Itate, Industry Environmental Programs
(Continued from Page A 22)
flucem, especially the way the
reposed Unified Strategy would
letennine which farms are to be
considered for mandatory com
prehensive nutrient management
planning approved by the federal
government
“There may be some merit to
rising animal numbers as (a deter
mining threshhold for considera
tion for mandatory planning) as
CAFOs are calculated, rather than
using the density as we do in Pen
nsylvania (average annualized ani
mal weights pa acre suitable to
receive manure nutrients),” he
offered.
“But it appears that using an
oversimplified, inaccurate, unre
presentative, inflexible method of
jffirmining animal units is a step
backwards from the system used
here in Pennsylvania, called the
Animal Equivalent Units
(AEUs),” Robinson said.
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“(Pennsylvania’s) system has
been recognized by EPA as being
much more accurate than their
method,” he said. “The excuse (for
using the federal method) that it's
the same all over the country gives
little comfort when the plans are to
consider revisions in a few years,
adding more confusion.
“Why not start right the first
time?”
Robinson also questioned the
wisdom of using water quality
monitoring data in a watershed as
an indicator of whether all farms in
that watershed jould be consid
ered a CAPO and be required to
have permitting and additional
restrictions.
He further questioned the use of
fertilizer sales in the county as a
source of data for farm-fertilizer
For watershed monitoring data
indicating high nutrient flows, he
explained that sources of nutrients
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are not known just by testing water
levels, and that just because the
drainage of a watershed indicates
nutrient pollution, there are many
other potential sources that should
be considered, not just farms.
He said the federal proposal also
seems to put small farms at higher
risk of failure because of extra,
unecessary costs. The result could
easily be to encourage the develop
ment of large, concentrated animal
operations.
Another speaker was Douglas
Goodlander, on behalf of Pennsyl
vania’s State Conservation Com
mission (SCC), which currently
oversees Pennsylvania’s nutrient
management laws and enforce
ment with help from both the state
Department of Environmental Pro
tection and the state Department of
Agriculture.
He said the SCC is still review
ing the proposal and will provide
formal written comments before
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the Jan. 19 deadline.
“Our general comments include
that the commission is pleased
with the general direction of the
AFO strategy initiative, in that it
specifically focuses regulatory
activities on operations thought to
have a high pollution potential.
“It relies on a voluntary
incentives-based approach to
encourage the remainder of far
mers to implement nutrient man
agement plans," he said.
.-“This is similar to Pennsylvani
a’s nutrient management program
..." he said.
He also said that the philoso
phies of the programs ate some
what similar, although:
• Pennsylvania’s mandatory
planning requirements differ
markedly from the federal propos
al in that the federal government
wants to include animal feeding as
part of the overall plan, and Pen
nsylvania’s planning doesn’t go so
far as to restrict a farmer to feeding
according to an inflexible plan;
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•Pennsylvania has been a leader
in working toward developing bet
ter feeding programs to reduce
manure escapes of nutrients (they
cost money and if they aren’t used
by the animal they cost more
money and detract from profits.)
Also, be said that the SCC
doesn’t believe that the Unified
Strategy’s reliance of existing
programs that provide cost-sharing
funds for farms to implement
environmental management prac
tices and devices is well
considered.
(The Strategy more or less
broadly suggests that funds from
existing federal programs could be
diverted and earmarked for the
national nutrient management
strategy.)
“We do not believe that
(USDA’s) EQIP (Environmental
Quality Incentive Program) and
other federal funding programs at
their current funding levels will
provide adequate resources to
(Turn to Page ASS)
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