Release No. 0373.98

Executive Summary

DRAFT UNIFIED AFO STRATEGY EXECUTIVE SUMMARY

Over the past quarter century, the United States has made tremendous progress in cleaning up its rivers, lakes, and coastal waters. While pollution from factories and sewage treatment plants has been dramatically reduced, runoff from city streets, agricultural activities (including animal feeding operations), and other sources continues to degrade the environment and puts drinking water at risk.

In February 1998, President Clinton released the Clean Water Action Plan (CWAP), which provides a blueprint for restoring and protecting water quality across the Nation. The CWAP identifies polluted runoff as the most important remaining source of water pollution and provides for a coordinated effort to reduce polluted runoff from a variety of sources. As part of this effort, the CWAP calls for the U.S. Department of Agriculture (USDA) and the U.S. Environmental Protection Agency (EPA) to develop a Unified National Strategy to minimize the water quality and public health impacts of animal feeding operations (AFOs).

The draft Unified AFO Strategy discusses the relationships between AFOs and environmental and public health, establishes a national performance expectation for all AFO owners and operators, and presents a series of actions that USDA and EPA will take to minimize public health impacts and improve water quality while complementing the long-term sustainability of livestock production.

Background

AFOs are agricultural enterprises where animals are kept and raised in confined situations. Approximately 450,000 AFOs in the United States congregate animals, feed, manure and urine, dead animals, and production operations on a small land area. USDA data indicate that the vast majority of farms with livestock are small - about 85 percent of these farms have fewer than 250 animal units (Aus), where an AU is equal to roughly one beef cow (therefore 1,000 Aus is equal to 1,000 beef cows or equivalent number of other kinds of animals). About 6,600 AFOs had more than 1,000 Aus in 1992 and are considered to be large operations.

As a result of domestic and export market forces, technological changes, and industry adaptations, the past several decades have seen substantial changes in the animal production industry.

These factors have promoted expansion of confined production unis, with growth in both existhingareas and new areas; integration and concentration of some of the industries; geographic separation of animal production and feed production operations; and the concentration of large quantities of manure and wastewater on farms and in some watersheds.

AFOs can pose a number of risks to water quality and public health, mainly because of the amount of animal manure and wastewater they generate. Manure and wastewater from AFOs have the potential to contribute pollutants ssuch as nutrients (e.g., nitrogen, phosphorus), sediment, pathogens, heavy metals, hormones, antibiotics, and ammonia to the environment. These pollutants can cause several types of water quality and public health impacts.

Even though many diverse sources contribute to water pollution, States report that agriculture is the most widespread source of pollution in the nation's surveyed rivers. In the 22 states that categorized impacts of specific types of agriculture, animal operations impact about 35,000 river miles of those assessed. While there are other potential environmental impacts associated withAFOs (e.g. habitat loss, ground water depletion), this Strategy focuses on addressing surfac and ground water quality problems. Once implemented, however, this Strategy will indirectly benefit other resources.

USDA and EPA's National Performance Expectation

To minimize water quality and public health impacts from AFOs and land application of animal waste, this draft Strategy establishes a national performance expectation that all AFO owners and operators develop and implement technically sound and economically feasible Comprehensive Nutrient Management Plans (CNMPs). A CNMP identifies actions that will be implemented to meet clearly-defined nutrient management goals at an agricultural operation. The following types of actions are contained in a CNMP:

• Feed Management - Where possible, animal diets and feed should be modified to reduce the amounts of nutrients in manure.



• Maure Handling and Storage - Manure needs to be handled and stored properly to prevent water pollution from AFOs.



• Land Application of Manure - Land application is the most common, and usually most desirable method, of utilizing manure because of the value of the nutrients and organic matter. Land application in accordance with the CNMP should minimize water quality and public health risk.



• Land Management - Tillage, crop residue management, grazing management, and other conservation practices should be utilized to minimize movement to surface and ground water of soil, organic materials, nutrients, and pathogens from -lands where manure is applied.



• Record Keeping - AFO operators should keep records thta indicate the quantity of manure produced and ultimate utilization, including where, when, and amount of nutrients applied.



• Other Utilization Options - In vulnerable watersheds, where the potential for environmentally sound land application is limited, alternative uses of manure, such as the sale of manure to other farmers, composting and sale of compost to home owners, and using manure for power generation may need to be considered.

AFO owners and operators may seek technical assistance for the development and implementation of CNMPs from qualified specialists. These specialists should assist in implementation and provide ongoing assistance through periodic reviews and revisions of CNMPs, as appropriate.

Relationship of Voluntary and Regulatory Programs

Voluntary and regulatory programs serve complementary roles in providing AFO owners and operators and the animal agricultural industry with the assistance and certainty they need to achieve individual business and personal goals, and in ensuring protection of water quality and public health.

Voluntary Program for Most AFOs

Voluntary programs provide an enormous opportunity to help AFO owners and operators and communities address water quality and public health concerns surrounding AFOs. For the vast majority of AFOs, voluntary efforts will be the principal approach to assist owners and operators in developing and implementing CNMPs, and in reducing water pollution and public health risks associated with AFOs. While CNMPs are not required for AFOs participating in voluntary programs, they are strongly encouraged as the best possible means of managing potential water quality and public health impacts from these operations.

There are three types of voluntary programs to assist AFO owners and operators. USDA and EPA are both committed to promoting locally led conservation as one of the most effective ways to help AFO owners and operators achieve their conservation goals. Environmental education can bring an awareness of possible water quality problems and inform AFO owners and operators about practices that will address such problems.

A variety of financial and technical assistance programs exist to provide AFO owners and operators advice in developing CNMPs and implementing solutions and to defray the costs of approved/needed structures (e.g., waste storage facilities for small operations) or to implement other practices, such as installation of conservation buffers to protect water quality.

Regulatory Program for Some AFOs

Impacts from certain higher risk AFOs are addressed through National Pollutant Discharge Elimination System (NPDES) permits under the authority of the Clean Water Act. AFOs that meet certain specified criteria in the NPDES regulations are referred to as concentrated animal feeding operations or CAFOs.

NPDES permits will require CAFOs to develop CNMPs and to meet other conditions that minimize the threat to water quality and public health and otherwise ensure compliance with the requirements of the Clean Water Act. NPDES permits will also ensure that the animal waste from CAFOs will be disposed of properly and require reporting on whether the permittee has a CNMP for land application of animal waste and whether it is being implemented properly. The draft Strategy identifies three categories of CAFOs that are priorities for the regulatory program:

• Significant Manure Production - Large facilities (those with greater than 1000 animal units) produce quantities of manure that are a risk to water quality and public health whether the facilities are well managed or not.
• Unacceptable Conditions - Facilities that have man-made conveyances that discharge animal waste to waters or have a direct discharge to waters that pass through the facility or come into direct contact with animals represent a significant risk to waster quality and public health.
• Significant Contributors to Water Quality Impairment - A facility or a collection of facilities that is significantly contributing to, or is likely to significantly contribute to, impairment of a waterbody and nonattainment of a designated use is also a priority for the NPDES permitting program.

The draft Strategy supplements these regulatory program priorities with two types of incentives for some types of AFOs. Smaller CAFOs that meet certain conditions may exit the regulatory program at the end of their permit term if they correct the problem(s) that caused them to be covered by the regulatory program. The draft Strategy also describes a "good faith incentive" for some AFOs to avoid being covered by the regulatory program if they have and are implementing a CNMP.

Strategic Issues

The draft Unified AFO Strategy addresses seven strategic issues. The discussion of each strategic issue identifies several action items.

• Building Capacity for CNMP Development and Implementation - The successful implementation of this Strategy depends on the availability of qualified specialists from either the private or public sectors to assist in the development and implementation of CNMPs. The draft Strategy describes actions to substantially increase AFO owners and operators' access to technical assistance for developing and implementing CNMPs.



• Accelerating Voluntary, Incentive-Based Programs - The draft Strategy sets out a desired outcome that all AFOs will have CNMPs by 2008. Several actions, including review and revision of USDA's practice standards, development of CNMP guidance, fair and equitable program delivery, and options for financial assistance, are directed toward achieving this objective.



• Implementing and Improving the Existing Regulatory Program - The draft Strategy clarifies the applicability and the requirements of the existing regulatory program, identifies permitting and enforcement priorities, and describes EPA's plans to strengthen and improve existing regulations.



• Coordinated Research, Technical Innovation, Compliance Assistance, and Technology Transfer - USDA and EPA will establish coordinated research, technical innovation, and technology transfer activities, and compliance assistance, and establish a single point information center.



• Encouraging Industry Leadership - The animal agriculture industry can play a key role in helping to encourage adoption of CNMPs and in addressing water quality problems on individual AFOs. The draft Strategy includes possible actions that USDA and EPA may take to promote industry involvement.



• Data Coordination - Several kinds of data are useful in assessing and managing the water quality impacts of AFOs. USDA and EPA's efforts to coordinate on data sharing will both protect the trust relationship between USDA and farmers and provide regulatory authorities with information that is useful in protection water quality and public health.



• Performance Measure and Accountability - USDA and EPA believe that it is critical to establish performance measure to gauge our success in implementing this Strategy and meeting relevant goals in each agency's strategic plan established under the Government Performance and Results Act. USDA and EPA will develop an approach for measuring the effectiveness of efforts to minimize the water quality and public health impacts of AFOs.

Next Steps

USDA and EPA published the draft Unified AFO Strategy in the Federal Register for public review on September 17, 1998. The draft Strategy is also available on the World Wide Web at http://www.nhq.nrcs.usda.gov or http://www.epa.gov/owm/afostrat.htm. USDA and EPA welcome your comments on the draft Strategy. During the next several months, we will conduct public meetings and promote discussions with interested parties to hear diverse views on ways the Strategy could be improved to better its objectives.

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