Revamping federal water quality rules would put small Iowa livestock farms out of business and notably accelerate consolidation of beef and dairy industries.

That was a major point driven home by Iowa State University (ISU) in comments to the Environmental Protection Agency (EPA).

The EPA proposal would place new rules on smaller livestock and dairy systems and require the containment of all feedlot runoff, according to ISU. Iowa has about 300 open feedlots under EPA regulation. The proposed rules would add 13,000 Iowa open feedlots to EPA’s jurisdiction.

"It is our belief that reducing the size of regulated facilities would pose a significant burden on many of the small facilities, with little environmental benefit," says Richard Ross, dean of ISU’s College of Agriculture.

Iowa Pork Producers Association (IPPA) stated EPA’s proposal "could potentially deteriorate effective statewide CAFO programs tailored to address state or regional specific production and management practices, nutrient usage and other environmental issues."

The EPA estimates 1,420 hog operations, 320 dairies, 150 broiler operations and 10 beef operations in Iowa would experience financial stress under the proposed rules.

But critics charge the actual numbers would be much higher than that. Under the EPA proposal, all operations with more than the equivalent of 1,000 animal units (1,000 lb. of animal = one animal unit) would be defined as CAFOs. The total cost of meeting the regulations for 1,000 a.u. or more is projected at $23,500/operation every five years, according to the IPPA. Structural cost is an additional $60,000/operation. Operations less than 1,000 a.u. could also end up falling under EPA guidelines if they are designated as major contributors to pollution (300-1,000 a.u.). Those less than 300 a.u. could be deemed a CAFO by the EPA or the state.

IPPA declares: "It is very important to point out that Iowa’s pork producers can’t pass costs on to end users. We strongly oppose the assumption by EPA, which suggests that 46% of the pork industry has the option to pass the compliance cost onto end-users."

ISU’s comments are on the Web at http://extension.agron.iastate.edu/immag/afocafo.html.