LOUISIANA DEPARTMENT Of AGRIcuLTuRE & FoREsTRY

Miiu Srju1N DVM 

Mr. Mathy Stanislaus 

Assistant Administrator 

Office of Solid Waste and Emergency Response (OSWER) 

USEPA He&iquarters 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Mail Code: 5101T 

Washington, DC 20460 

The Louisiana Department of Agriculture and Forestry respectfully requests an extension of the 

November 10, 2011 deadline for on-farm implementation of the Oil Spill Prevention, Control 

and Countermeasures Program (SPCC). Furthermore, I request that you reconsider 

implementing these measures as they will cause severe economic hardships to Louisiana farmers 

who have already suffered tremendous losses from both flooding as well as drought. 

Agriculture is the largest sector of our state's economy. Agriculture, forestry and aquaculture 

comprise over 85 percent of the surface area of this state, 9,7 percent of our work force, and over 

243,000 jobs. Valued at more than $30 billion, agriculture and forestxy combined make up one of 

Louisiana's largest and most economically dependent industries. If Louisiana is forced to comply 

with these actions, we are certain that many in Louisiana's agriculture community cannot meet 

these standards without the implementation of costly engineering plans. 

Louisiana agriculture and forestry has been very proactive in addressing environmental concerns. 

Scientifically based best management practices (BMPs) have been developed and 

recommendations to address on-farm fuel storage are a major component. These practices are 

being implemented through the Louisiana Master Farmer Program. These practices are targeted 

at reducing the generation and delivery of pollutants into the air and waters of the state. Our 

Louisiana Master Farmer Program is firmly rooted in state law, is backed by sound science and 

is a critical component of Louisiana's overall water resource management programs. 

Additionally, extreme losses have been incurred by our farmers and ranchers subsequent to this 

year's droughts and excessive rains. In Louisiana, since last year, our farmers and ranchers have 

lost over $300 million dollars in production. These losses follow only one year after our state 

incurred over $1 billion in losses due to tropical storm Faye, and Hurricanes Gustav and Ike. The 

disaster conditions severely impacted planting schedules and already limited farm budgets, and 

our farmers were not in a financial position to implement the SPCC plans. 

Post Office Box 631 5825 For)da Blvd. Baton Rouge. Louisiana 70821 -0631 Telephone 225) 922-1234 Fax i225 922 1253 www.ldf 5i.o'
Mr. Stanislaus 

August 11,2011 

Page 2 

Due to the extraordinary nature of the effects of natural disasters on our state's agriculture 

producers, we respectfully ask that you reconsider implementation of the final SPCC rule. We 

stand ready to assist in addressing environmental concerns in Louisiana; however we feel that: 1) 

Louisiana should be allowed to exercise the authority to develop its own standards and 

implement them through an approved and predictable process governed by existing state law, 2) 

decisions should be based on good science, 3) efforts are sensitive to economic costs to 

producers, and 4) consideration be given to the overall impact to the economic health of farmbased communities where agriculture is the economic base of these communities. 

In addition to the weather and economic challenges mentioned above a, Louisiana's agriculture 

industry is ill-equipped to implement the rule as sufficient guidance from EPA has not been 

provided as requested. Growers do not have dedicated environmental compliance officers that 

monitor EPA rules and regulations. Additionally, an extensive effort to identify professional 

engineers familiar with the SPCC rule AND willing to assist agriculture in its implementation 

yielded minimal to no results. Without such professionals, growers and landowners do not have 

the expertise to decipher this onerous unfunded EPA mandate. 

Due to EPA's failure to provide and disseminate adequate guidance regarding this rule growers, 

who are now focused on harvesting their crops through October, will not have enough time to 

meet the EPA deadline. 

Therefore we reiterate our request you reconsider implementing these measures or at the 

minimum the SPCC compliance date be extended until at least December 31, 2012 or preferably 

for 24 months. 

Finally, in addition to the compliance date extension we request that EPA provide and 

disseminate to the agriculture and professional engineering community the needed guidance on 

the rule to ensure that our state is equipped to meet the requirements of the mandate. 

Thank you for your thoughtful consideration of this request. 

Mike Strain DVM 

Commissioner