Debate over S.100: whether it will satisfy EPA demands after Vermont CAFO de‑delegation findings

Summary

Conservation advocates told the Natural Resources & Energy Committee that S.100 largely preserves split authority between ANR and the Agency of Agriculture, potentially falling short of EPA expectations; ANR officials said S.100 provides essential statutory groundwork while they finalize an updated corrective action plan to EPA.

Scott Sanderson, director of the Conservation Law Foundation’s Farm and Food Program, told the Natural Resources & Energy Committee on March 14 that S.100 does not, in his view, resolve the problems EPA identified in its September 2024 findings and could leave the state vulnerable to partial de‑delegation of Clean Water Act authority.

Sanderson summarized EPA’s conclusion that Vermont’s divided regulatory structure—where the Agency of Natural Resources (ANR) controls point-source permitting and the Agency of Agriculture, Food and Markets (AAFM) oversees many farm inspections and required agricultural practices—has impeded adequate monitoring and enforcement. He said EPA cited inadequate inspections, lack of enforcement, permitting gaps on discharging CAFOs, and manure-management failures as primary concerns.

"Mostly my understanding is that…

Debate over S.100: whether it will satisfy EPA demands after Vermont CAFO de‑delegation findings

Summary

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