Forty-five community, environmental, and animal welfare organizations — together representing tens of millions of people across the United States — filed public comments yesterday with the U.S. Environmental Protection Agency, pressing for strong protections against water pollution from slaughterhouses and animal rendering facilities. The EPA published a proposal to strengthen existing protections in January 2024, following lawsuits from several of the commenting organizations. The comments emphasized that the EPA must improve its proposal to address environmental injustice and reduce harm to people and the environment.

“For decades, slaughterhouses and meat processing plants have benefited from lax water pollution standards, and we are pleased that the EPA is finally taking action to strengthen these standards for some of the largest plants,” said Sarah Kula, Attorney for the Environmental Integrity Project. “But EPA’s proposal falls far short of what the Clean Water Act requires and exempts thousands of polluting plants that put downstream communities and our waterways in harm’s way. EPA must require that these plants install modern water pollution controls and clean up their act.”

Nearly 10 billion animals are killed each year in slaughterhouses across the United States — that is, over 18,825 animals every minute. Slaughterhouse byproducts such as fat, bone, and feathers frequently are sent to rendering facilities for conversion into tallow, animal meal, and other products. Both slaughterhouses and rendering facilities require a near-constant flow of water, and every year, these facilities discharge hundreds of millions of pounds of water pollution into rivers and streams. According to EPA, slaughterhouses and rendering facilities, which together comprise the Meat and Poultry Products (MPP) industrial point source category, are the largest industrial source of phosphorus pollution and the second largest industrial source of nitrogen pollution.

“EPA knows that pollution from slaughterhouses and rendering facilities disproportionately harms under-resourced communities, low-income communities, and communities of color,” said Earthjustice attorney Alexis Andiman. “Yet EPA’s proposal expressly ignores environmental justice and, instead, champions weak standards that, it claims, are necessary to thwart disruptions to the nation’s meat supply — despite clear evidence that stronger regulations will have virtually no impact on meat producers or consumers. The Agency’s priorities are backwards. We need the EPA to protect people and the environment, not corporations.”

Pollution from MPP facilities has devastating consequences for human health and the environment, and it disproportionately harms people living in vulnerable and under-resourced communities. Nonetheless, EPA has failed to revise its regulations governing water pollution from the MPP industry for at least 20 years. Some MPP facilities are still subject to outdated and under-protective standards promulgated in the mid-1970s. EPA’s existing regulations fail to impose any restrictions on discharges of phosphorus, and the Agency has never published national standards applicable to the vast majority of MPP facilities, which discharge wastewater indirectly through publicly owned treatment works (POTWs), even though EPA has known for decades that — without adequate pretreatment — pollutants in MPP wastewater pass through many POTWs into our nation’s rivers and streams.

The EPA’s proposal set out three options to strengthen existing standards. The comments made clear that the EPA’s preferred option, which offers the weakest protections for people and the environment, is inconsistent with federal law — not least because it is motivated by a desire to avoid disruptions to the country’s meat supply, even though claims of past disruptions have been resoundingly debunked. Instead, the commenting organizations pressed the EPA to select and strengthen the most protective of the regulatory options presented, which would prevent over 320 million pounds of pollution, reduce nitrogen and phosphorus pollution by 85%, and help to protect over 22 million people.

“We call on the EPA to rise above Big Ag’s push to weaken this plan to reduce harms from the millions of gallons of pollution slaughterhouses and animal rendering plants are spewing into our waterways,” said Hannah Connor, deputy director of environmental health at the Center for Biological Diversity. “This proposal would put very reasonable updates in place that will give critically imperiled fish and mussels the protections they need to survive.”

Food & Water Watch Attorney Dani Replogle said: “EPA’s preference for weak slaughterhouse regulations privileges the health of a polluting industry over that of frontline communities and our nation’s waters. To adopt anything less than the most stringent clean water protections in the agency’s final rule would be a missed opportunity and a big mistake.”

“We are disappointed that EPA chose the least protective option, which is bad news for the Chesapeake waterways and communities since we have far more indirect discharging slaughterhouses and rendering facilities than direct dischargers,” Robin Broder, Deputy Director of Waterkeepers Chesapeake, “In our region that is already suffering from nutrient pollution, the lack of limits on nitrogen and phosphorus for the majority of our plants is incredibly short sighted and ignores the harm caused by nutrient pollution. Pollution control technology exists and should be required.”

“Slaughterhouse pollution takes a huge toll on America’s rivers,” said John Rumpler, senior clean water director for Environment America Research & Policy Center. “We reject the idea that dead fish, toxic algae or contaminated drinking water are prices worth paying for a slightly cheaper chicken nugget. We call on the EPA to adopt a final rule that maximizes our chances for cleaner water across the nation — with rivers, lakes and streams that are safer for recreation, wildlife and our drinking water.”

“The draft rule is critical to protect vulnerable communities from pollution and yet the agency is opting for less stringent standards due to the misguided notion that meat suppliers will be severely impacted,” said Animal Legal Defense Fund Senior Staff Attorney Larissa Liebmann. “The EPA should not use the animal agriculture industry supply chain as an excuse to implement inadequate standards.”

“Across the country, and under the radar, large corporate slaughterhouses are sending massive amounts of industrial waste into aging publicly-owned sewage treatment plants, contributing to towns violating their Clean Water Act permits and causing untreated pollutants to pass through into waterways,” said Kelly Hunter Foster, Waterkeeper Alliance Senior Attorney. “EPA can put a stop to this industry pushing their environmental responsibilities and expenses onto the communities, residents, and taxpayers that cannot afford it by simply finalizing strong national water pollution standards.”

The commenting organizations are: Earthjustice, Environmental Integrity Project, Animal Legal Defense Fund, Atchafalaya Basinkeeper, Bayou City Waterkeeper, Bitterroot River Protection Association, Black Warrior Riverkeeper, Cahaba Riverkeeper, Cape Fear River Watch, Center for Biological Diversity, Center for Food Safety, Choctawhatchee Riverkeeper, Coastal Carolina Riverwatch, Comite Civico del Valle, Congaree Riverkeeper, Endangered Habitats League, Environment America, Environmental Working Group, FarmSTAND, Food & Water Watch, Freshwater Future, Good Stewards of Rockingham, Harpeth Conservancy, Humane Society of the United States, Los Angeles Waterkeeper, Lake Erie Waterkeeper, Local Environmental Action Demanded Agency Inc., Milwaukee Riverkeeper, MountainTrue, Ogeechee Riverkeeper, RE Sources, Rural Empowerment Association for Community Help, Save The River — Upper St Lawrence Riverkeeper, Seneca Lake Guardian, Snake River Waterkeeper, Socially Responsible Agriculture Project, Southern Environmental Law Center, Spring Creek Coalition, Tennessee Riverkeeper, Tualatin Riverkeepers, Upper Coosa Riverkeeper, Waterkeeper Alliance, Waterkeepers Chesapeake, Winyah Rivers Alliance, and Yadkin Riverkeeper.