MICHIGAN WASTEWATER PETITION
EGLE PUSHING THROUGH UPDATED REQUIREMENTS FOR MEAT PROCESSORS AND SLAUGHTERHOUSES
Is your business ready to pay for the updates required to meet the new guidelines?
Background
The Michigan Meat Association filed a lawsuit on October 28, 2022 against EGLE (Michigan Department of Environment, Great Lakes, and Energy) formerly known as MDEQ (Michigan Department of Environmental Quality) in response to EGLE overstepping their authority in developing new discharge criteria for the general groundwater discharge permit for meat processing and slaughter facilities. Currently, they are enforcing these requirements for the 26 current general permit holders, but EGLE’s future plan is to monitor an estimated additional 400 facilities.
Estimated Cost for Individual Processors
Our key-expert witness and Director of Regulatory Affairs, Matthew Germane, developed estimated costs based on the average existing facility to be as follows:
• Consulting Fees: $118,000
• TIN: $180,000
• Biological treatment: $550,000
This means an initial investment to satisfy the EGLE requirements for each facility will be approximately $848,000 (the sum of the above three numbers, plus some contingency). This amount would increase further if the low phosphorus concentrations were enforced due to proximity to surface waters.
Impacts
Food Supply Chain
The cost, both up front and ongoing maintenance, will be too much for small to midsized processors to afford. Many existing general permit holders are facing the reality of closing their doors permanently and once the list of 400+ is required to comply, they will also have to face this reality. This will impact the availability of custom processors for farmers raising livestock, as well as youth exhibitors at local county fairs.
Economic Impacts
For those processors that remain open, they will need to raise their prices to cover the costs to meet the updated requirements. Raising costs in an inflated market will raise questions on the viability of the farming market for livestock. Small to midsize processors will then become less competitive in the market, allowing a greater opportunity for larger processors to pay less to the farming community for processing.
Fundraising Efforts
The anticipated costs for our legal defense is budgeted to be $100,000.00. Collectively, we have raised over 30% of the funds needed. Please consider providing a monetary contribution for this topic to remain relevant.