Noted
Economist
Finds EPA
Analysis of
Water Rule
Flawed
Sunding documents how EPA excluded costs,
under-represented jurisdictional areas and used flawed
methods to arrive at much lower economic costs of the
proposed rule. Sunding’s report also notes that the lack of
transparency in the report makes it difficult to understand
or replicate EPA’s calculations, examine the agency’s
assumptions or understand discrepancies in its results.
Sunding has concluded that the errors in the EPA’s
analysis are so extensive as to render it useless for
determining the true costs of this proposed rule. His
report underscores the need for EPA to withdraw the rule
and complete a comprehensive and transparent economic
review.
“The EPA’s proposed waters of the U.S. rule is
irreparably flawed from an economic standpoint,” said
American Farm Bureau Federation President Bob
Stallman. “The rule is also an end run around Congress
and two Supreme Court rulings, and in their official
comments, farmers and ranchers across the national are
calling on EPA to ditch the rule.”
This rule will also have a huge impact on
communities and businesses across the country,
according to Stallman. He said it is not just businesses
trying to expand that will suffer. This proposed rule
would impact everything from local governments trying
to start or expand infrastructure projects to community
gardens.
The Environmental Protection Agency’s proposed
Clean Water Act rule is rife with errors, lacks
transparency and would greatly expand strict federal
control over land that was previously not regulated by the
federal government, according to a report by economist
“The rule will dictate land use across the United
and University of California-Berkley faculty member Dr. States,” Stallman said. “And EPA has not been forthright
David Sunding.
about the costs to our communities and businesses,
including countless small businesses.”
Sunding’s report, Review of 2014 EPA Economic
Analysis of Proposed Revised Definition of Waters of
Dr. Sunding prepared this report with support from the
the Unites States, raises the blinds on the controversial
Waters Advocacy Coalition, which represents Americans
proposal by detailing how EPA failed to provide a
involved in construction, real estate, mining, agriculture,
realistic explanation of the scope, costs and benefits of
wildlife conservation, forestry, manufacturing and
the rule.
energy. As a member of the coalition, AFBF will
continue to push for a better rule that balances the needs
The proposed EPA rule represents an expansion of
of affected communities with protections for our nation’s
the “Waters of the United States” to include waters such
waters.
as small, isolated wetlands, ephemeral drains and many
ditches. In the proposed rule’s economic analysis, the
To learn more, you may visit Farm Bureau’s “Ditch
EPA systematically underestimated the impact on affected the Rule” website at ditchtherule.fb.org.
communities and businesses, according to the report.
West Virginia Farm Bureau News 9