Ft
$3.71
314
Brush Management
Chemical - Riparian
Ac
$118.67
314
Brush Management
HU-Chemical - Riparian
Ac
$142.41
314
Brush Management
Chemical, Foliar Spot Treatment
Ac
$31.51
314
Brush Management
HU-Chemical, Foliar Spot Treatment
Ac
$37.81
314
Brush Management
Chemical, Uplands
Ac
$23.99
314
Brush Management
HU-Chemical, Uplands
Ac
$28.79
314
Brush Management
Mechanical and Chemical, Heavy Infestation
Ac
$308.35
314
Brush Management
HU-Mechanical and Chemical, Heavy Infestation
Ac
$370.02
314
Brush Management
Mechanical and Chemical, Low Infestation
Ac
$46.19
314
Brush Management
HU-Mechanical and Chemical, Low Infestation
Ac
$55.42
314
Brush Management
Mechanical and Chemical, Medium Infestation
Ac
$117.93
314
Brush Management
HU-Mechanical and Chemical, Medium Infestation
Ac
$141.51
314
Brush Management
Mechanical and Chemical, Severe Infestation
Ac
$468.45
314
Brush Management
HU-Mechanical and Chemical, Severe Infestation
Ac
$562.14
314
Brush Management
Mechanical, Hand tools
Ac
$52.38
314
Brush Management
HU-Mechanical, Hand tools
Ac
$62.86
Environmental Quality Incentives Program
B1P33ge 16 of 29
Nebraska - Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
327 Conservation Cover Introduced Species Ac $159.68
327 Conservation Cover HU-lntroduced Species Ac $191.62
327 Conservation Cover Introduced with Forgone Income Ac $382.35
327 Conservation Cover HU-lntroduced with Forgone Income Ac $405.15
327 Conservation Cover Monarch Species Mix Ac $671.23
327 Conservation Cover HU-Monarch Species Mix Ac $805.47
327 Conservation Cover Native Species Ac $175.17
327 Conservation Cover HU-Native Species Ac $210.20
327 Conservation Cover Native Species with Forgone Income Ac $443.55
327 Conservation Cover HU-Native Species with Forgone Income Ac $478.59
327 Conservation Cover Pollinator Species Ac $538.37
327 Conservation Cover HU-Pollinator Species Ac $646.04
327 Conservation Cover Pollinator Species with Forgone Income Ac $680.53
327 Conservation Cover HU-Pollinator Species with Forgone Income Ac $762.96
328 Conservation Crop Rotation Pr_Basic Rotation Organic and Non-Organic Ac $12.27
328 Conservation Crop Rotation Prjrrigated to Dryland Rotation Organic and Non-Organic Ac $203.22
329 Residue and Tillage Management, No Till No-Till/Strip-Till Ac $16.48
329 Residue and Tillage Management, No Till HU-No-Till/Strip-Till Ac $19.78
332 Contour Buffer Strips Introduced Species, Foregone Income (Organic and Non-Organic) Ac $372.73
332 Contour Buffer Strips HU-lntroduced Species, Foregone Income (Organic and Non-Organic) Ac $394.44
332 Contour Buffer Strips Native Species, Foregone Income (Organic and Non-organic) Ac $393.05
332 Contour Buffer Strips HU-Native Species, Foregone Income (Organic and Non-organic) Ac $418.83
340 Cover Crop Cover Crop - Adaptive Management No $2,114.63
340 Cover Crop HU-Cover Crop - Adaptive Management No $2,537.55
340 Cover Crop Cover Crop - Basic (Organic and Non-organic) Ac $44.91
340 Cover Crop HU-Cover Crop - Basic (Organic and Non-organic) Ac $65.32
340 Cover Crop Cover Crop - Multiple Species (Organic and Non-organic) Ac $56.22
340 Cover Crop HU-Cover Crop - Multiple Species (Organic and Non-organic) Ac $81.77
340 Cover Crop Cover Crop Multiple Species Frost Terminated Organic and Non-Organic Ac $43.57
Environmental Quality Incentives Program
BiP3§ge 17 of 29
Nebraska -
Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
340 Cover Crop HU-Cover Crop Multiple Species Frost Terminated Organic and Non-Organic Ac $63.38
342 Critical Area Planting Native or Introduced Vegetation - Normal Tillage (Organic and Non-Organic) Ac $315.24
342 Critical Area Planting HU-Native or Introduced Vegetation - Normal Tillage (Organic and Non-Organic) Ac $378.29
342 Critical Area Planting Native Vegetation - Heavy Grading Ac $1,071.15
342 Critical Area Planting HU-Native Vegetation - Heavy Grading Ac $1,285.38
342 Critical Area Planting Native Vegetation - Moderate Grading Ac $743.17
342 Critical Area Planting HU-Native Vegetation - Moderate Grading Ac $891.80
362 Diversion Diversion CuYd $2.83
362 Diversion HU-Diversion CuYd $3.40
367 Roofs and Covers Flex Membrane w/Flare SqFt $7.81
367 Roofs and Covers HU-Flex Membrane w/Flare SqFt $9.37
367 Roofs and Covers Flexible Membrane Cover Only SqFt $0.89
367 Roofs and Covers HU-Flexible Membrane Cover Only SqFt $1.07
367 Roofs and Covers Hoop Structure Roof SqFt $8.96
367 Roofs and Covers HU-Hoop Structure Roof SqFt $10.75
367 Roofs and Covers Timber or Steel Sheet Roof SqFt $12.20
367 Roofs and Covers HU-Timber or Steel Sheet Roof SqFt $14.64
382 Fence Barbed Wire, Multi-strand Ft $2.11
382 Fence HU-Barbed Wire, Multi-strand Ft $2.53
382 Fence Barbed Wire, Multi-strand with Fence Markers Ft $2.23
382 Fence HU-Barbed Wire, Multi-strand with Fence Markers Ft $2.67
382 Fence Barbed Wire, Multi-strand with fence markers, difficult terrain Ft $2.58
382 Fence HU-Barbed Wire, Multi-strand with fence markers, difficult terrain Ft $3.09
382 Fence Barbed Wire, Multi-strand, difficult terrain Ft $2.50
382 Fence HU-Barbed Wire, Multi-strand, difficult terrain Ft $3.00
382 Fence Confinement Ft $4.77
382 Fence HU-Confinement Ft $5.72
382 Fence Electric, high tensile with energizer Ft $0.99
382 Fence HU-Electric, high tensile with energizer Ft $1.19
Environmental Quality Incentives Program
BiP3§ge 18 of 29
Nebraska - Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
382
Fence
Electric, high tensile with energizer and fence markers
Ft
$1.12
382
Fence
HU-Electric, high tensile with energizer and fence markers
Ft
$1.35
382
Fence
Portable Fence
Ft
$0.21
382
Fence
HU-Portable Fence
Ft
$0.25
382
Fence
Protective Fence
Ft
$1.91
382
Fence
HU-Protective Fence
Ft
$2.29
382
Fence
Woven Wire
Ft
$2.03
382
Fence
HU-Woven Wire
Ft
$2.43
386
Field Border
Pr_Field Border, Introduced Species, Forgone Income
Ac
$378.33
386
Field Border
Pr_Field Border, Native Species, Forgone Income
Ac
$438.06
386
Field Border
Pr_Field Border, Pollinator, Forgone Income
Ac
$722.43
390
Riparian Herbaceous Cover
Native Species
Ac
$129.71
390
Riparian Herbaceous Cover
HU-Native Species
Ac
$155.65
390
Riparian Herbaceous Cover
Native Species with foregone income
Ac
$175.21
390
Riparian Herbaceous Cover
HU-Native Species with foregone income
Ac
$201.15
391
Riparian Forest Buffer
Pr_Bare-root, machine planted (Fl)
Ac
$1,714.15
391
Riparian Forest Buffer
Pr_Direct Seeding (Fl)
Ac
$1,085.27
391
Riparian Forest Buffer
Pr_Small container, machine planted (Fl)
Ac
$2,615.53
393
Filter Strip
Pr_Filter Strip, Introduced species, Forgone Income
Ac
$470.11
393
Filter Strip
Pr_Filter Strip, Native species, Forgone Income
Ac
$513.14
410
Grade Stabilization Structure
Concrete Block Chute
SqFt
$5.18
410
Grade Stabilization Structure
HU-Concrete Block Chute
SqFt
$6.22
410
Grade Stabilization Structure
Concrete Box Drop
CuYd
$812.96
410
Grade Stabilization Structure
HU-Concrete Box Drop
CuYd
$975.55
410
Grade Stabilization Structure
Embankment, No PS
CuYd
$3.81
410
Grade Stabilization Structure
HU-Embankment, No PS
CuYd
$4.57
410
Grade Stabilization Structure
Embankment, Pipe <24 inch
CuYd
$5.14
410
Grade Stabilization Structure
HU-Embankment, Pipe <24 inch
CuYd
$6.17
410
Grade Stabilization Structure
Embankment, Pipe >=24 inch
CuYd
$4.14
Environmental Quality Incentives Program
B1F£ge 19 of 29
Nebraska -
Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
410
Grade Stabilization Structure
HU-Embankment, Pipe >=24 inch
CuYd
$4.97
410
Grade Stabilization Structure
Gabion Rock Drop Structures
CuYd
$146.34
410
Grade Stabilization Structure
HU-Gabion Rock Drop Structures
CuYd
$175.61
410
Grade Stabilization Structure
Modular Concrete Block Drop
CuYd
$169.01
410
Grade Stabilization Structure
HU-Modular Concrete Block Drop
CuYd
$202.81
410
Grade Stabilization Structure
Pipe Drop, CMP
SqFt
$17.02
410
Grade Stabilization Structure
HU-Pipe Drop, CMP
SqFt
$20.43
410
Grade Stabilization Structure
Pipe Drop, Plastic - NP Reg 1
SqFt
$51.99
410
Grade Stabilization Structure
HU-Pipe Drop, Plastic - NP Reg 1
SqFt
$62.39
410
Grade Stabilization Structure
Rock Chute
CuYd
$103.06
410
Grade Stabilization Structure
HU-Rock Chute
CuYd
$123.67
410
Grade Stabilization Structure
Sheet Pile Weir Drop
SqFt
$48.44
410
Grade Stabilization Structure
HU-Sheet Pile Weir Drop
SqFt
$58.13
410
Grade Stabilization Structure
Tied Concrete Block Mat
SqFt
$8.65
410
Grade Stabilization Structure
HU-Tied Concrete Block Mat
SqFt
$10.38
412
Grassed Waterway
Waterway with Side Dikes or Checks
Ac
$5,019.01
412
Grassed Waterway
HU-Waterway with Side Dikes or Checks
Ac
$6,022.81
412
Grassed Waterway
Waterway, 25 to 50 ft2
Ac
$3,777.29
412
Grassed Waterway
HU-Waterway, 25 to 50 ft2
Ac
$4,532.74
430
Irrigation Pipeline
PVC, 10-in by the foot
Ft
$12.45
430
Irrigation Pipeline
HU-PVC, 10-in by the foot
Ft
$14.94
441
Irrigation System, Microirrigation
SDI (Subsurface Drip Irrigation)
Ac
$1,907.66
441
Irrigation System, Microirrigation
HU-SDI (Subsurface Drip Irrigation)
Ac
$2,289.20
442
Sprinkler System
Gravity to Pivot Conversion
Ft
$31.14
442
Sprinkler System
HU-Gravity to Pivot Conversion
Ft
$50.60
442
Sprinkler System
Gravity to Pivot Conversion with VRI
Ft
$51.96
442
Sprinkler System
HU-Gravity to Pivot Conversion with VRI
Ft
$84.43
442
Sprinkler System
Linear Move System
Ft
$93.23
442
Sprinkler System
HU-Linear Move System
Ft
$111.88
Environmental Quality Incentives Program
BiP3§ge 20 of 29
Nebraska -
Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
442 Sprinkler System System Renovation, Renozzle with Drops No $27.94
442 Sprinkler System HU-System Renovation, Renozzle with Drops No $33.53
442 Sprinkler System VRI System Retrofit Zone Ft $41.11
442 Sprinkler System HU-VRI System Retrofit Zone Ft $49.33
449
Irrigation Water Management
Consulatant Based IWM No Equipment
No
$545.28
449
Irrigation Water Management
HU-Consulatant Based IWM No Equipment
No
$654.34
449
Irrigation Water Management
IWM, Advanced Technique
No
$2,286.72
449
Irrigation Water Management
HU-IWM, Advanced Technique
No
$2,744.06
449
Irrigation Water Management
IWM, Advanced Technique Incorporating Precision Irrigation
No
$3,796.56
449
Irrigation Water Management
HU-IWM, Advanced Technique Incorporating Precision Irrigation
No
$4,555.87
472
Access Control
Pr_Animal exclusion from sensitive areas (Fl)
Ac
$45.67
500
Obstruction Removal
Removal and Disposal of Brush and Trees <= 6 inch Diameter
Ac
$856.45
500
Obstruction Removal
HU-Removal and Disposal of Brush and Trees <= 6 inch Diameter
Ac
$1,027.74
500
Obstruction Removal
Removal and Disposal of Brush and Trees > 6 inch Diameter
Ac
$1,638.30
500
Obstruction Removal
HU-Removal and Disposal of Brush and Trees > 6 inch Diameter
Ac
$1,965.96
500
Obstruction Removal
Removal and Disposal of Concrete Slab
SqFt
$0.61
500
Obstruction Removal
HU-Removal and Disposal of Concrete Slab
SqFt
$0.73
500
Obstruction Removal
Removal and Disposal of Fence, Feedlot
Ft
$3.01
500
Obstruction Removal
HU-Removal and Disposal of Fence, Feedlot
Ft
$3.61
500
Obstruction Removal
Removal and Disposal of Fence, landscape
Ft
$0.95
500
Obstruction Removal
HU-Removal and Disposal of Fence, landscape
Ft
$1.14
500
Obstruction Removal
Removal and disposal of individual landscape structures
SqFt
$4.78
500
Obstruction Removal
HU-Removal and disposal of individual landscape structures
SqFt
$5.74
500
Obstruction Removal
Removal and Disposal of Power Lines and Poles
Ft
$2.71
500
Obstruction Removal
HU-Removal and Disposal of Power Lines and Poles
Ft
$3.25
500
Obstruction Removal
Removal and Disposal of Steel and or Concrete Structures
SqFt
$10.20
500
Obstruction Removal
HU-Removal and Disposal of Steel and or Concrete Structures
SqFt
$12.23
500
Obstruction Removal
Removal and Disposal of Wood Structures
SqFt
$5.31
500
Obstruction Removal
HU-Removal and Disposal of Wood Structures
SqFt
$6.38
Environmental Quality Incentives Program
BiP3|ge21of 29
Nebraska -
Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
512 Pasture and Hay Planting Introduced Perennial & Native Grass Mix Ac $57.63
512 Pasture and Hay Planting HU-lntroduced Perennial & Native Grass Mix Ac $69.16
512 Pasture and Hay Planting Introduced Perennial & Native Grass Mix, foregone income Ac $245.97
512 Pasture and Hay Planting HU-lntroduced Perennial & Native Grass Mix, foregone income Ac $263.75
512 Pasture and Hay Planting Introduced Perennial Grasses with lime application Ac $132.98
512 Pasture and Hay Planting HU-lntroduced Perennial Grasses with lime application Ac $159.57
512 Pasture and Hay Planting Introduced Perennial Grasses-Legume Ac $60.48
512 Pasture and Hay Planting HU-lntroduced Perennial Grasses-Legume Ac $72.58
512 Pasture and Hay Planting Introduced Perennial Grasses-Legume, foregone income Ac $217.58
512 Pasture and Hay Planting HU-lntroduced Perennial Grasses-Legume, foregone income Ac $229.67
512 Pasture and Hay Planting Introduced Perennial Grasses-Legumes on irrigated cropland Ac $94.57
512 Pasture and Hay Planting HU-lntroduced Perennial Grasses-Legumes on irrigated cropland Ac $113.49
512 Pasture and Hay Planting Native Perennial Grasses, multi species Ac $121.57
512 Pasture and Hay Planting HU-Native Perennial Grasses, multi species Ac $145.89
512 Pasture and Hay Planting Native Perennial Grasses, multi species, forgone income Ac $278.67
512 Pasture and Hay Planting HU-Native Perennial Grasses, multi species, forgone income Ac $302.98
512 Pasture and Hay Planting Organic Ac $98.66
512 Pasture and Hay Planting HU-Organic Ac $118.39
512 Pasture and Hay Planting Organic, forgone income Ac $255.75
512 Pasture and Hay Planting HU-Organic, forgone income Ac $275.49
516 Livestock Pipeline Backhoe, 2 inch dia. or less Ft $4.65
516 Livestock Pipeline HU-Backhoe, 2 inch dia. or less Ft $5.59
516 Livestock Pipeline Backhoe, greater than 2 inch dia. Ft $6.57
516 Livestock Pipeline HU-Backhoe, greater than 2 inch dia. Ft $7.88
516 Livestock Pipeline Boring, any diameter Ft $58.14
516 Livestock Pipeline HU-Boring, any diameter Ft $69.76
516 Livestock Pipeline Rural Water Connection Equipment No $3,296.75
516 Livestock Pipeline HU-Rural Water Connection Equipment No $3,956.10
516 Livestock Pipeline Shallow or Above Ground Pipeline, any diameter Ft $2.35
Environmental Quality Incentives Program
BiPjge 22 of 29
Nebraska -
Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
516
Livestock Pipeline
HU-Shallow or Above Ground Pipeline, any diameter
Ft
$2.82
516
Livestock Pipeline
Standard Installation, 2 inch dia. or less (KS/NE)
Ft
$2.37
516
Livestock Pipeline
HU-Standard Installation, 2 inch dia. or less (KS/NE)
Ft
$2.85
516
Livestock Pipeline
Standard Installation, greater than 2 inch dia.
Ft
$4.42
516
Livestock Pipeline
HU-Standard Installation, greater than 2 inch dia.
Ft
$5.31
520
Pond Sealing or Lining, Compacted Soil Treatment
Soil Dispersant - Covered
CuYd
$5.21
520
Pond Sealing or Lining, Compacted Soil Treatment
HU-Soil Dispersant - Covered
CuYd
$6.25
520
Pond Sealing or Lining, Compacted Soil Treatment
Use On-Site Material with Soil Cover
CuYd
$4.45
520
Pond Sealing or Lining, Compacted Soil Treatment
HU-Use On-Site Material with Soil Cover
CuYd
$5.34
521
Pond Sealing or Lining, Geomembrane or Geosynthetic Clay
Liner
Flexible Membrane - Covered with liner drainage or venting
SqYd
$15.50
521
Pond Sealing or Lining, Geomembrane or Geosynthetic Clay
Liner
HU-Flexible Membrane - Covered with liner drainage or venting
SqYd
$18.60
521
Pond Sealing or Lining, Geomembrane or Geosynthetic Clay
Liner
Flexible Membrane - Covered without liner drainage or venting
SqYd
$7.90
521
Pond Sealing or Lining, Geomembrane or Geosynthetic Clay
Liner
HU-Flexible Membrane - Covered without liner drainage or venting
SqYd
$9.47
521
Pond Sealing or Lining, Geomembrane or Geosynthetic Clay
Liner
Flexible Membrane - Uncovered with liner drainage or venting
SqYd
$14.49
521
Pond Sealing or Lining, Geomembrane or Geosynthetic Clay
Liner
HU-Flexible Membrane - Uncovered with liner drainage or venting
SqYd
$17.39
528
Prescribed Grazing
Cover Crop/Aftermath
Ac
$6.05
528
Prescribed Grazing
HU-Cover Crop/Aftermath
Ac
$7.27
528
Prescribed Grazing
Grazing Lands, 30-73% Rest
Ac
$8.13
528
Prescribed Grazing
HU-Grazing Lands, 30-73% Rest
Ac
$9.76
528
Prescribed Grazing
Grazing Lands, Greater than 73% Rest
Ac
$11.19
528
Prescribed Grazing
HU-Grazing Lands, Greater than 73% Rest
Ac
$13.42
528
Prescribed Grazing
Habitat Mgt
Ac
$12.98
528
Prescribed Grazing
HU-Habitat Mgt
Ac
$15.58
528
Prescribed Grazing
Habitat Mgt. Long Term Monitoring
Ac
$24.12
528
Prescribed Grazing
HU-Habitat Mgt. Long Term Monitoring
Ac
$28.94
Environmental Quality Incentives Program
B1B$ge 23 of 29
Nebraska - Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
528 Prescribed Grazing Livestock Deferment (Fl) Ac $45.26
528 Prescribed Grazing HU-Livestock Deferment (Fl) Ac $45.67
528 Prescribed Grazing Livestock Deferment (Fl) High Production Sites Ac $58.91
528 Prescribed Grazing HU-Livestock Deferment (Fl) High Production Sites Ac $59.32
528 Prescribed Grazing Range Long Term Monitoring Ac $16.94
528 Prescribed Grazing HU-Range Long Term Monitoring Ac $20.33
528 Prescribed Grazing Range, 3-6 Pastures Ac $5.31
528 Prescribed Grazing HU-Range, 3-6 Pastures Ac $6.38
528 Prescribed Grazing Range, 7 or More Pastures Ac $7.13
528 Prescribed Grazing HU-Range, 7 or More Pastures Ac $8.55
528 Prescribed Grazing Small Ranch Unit Ac $23.45
528 Prescribed Grazing HU-Small Ranch Unit Ac $28.14
533 Pumping Plant Irrigation, Modify Pump No $22,268.07
533 Pumping Plant HU-lrrigation, Modify Pump No $26,721.68
533 Pumping Plant Irrigation, Submersible or Booster No $6,833.18
533 Pumping Plant HU-lrrigation, Submersible or Booster No $8,199.81
533 Pumping Plant irrigation, Surface Water No $11,508.61
533 Pumping Plant HU-irrigation, Surface Water No $13,810.33
533 Pumping Plant Irrigation, Variable Frequency Drive No $5,121.75
533 Pumping Plant HU-lrrigation, Variable Frequency Drive No $6,146.10
533 Pumping Plant Livestock, Manure Transfer No $17,944.80
533 Pumping Plant HU-Livestock, Manure Transfer No $21,533.76
533 Pumping Plant Livestock, Variable Frequency Drive No $5,098.32
533 Pumping Plant HU-Livestock, Variable Frequency Drive No $6,117.98
533 Pumping Plant Livestock, w/Pressure Tank, Low HP No $3,855.77
533 Pumping Plant HU-Livestock, w/Pressure Tank, Low HP No $4,626.93
533 Pumping Plant Livestock, without Pressure Tank (HP) HP $1,765.14
533 Pumping Plant HU-Livestock, without Pressure Tank (HP) HP $2,118.17
533 Pumping Plant Solar-Powered Pump lhp No $6,280.34
Environmental Quality Incentives Program
B1P4fge 24 of 29
Nebraska -
Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
533
Pumping Plant
HU-Solar-Powered Pump lhp
No
$7,536.41
533
Pumping Plant
Windmill-Powered Pump - NP Region
No
$6,303.51
533
Pumping Plant
HU-Windmill-Powered Pump - NP Region
No
$7,564.21
550
Range Planting
Native, Heavy Prep
Ac
$136.47
550
Range Planting
HU-Native, Heavy Prep
Ac
$163.77
550
Range Planting
Native, Standard Prep
Ac
$121.57
550
Range Planting
HU-Native, Standard Prep
Ac
$145.89
550
Range Planting
Native, Standard Prep (Fl)
Ac
$167.08
550
Range Planting
HU-Native, Standard Prep (Fl)
Ac
$191.39
550
Range Planting
Native, Wildlife, or Pollinator (Fl)
Ac
$219.27
550
Range Planting
HU-Native, Wildlife, or Pollinator (Fl)
Ac
$254.02
561
Heavy Use Area Protection
Reinforced Concrete with sand or gravel foundation - cubic yard - NP Region
CuYd
$348.05
561
Heavy Use Area Protection
HU-Reinforced Concrete with sand or gravel foundation - cubic yard - NP Region
CuYd
$417.67
561
Heavy Use Area Protection
Rock/Gravel
CuYd
$19.27
561
Heavy Use Area Protection
HU-Rock/Gravel
CuYd
$23.13
561
Heavy Use Area Protection
Rock/Gravel on Geotextile - cubic yard - NP Region
CuYd
$35.28
561
Heavy Use Area Protection
HU-Rock/Gravel on Geotextile - cubic yard - NP Region
CuYd
$42.34
561
Heavy Use Area Protection
Rock/Gravel-GeoCell-Geotextile
SqFt
$2.71
561
Heavy Use Area Protection
HU-Rock/Gravel-GeoCell-Geotextile
SqFt
$3.25
578
Stream Crossing
Bridge
SqFt
$51.32
578
Stream Crossing
HU-Bridge
SqFt
$61.58
578
Stream Crossing
Culvert installation
DialnFt
$2.62
578
Stream Crossing
HU-Culvert installation
DialnFt
$3.14
578
Stream Crossing
Low water crossing, concrete block
SqFt
$10.43
578
Stream Crossing
HU-Low water crossing, concrete block
SqFt
$12.52
578
Stream Crossing
Low water crossing, concrete slab
SqFt
$8.29
578
Stream Crossing
HU-Low water crossing, concrete slab
SqFt
$9.95
578
Stream Crossing
Low water crossing, geocell
SqFt
$4.32
578
Stream Crossing
HU-Low water crossing, geocell
SqFt
$5.18
Environmental Quality Incentives Program
BiPjge 25 of 29
Nebraska - Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
578 Stream Crossing Low water crossing, rock armor SqFt $5.63
578 Stream Crossing HU-Low water crossing, rock armor SqFt $6.76
587 Structure for Water Control Flow Meter with Electronic Index & Telemetry In $369.39
587 Structure for Water Control HU-Flow Meter with Electronic Index & Telemetry In $443.27
587 Structure for Water Control Flow Meter with Mechanical Index In $134.20
587 Structure for Water Control HU-Flow Meter with Mechanical Index In $161.04
590 Nutrient Management Pr_Adaptive NM No $2,588.70
590 Nutrient Management Pr_Basic NM (Non-Organic/Organic) Ac $8.75
590 Nutrient Management Pr_Basic NM (Organic/NonOrganic) greater than or equal to 0.5-10 acres No $295.16
590 Nutrient Management Pr_Basic NM with Manure and/or Compost (Non-Organic/Organic) Ac $18.56
590 Nutrient Management Pr_Prescription Nutrient Efficiency Ac $42.37
590 Nutrient Management Pr_Prescription Nutrient Efficiency and Precision Application Ac $57.01
595 Pest Management Conservation System Pr_Basic IPM Field Crops - Herbicide Substitution Ac $32.60
595 Pest Management Conservation System Pr_Pest Management Precision Ag Ac $57.39
595 Pest Management Conservation System Pr_Water Quality Pesticide Mitigation = 30 Point AND/OR Beneficial Insect Pesticide Ac $35.81
Mitigation
595 Pest Management Conservation System Pr_Water Quality Pesticide Mitigation = 30 Point AND/OR Beneficial Insect Pesticide No $1,052.87
Mitigation - Small Farm
595 Pest Management Conservation System Pr_Water Quality Pesticide Mitigation > 30 Point AND/OR Beneficial Insect Pesticide Ac $62.35
Mitigation
595 Pest Management Conservation System Pr_Water Quality Pesticide Mitigation > 30 Point AND/OR Beneficial Insect Pesticide No $1,748.56
Mitigation - Small Farm
614 Watering Facility Enclosed Storage Tank Gal $1.37
614 Watering Facility HU-Enclosed Storage Tank Gal $1.65
614 Watering Facility Fiberglass Tank on Concrete Gal $2.13
614 Watering Facility HU-Fiberglass Tank on Concrete Gal $2.56
614 Watering Facility Fiberglass Tank on Earth Gal $1.77
614 Watering Facility HU-Fiberglass Tank on Earth Gal $2.13
614 Watering Facility Rubber Tire Tank on Concrete Gal $1.83
614 Watering Facility HU-Rubber Tire Tank on Concrete Gal $2.19
Environmental Quality Incentives Program
B1B$ge 26 of 29
Nebraska - Fiscal Year 2023
-------
Code
Practice
Component
Units
Unit Cost
614
Watering Facil
ty
Rubber Tire Tank on Earth
Gal
$1.46
614
Watering Facil
ty
HU-Rubber Tire Tank on Earth
Gal
$1.76
614
Watering Facil
ty
Steel Rim Tank - Bottomless
Gal
$0.39
614
Watering Facil
ty
HU-Steel Rim Tank - Bottomless
Gal
$0.46
614
Watering Facil
ty
Steel Rim Tank - Concrete Base
Gal
$1.56
614
Watering Facil
ty
HU-Steel Rim Tank - Concrete Base
Gal
$1.88
614
Watering Facil
ty
Steel Tank
Gal
$1.77
614
Watering Facil
ty
HU-Steel Tank
Gal
$2.12
620
Underground Outlet
>=12 inch Single Wall PE Pipe (non-perf or perf), Multi-Inlet System
Lnft
$10.19
620
Underground Outlet
HU->=12 inch Single Wall PE Pipe (non-perf or perf), Multi-Inlet System
Lnft
$12.22
620
Underground Outlet
10 inch Single Wall PE Pipe (non-perf or perf), Multi-Inlet System
Lnft
$7.70
620
Underground Outlet
HU-10 inch Single Wall PE Pipe (non-perf or perf), Multi-Inlet System
Lnft
$9.24
620
Underground Outlet
12 inch -18 inch PVC or DW Pipe, Multi-Inlet System
Ft
$22.08
620
Underground Outlet
HU-12 inch -18 inch PVC or DW Pipe, Multi-Inlet System
Ft
$26.50
620
Underground Outlet
12 inch -18 inch PVC or DW Pipe, Single-Inlet System
Ft
$30.38
620
Underground Outlet
HU-12 inch -18 inch PVC or DW Pipe, Single-Inlet System
Ft
$36.46
620
Underground Outlet
4 inch - 6 inch PVC or DW Pipe, Multi-Inlet System
Ft
$6.48
620
Underground Outlet
HU-4 inch - 6 inch PVC or DW Pipe, Multi-Inlet System
Ft
$7.78
620
Underground Outlet
6 inch -10 inch PVC or DW Pipe, Single-Inlet System
Ft
$18.59
620
Underground Outlet
HU-6 inch -10 inch PVC or DW Pipe, Single-Inlet System
Ft
$22.31
620
Underground Outlet
6 inch or smaller Single Wall PE Pipe(non-perf or perf), Multi-Inlet System
Ft
$3.80
620
Underground Outlet
HU-6 inch or smaller Single Wall PE Pipe(non-perf or perf), Multi-Inlet System
Ft
$4.55
620
Underground Outlet
8 inch -10 inch PVC or DW Pipe, Multi-Inlet System
Ft
$15.56
620
Underground Outlet
HU-8 inch -10 inch PVC or DW Pipe, Multi-Inlet System
Ft
$18.68
620
Underground Outlet
8 inch Single Wall PE Pipe (non-perf or perf), Multi-Inlet System
Lnft
$5.31
620
Underground Outlet
HU-8 inch Single Wall PE Pipe (non-perf or perf), Multi-Inlet System
Lnft
$6.37
620
Underground Outlet
Over 18 inch PVC or DW Pipe, Single- or Multi-Inlet System
Ft
$38.12
620
Underground Outlet
HU-Over 18 inch PVC or DW Pipe, Single- or Multi-Inlet System
Ft
$45.74
634
Waste Transfer
Agitator, Slurry Transfer
No
$25,224.89
Environmental Quality Incentives Program
BiP4§ge 27 of 29
Nebraska -
Fiscal Year 2023
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Code
Practice
Component
Units
Unit Cost
634
Waste Transfer
HU-Agitator, Slurry Transfer
No
$30,269.87
634
Waste Transfer
Concrete Channel
SqFt
$11.69
634
Waste Transfer
HU-Concrete Channel
SqFt
$14.03
634
Waste Transfer
Gravity flow, less than or equal to 18 inch diameter conduit
Ft
$25.26
634
Waste Transfer
HU-Gravity flow, less than or equal to 18 inch diameter conduit
Ft
$30.31
634
Waste Transfer
Pressure flow, 10 inch diameter conduit
Ft
$28.41
634
Waste Transfer
HU-Pressure flow, 10 inch diameter conduit
Ft
$34.09
634
Waste Transfer
Pressure flow, 12 inch or greater diameter conduit
Ft
$41.47
634
Waste Transfer
HU-Pressure flow, 12 inch or greater diameter conduit
Ft
$49.77
634
Waste Transfer
Pressure flow, 8 inch diameter conduit
Ft
$19.69
634
Waste Transfer
HU-Pressure flow, 8 inch diameter conduit
Ft
$23.63
634
Waste Transfer
Pressure flow, less than or equal to 6 inch diameter conduit
Ft
$13.36
634
Waste Transfer
HU-Pressure flow, less than or equal to 6 inch diameter conduit
Ft
$16.04
635
Vegetated Treatment Area
Concrete Curb with major shaping
Ac
$9,224.14
635
Vegetated Treatment Area
HU-Concrete Curb with major shaping
Ac
$11,068.97
635
Vegetated Treatment Area
Concrete Curb, with or without flow spreaders
Ac
$3,577.17
635
Vegetated Treatment Area
HU-Concrete Curb, with or without flow spreaders
Ac
$4,292.60
635
Vegetated Treatment Area
Gated Pipe with major shaping
Ac
$9,402.56
635
Vegetated Treatment Area
HU-Gated Pipe with major shaping
Ac
$11,283.08
635
Vegetated Treatment Area
Gated Pipe, with or without flow spreaders
Ac
$2,340.74
635
Vegetated Treatment Area
HU-Gated Pipe, with or without flow spreaders
Ac
$2,808.88
635
Vegetated Treatment Area
Minor Shaping
Ac
$1,032.02
635
Vegetated Treatment Area
HU-Minor Shaping
Ac
$1,238.43
635
Vegetated Treatment Area
Sprinkler, Center Pivot
Ac
$3,331.86
635
Vegetated Treatment Area
HU-Sprinkler, Center Pivot
Ac
$3,998.24
635
Vegetated Treatment Area
Sprinkler, Mobile Pods
Ac
$3,179.06
635
Vegetated Treatment Area
HU-Sprinkler, Mobile Pods
Ac
$3,814.87
635
Vegetated Treatment Area
Sprinkler, Solid Set Distribution
Ac
$6,308.25
635
Vegetated Treatment Area
HU-Sprinkler, Solid Set Distribution
Ac
$7,569.90
Environmental Quality Incentives Program
B1P4|ge 28 of 29
Nebraska -
Fiscal Year 2023
-------
Code Practice Component Units Unit Cost
642 Water Well Dual Casing PVC Ft $47.43
642 Water Well HU-Dual Casing PVC Ft $56.91
642 Water Well Dug (Excavated) Well Ft $417.05
642 Water Well HU-Dug (Excavated) Well Ft $500.46
642 Water Well Single PVC Casing with pitless unit, greater than 100 ft. deep Ft $42.26
642 Water Well HU-Single PVC Casing with pitless unit, greater than 100 ft. deep Ft $50.72
642 Water Well Single PVC Casing, greater than 100 ft. deep Ft $40.52
642 Water Well HU-Single PVC Casing, greater than 100 ft. deep Ft $48.62
642 Water Well Steel or Copper, 100 ft. or deeper Lnft $61.43
642 Water Well HU-Steel or Copper, 100 ft. or deeper Lnft $73.72
642 Water Well WellPoint Ft $102.64
642 Water Well HU-Well Point Ft $123.17
Environmental Quality Incentives Program
B1P4^ge 29 of 29
Nebraska - Fiscal Year 2023
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Final Report of the Small Business Advocacy Review Panel on EPA's Planned Proposed Meat and Poultry
Products Effluent Limitations Guidelines Rulemaking
Appendix B2: Written Comments Submitted by Small Entity
Representatives following the July 17, 2023 Panel Outreach Meeting
Table of Contents
American Association of Meat Processors (AAMP) B2-2
Bob's Processing Inc. and Michigan Meat Association B2-6
Boone's Butcher Shop and Kentucky Association of Meat Processors B2-10
Missouri Association of Meat Processors (MAMP) B2-15
B2-1
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American Association of Meat Processors (AAMP)
B2-2
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AMERICAN ASSOCIATION
MEAT PROCESSORS
OF
One Meating Place
Elizabethtown, PA 17022
P: (717) 367-1168 F: (717) 367-9096
E-mail: aamp@aamp.com
Website: www.aamp.com
July 31, 2023
To Whom It May Concern,
I want to thank the Environmental Protection Agency (EPA) for the opportunity to serve on the panel as
a small entity representative and give input during the current Effluent Limitations Guidelines
rulemaking process. My name is Chris Young, and I am Executive Director of the American Association of
Meat Processors (AAMP). AAMP is America's largest meat trade association, representing over 1600
establishments. There are 30 state, regional, and provincial associations of meat processors that are also
affiliated with AAMP. The majority of our members are small and very small businesses, with most of
them being family-owned and operated.
I would like to start my comments by addressing my concern with the sources from which EPA gathered
the data they are using as a basis for some of the findings in their proposed rulemaking. I am specifically
concerned with the accuracy of the answers to the EPA Meat and Poultry Products Detailed
Questionnaire. As a trade association, AAMP attempted to work with small processors who contacted us
about it and tried to help them understand and answer the questions in the survey. I fear most small
and very small plant owners know very little about wastewater and really did not understand terms that
were used in the questionnaire as they relate to wastewater, and therefore their answers may have
been good guesses at best or left blank. Part of the survey asked about pounds produced; for most small
processors these are numbers they do not need to track; USDA facilities are the only facilities that have
to provide estimated daily averages. A large portion of small or very small processors engage in retail-
exempt or custom-exempt processing as part or all of their business and have no need to track these
numbers.
Additionally, I know that many small processors were also very hesitant to give financial information on
the survey, and I am concerned that the financial number from 2021 will not show an accurate picture
of the small side of the industry. Income for small and very small plants went up considerably during
2020 and 2021 due to the effects of Covid on the industry. There was a large rush on grocery stores
when everything first shut down for Covid, and families were eating 3 meals a day at home. When
grocery stores could not supply what consumers needed, they began looking elsewhere and found what
they needed in small retail butcher shops. Consumers were also recipients of government assistance
during this time, which enabled them to spend more on food. Many bought meat products in larger
quantities. Small plants also processed many more animals for farmers as larger packing plants were
temporarily closed or operating at a greatly reduced capacity. All these factors led to an increase in
business and revenue during this time and is not indicative of what revenue may look like in the future.
B2-3
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AMERICAN ASSOCIATION
MEAT PROCESSORS
OF
One Meating Place
Elizabethtown, PA 17022
P: (717) 367-1168 F: (717) 367-9096
E-mail: aamp@aamp.com
Website: www.aamp.com
I am also concerned that the only wastewater tested came from 6 larger facilities and that no small
facilities were monitored to see their output. Is there really enough phosphorus and nitrate discharge
coming from these small plants to affect the recipient of direct discharge or the POTW receiving the
discharge? I think EPA needs to take a closer look at what the discharge looks like coming from the
smaller facilities, which do a number of different processes, to better understand what the actual
wastewater discharge is in these small plants. I say this because small plants often are very diverse in
their operations, and there are no two that are alike. A small plant may slaughter and process those
animals for local farmers as well as buy in boxed beef, pork, etc., to further process into other products
to sell in the retail store. Many small plants do a variety of processing, particularly further processing
from boxed meat.
I want to address the definitions of "small" and "very small plants" to eliminate any confusion. USDA
defines a small plant as one that has less than 500 employees and a very small plant as one that has less
than 10 employees. The Small Business Administration defines small as 1,000 employees or less.
However, there are many large-production processing facilities that fit in the SBA definition, and their
processes and environmental impact are much different than what I would consider small and very
small. When I reference a small plant, I think of one that is 200 employees or less; in truth, it probably
should be 100 or less. A very small plant should be 25 or less employees. The majority of our almost
1700 members would fall into these categories, and this is what I am referencing in my comments
today.
My greatest concern is the financial impact on the small and very small processor. I was not on the panel
during your first presentation, but I have seen the slides of that presentation. I am happy to see that the
latest slides regarding the economic impact on small and very small plants reflect lower capital and
ongoing cost estimates. That said, the cost will still be very prohibitive to small and very small plants. I
fear that many will look at this as the last nail in their business, and they will close their doors. I am not
trying to be dramatic; I just am trying to explain the factual impact this rule in its current form will have
on these small businesses. The majority of small and very small businesses are multigenerational family-
owned companies that work on low margins in order to provide services and goods in their local
communities many of which are rural communities that rely on the small processor to process their
livestock or provide protein for their families. Farmers and consumers rely heavily on these small plants,
and the impact of losing them would be devastating in our small rural communities.
The need for processing capacity in our country is at an all-time high and was identified by the President
in 2020. President Biden committed funds to help expand slaughter and processing capacity through
ongoing grant programs. Those grants help small and very small processors upgrade their equipment
and facilities in order to increase processing capacity. The grants were needed because small and very
small processors did not have the capital needed to make these improvements on their own. I bring this
to your attention, because as the President is working to increase capacity on the small side of the
B2-4
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AMERICAN ASSOCIATION
MEAT PROCESSORS
OF
One Meating Place
Elizabethtown, PA 17022
P: (717) 367-1168 F: (717) 367-9096
E-mail: aamp@aamp.com
Website: www.aamp.com
industry, the proposed regulations from the EPA would have the opposite effect. We would see many
small plants close, only furthering the problem of low capacity and extreme industry consolidation. We
need to make sure that we do what we can to keep the small processor operating in a financially solvent
way to ensure they remain able to provide their goods and services at a price that local farmers and
consumers can afford. This will ensure the continuation of competitive markets for not only small
farmers with their animals, but also for consumers.
AAMP and its members understand the environmental concerns, and we all want to be good stewards
of the resources we have been given, but we need to find some sort of balance that considers not only
the environmental impact but also the impact that this rulemaking will have on thousands of small
businesses, their families and employees, and the farmers and communities they serve. How do we
work together to accomplish these things? I believe there is a need for more information to be gathered
on the small side of the industry because of the diversity of processes that go on in these plants and the
varying degree of impact they actually have on the environment. AAMP would be willing to work with
EPA to collect more specific data from our members through surveys and possible meetings. This way,
EPA would get better baseline data on what is actually happening in these small facilities and what their
wastewater discharge looks like. I would suggest that EPA look at the Regulatory Flexibility Act and work
with AAMP to find regulatory alternatives that would minimize or eliminate the burden of the rule on
small and very small processors. Slide 24 identifies an example regulatory structure; we would suggest
the adjustment be made to the lbs. per year to have tiers of less than 2 million, between 2 million and
20 million, and then greater than 20 million. I think we need to get a better understanding of
wastewater discharge data from the small and very small plants, but ultimately AAMP would like to see
a regulatory exemption for small and very small processors.
Thank you again for the opportunity to be a part of this process and I am available to answer any
questions or help in any way.
Sincerely,
Christopher Young
Executive Director
American Association of Meat Processors
B2-5
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Bob's Processing Inc. and Michigan Meat Association
B2-6
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Scott Filbrandt
Representing Bob's Processing Inc. and
Michigan Meat Association
I would like to start by thanking you for allowing me to participate in these meetings as a representative
for small and very small meat processors. I am writing on behalf of Bob's Processing Inc. and the
Michigan Meat Association that has 120 active Members and growing.
I feel as if these pending new regulations are geared for the large, very large plants and ones that
potentially dump directly into a waterway. These regulations are too broad and will hurt a lot of small
and very small plants from slight to substantial increases in their operating expenses. This could result in
many plants closing, with a loss of jobs to the local communities. The Biden Administration has a
concentrated focus for growing the small processors with grants and low interest loans, so our food
chain is not controlled by bigger companies. These pending regulations could stop plants in underserved
communities from even opening due to the cost. Additionally, the underserved communities also will
need massive amounts of technical support with the implementation of these new regulations. The
USDA/FSIS advisory board recently met and were tasked with how to get underserved and indigenous
communities funding for opening new meat plants. One of the recommendations was to communicate
with other departments such as EPA. As I mentioned, these pending regulations could hinder these
initiatives as well.
Below are points that support my concern.
My biggest argument is the size category and pounds of production per year of who this will affect. A
significant number of plants in the Ml meat association are under 100 employees. The plants with
under 100 employees will incur a more significant financial hardship if these new regulations are
imposed, than plants with over 100 employees. I would like to suggest that we reclassify the employee
count for very small, small, medium and large plants. Most meat associations would consider small
plants to be less than 100 employees and very small less than 25. Our plant has 8 counting myself, my
brother and daughter. Furthermore, the pounds per year for Indirect Further Processor would hinder
growth due to the pounds being too close together causing significant cost increases for water
treatment. A better structure may be <2, 2-20 and >20.
The EPA has gone into the larger facilities and done testing of wastewater discharge. How does this
correlate to the small and very small plants? Where is the research showing that a plant that has under
100 employees is doing the same type of discharge as these larger plants? Specifically, nitrites and
phosphorus. Additionally, where is the evidence that these plants are producing so many Nitrites and
Phosphorus vs the farm runoff?
In the regards to using a water bill to determine discharge, further processors are at a disadvantage. I
will explain with a few examples. First, we purchase some frozen products and thaw them in a water
bath. This could be upwards of 100 gallons of water each time we thaw product. This water is then
dumped down the drain. It is 100% clean water as all the products being thawed are vacuum sealed.
Next, our smokehouses shower products that are in a casing and sometimes for upwards of an hour
shower time. This all is being counted as discharge. Again, it is 100% clean water. With the above said,
B2-7
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we do have instances of "dirty" water only in our clean up procedures. Our cleanup is about 1 to 2
hours long, however by using pressure washers that reduce the amount of water used versus using a
common hose, we use less water during those 1-2 hours of cleanup. In sum, our water bill will indicate a
huge amount of water used, but a very small ratio of that water is "dirty" water each day.
Here in Michigan EGLE is imposing regulations on plants however we have not been shown any scientific
backing at all. I feel this is what the EPA is doing also. The testing that EPA has done is not taking into
consideration that we operate significantly different than large processing facilities.
In sum, the EPA could change the size category to expand the exemption for small and very small plants.
This may help to not have the burden of the expense. EPA needs to look at where the technical support
for these regulations is going to come from if imposed. Is the support out there that is not costly so that
plants can afford to get the support needed?
Speaking on this as a 2nd generation meat cutter. I don't know much about wastewater, and I feel most
of the people in the industry don't. We all do know that we need clean water and do our very best to
mitigate what goes down the drain to the environment.
What is the production size of your facility? We are a very small further processor
Do you know how much wastewater your facility generates? No
Do you discharge directly into a surface water or do you send your wastewater to a POTW?
POTW
What is your relationship with your POTW?
What technical assistance does the POTW provide you? NONE
Has the POTW discussed with you potential issues with the pollutants in your
wastewater? Slug loads, quality/quantity of wastewater discharged, inconsistent flows,
oil and grease issues NO, We only know they like having us on the line as it is a dead end
and we provide enough flow to help the system
Does your facility have any limits from your POTW? No
Are there other MPP facilities in your region you could work cooperatively with along with your
POTW to address pollution (e.g. hauling waste water to another facility)? Are there other
opportunities for cooperation or cost-sharing related to wastewater treatment? This does not
affect us but, there is many plants throughout Michigan that are small and very rural. This would
be very expensive
How does your facility currently manage or treat wastewater? None
Best management practices can include dry clean up practices, grease and solids
removal, segregate waste, minimize water usage, by-product recovery, animal pen
waste management, blood handling, training, etc.
Does your facility employ any of these best management practices? If so, what type(s)?
N/A to our facility. I do know that most of the small slaughter plants have blood pits and
separate tanks for the holding pens
B2-8
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Treatment technologies can include screens, oil & grease traps, equalization, dissolved
air flotation, anerobic lagoons, etc. Does your facility have any treatment technologies
in place? If so, which ones? N/A most that I know of in Michigan have lagoon systems
Some treatment technologies require space. For example, the size of an anerobic lagoon
should be greater the more waste is treated. Does your facility have space it could use
for treatment technologies? If so, how much? N/A
In thinking about the best management practices and treatment technologies discussed are
there any that would be easier or more challenging for you to implement? Why? We don't know
anything about this tech. This is all new to most of us, most likely the cost would be the biggest
challenge for most plants.
Are there practices or technologies where cost may be an issue? Again don't know about the
practices or tech, cost will most likely be an issue
Are there other challenges that would make it difficult for you to adopt any of the best
management practices or treatment technologies discussed?
Have you had difficulty finding vendors to take by-products and blood? Many in Michigan have a
very hard time getting rid of the by-products
Are there other options for management of these by-products? There is composting
but, most facilities don't have the space, money or equipment needed
Are there specific concerns your facility has with the ability to comply with potential ELG
revisions? For example: available space, lack of expertise, access to funding/borrowing to cover
the cost of the capital equipment The lack of expertise is definitely going to be the biggest
hurdle. The second would be the funding for many plants in Michigan. The last hurdle would be
space if there is equipment involved, most plants don't have room to add equipment to an
existing facility without an addition.
What type of technical assistance would your facility need? As much as possible. No one
that I have talked to has any knowledge at all about what we may need to do.
Is this ongoing rulemaking affecting how your facility makes decisions on current plans? How
can EPA mitigate this? This is a definite concern. We have talked about moving locations to
expand but, with this regulation looming with the potential costs involved, we may put this on
hold. USDA and the Biden administration is giving grants for small processors to expand. But the
EPA is making it harder for these expansions.
What recommendations do you have for small business flexibilities to reduce burden? For
example: delayed implementation schedule Maybe looking at the size of plants for exemptions
and pounds produced. If this was changed just a little bit it would not affect a lot of small and
very small plants
Are there other federal regulations currently under development that apply to small entities in
this industry that may overlap with this EPA action? Not to my knowledge
B2-9
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Boone's Butcher Shop and Kentucky Association of Meat Processors
B2-10
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Boone's Butcher Shop
100 Old Bloorafield Pike
Bardstown, KY 40004
Tel (502)348-3668
allison@booneshutchershop.com
www.boonesbutchershop.com
Kentucky Association of Meat
Processors
176 Pasadena Drive
Lexington, KY 40503
Kymeatprocessors.org
KAMP
US Environmental Protection Agency
Washington, DC
JULY 31, 2023
RE: SER Comments to Formal Conference Meat & Poultry Products Effluent Limitations Guidelines Rulemaking
To whom it may concern,
Thank you for again allowing the small entity representatives (SER) provide comments back to the information presented at
the formal conference regarding Meat & Poultry Products Effluent Limitations Guidelines Rulemaking on July 17, 2023.
I did appreciate that we spent time during the formal conference to discuss how the EPA could identify small or very small
meat and poultry processors who may be excluded from the potential regulations. The exclusion of small plants could save
this sector of the meat processing industry.
To be frank, I was disappointed in the information provided in the formal conference on July 17"'. I put a lot of time and
effort into my comments submitted on May 16, 2023, after the initial informal conference and asked a lot of questions within
my comment letter that were not addressed during the conference or in any other format prior to the formal conference or
following it. We were encouraged to ask questions in those comments, and based on that encouragement, 1 fully expected to
receive answers to my questions. There are only a handful of SERs participating in this process, and the EPA look over 8
weeks to review our comments. I, like the other SERs, spent a considerable amount of lime and effort composing my
thoughts. I do not think the EPA adequately responded to most of the questions 1 posed in my original comment letter.
I would like to resubmit questions from my original comment letter dated May 16,2023 that 1 believe are critical for the EPA
to answer:
Page 3:
3, Has the EPA considered where the majority of the wastewater issues stemmed and whether regulating small
processors has a significant impact on water quality?
1. What specific equipment would be required to treat wastewater at a small processing plant?
Although I did note that the formal conference presentation did provide some additional details on what types of
treatments could potentially be implemented to address the regulations, I did not find them to be in enough detail for
me to understand what I would have to do to comply with the potential proposed regulation. For the EPA lo
seriously understand the impact the proposed regulations would have on small processors, I believe this information
is needed.
2. Is any of the equipment scalable to small processing plants?
3. I low would the EPA regulate plants that do not have the space lo implement all the necessary wastewater
treatments?
Page 4:
B2-11
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Page 5:
1. What level of training or knowledge specifically is needed to operate and maintain the water treatment equipment
witli the understanding that nearly all small plants would have very little prior understanding of the treatments
proposed? A 4-year degree, a 2-year degree, a 6-month course, a two-week course?
This question is of critical importance to the overall cost of implementing equipment or processes to comply with
potential EPA wastewater regulations.
2. Does a workforce exist that can fill these roles?
3. To what degree does the EPA plan to provide technical assistance to small meal processors to comply with these
requirements?
I would submit that this question is also of critical importance to determining the impact the potential proposed
regulations would have on small meat processors.
Following the formal conference, Lanelle Wiggins sent out a list of questions the EPA has for the SERs. Please see my
responses below notated with my initials A BP:
What is the production size of your facility?
ABP: 1 submitted a response to the detailed version of the EPA's Meat & Poultry Questionnaire. My facility ID
was DPK2788. Although 1 expressed during the formal conference that 1 do not have a lot of confidence in my
answers, those are the best answers 1 could come up with to provide facility size. Our facility has
approximately 40 full-time employees.
Do you know how much wastewater your facility generates?
APB: Per our water and sewer bills, we generate approximately 2,5 million gallons per year, which would be
approximately 6,900 gallons per day.
Do you discharge directly into a surface water or do you send your wastewater to a POTW?
APB: We discharge to a POTW.
What is your relationship with your POTW?
APB: We do not have a relationship with our POTW.
What technical assistance does the POTW provide you?
ABP: None.
~ Has the POTW discussed with you potential issues with the pollutants in your wastewater? Slug
loads, quality/quantity of wastewater discharged, inconsistent flows, oil and grease issues
ABP: Our POTW has never contacted us regarding our wastewater. After the informal conference with
the EPA in May, I reached out to our POTW to ask whether they had ever had any problems with our
wastewater. They had not. We are a very small user of their system.
Does your facility have any limits from your POTW?
ABP: No.
Are there other MPP facilities in your region you could work cooperatively with along with your POTW to
address pollution (e.g. hauling waste water to another facility)? Are there other opportunities for cooperation
or cost-sharing related to wastewater treatment?
ABP: No. Most small and very small meat processors are at least 60 miles from other processors in Kentucky.
How does your facility currently manage or treat wastewater?
~ Best management practices can include dry clean up practices, grease and solids removal, segregate
waste, minimize water usage, by-product recovery, animal pen waste management, blood handling,
training, etc,
2
B2-12
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Does your facility employ any of these best management practices? If so, what type (s) 7
ABP: Yes, we do, 1 am not aware of dry clean up that would be appropriate in the meat processing
industry, other than that we do remove debris from equipment prior to starting washdown
procedures. We also use grease traps, drain screens for solids removal, and segregate blood during
slaughter to dispose of with our solid waste. We provide training to our sanitation personnel on
proper cleaning techniques including the removal of solids prior to beginning washdown, the
emptying of screens into solid waste receptacles, and segregating blood from wastewater during
slaughter.
Treatment technologies can include screens, oil & grease traps, equalization, dissolved air flotation,
anerobic lagoons, etc. Does your facility have any treatment technologies in place? If so, which ones?
ABP: Yes, we use screens and grease traps.
Some treatment technologies require space. For example, the size of an anerobic lagoon should be
greater the more waste is treated. Does your facility have space it could use for treatment
technologies? If so, how much?
ABP: We have zero buildable space on our property. We were grandfathered into our location from
our original establishment from 1946 and we are completely landlocked in the middle of a downtown
area.
In thinking about the best management practices and treatment technologies discussed are there any that
would be easier or more challenging for you to implement? Why?
ABP: As noted above, we have no space to implement a lagoon. I am not familiar with how dissolved air
flotation works or the space it requires, 1 searched the July 17, 2023, EPA presentation and did not see a
description of equalization and do not know what that is. This question continues to illustrate the enormous
knowledge gap between what a small meat processor knows about wastewater management and what the
EPA implies we might know about wastewater management. In the first bullet point about treatment
technologies, the bullet says, "Treatment technologies can include screens, oil & grease traps, equalization,
dissolved air flotation, anerobic lagoons, etc," The only treatment technologies that I am aware of are those
that the EPA has defined for me. From the last presentation, I finally got an understanding of what a DAF is.
However, I still do not understand what one looks like, how much it might cost, how big it is, what it requires
to operate one. I can say that grease traps, screens, and lagoons are concepts I understand, but cannot speak-
to the other technologies listed.
Are there practices or technologies where cost may be an issue?
ABP: As discussed in my written comments submitted on May 16, 2023, yes, I believe cost is still a significant
issue to implementing these technologies. I can only take costs into consideration based on the information
provided in the EPA's presentation. Please refer to my lengthy response regarding cost in my first comment
letter.
Are there other challenges that would make it d ifficult for you to adopt any of the best management practices
or treatment technologies discussed?
ABP: Again, I know very little about wastewater management. Please consider the lack of knowledge our the
small and very small processor portion of the meat processing industry has regarding wastewater
management and the technologies that would be needed. Most of us cannot answer a question about
challenges because we do not understand the technologies well enough to do so.
Have you had difficulty finding vendors to take by-products and blood?
Are there other options for management of these by-products?
ABP: It is difficult for us to dispose of beef hides. The remainder of our by-products go to a renderer.
Are there specific concerns your facility has with the ability to comply with potential ELG revisions? For
example: available space, lack of expertise, access to funding/borrowing to cover the cost of the capital
equipment.
ABP; Yes, I have concerns about all of the examples you listed above. Again, please refer back to my May 16,
2023 written comments.
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What type of technical assistance would your facility need?
ABP: We would need a lot of technical assistance. We would need to understand exactly what
technology or equipment we would need, how to run it, how to test water to see if it is working, how
to maintain it.
Is this ongoing rulemaking affecting how your facility makes decisions on current plans? How can EPA
mitigate this?
ABP; Absolutely this is a factor in our current plans. We considered building a small fully cooked products
plant, and we were planning to submit an application for the USDA's Meat Capacity Grant. We chose not to
submit an application or move forward with a building at this time, in part, due to the potential financial
burden these regulations could have. The best way to mitigate that would be to exclude small and very small
processing plants from these potential regulations. A large meat processing plant that might expect to profit
millions of dollars annually would be able to absorb these costs and still be profitable. I am not aware of a
single small meat processor with less than 100 employees who would be able to absorb these costs.
What recommendations do you have for small business flexibilities to reduce burden? For example: delayed
implementation schedule
ABP: At the financial costs described in both of the EPA's presentations to the SERs, 1 do not believe you can
reduce the burden without excluding us from these regulations. The financial costs would require a plant of
our size to forego profits for several years. For smaller plants, they would have to forego profits for a decade
or more. People are not going to be willing to work for free for that many years. 1 believe those who are
already carrying a significant amount of debt will elect to file for bankruptcy rather than shell out millions of
dollars to install technologies that do not generate revenues for their businesses.
Are there other federal regulations currently under development that apply to small entities in this industry
that may overlap with this EPA action?
ABP: Not 1 am aware of,
I continue to urge the EPA to consider the exclusion of small and very small meat processors from this regulation all
together. I also urge the Small Business Administration to consider the how devasting the financial impact of these
regulations will be to 1,000s of small meat processing businesses across the country, The amount of consolidation that
has occurred within the food industry is already terrifying. Many small, rural communities across the country have no
access to healthy, fresh food other than their local farmers and butcher shops. These potential regulations would
further reduce access for those communities.
Vice President and Co-Owner
Boone's Abattoir, hie. (DBA Boone's Butcher Shop)
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Missouri Association of Meat Processors (MAMP)
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PO Box 518 * Carthage, MO * 64836
417-237-0410 phone/text
niki@mamp.co * www.mamp.co
July 31, 2023
In response to the zoom meeting on July 17 in regards to potential regulatory action.
Once again, thank you for allowing me to participate as a small entity representative, i
appreciate this opportunity as this potential action could significantly impact members of
the Missouri Association of Meat Processors (MAMP). There are still several items of
concern for our membership that I would like to note.
Cost-While the amounts/numbers have decreased since the last time, these costs still
could be substantial to our small processors. Substantial enough some may decide it is
no longer feasible to be in business. This will have such a domino effect on their local
community. Many of these businesses, too, have been a mainstay in their community
for many generations. The costs are referred to on page 24 of the PowerPoint.
Size of small processor-Please keep in mind, most of MAMP members are less than
100 employees. MAMP represents 145 small and very small meat processors in
Missouri and surrounding states. We define "small and very small" as less than 100
employees. Some of our processors have 2 employees. Less than 2 dozen have more
than 50 employees.
Technical support-The comprehension and understanding of "what" the processor will
need to do is overwhelming. They are going to need significant technical support on
understanding these rules and procedures. Is the EPA willing to assist with this
support?
We would like to try and answer some of the questions asked at the end of the
PowerPoint.
In thinking about the best management practices and treatment technologies
discussed are there any that would be easier or more challenging for you to
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implement? Why? The less complicated, the better. Clean, specific instructions
and expectations will be required to fulfill what is being asked of the processor.
Are there practices or technologies where cost may be an issue? As mentioned,
cost is a huge issue/concern. This aspect of the business is not a money-maker
and will take away from the bottom line in a huge way.
Are there other challenges that would make it difficult for you to adopt any of the
best management practices or treatment technologies discussed? We are
curious how this could impact USDA and state inspected facilities. Will the
inspectors understand what is being asked? Will USDA and EPA understand
each others rules and make it understandable for the processor?
Have you had difficulty finding vendors to take by-products and blood? There
has been great difficulty in the last few years with "offal" in our industry. Beef
hides use to make processors money and now it is an expense. Other issues
have occurred with deer season offal as well.
Are there specific concerns your facility has with the ability to comply with
potential ELG revisions? For example: available space, lack of expertise, access
to funding/borrowing to cover the cost of the capital equipment
What type of technical assistance would your facility need? Putting this
into effect will take a lot of technical support. Space could be an issue
depending on the size of the location (are they landlocked?).
Is this ongoing rulemaking affecting how your facility makes decisions on current
plans? How can EPA mitigate this? There could be capital projects a processor
is looking to do but if this is going to cost, those projects (which could bring in
more jobs and revenue for their city) would have to be put to the side.
What recommendations do you have for small business flexibilities to reduce
burden? For example: delayed implementation schedule. Please make sure
there is plenty of time for implementation. If something is needing to be built,
there could be the need to purchase land for more space. You never know how
long a construction project will really take, etc.
Are there other federal regulations currently under development that apply to
small entities in this industry that may overlap with this EPA action? Please
make sure EPA and USDA, local/state health department, Department of
Agriculture are all on the same page. This will help tremendously.
MAMP appreciates the EPA considering these items while in this process. If MAMP can
be of any more assistance, please contact me.
Sincerely,
Niki Mahan-Cloud
Mark Reynolds
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Executive Director MAMP President
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