August 21, 2018

Before leaving his office as Governor, Eric Greitens set in motion an aggressive state government wide “red tape reduction” effort. His goal was to reduce the number of “needless and burdensome regulations” by one third across all state agencies.

We are tracking some the Missouri Department of Natural Resources’ (DNR) “red tape reduction” efforts to make sure that they do not result in changes that leave our public health and environment at risk. There are hundreds of rule changes under consideration. Many changes are, in fact, updating outdated language and protocols. Other changes, however, are concerning related to transparency and accountability.

We have identified 4 rules that we think will weaken public notice requirements and make it easier for Concentrated Feeding Operations (CAFOs) to get up and running in Missouri:

  • 10 CSR 20-4.050 Environmental Review: We are concerned that this rule is being changed to remove language about the requirements for public hearings and public access to documents related to new projects. Message: Don’t change 10 CSR 20-4.050.
  • 10 CSR 20-6.020 Public Participation, Hearing, and Notice to Government Agencies: We are concerned that changes to this rule weaken the public’s ability to access information because it deletes the following sentence: “Applications, draft permits, supporting documents and reports upon those documents shall be available to the public, except for those portions determined to be confidential.”Message: Don’t change 10 CSR 20-6.020.
  • 10 CSR 20.6.300 Concentrated Animal Feeding Operation (CAFO): We are concerned that the proposed deletions in this rule remove the requirement for CAFOs to apply for permits 90 and 180 days before starting operation and remove specific provisions for neighbor notice requirements. Message: Don’t change 10 CSR 20.6.300.
  • 10 CSR 20-14 Classification of CAFO Waste Management Systems: We are concerned about how the changes in this rule reduce the minimum standards required to become a CAFO Waste Management System Operator across the board and make it easier to become an operator. Message: Don’t change 10 CSR 20-14.

MCE will submit comments on these changes and a few others before Thursday, August 23, 2018 at 5:00pm CT. You can comment on these changes too! Commenting online is easy.

Go to DNR’s Regulatory Action Tracking System , find the rule you’re concerned about (save time by copying the rule number from above and pressing “Ctrl+F” on your keyboard to find it), and submit the comment electronically. Your comment can be as simple and short as what we have said above.

Please submit your comments before Thursday, August 23, 2018 at 5:00pm. If you want to learn more about DNR’s “red tape reduction” efforts or are having trouble submitting your comments, please reach out to MCE’s Water Policy Coordinator Maisah Khan at . If you do submit a comment, please drop Maisah a note so she can do a happy dance.