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EPA Threatens Locally Produced Beef

In Another Blow to Decentralized Natural Meat Production, EPA Rule Indirectly Shuts Down Small Meat Producers via Clean Water Act Overreach

by Dr. Robert Malone
April 14, 2024

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American’s Will Lose the Choice to Buy Local Meats

(Dr. Malone’s Substack)—On January 23, 2024, under Biden Administration guidance, the Environmental Protection Agency (EPA) proposed a new rule that will bring 3,879 meat and poultry products (MPP) processing facilities under their jurisdiction. This was swiftly followed by an abbreviated comment period which closed on March 25, 2024, and then immediate implementation of the rule change. All justified by wastewater levels of Nitrogen and Phosphorus coming from animal meat processing, mirroring the WEF agenda to minimize Nitrogen runoff from European farms which has sparked the widespread farmer protests throughout the European Union.

The new rule involves a major shift in the technology-based effluent limitations guidelines and standards (ELGs) for the meat and poultry industry, threatening their livelihoods by forcing them to add water filtration systems to their facilities.

What does this mean to small meat processing facilities?  It’s been reported that the initial cost to install a water filtration system bringing them into compliance be $300,000-400,000 with a minimum of $100,000 annual maintenance.  This would force many small meat processing facilities to shutter their doors.

It is also a direct attack on the buy local foods movement.  If local meat producers no longer have a nearby facility to process the meat, they will no longer be able to provide their product direct to the customer at food markets or online.

The EPA initially promulgated the MPP ELGs in 1974 and amended them in 2004.  Currently, they only apply to approximately 150 of the 5,055 MPP facilities in the industry.  But, in the EPA’s Benefit Cost Analysis, they state that “EPA estimates the regulatory options potentially affect 3,879 MPP facilities.”

Accordingly, the history of EPA’s regulation of MPP effluent guidelines and standards has never extended beyond direct discharge facilities and this rule significantly expands their regulatory overreach.

The Kansas Natural Resource Coalition (KNRC) filed comments opposing the proposed rule and was joined by other county coalitions and American Stewards of Liberty.  KNRC, an organization of 30 Kansas counties, states these proposed rules will “regulate indirect discharge facilities” that “departs from constitutional and statutory authority” significantly altering the balance between state and federal powers.

They also state that the proposal “gives priority to environmental justice goals and emphasizes ecological benefits, but the EPA jurisdiction under the Clean Water Act is not based on ecological importance or environmental justice.”

JD's Links
  • EPA Federal Register Notice of Proposed Rule
  • KNRC Filed Comments

Demonstrating that the “comment period” was mere window dressing to meet formal federal comment requirements, immediately on March 25, 2024 the EPA jammed through a finalized version of its devastating new interpretation of the Clean Water Act, which it has titled “Effluent Limitations Guidelines and Standards for the Meat and Poultry Products Point Source Category.” Clearly this is another case of aggressive, arbitrary and capricious EPA regulatory overreach, directly analogous to the recent Supreme Court case West Virginia v. Environmental Protection Agency, 597 U.S. 697 (2022), a landmark decision of the U.S. Supreme Court relating to the Clean Air Act, and the extent to which the Environmental Protection Agency (EPA) can regulate carbon dioxide emissions related to climate change.

According to the EPA, after months of study and testing to look for bacteria, viruses etc, what they actually found in the wastewater of processing facilities was Nitrogen and Phosphorus. Two of the fundamental elements which all living things are composed of (Carbon, Hydrogen, Nitrogen, Oxygen, Phosphorus).

As a result, The EPA has decided that the entire meat industry – from slaughtering beef to poultry, marinas to packaging – must now retrofit current facilities with lagoons and biomass dissipates to turn “nutrients” into C02 and methane in order to prevent these “pollutants” from entering local water supplies.

The EPA anticipates these new rules will, at least, result in the closure of 16 processing facilities across the country at a time when our country’s meat producers are already struggling to survive due to bottlenecks in USDA certified facilities. However, on the high side EPA estimates include an impact range of up to 845 processing facilities.

The EPA acknowledges (via the Federal Register) that this rule change will have far-reaching impacts up and down the supply chain from consumer prices to producer losses.

A press release was just put out by a consortium of protein producers who have said this will cost “millions more than the EPA’s highest estimates and result in the loss of tens of thousands of jobs.”

It gets worse;

Facilities can bypass these new regulations by drastically reducing their weekly/annual pounds processed. However, the US population continues to grow (largely due to immigration) at a rate that we’re currently incapable of feeding with record low volumes of meet production. Reducing pounds processed will have sizable impacts upon food security, as will further closures, and supply chain disruptions. These issues have now risen to the point of being a national security threat.

Problems in the rule change;

– The rule change fails to provide clarity or funding to local water treatment facilities for testing or range of acceptable levels of runoff, and in my opinion over-steps federal authority (WOTUS jurisdiction) by dictating local water rights. Especially as the EPA acknowledges most water used in processing is from a well source, or privately owned water source.

– The rules fail to account for foreign inputs, and actually incentivize domestic closures, prioritizing imported meat products in a manner conducive to the monopolistic multinational conglomerate beef producers who are not US based. This, at a time when the US has gradually become a net importer yet facing critical infrastructure collapses, such as Key Bridge.

– The rules specify 17 species of endangered animals that may become affected by the salt residues (a byproduct of the process they want used to turn biomass into gas), as these salts flow “downstream” from processing facilities. This is bogus language to attempt to establish jurisdictional standing, as the rules do not differentiate between facilities that are near navigable waters vs facilities that have private water rights.



However, for those who do comply, as opposed to reducing production, they’ll be left open and vulnerable to future lawsuits from environmental activists over endangered species. These lawsuits have historically become costly, with states eventually caving to the demands made, as evidenced by the Oregon Dept of Forestry v Cascadia in filing after filing – Spotted Owl to CoHo Salmon – resulting in the drastic reduction of privately owned timber lands and logging contracts.

– The rules currently allow for the off-gassing of the biomass as it becomes C02 and methane, but say nothing about future carbon taxes, or financial burdens that may be incurred due to the additional carbon outputs via the new carbon credit/taxes the Biden Administration created via the Commodities Credit Corporation. Oregon, California and Washington have already instituted state versions of Cap and Trade legislation e.g. requiring companies to purchase these carbon credits in order to remain in business.

Aside from the massive overreach in relation to non-navigable waters of the US, typically locally regulated, or an authority reserved to the states to regulate, these new rule changes have the potential to negatively impact our food supply for years to come.

Congressmen Estes and Burlison have proposed H.R 7079, the “BEEF ACT” (formally known as H.R.7079 – Banning EPA’s Encroachment on Facilities Act), as a means of prohibiting the EPA from using its deferential authority (Chevron doctrine) to interpret the Clean Water Act. However, this legislation currently has a 1% chance of being enacted, and only a 4% chance of passing out of the House Committee on Transportation.

In parallel to direct legislative action, there is clearly a need to mount a legal challenge to this action, one which can build upon the precedent established by West Virginia v. Environmental Protection Agency, which should benefit from the anticipated Supreme Court action to overturn the Chevron Deference legal precedent which currently enables this type of regulatory overreach. Further information concerning the Chevron Deference can be found in this substack essay, and SCOTUS Blog has covered the current status of the Supreme Court case in an article titled “Supreme Court likely to discard Chevron”.

This substack essay includes analysis and text from both Breeauna Sagdal, Senior Writer and Research Fellow at The Beef Initiative Foundation as well as from American Stewards of Liberty.

Advisor Bullion Numismatics

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Why Bullion Beats Numismatics and Collectible for Your Safe or IRA

Precious metals continue to attract Americans seeking reliable ways to protect their wealth amid inflation, geopolitical risks, and stock market swings. Whether stored in a home safe or held inside a self-directed IRA, physical gold and silver deliver tangible value that paper or digital assets often lack. Yet investors must choose carefully between bullion—pure bars and coins valued mainly for their metal content—and numismatics or collectibles, where rarity, history, and collector demand heavily influence pricing.

Advisor Bullion serves as a dependable source for straightforward, high-quality bullion. The company specializes in physical gold, silver, platinum, and palladium, emphasizing transparent pricing and products that deliver maximum metal content for every dollar spent. This approach makes it ideal for both personal holdings and retirement accounts.

Bullion consists of refined precious metals in standard forms like one-ounce coins (American Gold Eagles, Silver Eagles, Canadian Maple Leafs) or bars. Their value tracks closely to the current spot price of the metal. A typical gold bullion coin trades near the live gold spot price plus a small premium. This structure keeps costs clear and predictable.

Numismatic coins and collectibles add substantial value from factors such as age, rarity, minting errors, or historical significance. A pre-1933 U.S. gold coin or graded proof piece can carry premiums of 30%, 50%, or even 200% above melt value. While this appeals to hobbyists, it creates complexity. Pricing depends on subjective grading, collector trends, and auction results instead of daily spot prices.

For investors focused on wealth preservation and retirement security rather than building a collection, bullion often delivers better results.

Lower Costs and Better Liquidity for Home Storage

When keeping metals in a home safe or private vault, liquidity and efficiency count. Bullion offers clear benefits:

  • You acquire more actual gold or silver per dollar invested. Numismatics divert a large share of your money into rarity premiums and massive sales commission, reducing your metal exposure.
  • Selling bullion involves tight bid-ask spreads, so you recover nearly full spot value with minimal fees. Collectibles require finding the right buyer and may sell at a discount if demand for that specific item weakens.
  • Bullion prices remain transparent and update with global spot markets. You can track gold near current levels or silver accordingly and know exactly where your holdings stand. Numismatic values are priced by the Gold IRA companies with hefty margins applied.
  • Standardized coins and bars store efficiently and divide easily for partial sales. Rare coins often need protective slabs and controlled conditions, adding hassle and expense.
  • Bullion enjoys worldwide acceptance. A 1-oz Gold Maple Leaf or Silver Eagle sells quickly to dealers anywhere. Niche numismatic pieces may appeal only to limited buyers, slowing liquidation when speed matters.

In times when quick access to value becomes important, bullion’s simplicity stands out.

Stronger Fit for Precious Metals IRAs

Precious metals IRAs continue gaining traction as investors diversify retirement portfolios beyond stocks and bonds. IRS rules permit certain bullion products in self-directed IRAs if they meet purity standards (.995 fine for gold, .999 for silver) and are held by an approved custodian. Eligible items include American Gold and Silver Eagles plus many generic bars and rounds from recognized mints.

Numismatic and most collectible coins generally face heavy scrutiny from custodians due to valuation disputes and elevated markups. These higher premiums mean less actual metal ends up working inside the account.

Bullion avoids these issues. Its value links directly to verifiable spot prices, which simplifies reporting and lowers the risk of regulatory challenges. More of your IRA contribution purchases real metal instead of dealer profits or speculative upside. Over time, owning additional ounces that appreciate with the metal itself can create meaningful outperformance compared with high-premium alternatives that deliver fewer ounces.

Regulatory guidance from the CFTC and state securities offices repeatedly cautions against aggressive sales of expensive numismatics or “semi-numismatic” coins for IRAs. For retirement planning, transparent bullion from established providers reduces risk and aligns better with long-term goals.

How to Get Started with Bullion

Begin by clarifying your goals. Are you protecting savings in a safe, or moving part of a retirement account into a precious metals IRA? Focus on the number of ounces you can acquire at current prices rather than chasing marked-up collectibles.

Diversify sensibly: use gold for core preservation and silver for its blend of industrial and monetary qualities. Mix coins for easier divisibility with bars for lower per-ounce costs on larger buys. Arrange secure storage—whether at home with proper insurance or through professional facilities.

As economic uncertainties linger and faith in conventional assets erodes, bullion continues proving its worth as a dependable store of value. Its direct approach avoids the hype that sometimes surrounds collectible markets and keeps the focus on the metal itself.

For investors prepared to strengthen their portfolios, Advisor Bullion supplies the expertise and selection needed to acquire high-quality bullion efficiently. Whether building personal holdings or integrating metals into an IRA, their emphasis on transparent, investment-grade products helps secure more ounces today that support greater financial security tomorrow. In a complicated financial landscape, bullion’s clarity and reliability make it the smarter foundation for protecting what matters most.

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