New Study Shows Need for EPA to Rework “Waters of United States” Proposal


Washington, D.C. (May 28, 2014)—The National Council of Farmer Cooperatives (NCFC) today reiterated its call for the Environmental Protection Agency (EPA) to withdraw and significantly rework their recently-proposed rule on defining the “Waters of the United States.” The action came in response to an economic analysis released today by Dr. David Sunding, an economist at the University of California at Berkley and a principal with The Brattle Group.

The report, Review of 2014 EPA Economic Analysis of Proposed Revised Definition of Waters of the United States, was commissioned by the Waters Advocacy Coalition (WAC), which represents the nation’s construction, real estate, mining, agriculture, wildlife conservation, forestry, manufacturing and energy sectors and of which NCFC is a member. The report exams the EPA’s cost-benefit analysis of their proposed “waters of the U.S.” rule and can be found online at http://www.nssga.org/economist-reviews-epas-economic-analysis-proposed-waters-united-states-rule/.

“Dr. Sunding’s study shows that the EPA’s analysis of the costs of this proposed rule is fundamentally flawed,” said Chuck Conner, president and CEO of the NCFC. “They excluded costs and used flawed assumptions and calculations to greatly underestimate the economic impact of the proposed rule. What is worse, the study also shows that the agency’s methodologies and assumptions are so opaque that it is nearly impossible replicate their results and see how they arrived at them.”

“The EPA’s proposal to revise the definition of ‘waters of the United States’ has the potential to dramatically expand federal jurisdiction over a vast swath of rural America and increase the regulatory burden on millions of farmers, ranchers and co-ops,” Conner continued. “The EPA should withdraw this rule, rework it to address the concerns of stakeholders across the country and be more open and transparent in their analysis of the proposal’s economic costs.”

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