It shows more than that, imo. Nearly all seed corn and seed sorghum producers (really big ag) were all too happy to send excess product to a rural ethanol plant with a history of financial difficult for "recycling". /1 https://twitter.com/AlanGuebert/status/1357848845456084992
And they did this even thought the labels on at least some of the product prohibited what they were doing at the plant. /2
And they did this even though the product they were delivering was likely a waste for RCRA purposes, though this is debatable. It was clearly waste by the time the by-products were all that was left. In the hands of the plant. /3
The plant had CAA permits and CWA permits and RCRA problems as well. And there is plenty of state regulation to be found in the Nebraska Environmental Protection Act, as well as the Groundwater Management and Protection Act. /4
Early on the question was whether this thing was falling through some cracks. The more I think about it, it seems like it violated so many laws that no one really knew where to start. /5
The more difficult questions for our policy response relate to the willingness of enforcers to answer the calls of university researchers and concerned (and sometimes sick) rural residents. /6
All the laws in the world don't amount to a hill of beans if no one will enforce and dig in. That takes political will and institutional capacity. I worry that both are in short supply after years of tax cuts and hatred for government. As always, we reap what we sow. /fin
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