Advocacy Comments on Proposed Meat and Poultry Processing Regulations

On January 23, 2024, the Environmental Protection Agency (EPA) published a proposed rule entitled Clean Water Act Effluent Limitations Guidelines and Standards for the Meat and Poultry Products Point Source Category (MPP ELG). The small entities subject to the requirements of this action are facilities that engage in meat and/or poultry slaughter, further processing, and/or rendering.

The EPA is proposing revisions to a regulation that would apply to wastewater discharges from MPP facilities. The proposed requirements would reduce the amount of nutrients and other pollutants discharged, both directly under state or federal permits and indirectly via sewers. Transport of discharges to and through municipal sewage treatment plants, also known as Publicly Owned Treatment Works (POTWs), would also be regulated.

The EPA has proposed three different regulatory options in the proposed rule. The EPA’s preferred option is Option 1. Option 1 would establish more stringent effluent limitations for nitrogen and, for the first time, limitations for phosphorus. Option 1 would also establish pretreatment standards for oil and grease, total suspended solids, and biochemical oxygen demand for the first time. Options 2 and 3 would also apply effluent limitations to additional direct and indirect dischargers as well as establish pretreatment standards for nitrogen and phosphorus for some of the indirect discharging facilities.

The Office of Advocacy filed comments on the proposed MPP ELG on March 25, 2024, supporting Option 1. Advocacy also requested the EPA to consider whether the proposed rule is necessary in light of pollution control measures currently being implemented by POTWs. Additionally, Advocacy warned the proposed rule might impede the ability of small businesses to take advantage of the Administration’s efforts to expand capacity for small and independent meat and poultry processors.

For more information, please contact Assistant Chief Counsel Nick Goldstein at, or (202) 772-6948.


Comment Letter – Clean Water Act Effluent Limitations Guidelines and Standards for the Meat and Poultry Products Point Source Category, Docket No. EPA-HQ-OW-2021-0736 (PDF, 54.8 KB)

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