Dr. Dan L. Cunningham and Dr. Casey W. Ritz
Department of Poultry Science
The need to ensure that concentrated animal feeding operations (CAFOs) are not contributing to water quality issues in the United States has led many states to develop nutrient management plans (NMPs) for their livestock producers. These NMPs have been implemented through either voluntary participation or through mandated state regulations. Some states, such as Georgia, have used combinations of these two approaches.
NMPs are essentially best management practices for appropriate handling, storage and application of animal manures when used as organic fertilizers. The benefits of such programs are the continued protection of the state's surface and ground waters and the enhancement of the economic value of this organic fertilizer through the most efficient use of the contained nutrients.
Georgia's Response to NMPs
Georgia has responded to the need for poultry NMPs by developing and implementing two distinctly different nutrient management programs: Georgia's Voluntary Nutrient Management Program and State Rule 391-3-6, Animal (Non-Swine) Feeding Operations program. The two plans differ in that the first is directed to all poultry producers in Georgia regardless of the type of manure being managed and is dependent on voluntary compliance. The second is directed specifically to poultry producers with liquid manure systems and/or continuous overflow watering systems and is mandated by state rule. Poultry producers need to understand the differences between these two programs as well as the importance and implications of compliance with these programs.
The Voluntary Program
History of the Program. The Department of Poultry Science at the University of Georgia and the Georgia Poultry Federation began working collaboratively to develop nutrient management plans for Georgia's poultry producers in 1994. At that time, poultry industry representatives and members of the College of Agricultural and Environmental Sciences realized the importance of establishing and documenting uniform methods to apply poultry manures to the soil through an aggressive and pro-active voluntary program. To achieve these objectives, a task force was created involving members of the Georgia Poultry Federation; UGA faculty from the departments of Poultry Science, Biological and Agricultural Engineering, and Crop and Soil Sciences; and representatives from the Natural Resource Conservation Service.
As a result of the work of this task force, educational materials (NMP manuals and slide sets) were developed specifically for poultry producers to assist in the education and implementation of the voluntary program. These training materials contain sections related to the key components necessary for developing a farm-based nutrient management program.
Components of an NMP. The important aspects of NMP development covered in the voluntary program training manuals and the educational programs are:
Applicable federal and state regulations
Procedures for soil and litter analysis
Nutrient budgets and worksheets
Documentation of the plan (records)
Application and storage methods
Practices for preventing soil erosion
Methods for dead bird disposal
In August of 1999, the Board of Directors of the Georgia Poultry Federation passed a resolution approving the policy of providing all poultry growers in Georgia training related to the voluntary NMP program. This resolution also established the goal of having all poultry producers implementing NMPs by January, 2002.
Achievements of the Voluntary Program. Beginning in September, 1999, faculty in the departments of Poultry Science and Crop and Soil Sciences began conducting educational programs in conjunction with county extension agents across the state. By the end of 2001, more than 3,800 poultry producers had participated in these educational sessions and were issued certificates of NMP training. In addition, the Georgia Poultry Federation secured state funding to offset the cost of litter analysis needed for completion of an NMP. As a result of these programs, more than 4,000 litter samples were submitted to the University of Georgia Services Lab for analysis between the fall of 1999 and the end of 2002. Estimates are that these samples represented more than 75 percent of the poultry farms in Georgia and likely represent a higher percentage of the farms applying litter. Because of the voluntary nature of this program, we do not know exactly how many farms have fully completed the voluntary NMP program. Informal surveys, however, suggest that a high percentage of Georgia growers are complying with the voluntary approach.
These voluntary programs have provided uni-form manure management practices across Georgia and have been very instrumental in keeping state mandated programs to a minimum. Because of the awareness of the need to protect the environment, NMPs will continue to be very important in the future. Growers are encouraged to continue their participation in the voluntary program even though they may not be required to do so by the state.
Animal (Non-Swine) Feeding Operations Program
In June, 2001, the Department of Natural Resources Board approved the Georgia Environmental Protection Division's Animal (Non-Swine) Feeding Operators Rule 391-3-6. This rule requires poultry producers with liquid manure handling systems or continuous overflow watering systems to be permitted. The permits required under this rule are the Land Application System (LAS) and the National Pollutant Discharge Elimination System (NPDES) permits. To obtain these permits, producers must complete a comprehensive nutrient management plan and certified operator training.
Poultry Operations Requiring LAS Permitting. The LAS permit is required for poultry operators in the following categories:
9,000 laying hens or broilers with liquid manure handling systems.
30,000 laying hens or broilers if the facility has continuous overflow watering system.
16,000 turkeys.
1,500 ducks
Poultry Operations Requiring NPDES Permitting. The NPDES permit is required for poultry operators in the following categories:
30,000 laying hens or broilers with liquid manure handling systems.
100,000 laying hens or broilers with continuous overflow watering systems.
55,000 turkeys.
5,000 ducks.
With the passage of EPD's Animal (Non-Swine) Feeding Operations rule, the Georgia Department of Agriculture adopted their Animal Feeding Operators Training and Certification Rule 40-16-5 in June of 2001. The rule provides for certification training required to meet the Georgia Environmental Protection Division's AFO/CAFO permitting rule. Training requires 1½ days of classroom instruction followed by a written examination. A minimum score of 70 percent on the exam is necessary for certification. In addition, the rule requires 4 hours of continuing education every 2 years.
By definition, Georgia's Animal (Non-Swine) Feeding Operations Rule exempts dry manure poultry operations from the mandatory program. This exemption, however, will change for some dry manure poultry operators in the near future.
EPA's New CAFO Regulations
In 2001, Georgia's EPD did not include dry manure poultry operations in their AFO rule. This was partly a result of the implementation of the voluntary program and partly due to the fact that the U.S. Environmental Protection Agency (EPA) was expected to release a new version of their CAFO rule in 2002 that would address dry manure operations. In December of 2002, EPA unveiled to the states their "new" CAFO rule, which simplified and clarified the existing rule. This new rule includes some dry manure poultry operations and will require some amendments to the current Georgia rules. States must adopt rules that are at least equal to the federal rules. States do, however, have the option of adopting rules that are more stringent than the federal rules if necessary for protection of the environment. Georgia will be considering amendments of its AFO/ CAFO rules in 2003.
New Requirements for Poultry. Several of the components of EPA's new CAFO rules have implications for poultry producers.
Large poultry operations will be required to have NPDES permits regardless of the type of manure handled. Large poultry operations are defined as operations with:
125,000 or more broilers
82,000 or more laying hens
55,000 or more turkeys
NMPs will be required to include phosphorous risk assessments.
Setbacks of 100 feet from surface water and wells required for application of manures unless a 35-foot vegetative buffer is used.
Large CAFOs will be required to keep records of manure transfers.
Large CAFOs will be required to report annually to the permitting authority.
What Is Not Required. EPA dropped a number of proposed requirements from their final rule. Some of the more significant requirements dropped are:
No mandatory national co-permitting requirements.
No requirement that NMPs have to be prepared by a certified planner.
No NMP certification of manure recipients by sellers of poultry litter.
No requirements on when manure may be applied to frozen or saturated land.
No mandatory national ground water testing requirements.
Georgia's EPD must now consider the new EPA CAFO regulations and decide on what action needs to be taken in Georgia to comply with the new regulations. The state can either decide to go with the new regulations as finalized by EPA, or Georgia can decide to enact more stringent rules. Much of this decision may well depend on how effective and successful the voluntary program is perceived to be. It is imperative that Georgia poultry producers continue to develop and implement NMPs. The voluntary NMP program will serve as a solid basis of permitting for those individuals requiring the NPDES or LAS permits and, in addition, will provide continued assurance of environmentally sound programs for those poultry producers not subject to a state rule program.
Should you need assistance in developing an NMP or if you need more information on Georgia's poultry nutrient management plans, contact your local Cooperative Extension office or the departments of Poultry Science and Biological and Agricultural Engineering, the University of Georgia. Information on developing poultry NMPs can be found on the Department of Poultry Science web page
www.department.caes.uga.edu/poultry/
Information on regulated CNMPs is also available on the AWARE web page:
www.engr.uga.edu/service/aware
Bulletin 1226/March, 2003
The University of Georgia and Ft. Valley State University, the U.S. Department of Agriculture and counties of the state cooperating. The Cooperative Extension Service, the University of Georgia College of Agricultural and Environmental Sciences offers educational programs, assistance and materials to all people without regard to race, color, national origin, age, sex or disability.
An Equal Opportunity Employer/Affirmative Action Organization Committed to a Diverse Work Force
Issued in furtherance of Cooperative Extension work, Acts of May 8 and June 30, 1914, The University of Georgia College of Agricultural and Environmental Sciences and the U.S. Department of Agriculture cooperating.
Gale A. Buchanan, Dean and Director
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