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NASDA Member Chris Chinn Emphasizes Necessary Cooperation Between the EPA and State Departments of Agriculture

WASHINGTON, D.C. – Missouri Agriculture Director Chris Chinn, a board member of the National Association of State Departments of Agriculture, testified before the U.S. House Committee on Agriculture today. As director of the Missouri Department of Agriculture, Chinn plays a crucial role in protecting the well-being of farmers and consumers while ensuring the vitality of Missouri’s diverse food supply within her state and beyond.

Chinn’s testimony focused on challenges faced by states in their role as co-regulators with the U.S. Environmental Protection Agency while also emphasizing recent successful cooperation.

During her testimony, Chinn underscored the need for federal agencies to more meaningfully include state departments of agriculture in conversations concerning regulatory policymaking, more commonly known as cooperative federalism.

“When it comes to protecting the environment, agricultural producers and communities of every size rely on decisions from the EPA that are based on sound science, collaboration and transparency throughout each step of the process,” Chinn said. “It is time for the EPA to invite agriculture generally, and state departments of agriculture specifically, into discussions early and often to find solutions that can elevate environmental protections and production agriculture.”

Chinn stated that a collaborative approach from the EPA would elevate state departments of agriculture’s critical contributions as co-regulatory partners while reducing the negative effects of burdensome mandates on American agriculture.

“Regulations must be based on validated science and science-based risk assessments,” Chinn said. “To achieve this goal, the federal government must embrace states’ co-regulatory role – lifting them up as true partners in the regulatory process, not simply stakeholders.”

When discussing the EPA’s Vulnerable Species Pilot Project and Herbicide Strategy in the 2022 Endangered Species Act Workplan Update, Chinn noted how a lack of collaboration from the EPA resulted in frameworks that were not feasible for the agriculture community.

“The Agency’s failure to engage with co-regulators that are closest to producers is a major factor in those frameworks being unworkable for both pesticide applicators and state enforcement agencies,” Chinn said.

Chinn expressed additional concern about regulations regarding the EPA and U.S. Army Corps of Engineers’ revisions and inaction of implementation of the 2023 Waters of the U.S. rule after the Sackett v. EPA Supreme Court decision.

“It’s been over a year since the Supreme Court’s decision in Sackett v. EPA, and state departments of agriculture, farmers, ranchers and landowners are still waiting on the agency to implement the decision into their WOTUS rule and, most importantly, recognize the critical role of states in regulating non-navigable waters,” Chinn said.

Despite these concerns, Chinn applauded the EPA’s efforts in incorporating cooperative federalism objectives into various regulatory policy developments. This includes the agency forming the Animal Agriculture and Water Quality Federal Advisory Subcommittee and the successful Mississippi River/Gulf of Mexico Hypoxia Task Force.

Chinn thanked the House Committee on Agriculture for the opportunity to speak during the “Examining the Consequences of EPA’s Actions on American Agriculture” hearing and to share her and NASDA’s perspectives on these issues. NASDA looks forward to continued collaboration between the EPA and state agricultural departments.

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