VP2014_Viewpoint 8/29/2014 8:32 AM Page 1
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Issues impacting your operation
The 2014 Illinois Farm Bureau Policy Development Supplement
Proposed rule makes farming difficult Issue: ‘Waters of the U.S.’
In March, the U.S. Environmental Protection Agency (EPA) and the United States Army Corps of Engineers (Corps) announced a proposed rule that would expand their regulatory authority under the Clean Water Act (CWA). Specifically, the proposed rule makes changes to the definition of “waters of the U.S.” EPA and the Corps claim they are just clarifying their current jurisdiction, but, in fact, they are expanding their jurisdiction to include: • a broad definition of tributaries to traditional navigable waters, which includes seasonal and rain-dependent streams and most ditches; • all waters adjacent to traditional navigable waters, which includes adjacent streams, ditches and wetlands; and • isolated wetlands or “other waters” that have a “significant nexus” to the traditional navigable waters. The federal jurisdiction contemplated by the proposed rule goes far beyond what Congress intended with the CWA, and far beyond the limits on federal jurisdiction brought about by
U.S. Supreme Court case law. What does this mean for your farm in particular? Well, most farm ponds, ditches and rain-dependent streams are all covered under this proposed rule. Giving EPA and the Corps jurisdiction over these water and land features gives them the power to regulate or prohibit land uses and farming practices in, over or near them. This proposed rule would make it more difficult to farm or change a farming operation to remain competitive and profitable. The definition of “waters of the U.S.” is found throughout the CWA: Section 402 (National Pollutant Discharge Elimination System Permits), Section 404 (Dredge and Fill Permits), Water Quality Standards, Total Maximum Daily Loads and the list goes on. This expanded jurisdiction would allow EPA to overstep Illinois EPA in many more cases, and allow for citizen lawsuits that could create regulation and enforcement in cases where currently no such programming exists.
Jim Koeller kneels near the edge of a field ditch on his farm near New Canton. Farmers worry ditches like this could be federally regulated. (Photo courtesy of Pike and Scott County Farm Bureaus)
Illinois Farm Bureau policy process: ‘Truly, it works’ DAVID ERICKSON, CHAIRMAN, RESOLUTIONS COMMITTEE
At a recent county Farm Bureau policy meeting, I told members policy development for the Illinois Farm Bureau works for three simple reasons. First, any member can raise an issue of concern to his or her county Farm Bureau for consideration as a possible policy resolution. Nearly every year, a member from somewhere in the state has an idea or issue of personal importance that may affect many other members as well. The member brings that issue to his or her county Farm Bureau where it is dis-
Please see WOTUS, page 4
cussed and perhaps develops into a policy resolution for the IFB Resolutions Committee to consider. The members know that policy at the local and state level may also be considered at the national level if it is of national significance or importance. It works because individual members have a voice. Next, IFB policy development is known and regularly scheduled. Farm Bureau members know policy development is scheduled to take place at the same time each year using the same basic procedure. There is no mystery surrounding the process. Members and county Farm Bureaus know that it will happen, when it will happen and how they can be an active part of the process.
In addition, IFB leadership constantly educates elected state and national officials about our policy process. Those officials know that we develop policy positions with active engagement from our members. It works because it is a reliable process. Finally, Illinois Farm Bureau policy is respectfully regarded and held in high esteem. Voting delegates at the IFB Annual Meeting take the process of policy resolutions discussion very seriously. Delegates have the opportunity to discuss resolutions in great detail and work passionately to gain the support of fellow delegates for their specific policy resolution submittals. Once approved by the voting delegates, the Policy Resolutions Hand-
book is used to guide the legislative, regulatory and economic principles for our organization for the next year. Farm Bureau is well known in Springfield and Washington, D.C., for our well-defined policies and principled approach to advocacy. It works because our policies are highly regarded and well respected. We must continue to make policy development and review a cornerstone of the Illinois Farm Bureau. This important work helps to keep members engaged, issues reviewed and our efforts focused. Thank you to all county Farm Bureaus, county presidents, Resolutions Committee and members who have made policy development a priority. Truly, it works.
ARTICLES FOR THIS SUPPLEMENT WERE WRITTEN BY IFB STAFF: LAUREN LURKINS, KEVIN RUND AND DOUG YODER