WASHINGTON — Vice President Al Gore waded into the waste waters last week, unveiling the joint USDA-EPA “Unified National Strategy for Animal Feeding Operations.”
The draft strategy for animal waste management standards had been the object of much debate since introduced last year, primarily because it expands the EPA’s regulation of livestock operations and defines manure as a “point source.” Both the USDA and EPA hosted listening sessions across the country during the open comment period.
Much of the attention is on larger Concentrated Animal Feeding Operations, or CAFOs, but a stated goal of the new strategy is to develop and implement nutrient management plans for all animal feeding operations by 2009, an estimated 450,000 farms nationwide.
The plans will encompass feed management, manure storage and handling, and land management.
U.S. livestock operations with more than 1,000 animal units (the equivalent of 1,000 beef cattle or 700 mature dairy cattle) will be required to obtain Clean Water Act discharge permits. About 5 percent of U.S. livestock operations fall into that bracket.
But other operations will also be required to get discharge permits: those that discharge directly into waterways or have other “unacceptable” conditions; and those that contribute significantly to the “impairment of a water body.”
The strategy also requires “integrators” — large livestock companies that contract with smaller operators to raise their animals — to share responsibility for meeting regulatory requirements.
“I don’t disagree that the industry needs to be watched. We all have to be environmentally sound,” said dairyman Kurt Steiner, who milks 225 Holsteins in Wayne County. “But a widespread stamp on this isn’t the answer.”
Steiner said large producers are already dealing with environmental concerns. In Ohio, the OEPA permitting process kicks in at 1,000 animal units.
Jim Newburn, who milks 76 head in Jefferson County, sees the permitting regs as targeting the larger operations. “It really doesn’t affect us at our level,” he said, “yet it will have the trickle-down effect.”
After the vice president’s announcement, House Agriculture Committee Chairman Larry Combest quickly voiced his concerns. “I am afraid that the USDA will either pass the buck to the EPA for enforcement or divert agriculture department manpower,” Combest said.
“At the very least, the vice president and EPA should give livestock producers real assurance that they will not bear the cost of command and control regulations.”
Speaking to the Ohio Farm Bureau county presidents visiting Washington when the vice president’s announcement was made, Dave Salmonsen put it bluntly. “This strategy just doesn’t make a whole lot of sense,” the American Farm Bureau Federation staffer said. “We don’t believe the EPA has authority over state issues.”
He cited information from the USDA’s Natural Resources Conservation Service that estimates the technical assistance to implement the strategy will cost $2 billion over 20 years. NRCS figures the financial assistance could total $13 billion.
NRCS is also slated to lose roughly 1,000 field staffers. The USDA agency is geared up to do 3,000 manure nutrient management plans a year, Salmonsen said, but producers need about 400,000 plans.
“To say it doesn’t make any sense is an understatement,” he added.
Like it or not, Salmonsen said the reality is that EPA’s water programs are moving from point source pollution concerns to nonpoint source pollution targets, like agriculture. “There will be more permit-based regulations of livestock farms.”
The National Cattlemen’s Beef Association said the strategy “mandates ‘one size fits all’ regulations that are unworkable. It makes no distinction between a feedlot that is 10 miles from a river and located in a humid climate, or a feedlot that is in an arid climate and far from any natural sources of groundwater.”
According to the American Sheep Industry Association, the Wyoming Association of Conservation Districts has filed notice of intent to sue USDA and EPA in regard to the Unified National Strategy and certain provisions of Gore’s Clean Water Action Plan.
The strategy now moves into the regulatory process; interested parties may still give comments and input as the Environmental Protection Agency writes regulations to implement it.