--part0_899844669_boundary
Content-ID: <0_899844669@inet_out.mail.aol.com.1>
Content-type: text/plain; charset=US-ASCII
--part0_899844669_boundary
Content-ID: <0_899844669@inet_out.mail.aol.com.2>
Content-type: message/rfc822
Content-transfer-encoding: 7bit
Content-disposition: inline
Return-Path: <campaign@magiccarpet.com>
Received: from relay20.mx.aol.com (relay20.mail.aol.com [172.31.106.66]) by
air12.mail.aol.com (v45.13) with SMTP; Tue, 07 Jul 1998 13:49:52
-0400
Received: from bambam.magiccarpet.com (bambam.magiccarpet.com [205.229.228.5])
by relay20.mx.aol.com (8.8.8/8.8.5/AOL-4.0.0)
with ESMTP id NAA19669;
Tue, 7 Jul 1998 13:49:42 -0400 (EDT)
Received: from ts2ppp2.magiccarpet.com (ts2ppp2.magiccarpet.com
[205.229.228.67])
by bambam.magiccarpet.com (8.8.7/8.8.7) with SMTP id MAA28636;
Tue, 7 Jul 1998 12:23:29 -0400 (EDT)
Message-Id: <3.0.1.16.19980707122829.259725dc@magiccarpet.com>
X-Sender: campaign@magiccarpet.com
X-Mailer: Windows Eudora Light Version 3.0.1 (16)
Date: Tue, 07 Jul 1998 12:28:29
To: Conserve@savethebay.cbf.org
From: "Natl. Campaign for Sustainable Agriculture" <campaign@magiccarpet.com>
Subject: Nutrient Mgmnt.Policy Alert
Mime-Version: 1.0
Content-type: text/plain; charset=US-ASCII
Content-transfer-encoding: 7bit
>ACTION NEEDED
>USDA IS REVISING ITS POLICY FOR NUTRIENT MANAGEMENT
>COMMENT PERIOD EXTENDED TO JULY 22, 1998
YOUR COMMENTS NEEDED
>
>USDA's Natural Resources Conservation Service (NRCS) is revising its
nutrient management policy and has issued a notice that has extended the
period for taking public comments on the policy until July 22, 1998. The
revised policy will become the new policy for all NRCS field staff (and
crop consultants and dealers who contract for services with NRCS) for
technical and program assistance with regard to the application of all
nutrients, especially phosphorus and nitrogen.
>
> The proposed nutrient management policy will most likely be the basis
for managing land application of animal waste from Concentrated Animal
Feeding Operations (CAFOs) under the joint strategy being developed by the
Environmental Protection Agency and USDA. Nutrient management plans for
NPDES permits regulating CAFOs could be based on this NRCS policy. NRCS
has established a relatively high standard for nutrient management for
nutrient sources other than manure and organic by-products. For other
nutrient sources, the application rates must meet a "Resource Management
System" standard for phosphorus application. NRCS defines a Resource
Management System as one that achieves a sustainable use of the soil,
water, and related natural resources. For nutrients from animal waste,
especially phosphorus, NRCS is proposing a less stringent standard under a
scheme of "progressive plans" to achieve a Resource Management System.
Under this "progressive plan" system, animal waste could be applied for up
to ten years or even longer in an unsustainable fashion with NRCS
assistance. This approach essentially sanctions the continued operation of
CAFOs under circumstances where animal waste is not being adequately
managed.
> The NRCS has extended the period for receiving comments on the proposed
nutrient management policy, primarily in response to requests by businesses
involved with large-scale CAFOs. These businesses realize that even a
flawed nutrient management policy, based on a phosphorus standard for
protecting water quality, will curtail the current practice of animal waste
"dumping" without regard to nutrient requirements of crops and other
vegetation or regard to water quality.
>
>We support USDA for proposing a phosphorus standard for its nutrient
management policy but find significant flaws with the current proposal. As
currently proposed, the nutrient management policy would allow NRCS to
spend technical assistance and Environmental Quality Incentives Program
(EQIP) funds and other financial assistance to support, for a period of up
to ten years and perhaps longer, animal feeding and other livestock
operations that cannot utilize animal waste at agronomic rates. As EPA
improves its permitting and enforcement program for dealing with CAFOs,
there is a very real danger that under the proposed nutrient management
policy precious TA and EQIP funds will start flowing to areas with very
high animal-to-land ratios and to large-scale confinement facilities.
Currently under EQIP, program funds cannot be used for CAFO waste storage
facilities, such as large cesspool lagoons, but with increasing regulation
of CAFOs, USDA will be under great pressure to authorize state-by-state
exceptions to this limitation. A sound USDA nutrient management policy
should ensure that livestock and poultry operations are sustainable,
environmentally sound systems in which animal waste is managed responsibly
from generation by the animal to land application or other ultimate
disposition.
>Ferd Hoefner, Washington D.C. representative of the Sustainable
Agriculture Coalition, submitted a comprehensive set of comments on the
nutrient management policy to NRCS on May 1, 1998. This action alert
provides a model letter summarizing major points from those comments.
Please feel free to build on this model letter, including additional points
or information from your own experience. Also, if you wish, you may
reference the Sustainable Agriculture Coalition's May 1, 1998 letter and
express support for the points made in that letter. If you would like a
copy of the Coalition's letter, contact Martha Noble at the Sustainable
Agriculture Coalition: Phone (202) 547-5754 / e-mail: <mnoble@msawg.org>.
>
>NRCS' Proposed Policy Revision for Nutrient Management Technical and
Program Assistance Activities was published in the Federal Register, Vol.
63 at pp. 19889-19892 (April 22, 1998) and is also posted on the Web at
<http://www.nhq.usda.gov/CCS/Nutrpost.html>. You can submit comments
electronically from this website or by mail addressed to: Charles H.
Lander, Nutrient Management Specialist, Natural Resources Conservation
Service, P.O. Box 2890, Room 6155-S, Washington D.C. 20013-2890.
>
>MODEL LETTER WITH KEY POINTS
>
>Charles H. Lander, Nutrient Management Specialist
>Natural Resources Conservation Service
>P.O. Box 2890
>Room 6155-S
>Washington D.C. 20013-2890
>
>RE: NRCS Proposed Policy Revision for Nutrient Management / 63 Fed. Reg.
19889 (4/22/98)
>
>Dear Mr. Lander:
>
>[Pt. 1] We / I commend you and the NRCS for proposing a revised nutrient
management policy based on application rates for phosphorus. We / I also
strongly support the adoption of a policy limiting applications rates for
phosphorus and other nutrients based on a Resource Management System (RMS)
that achieves sustainable use of the soil, water, and related natural
resources. Application rates for phosphorus, nitrogen, and other nutrients
should ensure that the application will not result in runoff of the
nutrients leading to degradation of the quality of receiving waters,
including both surface and ground waters.
>
>[Pt. 2] We/ I are very concerned, however, about the proposed policy's
exemption to an RMS standard for the application of phosphorus from animal
manure and other animal by-products. Phosphorus run-off from large-scale
confined livestock operations is a major pollution problem in our / my
state. [Provide examples from your state]. In establishing this exemption
from an RMS standard for application of animal waste, NRCS is acknowledging
that it will be approving nutrient management plans that allow
unsustainable application of phosphorus and fail to curb polluting run-off.
>
>[Pt. 3] We/I would prefer to see no exemptions from an RMS standard for
animal waste application based on phosphorus levels. If the NRCS is wedded
to providing exemptions, however, we/I strongly recommend that the
exemptions be limited in scope. First, the RMS exemption should not be
extended to large-scale CAFOs. Under the Clean Water Act's draft Strategy
for Animal Feeding Operations, CAFOs are subject to NPDES permits. The
pollution controls imposed on CAFOs are not voluntary and will require a
standard sufficient to prevent degradation of water quality. In many areas
of the country, vertical integrators have encouraged the establishment and
geographic concentration of industrialized, large-scale CAFOs to increase
their profits with little regard for subsequent environmental harms. The
risk of harms to the environment and surrounding communities from CAFOs is
too great for the establishment of NRCS policies sanctioning their
continued operation for years.
>
>[Pt. 4] Second, existing livestock operations below the regulatory
threshold number for CAFOs may need some time and resources in making the
transition to sustainable RMS standards for handling and use of animal
waste. The time allowed for a special temporary exemption from an RMS
should be limited to five years, or to two or three years in watersheds
already seriously impaired by excess nutrient application. As for new or
expanding operations, they should be held to an RMS standard for phosphorus
application. No federal policy should encourage or promote the
establishment of unsustainable operations.
>
>[Pt. 5] USDA support, including both technical assistance and program
funds, should be limited to existing operations below the CAFO regulatory
threshold to help ensure that these smaller operations do not pose
environmental problems. These funds should be used to complement the
regulatory system. Large-scale CAFOs, which are often part of large and
well-funded integrated systems, should pay their own way to clean up
problems generated by years of unsound management and waste handling.
>
>[Pt. 6] In general, the nutrient management planning process, both for RMS
and transitional systems, should include: (1) a thorough assessment of the
carrying capacity for nutrients of the available land resources and local
watersheds; (2) consideration of a wide variety of alternate practices for
nutrient management including the full range of animal production systems,
many of which are more environmentally sound than confined operations; and
(3) consideration of a full range of practices to lessen nutrient run-off
such as crop rotation choices, in-field and edge buffers, strip practices,
etc. A sound USDA nutrient management policy should ensure that livestock
and poultry production operations are sustainable, environmentally sound
systems in which animal waste is managed responsibly from generation by the
animal to land application or other ultimate disposition.
>
> Sincerely
>
Liana Hoodes
National Campaign for Sustainable Agriculture
P.O. Box 396
Pine Bush, NY 12566
P: 914-744-8448; F: 914-744-8477
campaign@magiccarpet.com
--part0_899844669_boundary--
To Unsubscribe: Email majordomo@ces.ncsu.edu with "unsubscribe sanet-mg".
To Subscribe to Digest: Email majordomo@ces.ncsu.edu with the command
"subscribe sanet-mg-digest".