Monday, November 27, 2006

Time to Reevaluate Our Strategy for Reducing Pollution from Animal Feedlots

In President Clinton's 1998 presidential inauguration address, delivered shortly after the 25th anniversary of the Clean Water Act, President Clinton announced the Clean Water Action Plan. The Clean Water Action Plan included 111 proposed actions to protect water resources. One of the proposed actions was the EPA and USDA were to jointly develop a plan for reducing pollution from animal feedlots.

Feedlot
Thus, on March 9, 1999, the EPA and USDA unveiled the Unified National Strategy for Animal Feeding Operations ("Unified Strategy for AFOs"). The purpose of the Unified Strategy for AFOs was to reduce surface and ground water quality problems caused by animal feedlots. Twenty-five years after the Clean Water Act had been enacted, 40% of the Nation's waterways were still not meeting water quality goals. While the Clean Water Act had been successful at reducing point source pollution from factories and sewage treatment plants, the Clean Water Act had been unsuccessful at reducing non-point source pollution from city streets, farmland, and other sources.

In the Unified Strategy for AFOs, the EPA and USDA announced the goal of having all animal feedlots develop and implement Comprehensive Nutrient Management Plans (CNMPs) by 2009. To achieve this goal, the EPA would impose regulations on the 5% of animal feedlots that posed the greatest threat to water quality. The EPA and USDA would encourage the remaining 95% of animal feedlots to voluntarily adopt CNMPs.

The CNMPs proposed by the Unified Strategy for AFOs were to be comprehensive both in terms of the water pollutants addressed (nitrogen, phosphorus, pathogens, and others) and in terms of the approaches used to reduce the pollutants entering waterways. For example, a CNMP might include plans to modify animal diets to reduce the quantities of nutrients in manure, plans to apply manure to farmland at rates that would ensure that the nutrients in the manure would be used by crops, and plans to plant a buffer strip to reduce the quantities of pollutants transported from an animal feedlot to an adjacent river. To ensure that CNMPs would be effective at reducing water pollution, CNMPs were to be developed by certified specialists in accordance with the Natural Resources Conservation Service's (NRCS's) Field Office Technical Guide and were to include implementation schedules.

Plans for Increasing Regulation of Animal Feedlots that Pose the Greatest Environmental Threat

At the time that the Unified Strategy for AFOs was unveiled, the EPA was directly regulating pollution from approximately 2,000 animal feedlots. The EPA declared that, under current Clean Water Act regulations, it had the authority to regulate 15,000 to 20,000 more animal feedlots. The EPA announced its intension to begin requiring these feedlots to develop and implement CNMPs. According to the Unified Strategy for AFOs, the animal feedlots that pose the greatest environmental threat and hence would be required to develop and implement CNMPs are: 1) facilities that produce a lot of manure (>1,000 animal units); 2) facilities that discharge animal manure directly into rivers, lakes, or streams via man-made conveyances; and 3) facilities that significantly contribute to the impairment of water bodies, preventing water bodies from being useable for fishing or swimming.

Plans for Encouraging Voluntary Adoption of CNMPs by Animal Feedlots

The Unified Strategy for AFOs recognized that the goal of having all animal feedlots adopt CNMPs would only be met if livestock producers adopted a land stewardship ethic, a feeling of responsibility for being good stewards of the land under their care. To foster a land stewardship ethic among livestock producers, the Unified Strategy for AFOs proposed undertaking an aggressive environmental education effort and providing technical and financial assistance to farmers to help farmers develop CNMPs. The Unified Strategy for AFOs did not propose creating any new programs. Instead, the Unified Strategy for AFOs proposed redirecting existing programs towards achieving the goal of having all animal feedlots develop and implement CNMPs.

Specific actions proposed in the Unified Strategy for AFOs:
  1. The federal government would substantially increase funding for the Environmental Quality Incentives Program (EQIP). EQIP would provide the primary source of financial assistance for livestock producers developing and implementing CNMPs.

  2. The Natural Resources Conservation Service (NRCS) would revise its Field Office Technical Guide to provide up-to-date technical guidance for livestock producers developing CNMPs.

  3. The USDA would increase funding for the NRCS Conservation Technical Assistance (CTA) Program and the Cooperative Extension System Program to increase the number of certified specialists to help livestock producers develop CNMPs.
The development of the Unified Strategy for AFOs by the EPA and USDA seemed like an important first step for addressing the environmental and public health threats posed by animal feedlots. Pollution from animal feedlots has historically been regulated by a variety of uncoordinated federal and state programs. It seemed valuable for the EPA and USDA, the two federal agencies regulating animal feedlots, to articulate a single plan to guide future efforts.

While critics of the Unified Strategy for AFOs have emphasized its heavy reliance on voluntary adoption of CNMPs, the Unified Strategy for AFOs included significant increases in regulatory efforts. Under the Unified Strategy for AFOs, the EPA would increase the number of animal feedlots required to obtain NPDES permits from 2,000 to roughly 20,000. Furthermore, the Unified Strategy for AFOs reflected a smart use of money. Under the Unified Strategy for AFOs, the EPA would target regulatory efforts, with their high administrative costs, at animal feedlots that posed the greatest environmental threat. Lastly, the Unified Strategy for AFOs wisely recognized that substantial progress towards minimizing pollution from animal feedlots would only be made if livestock producers were committed to this goal.

As we approach another presidential inaugural address, this seems like an appropriate time for reevaluating our efforts to clean up our Nation's waterways. Has the Unified Strategy for AFOs been effective at reducing water pollution from animal feedlots? Has progress been made towards the goal of having all animal feedlots develop and implement Comprehensive Nutrient Management Plans (CNMPs) by 2009? Should we recommit ourselves to following the plan outlined in the Unified Strategy for AFOs, or should we chart another course?

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