A36-Lancaster Farming. Saturday. April 16, iwT Advisory (Continued from Page A 1) morning. The board was created solely to advise the State Conservation Commission as the Commission creates regulations implementing the Nutrient Management Act The act was created in order to establish legal controls of non point nutrient pollution. It also provides for yet-untested protec tion from liability and from multi ple prosecution for those who establish and follow an approved nutrient management plan. Though the law calls for the establishment of regulations for controlling agricultural contribu tions to the flow of nutrients, it also directs the state Department of Environmental Resources to research and address other contri butors of nutrient flow. Currently the effort is to develop regulations and procedures to assess nutrient application activi ty, determine some level of con trol, acceptibility of devices of nutrient control, and subject a degree of responsibility and reward for excetcising control. In that effort, the first major catagory of non-point nutrient sources to be addressed under the Nutrient Management Act is agri cultural livestock operations, espe cially the mote modem operations which can accept densities of animals-per-acre that are much higher than historic practices permitted. Wednesday’s Agenda On Wednesday. Michael Krempasky, secretary of the com mission, presented an agenda which included: • a comment period on the adoption of the interim criteria which establishes a framework for creating a certifica tion program; • a review of preli minary regulations for nutrient management with emphasis on defin itions of a concentrated animal operation and nutrient application; • discussion on envir onmentally sensitive areas; • an introduction to SCS standards for con servation planning; * and update on inter im certification work by the Department of Agri culture, which is charged with creating and administering certi fication of nutrient man agement specialists; • and an overview ot the One-Plan Concept, which is an attempt to combine all the various operational plans per taining to an agricultural operation so that the plan works in syncopa tion, in confliction. However, because of the intensity of discus sion over the review of preliminary regulations, the rest of the topics were postponed until the next meeting, scheduled May 4, also in Room 309 at the PDA head quarters building. Board Talks The main -issue of contention during Wednesday’s meeting was in agreeing on definitions and get ting some kind of assurances that proposed regulations for the con trol of nutrients would not become so bureaucratic that agricultural ists would shy away from doing voluntary nutrient management plans for their farms. Dr. Douglas Bcegle, though not a member of the board, has been attending meetings at its request and has been asked by the board many times to provide expert opin ion as to what is practicable and what is not Beegle has been involved in the process for some time, and is resprected by the board for his agronomic expertise. Throughout the process, Beegle has stated that the regulations under nutrient management should not be so detailed or restricting that it would confine an operator’s abil ity to create a workable plan for controlling nutrients. In that sense, Beegle has said a goal of minimizing the loss of nutrients from the control of the farmer should be the main key to any plan. He has suggested that the Commission approach the Act with a view toward creating reg ulations which address topics of concern, but which allow refer ence to approved guidelines, as could be eventually approved by the commission for use in imple menting a plan. r^im STEEL BARN a Duii Oußtg.lf DuD Do| equipment GATES and FENCING 'V" ' \ 4 " "v> V. 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Furthermore, defining accept able practices in the regulations would require another regulation making process every time a new type of possible method of hand ling nutrients and nutrient containing materials, such as man ure, would be suggested. The apparent dcs ire by the board majority is to allow flexibility in a nutrient management plan so that business management plans can coincide and be implemented without reducing the effectiveness of nutrient control. An expressed fear is that far mers may be prevented from work ing the farm according to the changes in nature, in order to stay in business. Currently, with a delayed plant ing date, a farmer may choose to plant another crop or shorter maturing variety in a specific field which may change the way a por tion of his nutrient uses are handled. Under the proposal reviewed for the first time Wednesday, specific crops and acres planted are requested. The objection was raised that writing down a plan that contains crop acreage specifics may somehow limit die ability of the farmer to be flexible in trying to succeed in farming. The argument against being spe cific with crop information was illustrated in a scenario in which a government official would review the plan, note the disciepency, and declare the operator to be out of compliance with the nutrient man agement plan. The nine-page proposal of reg ulations included several passages that were more specific than what some members of the board thought was appropriate, and the board approved recommending several changes. However, it was also made clear that in order for controls of nutri ents to be effective, regulations had to contain some specific rules so that enforcement challenges to practices could be supported by law. The proposed preliminary draft of regulations were created for dis cussion purposes only and covered a partial list of definitions, general provisions, general requirements of nutrient management plans, identification of concentrated ani mal operations, the plan concept Under the plan concept are para graphs covering the scope of the plan to identification of farms and acreage, summary statements of nutrient management plans, deter minations of available-nutrients, and nutrient application rates and procedures. Classified ads*3 £ PAY OFF! fi H * * Discussions seemed to get bogged down on how specific a plan would have to be with regard to the application of nutrients, as far as timing and testing 0 f manure. The degree of specificity in documenting how much volume of nutrients are to be used in an opera tion are yet to be fully discussed. On one hand, arguments were made that too much specificity, would interfere in daily operation al and business decision-making abilities of fanners, hindering their ability to make quick decisions in response to changes in environ mental conditions. On the other hand, it was argued that too little specificity would not provide enough confidence that nutrients would be properly con trolled under a plan. Other than Dr. Bregie’s request (which was also supported by other members, but not made into a motion) that official guidelines for practices be adopted by the com mission and reviewed by the advis ory board, no discussion yet focussed on the possibility of a plan including a list of preferred backup options for handling nutri ents given forseeable variations in conditions. The board is expected to pick back up on talks during its May meeting.
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