Participate in Oil Spill Survey

01/14/05

Report accurate data of your on-farm oil products to prove the SPCC
(Spill Prevention, Control and Countermeasure Plan) rule should not apply to most farms!

USDA is now collecting oil spill survey to have information about actual on-farm practices used in managing fuel and oil products. Please fill out this survey and return it to USDA by January 24, 2005. Click here to download the survey form.

The Environmental Protection Agency (EPA) published the final Spill Prevention, Control and Countermeasure Plan (SPCC) rule in the Federal Register on July 17, 2002 without accurate data on the storage of fuel on farms. Click here to review the SPCC rule on July 17, 2002.

The rule required any facility, including farms, with 1,320 gallons of oil on their property, in above ground tanks of 55 gallon containers or greater to do the followings:

1. Developing an approved Oil Spill plan by February 2006
2. Installing secondary containment (berms or drain basins) by August 2006
3. Installing fencing of tank sites by August 2006
4. Installing monitoring of tank sites by August 2006
5. Having a plan for integrity testing of tanks and pipes by August 2006
6. Having approval of site and plans by certified Professional Engineer

Note: In this rule oil is defined as animal fats, vegetable oils, and petroleum lubes, oil, fuels.

At the 138th National Convention in November, 2004, the National Grange adopted a policy saying that:

"The National Grange supports agricultural exemptions from the Environmental Protection Agency's Spill Prevention Containment and Control ruling."

In a coalition letter last year the National Grange also pointed its more specific views on the SPCC rule:

1. Farming operations do not really fit the regulation's "facility" definition. Farms are not defined as a single facility at a fixed location. Farming operations that cover more than one area should not be considered a single facility and that aggregate tankage should be determined separate for each field. It is also considered necessary that the EPA rule change its limit from a single 1,320-gallon trigger to encompass several triggers depending on the size and number of fields.
2. The only requirements that should be made on tanks on agricultural lands consist of visual inspection and appropriate record keeping because commercial fuel distributors inspect the tanks on a regular basis. During most times, the tanks are seldom used.
3. An additional two years beyond the August 17, 2004 deadline is needed for farmers to comply with the EPA's final rule. Furthermore, states should also be given additional time to facilitate implementation and compliance before the EPA enforcement takes effect.

In order to help USDA convince the EPA that the SPCC regulations should not apply to most operating farms, more information on actual farm use of fuels and oils is needed. Please fill out this survey and return it to USDA by January 24, 2005.

Click here to download the survey form

This survey will help any new regulations reflect actual farm practices so that they will be less costly to farmers.

If you have any questions or comments please contact Legislative Research Analyst Chil-Sook Hwang by e-mail: chwang@nationalgrange.org by fax: 202-347-1091 or by phone: 1-888-4GRANGE, ext 109.

Thank you for your grassroots participation in the National Grange Legislative program.

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