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EPA/USDA Animal Feeding Operation Strategy

Farm Business Management Update, October 1998

By Jim Pease of the Department of Agricultural and Applied Economics, Virginia Tech

On September 17, the U.S. Environmental Protection Agency (EPA) and USDA released the draft of their unified animal feeding operation (AFO) strategy. An animal feeding operation is any agricultural enterprise where animals are kept or raised in confined situations, and feed is brought to the animals. Nationwide, about 450,000 operations fit this definition. In Virginia, all confined poultry operations, beef feedlots, and confined dairy operations would be covered under this definition. This strategy forms part of a larger collaboration between the two agencies under the Clinton Administration's Clean Water Action Plan. Regardless of what you may have heard in the media, note that the document is a draft and it is a strategy. It will undoubtedly be modified before its final version is issued in early 1999, and in any case it will be a plan of action or strategy that both agencies will follow -- it does not create new law or regulations.

The key objective of this joint strategy is that ALL AFOs should have implemented a Comprehensive Nutrient Management Plan (CNMP) by 2008. A CNMP is required for an operation in the regulatory program, and strongly encouraged for an operation in the voluntary program. A CNMP, like the Va. Dept. of Conservation and Recreation (DCR) Nutrient Management Plans, identifies management actions necessary to meet nutrient management goals. According to the proposed strategy, the following types of actions are contained in a CNMP: 1) feed management, 2) manure handling and storage, 3) land application of manure, 4) land management, 5) record keeping, and 6) other manure utilization options. Whether the nutrient management plans as developed or certified by DCR cover all these actions is not clear, nor is it clear from the strategy whether such plans would be developed on a nitrogen basis or on a nitrogen and phosphorus basis.

As noted above, an operation could be covered by the regulatory program or the voluntary program. The regulatory program is implemented nationally under the Clean Water Act, and the system is called the National Pollutant Discharge Elimination System or NPDES. This program is administered by Virginia state government through its Virginia Pollution Abatement (VPA) and its Virginia Pollutant Discharge Elimination System (VPDES). The EPA/USDA strategy as it applies to regulatory programs covers CAFOs, or Concentrated AFOs, which under the new strategy will cover three categories of AFOs: 1) large facilities with more than 1000 animal units (AUs), 2) facilities with more than 300 AUs with unacceptable conditions that pose a significant risk of water pollution and have been designated by EPA or the state as CAFOs, and 3) facilities in an area where a large number of (possibly) small AFOs contribute to significant waterbody impairment. Currently, about 2,000 CAFOs have NPDES permits nationwide. EPA estimates that about 15,000 to 20,000 CAFOs will be under the regulatory umbrella under the new strategy. How many Virginia operations would be covered is unclear, but at least 900-1,000 Virginia operations have more than 300 AU. The EPA/USDA strategy clearly states that poultry operations with dry manure handling systems are not exempted from NPDES permitting as they have been in the past and are currently under the VPA system.

Approximately 95 percent of AFOs will be covered under the voluntary system. EPA/USDA consider that the cornerstones of voluntary programs are locally led conservation, environmental education, and technical/financial assistance programs. The agencies will develop stronger relationships with Soil and Water Conservation Districts (SWCD); actively engage such units as Extension, USDA/Ag Research Service, state and local governments, land grant universities, and the private sector in environmental education efforts directed towards AFO operators; and seek to fund more technical assistance and cost-share programs through USDA/NRCS's Conservation Technical Assistance (CTA) program, the Conservation Reserve Program (CRP), the Conservation Reserve Enhancement Program (CREP), and the Environmental Quality Incentives Program (EQIP).

The remainder of the strategy consists of an outline of seven strategic issues and actions necessary to accomplish the strategy. Numerous details not described here could be extremely important as to which Virginia operations will be covered by the regulatory program. The strategy and an executive summary are both available on the Web at Feel free to contact me at 540-231-4178 or if you have any questions.

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