CNMP’s and Animal Feeding Operations, Ronald Harris, AFOD

CNMP’s and Animal Feeding Operations, Ronald Harris, AFOD

Livestock manure has emerged over the past several years as a major environmental issue, with significant social and political considerations. As a result, national policy attention has also become focused on animal feeding operations over the last few years, as symbolized by the issuance of the “United States Department of Agriculture’s (USDA)/Environmental Protection Agency’s (EPA) Unified National Strategy for Animal Feeding Operations” in March 1999.

The Unified Strategy presents USDA and EPA’s plan for addressing the water quality and public health impacts associated with Animal Feeding Operations (AFOs).

The USDA’s Natural Resources Conservation Service (NRCS) released for public comment the draft “Technical Guidance for Developing CNMPs” in December of 1999. The final Technical Guidance is scheduled for release in August of 2000. The Technical Guidance defines what a CNMP is, and addresses the key elements to consider in the development of a CNMP. The Technical Guidance is a document intended for use by those who will be developing or assisting in the development of comprehensive nutrient management plans.

The purpose of this document is to provide technical guidance for the development of CNMPs, whether they are developed for USDA voluntary incentive programs or as a means to comply with United States Environmental Protection Agency’s (EPA) National Pollutant Discharge Elimination System (NPDES) permit requirements. The Technical Guidance is intended to be used in conjunction with NRCS’ existing planning procedures and other technical references to effectively address both management activities and natural resource concerns associated with minimizing the potential adverse impacts of animal feeding operations on water quality.
What is a CNMP?

A CNMP is a conservation system for animal feeding operations that addresses Field Office Technical Guide quality criteria to the resource management system (RMS) level for water and soil resources. The development of a CNMP needs to address the following six elements:

1. 
   Manure and Wastewater Handling and Storage - This element addresses the components and activities associated with the production facility, feedlot, manure and wastewater storage and treatment structures and areas, and any areas or mechanisms used to facilitate transfer of manure and wastewater.
   

3. Nutrient Management - This element addresses the requirements for land application of all nutrients and organic by-products (e.g., animal manure, wastewater, commercial fertilizers, crop residues, legume credits, irrigation water, etc.) that must be evaluated and documented for each Conservation Management Unit (CMU).

4. Record Keeping - It is imperative that records are kept to effectively document and demonstrate implementation activities associated with CNMPs. This element lists documentation requirements associated with developing and implementing a CNMP.

5. Feed Management - Feed management activities may be used to reduce the nutrient content of manure, resulting in less land being required to utilize the nutrient contents of the manure. This element addresses feed management acitivites as a possible opportunity in the CNMP planning process.

6. Other Utilization Options – This element addresses other utilization options associated with animal manure and wastewater as alternatives to traditional operational methods.
Public Comments

NRCS posted the draft Technical Guidance in the Federal Register for a 120 day public comment period. A total of 62 separate letters were received, representing comments from the following general groups: Federal, State, and Local Units of Government (19 letters); Agribusiness/Commodity Groups (20 letters); Environmental Groups (12 letters); University/Professional Society (6 letters); Individuals (5 letters).

• 
  The draft Technical Guidance does not address all of the environmental and public health concerns associated with animal feeding operations. (i.e., air quality, odors, pathogens, heavy metals, etc.)
  
• 
  Lack of coordination between the NRCS CNMP process and the NPDES CAFO permit process will result in regulatory confusion and uncertainty for AFO/CAFOs.
  
• 
  The draft Technical Guidance does not contain specific enough procedures or criteria to allow someone other than an NRCS employee to develop a CNMP.
  
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  CNMP Process – Include a description of how USDA envisions that public and private professionals will be trained and certified in accordance with NRCS’ National CNMP Certification Policy. Clarification of whom can develop and/or certify a CNMP – many groups would like clarification regarding the credentials of entities involved in developing and certifying a CNMP.
  
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  The CNMP should be the tool used to achieve the requirements of a CAFO-NPDES permit, and therefore, should be subject to public review as other industry NPDES permits.
  

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  Confidentiality of records is of utmost importance. It is not clear from the proposed draft Technical Guidance who will have control, and access to, the records that are proposed to be a part of a CNMP.
  
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  In states having nutrient management certification programs, any Federal employee who will be developing or approving nutrient management plans for federal programs must be certified by that state program.
  
• 
  Neither the USEPA nor the NRCS appear to understand the potential ramifications of feed management. Feed management is the first and logical place to start when evaluating manure management.
  

• 
  NRCS recognizes that the Technical Guidance does not establish criteria to address resource concerns other than water quality. Many issues related to air quality, odors, pathogens, and heavy metals are not fully understood, and only a few conservation practices addressing these problems have been developed by NRCS. However, a Comprehensive Nutrient Management Planning (CNMP) research needs assessment has been developed and is being addressed by the Partnership Management Team (Agricultural Research Service; Cooperative State Research, Education, and Extension Service; NRCS). NRCS, working with these other USDA agencies and professional organizations and societies, is developing a series of fact sheets that address these other resource issues. It is anticipated these fact sheets will be available in Fall of 2000.
  
• 
  NRCS and EPA have worked closely over the last 8 months to ensure the compatibility of the NRCS Technical Guidance with EPA’s Guidance Manual and NPDES Example Permit for CAFOs. The intent of both agencies was to ensure that a CNMP, whether developed for a voluntary USDA program or to meet NPDES regulatory requirements provided the same level of resource protection.
  
• 
  More clarity has been added to the Technical Guidance to distinguish between requirements and considerations when addressing criteria for each of the six elements in developing a CNMP. In the criteria for the elements, direct reference to standards, specific policy locations, and sections or chapters of technical references to enhance the functionality of the Technical Guidance. Also, key conservation practice standards (i.e., Nutrient Management (Code 590)), policy (i.e., 190-GM, Nutrient Management), an example of RMS planning alternatives development, and informational fact sheets (i.e., Pathogens, Feed Management, Air Quality) will be included.
  
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  A new section has been added that explains the CNMP certification issue, how certification programs will be established, and the types of certifications that will be needed to address CNMP development and implementation.
  

Providing conservation planning and other technical assistance to AFO/CAFO operators through voluntary incentive based programs and/or to meet regulatory requirements presents a potentially tremendous workload. NRCS traditionally has been the primary provider of conservation planning and related technical assistance to agricultural producers and others, having the ability to make and carry out natural resource management decisions. In an effort to build capacity to meet this potential workload, NRCS is establishing a process for certifying “approved sources” of conservation assistance. An individual who is appropriately certified through a USDA recognized certification organization is an “approved source.” These individuals are then referred to as “certified specialists.”

Certification organizations can come from the private or public sectors. Private consultants, employees of agribusiness, and others who hold appropriate certifications through an approved independent certification organization or state licensing agency can be approved as “certified specialists.” Employees of natural resource conservation agencies, departments, or other entities organized under local, State, or Federal law who have planning and technical assistance functions as part of their assigned responsibilities also can be approved as “certified specialists.” Other non-commercial sources, as determined by the NRCS state conservationist, can also be approved.

Individuals can be recognized as an approved source for conservation planning by obtaining a “certified conservation planner” designation, or as an approved source of technical assistance for developing components of a conservation plan by obtaining a “certified specialist” designation. An individual that is capable of developing a complete CNMP would require a “certified conservation planner” designation. To develop components (specific elements) of a CNMP would require a “certified specialist” designation.

In the development of a CNMP, as a minimum, the elements Manure and Wastewater Handling and Storage, Land Treatment Practices, and Nutrient Management must be developed by “certified specialists”. Because of the diversity and complexity of specific skills associated with each element of the CNMP, it is anticipated most individuals will pursue “certification” for only one of the elements. Therefore, to achieve a CNMP may require the interaction of three separate “certified specialists”, each addressing only one of the three elements.

It is envisioned that a “certified conservation planner”, assisting the AFO/CAFO owner/operator, would facilitate the CNMP development process, with “certified specialists” developing the more detailed specifics associated with the element they are “certified” to produce. It is anticipated that NRCS will continue its traditional role as the leader in conservation planning assistance by filling the role of “certified conservation planner” associated with CNMP development and implementation, within its available resources on a State-by-State basis.