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