WV Farm Bureau Magazine June 2014 | Page 9

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