The Michigan Department of Environment, Great Lakes and Energy’s (EGLE) newly updated groundwater discharge permit for meat processors and slaughter facilities takes effect today, Nov. 1.
Seemingly specialized by title, Michigan Farm Bureau (MFB) experts say EGLE will likely use the meat processor and slaughterhouse permit conditions as a model when the agency updates other groundwater discharge permits, like those for fruit and vegetable processing.
“All industry sectors should review the permit conditions, to preview the potential changes coming their way,” said Tess Van Gorder, MFB’s conservation and regulatory relations specialist. “Updates to groundwater discharge permits for fruit and vegetable processors, wineries, breweries, distilleries and other small to medium food processors will likely be next.”
Groundwater discharge permits regulate wastewater, wash water and cooling water for facilities not connected to municipal wastewater systems.
Van Gorder said permit requirements can vary significantly depending on the operation and type of wastewater.
“Whether you’re a current permitholder, or someone who is not currently permitted but may need to be in the future, I encourage you to evaluate the requirements in the slaughterhouse and meat processor permit as it relates to your operation and leverage the resources listed in our fact sheet on the permit.”
EGLE hasn’t announced a timeline for updating other groundwater discharge permits.
Managing regulatory burden
In May, MFB submitted public comments on the revised permit for meat processors and slaughterhouses, bringing several concerns to EGLE’s attention, but also recognizing improvements made to the regulations.
“The revised permit allows more meat processing and slaughter facilities to fall under the general permit rather than an individual permit,” providing more regulatory certainty, Van Gorder said.
And the permit offers more flexibility than its predecessor.
Van Gorder explained that “permit holders have more wastewater treatment options, and the ability to time land applications based on field conditions as opposed to calendar month, which is unrealistic given our state’s infamously variable weather.”
While there are some improvements to the permit, concerns remain about some of the restrictive requirements of the final permit. These are outlined in MFB’s fact sheet.
Member direction is key
The updated groundwater discharge permit also lends an opportunity to highlight the role of MFB’s grassroots policy.
“Our members’ policy guidance, paired with staff technical expertise, enables us to best advocate on behalf of the state’s farmers to ensure we advocate for science-based regulations that don’t create unnecessary burden,” Van Gorder said.
Among the state-level policies providing guidance on the topic:
- #27 Michigan Meat Processing Industry calls for limiting regulatory burden for small- and medium-sized meat processors while protecting and enhancing food safety.
- #69 Streamlining Michigan Government states that regulatory agencies should maintain constitutional roles and reasonable environmental protection without creating undue regulatory burdens.
- #76 Environmental Protection and Authority devotes an entire section to processing wastewater and groundwater regulation.
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