# Lou Lciuna Farm Bureau Federation, Inc.

Mr. Mathy Stan islaus

Assistant Administrator Office of Solid Waste and Emergency Response (OSWER) USEPA Headquarters Ariel Rios Building 1200 Pennsylvania Avenue, NW
Mail Code: 5101T Washington, DC 20460

Dear Mr. Stanislaus:

The Louisiana Farm Bureau Federation (LFBF) would like to express our concerns regarding the implementation of the Oil Spill Prevention, Control and Countermeasure(SPCC) rule for farmers and ranchers and ask for an extension of the deadline for onfarm implementation. We are concerned that many operations will not meet the current deadline. Farming and ranching in Louisiana is very diverse. Therefore grower needs and understanding of this issue varies greatly.

While farmers in Louisiana have a strong environmental record and follow scientifically based best management practices, their ability to address any one concern is heavily influenced by the information they receive, the timeliness of the information and their financial resources. Louisiana farmers do not have employees dedicated to environmental compliance issues. They depend on organizations, agencies and University's to inform them of issues that they need to address. EPA's farm SPCC factsheet was posted in March of this year and the farm scenario template was posted in late April. At that time Louisiana growers were already busy with field and planting operations and have since been dealing with a very challenging growing season. Growers do not have the means to stop field operations during the growing season to work on an unfunded mandate. For something to be implemented effectively there needs to be a much more timely and expanded outreach to growers so that during their off season they can address this compliance issue. In many instances they do not own the land where the facilities are and this further complicates the issue and requires additional education and approval of landowners.Among the growers that are aware of the issue, most are still confused on exactly what

they needed to do and in many cases are still waiting for further clarification. Growers are willing to do what it takes to comply however for many the required improvements to infrastructure are very expensive. They cannot afford nor do they want to do this work twice. Additional detailed guidance regarding this rule needs to be provided, so that they can construct the proper safeguards the first time. Additionally, Professional Engineers (PEs) qualified, registered or willing to provide services regarding SPCC are extremely limited in Louisiana. Hopefully a greater outreach to them would increase the services available to growers and landowners.

This has been a very difficult growing season in Louisiana. We have experienced both floods and extreme drought conditions. Growers with the ability to irrigate have done so around the clock and most are still experiencing production losses. They could not stop irrigation operations to address fuel tank issues while trying to keep up with the water demands of their crops. It will be extremely difficult for growers to deal with their financial losses and yet be out the additional costs to comply with this rule.

We hope you will look upon this request favorably. Farmers and Ranchers are experiencing a very difficult year in Louisiana and many do not have the additional resources required to comply with this rule. Louisiana Agriculture has a long history of proactively addressing various environmental concerns but additional time is needed to comply with the current SPCC regulations.

Thank you for your consideration.

Since rely,

Ronald Anderson

President

LFBF

cc: Lawrence Elworth Agricultural Advisor to the Administrator USEPA Headquarters