A2O-Lancaster Farming, Saturday, November 28,1898 EPA, USD A Officials Present AFO Strategy- Listen To Comments (Continued from Pag* A 1) Administration's Clean Water Action Plan. The strategy establishes a national expectation that all animal feeding operations develop and implement comprehensive nutri ent management plans by the year 2008. These plans are to include man ure handling and storage, applica tion of manure to the land, record keeping, feed management, integ ration with other conservation measures, and other manure options. Last week's regional meeting about the strategy was called a -public listening session,” and the purpose was to educate and receive public comment. The session was open to all, and 23 people signed up to give comment, though not all spoke. Copies of the 41-page USDA/EPA draft Uni fied National Strategy for AFOs were made available at the meeting, and are still available over the Internet, through the USDA and EPA. A panel of people representing involved agen cies sat at a long table at the front of the room, to respond to questions later in the program, and to gauge public sentiment On the “listening panel” were James Lyons, the USDA under secretary for natural resources and the environment; J. Charles Fox, EPA asso ciate administrator for water, Humberto Hernan dez, USDA NRCS East Region regional conser vationist; Joe Piotrowski, associate director for EPA Region 3 Office of Watersheds; Janet Oert ly, NRCS state conservationist for Pennsylvania; Abigail Ladd, representing U.S. Sen. Rick San tonins; and Jennifer Saraceno, legislative assis tant to U.S. Rep. Tim Holden. Prior to the public comment period, represen tatives from both agencies gave an overview of the proposal. The presentation was done differently than has been routinely done at such an event, apparently using more modem presentation techniques. Two presenters worked together, one each from the EPA and USDA Joe DelVecchio, assistant state conservationist for New York USDA Natural Resources Conservation Service, and co-leader of the national USDA/EPA AFO strategy team; and Jeff Lape, branch chief of water quality and industrial permits with the Office of Water of the EPA, and co-leader of the national AFO strategy team. 'i he two traded the floor, subtopic by subtopic, presenting information and background about the program and its seven “strategic issues.” The effect blurred the perception of whether the information was being presented by EPA or USDA. The two were part of the technical panel those with day-to-day technical dealings with agency programs. Others on the technical panel included Tim Murphy, Pa.NRCS conservation engineer; Dou glas Goodlander, director of nutrient manage ment and technical services for the Pa. State Con servation Commission; Dr. Hugh Archer, deputy secretary for water management with the Pa. Department of Environmental Protection; and Hank Zygmunt, assistant associate director of the EPA Office of Watersheds. The Unified Strategy proposal itself is con structed sectionally, starting with building a case for itself, arguably using assumptions of water quality problems and public risks. It defines goals and performance expectations for AFOs, and then explains how the authorities to cany out the program exist within the Clean Water Act and regulations. From a production agriculture perspective, the proposal poses several obvious areas of concern. The presentation seemed to suggest that all of the livestock production industry commercial and hobby is to be viewed as potentially being required to have a permit to operate under the National Pollutant Discharge Elimination System (NPDES). The NPDES pennits were originated for point sources of pollution. 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