Unified National
AFO Strategy
Executive U.S. Environmental
Protection Agency
Summary
Over the past quarter century, the United States has made tremendous
progress in cleaning up its rivers, lakes, and coastal waters. While pollution
from factories and sewage treatment plants has been dramatically reduced,
runoff from city streets, agricultural activities (including animal feeding
operations or AFOs), and other sources continues to degrade the environment
and puts drinking water at risk.
In February 1998, President Clinton released the Clean Water Action Plan
(CWAP), which provides a blueprint for restoring and protecting water
quality across the Nation. The CWAP identifies polluted runoff as the most
important remaining source of water pollution and provides for a coordinated
effort to reduce polluted runoff from a variety of sources. As part of this
effort, the CWAP calls for the U.S. Department of Agriculture (USDA) and
the U.S. Environmental Protection Agency (EPA) to develop a Unified
National Strategy to minimize the water quality and public health impacts of
animal feeding operations (AFOs).
USDA and EPA issued a draft of this Strategy on September 16, 1998, and
requested public comment during a 120-day period. In addition, 11 national
"listening sessions" were held throughout the U.S. to discuss the draft
Strategy and hear public feedback. The final Strategy reflects written
comments received as well as issues raised during the listening sessions.
The Unified AFO Strategy discusses the relationships between AFOs and
environmental and public health, is based on a national performance
expectation for all AFO owners and operators, and presents a series of
actions to minimize public health impacts and improve water quality while
complementing the long-term sustainability of livestock production.
Background
AFOs are agricultural enterprises where animals are kept and raised in
confined situations. Approximately 450,000 AFOs in the United States
congregate animals, feed, manure and urine, dead animals, and production
operations on a small land area. USDA data indicate that the vast majority of
farms with livestock are small — about 85 percent of these farms have fewer
than 250 animal units (AUs), where an AU is equal to roughly one beef cow
(therefore 1,000 AUs is equal to 1,000 beef cows or an equivalent number of
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other kinds of animals). About 6,600 AFOs had more than 1,000 AUs in
1992 and are considered to be large operations.
As a result of domestic and export market forces, technological changes, and
industry adaptations, the past several decades have seen substantial changes
in the animal production industry. Despite USDA support for sustainable
agricultural practices, these factors have promoted expansion of confined
production units, with growth in both existing areas and new areas;
integration and concentration of some of the industries; geographic
separation of animal production and feed production operations; and the
concentration of large quantities of manure and wastewater on farms and in
some watersheds.
AFOs can pose a number of risks to water quality and public health, mainly
because of the amount of animal manure and wastewater they generate.
Manure and wastewater from AFOs have the potential to contribute
pollutants such as nutrients (e.g., nitrogen, phosphorus), organic matter,
sediments, pathogens, heavy metals, hormones, antibiotics, and ammonia to
the environment. These pollutants can cause several types of water quality
and public health impacts, such as contamination of drinking water supplies
and fish kills. While there are other potential environmental impacts
associated with AFOs (e.g., odor, habitat loss, ground water depletion), this
Strategy focuses on addressing surface and ground water quality problems.
Once implemented, however, this Strategy will indirectly benefit other
resources.
USDA and EPA's National Performance Expectation
To minimize water quality and public health impacts from AFOs and land
application of animal waste, this Strategy is based on a national performance
expectation that all AFO owners and operators develop and implement
technically sound and economically feasible site-specific Comprehensive
Nutrient Management Plans (CNMPs). A CNMP identifies actions that will
be implemented to meet clearly-defined nutrient management goals at an
agricultural operation. The following components may be contained in a
CNMP:
• Feed Management - Animal diets and feed may be modified to reduce
the amounts of nutrients in manure.
• Manure Handling and Storage - Manure needs to be handled and
stored properly to prevent water pollution from AFOs.
• Land Application of Manure - Land application is the most common,
and usually most desirable method, of utilizing manure because of the
value of the nutrients and organic matter. Land application in
accordance with the CNMP should minimize water quality and public
health risk.
• Land Management - Tillage, crop residue management, grazing
management, and other conservation practices should be utilized to
minimize movement to surface and ground water of soil, organic
materials, nutrients, and pathogens from lands where manure is
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applied.
• Record Keeping - AFO operators should keep records that indicate
the quantity of manure produced and how the manure was utilized,
including where, when, and amount of nutrients applied.
• Other Utilization Options - Where the potential for environmentally
sound land application is limited, alternative uses of manure, such as
the sale of manure to other farmers, composting and sale of compost to
home owners, and using manure for power generation may also be
appropriate.
AFO owners and operators may seek technical assistance for the
development and implementation of CNMPs from qualified specialists.
These specialists should assist in implementation and provide ongoing
assistance through periodic reviews and revisions of CNMPs, as appropriate.
USDA and EPA recommend that certified specialists be used to develop and
ensure the quality of CNMPs.
Relationship of Voluntary and Regulatory Programs
Voluntary and regulatory programs serve complementary roles in providing
AFO owners and operators and the animal agricultural industry with the
assistance and certainty they need to achieve individual business and
personal goals, and in ensuring protection of water quality and public health.
Voluntary Program for Most AFOs
Voluntary programs provide an enormous opportunity to help AFO owners
and operators and communities address water quality and public health
concerns surrounding AFOs. For the vast majority of AFOs, voluntary
efforts will be the principal approach to assist owners and operators in
developing and implementing site-specific CNMPs, and in reducing water
pollution and public health risks associated with AFOs. While CNMPs are
not required for AFOs participating only in voluntary programs, they are
strongly encouraged as the best possible means of managing potential water
quality and public health impacts from these operations.
There are three types of voluntary programs to assist AFO owners and
operators. USDA and EPA are both committed to promoting locally led
conservation as one of the most effective ways to help AFO owners and
operators achieve their conservation goals. Environmental education can
bring an awareness of possible water quality problems and inform AFO
owners and operators about practices that will address such problems. A
variety of financial and technical assistance programs exist to provide AFO
owners and operators advice in developing CNMPs and implementing
solutions and to help
defray the costs of approved/needed structures (e.g., waste storage facilities
for small operations) or to implement other practices, such as installation of
conservation buffers to protect water quality.
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Regulatory Program for Some AFOs
Impacts from certain higher risk AFOs are addressed through National
Pollutant Discharge Elimination System (NPDES) permits under the
authority of the Clean Water Act. AFOs that meet certain specified criteria in
the NPDES regulations are referred to as concentrated animal feeding
operations or CAFOs.
NPDES permits will require CAFOs to develop CNMPs and to meet other
conditions that minimize the threat to water quality and public health and
otherwise ensure compliance with the requirements of the Clean Water Act.
NPDES permits will also ensure that the animal manure from CAFOs will be
utilized properly and require reporting on whether the permittee has a CNMP
including land application of animal manure and whether it is being
implemented properly. The Strategy identifies three categories of CAFOs
that are priorities for the regulatory program:
• Significant Manure Production - Large facilities (those with greater
than 1000 animal units) produce quantities of manure that can be a risk
to water quality and public health.
• Unacceptable Conditions - Facilities that have man-made
conveyances that discharge animal waste to waters or have a direct
discharge to waters that pass through the facility or come into direct
contact with animals represent a significant risk to water quality and
and public health.
• Significant Contributors to Water Quality Impairment - A facility
that is significantly contributing to impairment of a waterbody or a
watershed and nonattainment of a designated use is also a priority for
the NPDES permitting program.
The Strategy supplements these regulatory program priorities with three
types of incentives for some AFOs. Smaller CAFOs that meet certain
conditions may exit the regulatory program at the end of their permit term if
they correct the problem(s) that caused them to be covered by the regulatory
program. The Strategy also describes a "good faith incentive" for some AFOs
to avoid being covered by the regulatory program if they have and are
implementing a CNMP. Finally, there are tax incentives that may be
available to encourage AFOs owners and operators to develop and
implement a CNMP.
Coordination with State and Tribal Programs
States and Tribes play a critical role in the development and implementation
of national and State and Tribal resource protection programs. USDA and
EPA expect to work with States and Tribes to implement effective programs
to achieve the national goal and performance expectation of this Strategy.
The Strategy includes actions to address a range of State and Tribal issues.
Strategic Issues
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The Unified AFO Strategy addresses seven strategic issues. The discussion
of each strategic issue identifies several action items.
• Building Capacity for CNMP Development and Implementation -
The successful implementation of this Strategy depends on the
availability of qualified specialists from either the private or public
sectors to assist in the development and implementation of CNMPs.
The Strategy describes actions to substantially increase AFO owners
and operators' access to technical assistance for developing and
implementing CNMPs.
• Accelerating Voluntary, Incentive-Based Programs - The Strategy
sets out a desired outcome that all AFOs will have CNMPs by 2009.
Several actions, including review and revision of USDA's practice
standards, development of CNMP guidance, fair and equitable
program delivery, and options for financial assistance, are directed
toward achieving this objective.
• Implementing and Improving the Existing Regulatory Program -
The Strategy describes the applicability and the requirements of the
existing regulatory program, identifies permitting and enforcement
priorities, recognizes State and Tribal CAFO permit programs, and
describes EPA's plans to strengthen and improve existing regulations.
• Coordinated Research, Technical Innovation, Compliance
Assistance, and Technology Transfer - USDA and EPA will
establish coordinated research, technical innovation, and technology
transfer activities, provide compliance assistance, and establish a
single point information center. The two agencies are also committed
to promoting sustainable agriculture and will support development of a
livestock environmental issues curriculum for producers.
• Encouraging Industry Leadership - The animal agriculture industry
can play a key role in helping to encourage adoption of CNMPs and in
addressing water quality problems on individual AFOs. The Strategy
includes possible actions that USDA and EPA may take to promote
industry involvement.
• Data Coordination - Several kinds of data are useful in assessing and
managing the water quality impacts of AFOs. USDA and EPA's efforts
to coordinate on data sharing will both protect the relationship of trust
between USDA and farmers and provide regulatory authorities with
information that is useful in protecting water quality and public health.
• Performance Measures and Accountability - USDA and EPA
believe that it is critical to establish performance measures to gauge
our success in implementing the Strategy and meeting relevant goals in
each agency's strategic plan established under the Government
Performance and Results Act. USDA, EPA, States, Tribes, and other
Federal agencies will work with other stakeholders to develop an
approach for measuring the effectiveness of efforts to minimize the
water quality and public health impacts of AFOs.
Printed copies of the Unified National Strategy for Animal Feeding
Operations may be obtained by calling USDA on (202) 720-3210 or EPA on
(202) 260-7786. Click here to view the full AFO Strategy.
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