Policy Memo: The Need To Regulate the Meat Industry’s Immense Water Pollution

MEMORANDUM

TO: EPA Administrator, Gina McCarthy

FROM: Allie Hale, Davidson College student

SUBJECT: The Need To Regulate the Meat Industry’s Immense Water Pollution

DATE: April 11, 2016 

The EPA has overlooked the massive ecological footprint of the meat industry, and stricter regulations must be put in place. Between 2010 and 2014, Tyson Foods Inc., an international leader in the poultry and beef industry, released 104,468,732 pounds of toxic waste into American water, ranking second in water-polluting companies.[i] These large-scale livestock factories like Tyson, also known as CAFOs (concentrated animal feeding operations), produce enormous amounts of toxic waste through fertilizer and animal manure. According to the EPA, a medium-sized dairy farm of roughly 2,500 cows produces the same amount of waste as the city of Miami.[ii] In considering the fact that there are about nine hundred thousand dairy farms in the United States, these figures are very significant.[iii] The dumping of this waste into waterways causes pollution that is detrimental to wildlife as well as a human health hazard. Among the affected waters are the Great Lakes, Chesapeake Bay, and Puget Sound.[iv] The meat industry’s pollution is dreadfully widespread, highly detrimental, and entirely unnecessary. The government must take action to prevent this immense water pollution whether it is through an incentive-based approach, improved cleaning technology, or direct regulation. This memo explains and evaluates these three different strategies, and recommends that the EPA prioritize regulating pollution from CAFOs. 

PROPOSED SOLUTIONS

1. Approach #1: Incentive-based approach: Offer monetary incentives for CAFOs that are below a particular level of waste-produced. Financial rewards could be action inducing for companies, motivating them to reduce their levels of waste.
2. Approach #2: Increased transparency and direct regulation: Industrial factories and sewage operations are considered “point sources” under the Clean Water Act and are required to receive permits and comply with set limitations on pollution.[v] This same system, however, is currently not in place for CAFOs.[vi] CAFOs should be required to obtain a permit and register with the EPA. Through this registration, they will need to report their toxic waste levels and how and where it is disposed. The EPA will create limitations to the amount of waste that companies are allowed to produce and dispose of, enforcing a fine if these levels are exceeded.
3. Approach #3: Focus on water-cleaning technology systems and improvement: Rather than focusing on the companies, efforts could be made to clean the water itself through working to improve The government would fund the creation of new, more efficient waste-management systems for affected American waterways to deal with the pollution directly. 

CRITERIA FOR DECISION ANALYSIS

In order to properly evaluate these policy options, I will use the five criteria for decision analysis, which include: administrative feasibility, effectiveness, social costs and benefits, environmental costs and benefits, and economic costs and benefits. The criteria have been weighted in accordance with their importance. Effectiveness and environmental costs and benefits are prioritized here, weighted with most importance, with social costs and benefits following. Possible rankings include 1 = costs exceed benefits, 2 = costs and benefits are roughly equivalent, 3 = benefits exceed costs.

EFFECTIVENESS

• Approach #1: May motivate smaller CAFOs to reduce waste in order to obtain the monetary reward. Seeking out financial rewards from incentives, however, may not be in the best interest for the larger, more pollution-heavy companies such as Tyson when considering a cost-benefit analysis. (Low)
• Approach #2: This method would be effective as it sets clear boundaries as a law that must be followed, resulting in high fines if broken. Creating a set EPA regulation for all CAFOs would heighten the level of seriousness and legitimacy. (High)
• Approach #3: The improvement of water-cleaning technology would accomplish the goal of reducing pollution, though it may not be achieved in a timely manner. (Moderate)

ADMINISTRATIVE FEASIBILITY

• Approach #1: Feasible for the government, likely the simplest approach to administer, as it requires only a default payment based on a measurement. (High)
• Approach #2: Places the burden on the companies themselves, requiring them to self-regulate in order to report numbers. The work of the government would be to set and monitor restrictions, which is feasible, as the EPA uses the same system for oil and gas companies.[vii] (High)
• Approach #3: Requires time and a detailed planning process, but it is feasible and could be modeled after already existing waste management systems. Burden placed on government, however, not requiring any effort by companies creating waste. (Moderate)

SOCIAL COSTS AND BENEFITS

• Approach #1: The monopoly of Tyson and only a few other huge companies in this industry requires policies that do not enhance this inequality. The incentives approach may drive more financially stable companies to ignore environmental concerns while forcing smaller companies to comply. (High social cost)
• Approach #3: Potential for increased taxes in the areas of highly polluted water to pay for instruments of waste-removal and their administration. Places financial burden on citizens rather than companies. (High social cost)

ENVIRONMENTAL COSTS AND BENEFITS

• Approach #1: May reduce less waste due to low motivation by largest contributors with high financial stability (Tyson, etc.). (Low environmental benefit)
• Approach #3: The procedure of creating new technological cleaning systems may be in itself a burden to the environment with the potential to create more pollution and use many materials. (High environmental cost)

ECONOMIC COSTS AND BENEFITS

• Approach #1: Some might argue that it is unnecessary to reward companies for decreasing pollution, because they should not be dumping this excessive amount of waste in the first place. By providing incentives we are supporting these companies. (Moderate economic cost)
• Approach #3: Costly to build new technology to be used nation-wide. (High economic cost)

RECOMMENDATION

As evidenced by the decision analysis and its weighing of the five criteria, the direct regulation along with increased transparency is the best solution to the problem of CAFO water pollution through waste disposal. Enacting regulations give companies no choice but to reduce their waste in order to decrease the unsanitary measures of polluting American waterways. Of all the potential options, this is the most all-over effective method and does not inadvertently give larger monopolistic companies an advantage.

Bibliography

“America’s Next Big Polluter: Corporate Agribusiness: Company Profile: Tyson Foods, Inc.” Environment Massachusetts. http://www.environmentmassachusetts.org/sites/environment/files/reports/Env_Am_Tyson_v4.pdf.

Benson, Jonathan. “Tyson Foods dumps more than 18 million pounds of toxic chemicals into America’s waterways each year.” Natural News. Last modified June 29, 2014. Accessed March 21, 2016. http://www.naturalnews.com/045788_Tyson_Foods_pollution_toxic_chemicals.html.

Geiling, Natasha. “This Meat Company Dumps More Pollution Into Waterways Each Year Than ExxonMobil.” Think Progress. Last modified February 8, 2016. Accessed March 21, 2016. http://thinkprogress.org/climate/2016/02/08/3747114/agribusiness-tyson-water-pollution/.

Huber, Bridget. “As Factory Farms Spread, Government Efforts to Curb Threat From Livestock Waste Bog Down.” Fair Warning. Last modified May 20, 2013. Accessed March 21, 2016. http://www.fairwarning.org/2013/05/as-factory-farms-spread-government-efforts-to-curb-threat-from-livestock-waste-bog-down/.

Philpott, Tom. “Obama’s 5 Biggest Sellouts to the Meat Industry.” Mother Jones. Last modified November 5, 2013. Accessed March 21, 2016. http://www.motherjones.com/tom-philpott/2013/10/obamas-five-biggest-sellouts-meat-industry.

“Pollution from Giant Livestock Farms Threatens Public Health.” NRDC: Natural Resources Defense Council. Last modified February 21, 2013. Accessed March 21, 2016. http://www.nrdc.org/water/pollution/nspills.asp.

[i] Bridget Huber, “As Factory Farms Spread, Government Efforts to Curb Threat From Livestock Waste Bog Down,” Fair Warning, last modified May 20, 2013, accessed March 21, 2016, http://www.fairwarning.org/2013/05/as-factory-farms-spread-government-efforts-to-curb-threat-from-livestock-waste-bog-down/.

[ii] Huber, “As Factory Farms Spread,” Fair Warning.

[iii] Huber, “As Factory Farms Spread,” Fair Warning.

[iv] Jonathan Benson, “Tyson Foods dumps more than 18 million pounds of toxic chemicals into America’s waterways each year,” Natural News, last modified June 29, 2014, accessed March 21, 2016, http://www.naturalnews.com/045788_Tyson_Foods_pollution_toxic_chemicals.html.

[v] Huber, “As Factory Farms Spread,” Fair Warning.

[vi] Huber, “As Factory Farms Spread,” Fair Warning.

[vii] Huber, “As Factory Farms Spread,” Fair Warning.