Farming Means a World of Good

Posted on | June 23, 2014 | No Comments

By Meghan Osterbauer of Benson, Minn.

At the end of June 2013, I attended the National Farmers Union All-States Leadership Camp in Bailey, Colo. I can genuinely say that it was one of the most life-changing experiences I’ve ever had. I gained an entirely new outlook on everything just by spending one short week with some of the most amazing people I’ve ever met. In that brief time, I made lifelong friendships.

How does that work? How is it that after a few short days these complete strangers that I don’t even really have that much in common with have become so important to me?

Then I remembered a sort of mantra we had at camp. We would say, “This week, I am from all states.” Not from Minnesota or North Dakota or Wisconsin…. we are from all states. You didn’t really know or care where people were from.  I realized that that was the key. The key was that at All-States Leadership Camp we focused on all states ­– or what we had in common — and became friends because of it.

Now imagine if we could do this for everyone in the world. If we could look at a globally uniting factor such as farming … if we can just grab that idea, that we all need farming and that it is something we all share and we use that to hold us all together, then the differences among us become our “uniques” and our contributions the world community rather than rifts that separate us into different groups of people. These separations cause problems.

In order to generate the idea that one group of people is better than another, we must first entertain the notion that there are separate groups of people. No.  If something we all share, a common factor like farming, can show that we don’t have to divide ourselves like this. Farming says we don’t have to be these people and those people…. farming can make us ask the question:  Why can’t we all just be people? And it is when the world understands we are all just people, we will find peace. And so I will argue that farming means a world of good.

Meghan is majoring in psychology at the University of Minnesota in Duluth and was a member of the NFU National Youth Advisory Council.

Adapting the global food system to climate change should be a priority,” says CCGA

Posted on | June 19, 2014 | No Comments

by Daryll E. Ray and Harwood D. Schaffer, Agricultural Policy Analysis Center, University of Tennessee, Knoxville, Tenn.

Read the original post at agpolicy.org.

The first portion of the publication, “Advancing Global Food Security in the Face of a Changing Climate” (www.tinyurl.com/mb4pj5s), by the Chicago Council on Global Affairs (CCGA) focuses on the science of global warming and the impact it will have on agricultural production—see our column (http://agpolicy.org/weekcol/723.html) for a summary of this analysis.

It is our observation that much of the denial—including by some in the US farming community—of the concept of human-induced climate change has less to do with scientific analysis than it does with the policy implications of climate change. They don’t like the regulatory policies—like cap and trade (a proven market-oriented motivator originally proposed by free market advocates) or just about any Environmental Protection Agency emissions controls—that might be required.

The CCGA analysis that we look at in this column suggests that doing nothing could be worse.

In the second section of the council’s publication, the lead author, Gerald C Nelson, makes the case that given the magnitude of the impact that global warming will have on farmers and food production worldwide, “adapting the global food system to climate change should be a priority.”

Nelson begins by identifying research that indicates that as average temperatures increase by a couple of degrees, crop yields begin to decrease by as much as a couple of percent a decade. The impact on yield is most likely to occur in low latitude regions where hunger is already the greatest.

He also makes the case that the current models used by climate scientists probably underestimate “the impacts of climate change. Even if the world’s population were to remain stable, climate change would put significant pressure on agricultural production. The combination of population increase and a growing middle class in the developing world makes the challenges agriculture faces even greater.

It is estimated that wheat yields in South Asia will decline by 12 percent over the first half of the 20th century. Thirty years later, the yield loss will have increased to 29 percent.

As a result, Nelson writes, “given the long lead times needed to advance scientific research and transfer new technologies and farming practices to the field, action must be taken now to meet the increasingly difficult challenges of climate change.” Waiting until the last minute to invest in the needed agricultural research is not a reasonable option.

To manage the challenges brought about by climate change, farmers will have to adapt by growing new crops, changing agricultural practices, and purchasing different inputs. The cost of making these changes will divert resources that otherwise would be used “for other farming upgrades.” Some areas will no longer suitable for agricultural production, forcing farmers off the land.

Nelson argues that not only will consumers face higher prices generally they will also see more price spikes like the one that occurred in 2008. Those most affected by higher prices, punctuated by price spikes, will be the poor. Nearly half of those facing chronic hunger “are smallholder farmers living in rural parts of Sub-Saharan Africa and South Asia.”

He continues writing, “if the international community wants a world without hunger, it must equip the world’s food producers to grow more food using fewer resources in the face of climate change.”

One of the results of food shortages and higher food prices is civil unrest. During the 2008 food price spike, over 30 countries experienced increased social tension. Quoting from the 2014 Quadrennial Defense Review by the US Department of Defense, Nelson makes the case that food is a security issue, at both the national and global levels.

He concludes the second section saying, “Our nation [the US] has a strong interest in preventing the sorts of conflicts that open the way for civil wars or turn weakened states into sanctuaries for terror groups that pledge harm to the United States and its allies. When events spiral out of control, US intervention in the form of emergency food assistance—or even more costly military engagement—becomes more likely.”

Daryll E. Ray holds the Blasingame Chair of Excellence in Agricultural Policy, Institute of Agriculture, University of Tennessee, and is the Director of UT’s Agricultural Policy Analysis Center (APAC). Harwood D. Schaffer is a Research Assistant Professor at APAC. (865) 974-7407; Fax: (865) 974-7298; dray@utk.edu and hdschaffer@utk.edu; http://www.agpolicy.org.

Chicago Council lists three-decade changes in greenhouse gases and average temperature

Posted on | June 11, 2014 | No Comments

by Daryll E. Ray and Harwood D. Schaffer, Agricultural Policy Analysis Center, University of Tennessee, Knoxville, Tenn.

Read the original post at agpolicy.org.

In 2011, we wrote a column, “Global warming is happening: How should farmers respond?” (http://agpolicy.org/weekcol/549.html). In that column we began by saying, “There was a time when one could legitimately argue that there was a lack of scientific agreement over the issue of the role of humans in global warming and even whether we were in a cooling or warming period. It is becoming increasingly difficult to ignore the scientific evidence.”

Well, we were wrong, not about the global warming part, but rather the “increasingly difficult to ignore the scientific evidence” part. Shortly after that column appeared in print, we were contacted by an attorney for a state’s department of agriculture who demanded to know what evidence we used to support our contention that the climate change that is occurring is human induced. He had been contacted by farmers in his state who were troubled by our column.

We also received emails from several readers. One wrote, “It was with some degree of astonishment that I read, and have heard discussed, this latest piece about human-caused global warming. I was under the impression that the theories about mankind’s addition to the global warming trend had been thoroughly debunked.”

Well the issue of the role of humans in climate change has not gone away. In fact, with the release of the most recent report from the Intergovernmental Panel on Climate Change, the urgency of addressing the issue has become greater than ever.

Both the National Geographic’s article, “A Five Step Plan to Feed the World,” which we examined in our previous column, and the Chicago Council on Global Affairs’ publication, “Advancing Global Food Security in the Face of a Changing Climate” (www.tinyurl.com/mb4pj5s)—the focus of this week’ column, takes the impact of agriculture on climate change and the impact of climate change on agriculture seriously.

While the National Geographic article acknowledges both impacts, it focuses its comments on feeding a larger population in 2050 and an increasing middle class in developing countries, the publication by the Chicago Council gives more background on the issue of climate change.

The Chicago Council report, with Gerald C Nelson serving as the principal author of the report and Douglas Bereuter and Dan Glickman serving as Cochairs of the advisory group responsible for the publication, provides a definition for “weather and climate.”

In defining “weather and climate,” Nelson writes “‘Climate’ is usually defined as average weather. The United Nations Framework Convention on Climate Change (UNFCCC) defines ‘climate change’ as changes in climate caused directly or indirectly by human activity.* People do many things to cause local changes in climate. For example, ‘heat islands’ are caused by higher temperatures in cities compared to the surrounding countryside. Deforestation can cause local increases in temperature and changes in rainfall patterns. This report, however, focuses on global changes in climate.”

The asterisked footnote says, “Article 1 of the UNFCCC defines climate change as ‘a change of climate which is attributed directly or indirectly to human activity that alters the composition of the global atmosphere and which is in addition to natural climate variability observed over comparable time periods.’”

The first section of the first part of the report is titled “A Changing Climate Will Alter the Global Food System,” and is the section that reviews the key points on climate change. They start with an idea that every farmer understands better than almost anyone else: “food production and food prices are inextricably linked to weather.”

With climate change, the likelihood of extreme weather events increases, triggering more frequent fluctuations in production and thus prices. While farmers in the US and around the world have normal variations in weather and production factored into their farming activities, an increase in extreme weather events can put their livelihood at risk.

The report provides graphs that show the increase in the atmospheric concentrations of major greenhouse gases between 1978 and 2013—carbon dioxide, 335 parts per million to 390 ppm; nitrous oxide, 340 parts per billion to over 390 ppb; methane, over 1550 ppb to over 1800 ppb. Over that same period, the average global temperature has increased by 1 degree. They also point out that “unlike other major greenhouse gases that disappear from the atmosphere relatively quickly, carbon dioxide stays put for hundreds to thousands of years, making increased concentrations in the atmosphere difficult to reverse.”

Agricultural activity is responsible for 24 percent of greenhouse gasses that contribute to global warming. The biggest contributor is the conversion of grasslands and forests to agricultural production. “Without careful management practices, soils in the newly converted lands lose about 50 percent of the initial soil organic carbon in the top surface layer in 25 to 50 years in temperate climates and in five to 10 years in the tropics, making land less productive.” Other contributors include digestion and decomposition of manure from ruminants, rice production, improper use of fertilizers, and farm machinery that burns fossil-based fuels.

As average global temperatures increase, the zones in which crops are grown will for the most part move toward the poles or to higher elevations—there is a limit to both moves. One only has to look at the northward march in US corn production to understand this. In addition, the areas with comparative advantage in crop production will be partly determined by changes in rainfall and rainfall patterns. Too much rain at the wrong time can be devastating while drier weather at harvest can be beneficial.

They point out that for most countries, between 1980 and 2008 climate change has had a negative impact on crop yields. In addition to yield drag, farmers will face increased problems from plant diseases and pests, both domestic and invasive. As any temperate farmer can attest, cold winters reduce pest pressure while warmer winters allow them to survive in greater numbers. With climate change, the winters will generally be warmer.

Although it has been less studied than yield and production, climate change also has a negative impact on the quality of the food that is produced. Wheat protein levels fall at high carbon dioxide levels. In addition, “experiments in the United States and China have shown that in nonleguminous grain crops, protein and mineral content such as iron and zinc are substantially reduced when carbon dioxide concentrations reach levels likely to occur by midcentury.”

Livestock production will be negatively impacted as animals face increased heat stress. Higher temperatures also affect fertility. Higher temperatures will negatively affect the nutritional content of forages, they argue.

For farmers whose fields are only slightly above the average sea level, any increase in that level can be devastating, either by flooding or salt-water intrusion into fresh water aquifer. Some island states will be submerged by a rise in the sea level.

And if this is not challenging enough for farmers, the report says that transportation costs will increase because “higher temperatures reduce the efficiency of human and animal transport, require roads to be built to higher standards, and increase the costs of cooling for sensitive produce.”

Next week we will look at their argument that “Adapting the global food system to climate change should be a priority.”

Daryll E. Ray holds the Blasingame Chair of Excellence in Agricultural Policy, Institute of Agriculture, University of Tennessee, and is the Director of UT’s Agricultural Policy Analysis Center (APAC). Harwood D. Schaffer is a Research Assistant Professor at APAC. (865) 974-7407; Fax: (865) 974-7298; dray@utk.edu and hdschaffer@utk.edu; http://www.agpolicy.org.

Water categories included in EPA’s “Waters of the U.S.”

Posted on | May 23, 2014 | No Comments

by Daryll E. Ray and Harwood D. Schaffer, Agricultural Policy Analysis Center, University of Tennessee, Knoxville, Tenn.

Read the original post at agpolicy.org.

In the three previous articles that have dealt with the proposed rule issued by the Environmental Protection Agency and the US Army Corps of Engineers to provide a “Definition of ‘Waters of the United States’ Under the Clean Water Act [CWA],” we have provided: 1) an overview of the proposed rule, how to submit comments on the rule, and reactions by general farm organizations to the proposed rule; 2) US Supreme Court rulings on waters covered by the CWA and the need to identify a significant nexus between clearly covered waters and other waters that drain into those the regulation of which is unquestioned along with a list of waters that are excluded from existing regulations and the proposed rule; and 3) the ways in which the scientific literature clarifies the issues of “connectivity of waters” and “significance” providing the agencies a defensible way of identifying the significant nexus the Supreme Court said was needed for the agencies to have regulatory authority over a water feature or class of water features like wetlands in various locations.

In this article, we look at the definition of “waters of the United States” in the proposed rule. Existing regulations include traditional navigable waters in the definition and the agencies propose no changes to those regulations. The term “traditional navigable waters” includes “all waters that are currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide.” In addition, traditional navigable waters include all waters that have been, currently are, or are susceptible to “being used for commercial navigation, including commercial waterborne recreation (for example, boat rentals, guided fishing trips, or water ski tournaments).”

The second broad category of covered waters is interstate waters “including interstate wetlands and the agencies’ proposal today does not change that provision of the regulations. Interstate waters would continue to be ‘waters of the United States’ even if they are not navigable for purposes of Federal regulation…and do not connect to such waters.”

In the next section, the agencies write, “the CWA and its existing regulations include ‘the territorial seas’ as a ‘water of the United States.’ The agencies propose to make no changes to that provision of the regulation other than to move the provision to earlier in the regulation…. The CWA goes on to define the ‘territorial seas’ as ‘the belt of the seas measured from the line of ordinary low water along that portion of the coast which is in direct contact with the open sea and the line marking the seaward limit of inland waters, and extending seaward a distance of three miles.’ The territorial seas establish the seaward limit of ‘waters of the United States.’”

As to the fourth category, “The agencies do not propose to make any substantive changes to the existing regulatory language with respect to impoundments of waters otherwise defined as ‘waters of the United States’ under this definition. The changes proposed are clarifying. Impoundments are jurisdictional because as a legal matter an impoundment of a ‘water of the United States’’ remains a ‘‘water of the United States’ and because scientific literature demonstrates that impoundments continue to significantly affect the chemical, physical, or biological integrity of downstream waters traditional navigable waters, interstate waters, or the territorial seas. The Supreme Court has confirmed that damming or impounding a ‘water of the
United States’ does not make the water non-jurisdictional.”

It is with the next category, tributaries, that the agencies begin to use the significant nexus requirement to provide a new definition. “Under this proposal, the agencies provide a definition of ‘tributary’ supported by the scientific literature. The agencies also propose that all waters that meet the proposed definition of tributary are ‘waters of the United States’ by rule, unless excluded,…because tributaries and the ecological functions they provide, alone or in combination with other tributaries in the watershed, significantly affect the chemical, physical, and biological integrity of traditional navigable waters, interstate waters, and the territorial seas.”

A tributary is defined “as a water physically characterized by the presence of a bed and banks and ordinary high water mark, as defined…, which contributes flow, either directly or through another water, to a water [previously] identified…. In addition, wetlands, lakes, and ponds are tributaries (even if they lack a bed and banks or ordinary high water mark) if they contribute flow, either directly or through another water to a water [previously] identified….

“A water that otherwise qualifies as a tributary under this definition does not lose its status as a tributary if, for any length, there are one or more manmade breaks (such as bridges, culverts, pipes, or dams), or one or more natural breaks (such as wetlands at the head of or along the run of a stream, debris piles, boulder fields, or a stream that flows underground) so long as a bed and banks and an ordinary high water mark can be identified upstream of the break. A tributary, including wetlands, can be a natural, man-altered, or man-made water and includes waters such as rivers, streams, lakes, ponds, impoundments, canals, and ditches [that are] not excluded.” The following ditches are excluded: “ditches that are excavated wholly in uplands, drain only uplands, and have less than perennial flow, ditches that do not contribute flow either directly or through another water, to a traditional navigable water, interstate water, the territorial seas or an impoundment of jurisdictional water….[or] artificial lakes or ponds created by excavating and/or diking dry land and used exclusively for such purposes as stock watering, irrigation, settling basins, or rive growing,”

The rationale of the agencies for including tributaries is that they “have a significant impact on the chemical, physical, and biological integrity of waters into which they eventually flow—including traditional navigable waters, interstate waters, and the territorial seas—and they have a significant nexus and thus are jurisdictional as a category. The great majority of tributaries are headwater streams, and whether they are perennial, intermittent, or ephemeral, they play an important role in the transport of water, sediments, organic matter, nutrients, and organisms to downstream environments. Tributaries serve to store water, thereby reducing flooding, provide biogeochemical functions that help maintain water quality, trap and transport sediments, transport, store and modify pollutants, provide habitat for plants and animals, and sustain the biological productivity of downstream rivers, lakes and estuaries.”

The rule also discusses waters that are not a tributary under the proposed rule, including “ephemeral features located on agricultural lands that do not possess a bed and bank are not tributaries. The defined bed and bank no longer exists due to past normal farming practices such as plowing or discing…and these farming practices often pre-date the CWA. Such farm field features are not tributaries even though they may contribute flow during some rain events or snowmelt.”

Adjacent waters are waters that are “integrally linked to the chemical, physical, or biological functions of the…[previously listed] waterbodies to which they are adjacent…. The term adjacent means bordering, contiguous or neighboring. Waters, including wetlands, separated from other waters of the United States by man-made dikes or barriers, natural river berms, beach dunes and the like are ‘adjacent waters.’”

In the proposed rule, “‘other waters’ are not jurisdictional as a single category; rather, as the proposed rule language states, ‘other waters’ are jurisdictional provided that they are found, on a case-specific basis, to have a significant nexus to” traditional navigable waters, interstate waters, or territorial seas.

According to the agencies “one of the primary purposes and functions of the CWA is to prevent the discharge of petroleum wastes and other chemical wastes, biological and medical wastes, sediments, nutrients and all other forms of pollutants into the ‘waters of the United States,’ because such pollutants endanger the nation’s public health, drinking water supplies, shellfish, fin fish, recreation areas, etc. Because the entire tributary system of the traditional navigable, interstate waters or the territorial seas is interconnected, pollutants that are dumped into any part of the tributary system eventually are washed downstream to traditional navigable waters, interstate waters, or the territorial seas where those pollutants endanger public health and the environment.”

Daryll E. Ray holds the Blasingame Chair of Excellence in Agricultural Policy, Institute of Agriculture, University of Tennessee, and is the Director of UT’s Agricultural Policy Analysis Center (APAC). Harwood D. Schaffer is a Research Assistant Professor at APAC. (865) 974-7407; Fax: (865) 974-7298; dray@utk.edu and hdschaffer@utk.edu; http://www.agpolicy.org.

Scientific literature used to clarify which U.S. waters are within EPA’s jurisdiction

Posted on | May 16, 2014 | No Comments

by Daryll E. Ray and Harwood D. Schaffer, Agricultural Policy Analysis Center, University of Tennessee, Knoxville, Tenn.

Read the original post at agpolicy.org.

In enforcing the Clean Water Act (CWA), the US Environmental Protection Agency (EPA) and the US Army Corps of Engineers (COE) have clear jurisdiction over “[1] traditional navigable waters; [2] interstate waters, including interstate wetlands; [3] the territorial seas; [and 4] impoundments of traditional navigable waters, [and] interstate waters, including interstate wetlands, [and] the territorial seas.” The further upstream a water body, intermittent stream, or wetland is from one of these, the less clear it becomes that the EPA and the COE have jurisdiction.

This lack of clarity has resulted in lawsuits on behalf of landowners, several of which have ended up before the US Supreme Court. In the 2001 and 2006 cases, justices argued that there must a “significant nexus” between other waters and those over which the agencies have clear jurisdiction for the agencies to exercise regulatory control. The purpose of the April 21, 2014 proposed rule, “Definition of ‘Waters of the United States’ Under the Clean Water Act,” is in part to clarify what that “significant nexus” is and what waters would fall under the jurisdiction of the EPA and/or the COE. All quoted material in this article comes from the Proposed Rule.

To accomplish this goal, the “EPA’s Office of Research and Development prepared a draft peer-reviewed synthesis of published peer-reviewed scientific literature discussing the nature of connectivity and effects of streams and wetlands on downstream waters…. The draft Report provides a review and synthesis of the scientific information pertaining to chemical, physical, and biological connections from streams, wetlands, and open waters such as oxbow lakes, to downstream larger water bodies such as rivers, lakes, and estuaries in watersheds across the United States and the strength of those connections.” For the EPA, the first step is to identify the ways in which the scientific literature makes the connection between upstream tributaries and adjacent wetlands and downstream larger waters.

Connectivity (emphasis added) is the degree to which components of a system are joined, or connected, by various transport mechanisms and is determined by the characteristics of both the physical landscape and the biota of the specific system. The structure and function of downstream waters are highly dependent on the constituent materials contributed by and transported through waters located elsewhere in the watershed. Connectivity for purposes of interpreting the scope of ‘waters of the United States’ under the CWA serves to demonstrate the ‘nexus’ between upstream water bodies and the downstream traditional navigable water, interstate water, or the territorial sea.

“Based on the literature, the Office of Research and Development was able to assess the types of connections between the tributaries and adjacent waters and the chemical, physical, and biological integrity of downstream traditional navigable waters, interstate waters, and the territorial seas.”

But identifying the nexus alone is not enough to satisfy the court’s concern. “as Justice Kennedy found…a mere hydrologic connection may not suffice in all cases to establish CWA jurisdiction and there needs to be ‘some measure of the significance (emphasis added) of the connection for downstream water quality.’”

In the proposed rule the agencies write, “The data and conclusions in the Report concerning the strength of the relevant connections (emphasis added) and effects of certain types of waters on downstream waters provide a foundation for the agencies’ determinations that certain waters have effects on the chemical, physical, and biological integrity of traditional navigable waters, interstate waters, or the territorial seas that are ‘significant’ (emphasis added) and thus constitute a significant nexus(emphasis added).”

The proposed rule says, “the Report concludes that the scientific literature clearly demonstrates that streams, regardless of their size or how frequently they flow, strongly influence how downstream waters function. Streams supply most of the water in rivers, transport sediment and organic matter, provide habitat for many species, and take up or change nutrients that could otherwise impair downstream waters.

“The Report also concludes that wetlands and open waters in floodplains of streams and rivers and in riparian areas (transition areas between terrestrial and aquatic ecosystems) have a strong influence on downstream waters. Such waters act as the most effective buffer to protect downstream waters from nonpoint source pollution (such as nitrogen and phosphorus) [it should be noted that much of the potential pollution caused by farming is nonpoint source pollution], provide habitat for breeding fish and aquatic insects that also live in streams, and retain floodwaters, sediment, nutrients, and contaminants that could otherwise negatively impact the condition or function of downstream waters.

“Regarding wetlands and open waters located outside of floodplains and riparian areas, the Report finds that they provide many benefits to rivers, lakes, and other downstream waters. If the wetland or open water has a surface or shallow subsurface water connection to the river network, it affects the condition of downstream waters.

“Where the wetland or open water is not connected to the river network through surface or shallow subsurface water, the type and degree of connectivity varies geographically, topographically, and ecologically, such that the significance of the connection is difficult to generalize across the entire group of waters.

“Lastly, the Report concludes that to understand the health, behavior, and sustainability of downstream waters, the effects of small water bodies in a watershed need to be considered in aggregate. The contribution of material by, or an important water-retention function of, a particular stream, other open water, or wetland might be small, but the aggregate contribution by an entire class of streams, other open waters, and wetlands (e.g., all ephemeral streams in the river network) can be substantial.”

Based on the draft report, the agencies conclude that both “tributary streams” and “adjacent waters,” as defined in the proposed rule, “perform the requisite functions for them to be considered ‘waters of the United States’ by rule.” In addition, “other waters” may, in some cases, perform these requisite functions.” But the agencies are proposing that these would be evaluated on a case-specific basis.

The agencies assert that the scientific literature shows that the included waters “supply sediment, wood, organic matter, nutrients, chemical contaminants, and many of the organisms found in downstream traditional navigable waters, interstate waters, and the territorial seas.”

Furthermore, “These chemical, physical, and biological connections affect the integrity of downstream traditional navigable waters, interstate waters, and the territorial seas through the export of channel-forming sediment and woody debris, storage of local groundwater sources of baseflow for downstream waters and their tributaries, and transport of organic matter. Wetlands and open waters located in riparian and floodplain areas remove and transform nutrients such as nitrogen and phosphorus. They provide nursery habitat for fish, and colonization opportunities for stream invertebrates.

“Adjacent waters, including those located in riparian and floodplain areas, serve an important role in the integrity of traditional navigable waters, interstate waters, and the territorial seas because they also act as sinks for water, sediment, nutrients, and contaminants that could otherwise negatively impact traditional navigable waters, interstate waters, and the territorial seas.”

In the next column, we will examine the definition that the agencies have developed for the term “waters of the United States.”

Daryll E. Ray holds the Blasingame Chair of Excellence in Agricultural Policy, Institute of Agriculture, University of Tennessee, and is the Director of UT’s Agricultural Policy Analysis Center (APAC). Harwood D. Schaffer is a Research Assistant Professor at APAC. (865) 974-7407; Fax: (865) 974-7298; dray@utk.edu and hdschaffer@utk.edu; http://www.agpolicy.org.

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National Farmers Union was founded in 1902 in Point, Texas, to help the family farmer address profitability issues and monopolistic practices. NFU works to protect and enhance the economic well-being and quality of life for family farmers, ranchers and rural communities through advocating grassroots-driven policy positions adopted by its membership.
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