Little Antietam Creek
Watershed Assessment Report
February 2015
Prepared By:
United States Environmental Protection Agency, Region III
Water Protection Division
1650 Arch Street
Philadelphia, PA 19103
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Acknowledgement
A special thanks to the farmers for their time to participate in this project and their environmental
stewardship. We also thank Maryland Department of the Environment (MDE), the Maryland
Department of Agriculture (MDA), and the Washington County Soil and Conservation District
(WCSCD) for their participation.
Gary Kelman (MDE)
David Bramble (MDE)
Richard Stewart (MDE)
Dwight Dotterer (MDA)
Elmer Weibley (WCSCD)
Hans Kefauver (WCSCD)
This project was conducted by the United States Environmental Protection Agency,
Region Ill's (EPA) CAFO Team with technical support from EPA's contractor, Tetra Tech.
Mark Zolandz (EPA)
Ashley Toy (EPA)
Kyle Zieba (EPA)
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Table of Contents
I. Executive Summary
II. Background
a. Purpose of AFO Watershed Assessments
b. Watershed and AFO Selection Process
III. Antietam Creek and Little Antietam Creek Watersheds
IV. Collaboration with State and Local Partners
V. Findings
a. Maryland's AFO General Permit Program
b. Maryland's Nutrient Management Program
c. Antietam Creek Watershed Restoration Plan
i. Background
ii. Observations
VI. Conclusions
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List of Abbreviations
AFO
Animal Feeding Operation
BMP
Best Management Practices
CAFO
Concentrated Animal Feeding Operation
CNMP
Comprehensive Nutrient Management Plan
EPA
United States Environmental Protection Agency, Region III
MAFO
Maryland Animal Feeding Operation
MDE
Maryland Department of the Environment
NMP
Nutrient Management Plan
NPDES
National Pollutant Discharge Elimination System
TMDL
Total Maximum Daily Loading
SCD
Soil Conservation District
SCWQP
Soil Conservation and Water Quality Plan
WCSCD
Washington County Soil Conservation District
WIP
Watershed Implementation Plan
WRP
Watershed Restoration Plan
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I. Executive Summary
The United States Environmental Protection Agency, Region III (EPA) visited four farms in the
Little Antietam Creek Watershed in an effort to assess how effective the state's agricultural
programs are in protecting local waterways from runoff from animal feeding operations (AFOs).
This watershed-based AFO assessment looked at 1) on the ground effectiveness of and
compliance with state or federal requirements for reducing nitrogen, phosphorus, and sediment,
and 2) the implementation of various best management practices (BMPs) relevant to improving
water quality at the farm level. Antietam Creek and its tributaries, such as Little Antietam
Creek, have been identified as impaired and not meeting water quality standards set by Maryland
for sediments, dissolved oxygen, nutrients (phosphorus), and fecal coliform. EPA has approved
a Total Maximum Daily Load (TMDL) for each of these pollutants. Antietam Creek is in the
Potomac River Basin which drains to the Chesapeake Bay.
Protection of local waterways depends on local farmers implementing BMPs, whether required
or voluntary. Maryland has two regulatory programs that impact animal feeding operations, the
General Permit for Animal Feeding Operations and the Nutrient Management Program. The
BMPs selected for evaluation in this assessment are required under one or both of these state
programs. Another program that is relevant to animal feeding operations is Maryland's
voluntary Soil Conservation and Water Quality Plan program which assists farmers with
controlling erosion and sediment loss and managing runoff from agricultural lands. Maryland
also has various programs to provide technical and financial assistance to farmers to enhance
environmental stewardship, such as the Maryland Agricultural Water Quality Cost-Share
Program and the Maryland Nonpoint Source Program. These programs, along with others, are
vital to the success of protecting and restoring local waterways and ultimately the Chesapeake
Bay.
EPA pursued a watershed-based approach in order to assess multiple AFOs where many
Maryland programs intersect to drive and support BMP implementation on farms in a watershed
in need of restoration. This allowed EPA to evaluate how the state programs, tools and resources
translate to implementation of on-the-ground practices to protect water quality. Water quality
improvements are not solely the result of state actions, but they rely on the individual farmers
who ultimately make the decisions on a day-to-day basis to implement these practices, even
without technical and financial assistance.
Based on the watershed assessment, EPA found that Maryland's animal agricultural programs
are fairly comprehensive and address most environmental resource concerns on dairy farms. The
farms in the assessment were small AFOs not covered under Maryland's General Discharge
Permit for AFOs General permit. Therefore, Maryland is relying upon its Nutrient Management
Program to address water quality concerns for these operations. Maryland can address a wide
range of issues through the NMP; however, the NMP does not appear to address feed storage
areas. Additionally, the Washington County Soil Conservation District has a watershed
restoration plan in place to address the environmental resource concerns causing impairment to
the local streams by developing Soil Conservation and Water Quality Plans (SCWQPs) and
funding best management practices (BMPs) through financial assistance of the Maryland
Agricultural Water Quality Cost-Share Program and other funding sources.
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General observations made during the assessments include the following:
• Maryland's Nutrient Management Program is fairly comprehensive and addresses
most environmental resource concerns on dairy farms.
• All four farms were regulated under Maryland's Nutrient Management Program, and
all four farms were generally in compliance with Maryland's Nutrient Management
Program requirements.
• Overall, the farms were implementing agricultural conservation practices that are
effective at reducing nutrient and sediment pollution to surface waters such as animal
waste management systems, nutrient management plans, cover crops, and varying
degrees of conservation tillage and barnyard runoff controls.
• Although the farms had many agricultural conservation practices in place, each farm
had areas that could be improved upon such as:
o Ensuring NMPs include generation and land application rates for all manure
sources.
o Addressing feed storage areas and potential silage leachate runoff to surface
waters.
The assessments were conducted prior to or just after several new nutrient management
requirements went into effect in January 2014. Some of the farms assessed were already in
compliance with the new nutrient management regulations, while other farms needed to take
steps to meet the new regulatory requirements. It will be important for Maryland to continue to
take steps to implement an effective education and outreach strategy to ensure compliance with
the new regulations pertaining to nutrient application setbacks and animal exclusion from
streams.
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II. Background
This watershed assessment is part of the U.S. Environmental Protection Agency's (EPA's)
broader activities working with states to strengthen their animal agricultural programs to improve
local water quality, and ultimately the restoration and protection efforts of the Chesapeake Bay.
EPA has oversight of the National Pollutant Elimination Discharge System (NPDES) Program
which regulates concentrated animal feeding operations (CAFOs). EPA also has oversight of the
Chesapeake Bay Total Maximum Daily Load (TMDL) which addresses impairments due to
excess nitrogen, phosphorus and sediment. The TMDL is supported by state Watershed
Implementation Plans (WIPs) that set forth the pollution control measures needed to fully restore
the Bay and its tidal rivers for various sectors including agriculture.
Maryland's Phase I and Phase II WIPs promote implementation of both regulatory and voluntary
programs that implement a broad suite of agricultural conservation practices to reduce nutrient
and sediment loads from agricultural cropland and animal production operations. Key practices
include animal waste storage facilities, barnyard runoff controls, cover crops, nutrient
management, land retirement, manure incorporation, and soil conservation and water quality
plans.
CAFOs are a subset of animal feeding operations (AFOs). Both AFOs and CAFOs fall within
the agricultural sector. The agricultural sector also encompasses pastures, cropland, and
nurseries. According to the Chesapeake Bay Program Partnership Watershed Model 2013
Progress scenario, agricultural lands account for 22 percent of the watershed, making agriculture
one of the largest land uses in the area, second only to forested and open wooded areas (64
percent). The Bay watershed has more than 87,000 farm operations and 6.7 million acres of
cropland. Agriculture is the largest single source of nitrogen, phosphorus, and sediment loading
to the Bay through applying fertilizers, tilling croplands, and applying animal manure.
Agricultural activities are responsible for approximately 44 percent of nitrogen loads delivered to
the Bay and about 58 percent of phosphorus and sediment loads delivered to the Bay
(Chesapeake Bay Program Watershed Model 2013 Progress scenario).
Of the agricultural nutrient and sediment loadings to the Bay from all Jurisdictions, Maryland's
agricultural sector accounts for 16% of the total nitrogen, 16% of the total phosphorus, and 13%
of the total sediment delivered to the Bay (Chesapeake Bay Program Watershed Model 2013
Progress scenario). Amongst all the Jurisdiction's agricultural sectors, Maryland's agricultural
sector ranks third in nutrient and sediment loadings to the Bay, following Pennsylvania and
Virginia. Agriculture is the largest sector in Maryland of nitrogen, phosphorus and sediment
loading to the Bay.
EPA has authority to oversee and evaluate state NPDES permit programs to ensure compliance
with the Clean Water Act, including whether CAFO regulations are implemented appropriately
in the state. That evaluation may include assessments of animal agriculture operations to see
whether those facilities may meet the federal regulatory thresholds to qualify as CAFOs. In
addition, EPA has authority to determine if AFO operations should be designated as CAFOs due
to their impact on receiving waters. These AFO reviews are part of EPA's ongoing regulatory
oversight activities to ensure compliance with the Clean Water Act and to assess the
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effectiveness of state programs in addressing agricultural impacts upon receiving waters.
Consistent with those regulatory oversight activities, in a May 29, 2013 modification to the EPA-
CBF Settlement Agreement, EPA agreed to undertake AFO reviews in four sub-watersheds
throughout the Chesapeake Bay basin over the next four years, starting in 2013. The Little
Antietam Creek watershed is the first of these four subwatershed assessments. This
subwatershed assessment is also being conducted as part of EPA's oversight responsibilities
under the Chesapeake Bay TMDL to oversee Maryland's progress towards achieving its animal
agriculture WIP commitments to reduce nitrogen, phosphorus, and sediment consistent with the
Chesapeake Bay TMDL allocations.
a. Purpose of AFO Watershed Assessments
The purpose of the AFO watershed assessment is to assess compliance of farms with applicable
legal requirements for reducing nitrogen, phosphorus, and sediment; document the
implementation of agricultural conservation practices by farmers; assess the effectiveness of
state programs in addressing water quality impacts; and get a better sense of how well the
Maryland Department of the Environment (MDE) and the Maryland Department of Agriculture
(MDA) are providing oversight and outreach to these farms. The farm visits provided EPA with
insight into what types of programs Maryland is implementing and how informed farmers are of
the regulatory requirements. Maryland's animal agricultural programs include, but are not
limited to, the Nutrient Management Program, Soil Conservation and Water Quality Plan
(SCWQP) Program, and the AFO General Permit Program. The effective implementation of
these programs is the main focus for this assessment.
CAFOs are regulated by MDE and are also subject to the Nutrient Management Program that is
administered by the MDA. An AFO with 700 or more mature dairy cows or 1,000 or more cattle
(including heifers) is considered a Large CAFO and needs an NPDES CAFO permit if it
discharges manure, litter, or process wastewater. An AFO with 200-699 mature dairy cows or
300-999 cattle (including heifers) is considered a Medium CAFO and needs a CAFO permit if it
discharges through a man-made device such as a ditch, swale, or pipe or confined animals have
access to surface waters. Under an NPDES CAFO permit, an AFO is required to develop and
implement either a comprehensive nutrient management plan (CNMP) or a combination of a
nutrient management plan (NMP) and a soil conservation and water quality plan (SCWQP), as
well as submit a Nutrient Management Annual Implementation Report (AIR) to MDE each year.
Maryland animal agricultural operations that meet the animal threshold of the CAFO program,
but do not meet the discharge requirements are regulated as Maryland Animal Feeding
Operations (MAFOs). Under a MAFO permit, an AFO is required to develop and implement an
NMP and a conservation plan and submit a Nutrient Management Annual Implementation
Report (AIR) to MDE each year.
Maryland regulations also require all farmers grossing $2,500 a year or more or livestock
producers with 8,000 pounds or more of live animal weight to develop and implement an NMP.
The NMP must be developed by an MDA-certified consultant or farmer and specifies how much
manure and other fertilizer can be safely applied to crops. Maryland revised its nutrient
management regulations in October 2012, and certain stream protection practices became
effective in January 2014. They include requirements such as setbacks for nutrient application
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and livestock exclusion measures. A summary of the new nutrient management regulations and
timeframes for implementation are listed in Appendix A.
Maryland's SCWQP Program is a voluntary program to assist farmers with controlling soil
erosion from agricultural lands. At the request of a farmer, a Soil Conservation District, MDA,
or USDA professional works with the farmer to develop a SCWQP. An SCWQP is "a
comprehensive plan that addresses natural resource management on agricultural lands and
utilizes BMPs that control erosion and sediment loss and manage runoff"1 The BMPs include,
but are not limited to: crop rotations, tillage practices, cover crops, grass waterways, terraces,
diversions, sediment basins, drop structures, and other grade stabilization structures.
Conservation practices such as forestry management, wildlife habitat and planting, and ponds
construction and management may also be included. Furthermore, the Nutrient Management
Program allows farmers to meet their regulatory requirements for both livestock exclusion, and
incorporation and/or injection requirements through alternative practices that are identified in an
SCWQP.
Maryland's Nonpoint Source Program uses funding from EPA's Clean Water Act Section 319(h)
Grant Program to support the state nonpoint source management program and provide grants for
state and local projects that help eliminate water quality impairments caused by nonpoint
sources, including agricultural sources. A prerequisite for §319(h) funding of implementation
projects (i.e. any project involving on-the-ground construction) is EPA's acceptance of a
watershed restoration plan.2 Maryland's WIP summarizes other programs available to Maryland
farmers that provide financial assistance for BMPs implementation and manure transport.
Whether a farmer is participating in one of these additional programs was not considered as part
of this assessment. However, these programs may be able to provide financial resources to
address water quality concerns that were found as part of this assessment. State programs
include: Maryland Agricultural Water Quality Cost-Share (MACS) Program, Cover Crop
Program, Manure Transport Program (MTP), and Low Interest Loans for Agricultural
Conservation (LILAC) Program. The MACS and MTP programs include reviews to ensure
BMPs are implemented. Examples of federal programs administered through USDA include:
Environmental Quality Incentives Program (EQIP), Conservation Reserve Program (CRP) and
Conservation Reserve Enhancement Program (CREP), Conservation Stewardship Program
(CSP), and the Wetland Reserve Program (WRP).
b. Watershed and AFO Selection Process
In the Chesapeake Bay watershed, there are several geographic areas that have large numbers of
livestock operations. EPA decided to focus primarily on dairies and cattle for the four AFO
subwatershed assessments. Dairies and cattle were selected since most dairy and cattle
operations in the Chesapeake Bay watershed are not subject to permitting under the federal
NPDES CAFO program due to size and design. The geographic areas with the largest numbers
1 http://mda.marvland.gov/resource conservation/pages/scwqpi.aspx
2
http://www. mde. state. md.us/programs/Water/319NonPointSource/Pages/Programs/WaterPrograms/319nps/fac
tsheet.aspx
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of dairy cattle are southern New York, south-central Pennsylvania, western Maryland, and the
Shenandoah Valley.
In 2013, EPA chose to conduct the AFO watershed review in western Maryland. In Maryland,
the counties with the largest numbers of dairy cows are Frederick County (104 farms and 15,726
milk cows) and Washington County (143 farms and 12,672 milk cows) (USDA 2012 Ag
Census). Together, these two counties account for approximately 43% of the dairy farms and
approximately 56% of the dairy cows in Maryland (USDA 2012 Ag Census). Therefore, EPA
decided to select a watershed in one of these two counties.
EPA identified all 12-digit HUC watersheds in Washington County and Frederick County.
Starting with this list of 58 watersheds, EPA identified those watersheds that had at least 4
AFOs, whose surface waters were identified as impaired on Maryland's 303(d) list with a TMDL
developed, with a headwater stream, and located entirely in Maryland. These criteria narrowed
the list of potential watersheds to nine. Of those nine watersheds, EPA identified those
watersheds whose surface waters were impaired for sediment, fecal bacteria, and nutrients and
were listed as a "priority agriculture watersheds" by USDA for funding through the Chesapeake
Bay Watershed Initiative.
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J -A. J U—/L irJCAJ T •/. .1 V. / I V .A/V JJ ^
Figure 1: Milk cow inventories, 2012 (1 dot = 2,000 cows). Source: USDA2012 Ag Census
Little Antietam Creek was chosen for the assessment due to having a number of AFOs located
close to surface waters with the potential for having a water quality-related impact. All of the
AFOs in the watershed appeared to be dairy, heifer, or cattle operations; no poultry or swine
farms were identified in the watershed. EPA selected individual AFOs to assess that were
located near streams or other surface waters. EPA focused on these AFOs because, due to their
location, they may have a larger impact on water quality than farms farther away.
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III.
Antietam Creek and Little Antietam Creek Watersheds
The Antietam Creek Watershed includes several subwatersheds, including Little Antietam Creek,
Beaver Creek, and Marsh Run. The Antietam Creek watershed covers approximately 290 square
miles, and Antietam Creek itself is approximately 54 miles in length. Antietam Creek starts in
Franklin County and Adams County, Pennsylvania and flows south into Washington County,
Maryland. The Antietam Creek watershed includes approximately 105 square miles in
Pennsylvania and 185 square miles in Maryland. Antietam Creek eventually empties into the
Potomac River along the Maryland-Virginia border. Approximately 42% of the Antietam Creek
watershed is in agriculture consisting of cropland, pasture, animal feeding operations, hay, high
till and low till farming, and nurseries, with the primary animal based agricultural enterprise
being dairies.3
Antietam Creek and its tributaries have been identified as impaired and not meeting water quality
standards set by Maryland. The Antietam Creek watershed was listed on Maryland's 1996
303(d) list as impaired for sediments, dissolved oxygen, and nutrients. EPA approved a TMDL
for biological oxygen demand (BOD) on August 23, 2002, a TMDL for sediment on December
18, 2008, and a TMDL for nutrients (phosphorus) on September 25, 2013. The Antietam Creek
Watershed was also listed on Maryland's 2002 303(d) list as impaired for fecal coliform bacteria,
and EPA approved a TMDL for fecal bacteria on October 8, 2009.
The Little Antietam Creek Watershed (HUC-12 Code: 020700041004) is located entirely in
Maryland east of Hagerstown, Maryland in northeast Washington County, Maryland along its
border with Frederick County, Maryland. Little Antietam Creek is approximately 10 miles long,
with the Little Antietam Creek Watershed covering approximately 25 square miles. Little
Antietam Creek has one named tributary, Grove Creek, and several unnamed tributaries. Little
Antietam Creek and its tributaries generally flow from east to west, starting in the mountains in
South Mountain State Park and flowing west toward Antietam Creek.
Land use in the Little Antietam Creek Watershed is dominated by agriculture and forests (see
Table 1). Approximately 57.5% of land in the watershed is involved in agriculture, including
9.8% of land in orchards. Approximately 39.2% of the watershed remains in forest, with the
majority located in the South Mountain State Park located in the eastern part of the watershed.
The Appalachian Trail passes through South Mountain State Park and the Little Antietam Creek
Watershed. Only 3.0%> of land area is urban, mostly in the southern part of the watershed near
Smithsburg, Maryland.
http://www. mde. state. md.us/programs/Water/319NonPointSource/Documents/Watershed%20Plans/Antietam%
20Creek%20Plan/AntietamCreek 9.17.12 No AppendicesfMDE1.pdf
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Table 1: Land use in the Little Antietam Creek watershec
Land Use (Type)
Land Use (Percent)
Cropland
41.6%
Pasture
6.1%
Orchard
9.8%
Forest/Recreation
39.2%
Urban
3.0%
Industrial/Other
0.3%
With 319h funds, the Washington County Soil Conservation District developed a watershed plan
entitled "Antietam Creek Watershed Restoration Plan" (the "Plan") dated September 17, 2012.
The Plan addresses reductions needed to meet the local sediment and fecal bacteria TMDLs. The
Plan does not address reductions needed to meet the local phosphorus TMDL that was developed
for the Antietam Creek watershed and approved by EPA on September 25, 2013. Watersheds
identified in the Plan to be given priority for sediment and fecal bacteria reductions include the
subwatershed Antietam Creek at Marsh Run (ANT0277) which encompasses Little Antietam
Creek Watershed near Smithsburg, Maryland. In addition to providing funding for development
of the Plan, EPA assisted in funding technical staff to provide design and installation assistance
for implementation of non-point source projects, including agricultural conservation practices,
throughout the entire Antietam Creek Watershed (see Appendix B). In total, approximately
$855,000 in 319h funds was committed to the Antietam Creek watershed to support technical
agricultural staff between 2003 and 2013. The Washington County Conservation District
continues to fund and implement projects to improve water quality in the Little Antietam Creek
Watershed.
4 http://www.epa.gov/reg3wapd/pdf/pdf nps/success/md/antietamcreek.pdf
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IV.
Collaboration with State and Local Partners
Both MDE and MDA provided valuable support for EPA's watershed assessment. MDE and
MDA helped coordinate the farm visits and provided guidance while at each farm about how
Maryland's state requirements apply to that particular farm. MDE and MDA also provided
compliance assistance to the farmers while on site about things that the farmers could do to help
improve their operations.
In addition to MDE and MDA, the Washington County Soil Conservation District also assisted
EPA during the farm visits, given its familiarity and relationships with the local farms and
farmers throughout Washington County, Maryland.
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V. Findings
For this AFO assessment, EPA collected information from on-site visits to four AFO farms
within Little Antietam Creek Watershed and public documents pertaining to the impairment and
restoration plans inclusive of the Little Antietam Creek Watershed.
Between December 13, 2013 and January 9, 2014, EPA visited four dairy farms in the Little
Antietam Creek Watershed. The farm visits were scheduled with the owners in advance. A
check list was utilized to ensure that similar information was collected at each of the farms. This
information was used to determine whether farms were in compliance with applicable legal
requirements related to nitrogen, phosphorus, and sediment. A sample AFO farm visit checklist
is included in Appendix C.
The following are the major findings from this assessment:
Finding #1: All four farms were regulated under Maryland's Nutrient Management Program
Finding #2: All four farms were found to be meeting many of Maryland's Nutrient
Management Program requirements, including some of the newer requirements of
Maryland's Manure Management Manual that went into effect in January 2014.
Finding #3: The Nutrient Management Program appears to be comprehensive in addressing
the areas of an operation where manure is generated, stored and land-applied, but does not
appear to address feed storage areas which can be a potential water quality concern.
Finding #4: The Washington County Soil Conservation District's implementation of the
watershed restoration plan is helping to provide funding and assistance to farmers to
implement key agricultural conservation practices that will help address water quality
concerns.
Finding #5: Nutrient Management Plans and Soil Conservation and Water Quality Plans are
good planning tools provided they are periodically updated. State and local coordination is
important to ensure quality plans, maximize limited resources, and effectively work with
farmers to implement agricultural conservation practices.
The following is a more detailed description of how well the AFOs complied with Maryland
programs.
a. Maryland's AFO General Permit program
Requirement: Maryland regulations require that all large and medium AFOs that discharge or
propose to discharge to waters of the State must be covered as CAFOs under Maryland's General
Discharge Permit for AFOs, and all large AFOs that do not discharge or propose to discharge to
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waters of the State must be covered as MAFOs under Maryland's General Discharge Permit for
AFOs.5 Large AFOs include farms with 700 or greater dairy cattle or 1,000 or more cattle
including heifers. Medium AFOs include farms with between 200 and 699 dairy cattle or
between 300 and 999 cattle including heifers. Under certain circumstances, a small AFO may be
designated a CAFO by MDE or EPA and be required to obtain coverage under Maryland's
General Discharge Permit for AFOs.
Observation: All four farms were small AFOs that were not large enough to require coverage
as either a CAFO or a MAFO under Maryland's General Discharge Permit for AFOs. The
number of dairy cattle at each farm ranged from 133 to 160 head, with an average of 140 mature
dairy cows. The number of cattle including heifers at each farm ranged from 111 to 170 head,
with an average of 140 cows (other than mature dairy cows). Average total herd size at each of
the four farms was 280 head. Neither EPA nor MDE has designated any small AFOs as CAFOs
in Maryland.
b. Maryland's Nutrient Management Program
Requirement: As of 2001, Maryland's Nutrient Management Law requires all farmers grossing
$2,500 a year or more or livestock producers with 8,000 pounds or more of live animal weight to
follow an NMP when fertilizing crops and managing animal manure [Md. Code Ann., Agric. §8-
803.1; COMAR 15.20.07.03(B)(2) and 15.20.07.04],
Observation: All four farms had 8,000 pounds or more of live animal weight and thus are
regulated under Maryland's Nutrient Management Program.
Requirement: As of 2001, Maryland's Nutrient Management Law requires all farmers using
chemical fertilizer or animal manure to have and comply with an NMP for nitrogen and
phosphorus [Md. Code Ann., Agric. §8-803.1(e) and §8-803.1(f); COMAR 15.20.07.04(A)],
Observation: All four farms had current NMPs at the time of the farm visit. All four NMPs
were written after October 15, 2012, meaning the NMPs were to have been developed and
implemented in accordance with the May 2012 revised requirements outlined in Maryland's
Nutrient Management Manual.
Requirement: As of 2001, Maryland's Nutrient Management Manual requires that all materials
that provide crop nutrients (including chemical fertilizer and organic materials such as animal
manure) shall be included in, and managed by, an NMP [COMAR 15.20.07.02; Nutrient
Management Manual Section 1(D)(1)(C)],
Observation: One farm's NMP did not identify fields and application rates for land application
of bed pack manure that was generated and being land-applied at the farm.
5 COMAR 26.08.04.09N
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Requirement: As of October 2012, Maryland's Nutrient Management Manual requires that
organic nutrient sources (such as animal manure) shall be injected or incorporated as soon as
possible but no later than 48 hours after application [COMAR 15.20.07.02; Nutrient
Management Manual Section 1(D)(III)(B)(2) and Section l(D)(III)(C)(3)(b)(i)]. This
requirement does not apply to pastures, hay fields, and highly erodible lands (HELs) [COMAR
15.20.07.02; Nutrient Management Manual Section 1(D)(III)(B)(3) and Section
1 (D)(IH)(C)(3)(b)(ii)].
Observation: All four farms incorporate manure to some extent. Two farms appear to meet this
requirement appropriately on their fields. A third farm does not normally incorporate manure
but did incorporate manure in fall 2013. A fourth farm incorporates manure on some fields,
although incorporation may not occur within 48 hours after application. This farmer said he was
waiting on the state for clarification about which of his fields were considered "highly erodible
lands" (HELs) and exempt from this requirement. The farmer also expressed concern that some
fields which may not be HELs because they are flat may not be suitable for injection or
incorporation due to heavy concentrated flow from upland areas. While all farms were using
injection or incorporation to some extent, compliance with the requirement is dependent on field-
specific conditions that were beyond the scope of EPA's review, such as HELs or fields where a
current SCWQP prohibits or restricts soil disturbance.
Requirement: As of October 2012, Maryland's Nutrient Management Manual requires that a
person applying organic nutrient sources (such as animal manure) in the fall to fallow cropland
shall plant a cover crop as soon as possible after application, but no later than November 15
[COMAR 15.20.07.02; Nutrient Management Manual Section l(D)(III)(C)(3)(b)(iv)].
Observation: The four farms planted cover crops on 35% to 100% of crop acreage. EPA was
unable to determine how soon cover crops were planted after fall application of manure.
Requirement: As of October 2012, Maryland's Nutrient Management Manual requires that
applications required in emergency situations such as imminent overflow of a storage facility
shall be managed in consultation with MDA [COMAR 15.20.07.02; Nutrient Management
Manual Section 1(D)(III)(C)(4) and Section l(D)(III)(D)(3)(e)(vi)].
Observation: One farm had an overflow from the liquid manure storage structure in fall 2013.
The farmer immediately called his hauler to pump out some manure and land apply it in order to
lower the manure level. It is unclear whether or not the farmer contacted MDA in this situation.
Requirement: As of 2012, Maryland's Nutrient Management Manual prohibits winter
application of a chemical fertilizer to cropland [COMAR 15.20.07.02; Nutrient Management
Manual Section 1(D)(III)(D)(2)].
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Observation: None of the farms applied chemical fertilizer to cropland in winter.
Requirement: As of October 2012, Maryland's Nutrient Management Manual allows winter
application of organic nutrient sources (such as animal manure) to cropland only if the operation
has inadequate storage and the storage capacity will be exceeded before March 1, the nutrient
source is non-stackable (i.e. moisture content over 60%), and there is no other reasonable option
to manage it [COMAR 15.20.07.02; Nutrient Management Manual Section l(D)(III)(D)(3)(a)].
Maryland's Nutrient Management Manual prohibits winter application of animal manure if the
manure is stackable or adequate storage is available [COMAR 15.20.07.02; Nutrient
Management Manual Section l(D)(III)(D)(3)(e)(i)].
Observation: Three of the four farms do not apply animal manure to cropland in winter. At one
of these farms, the liquid manure storage system seemed to have insufficient capacity to make it
through the winter season without land applying manure. This farm had not previously land
applied manure in the winter, but experienced an overflow last fall. Because this is liquid
manure, winter application due to inadequate storage would appear to be allowable under
Maryland's Nutrient Management Manual requirements. The fourth farm has land-applied bed
pack manure in winter in the past due to inadequate storage capacity. If the moisture content of
the bed pack manure is less than 60%, this farm would not be meeting the Maryland's Nutrient
Management Manual requirements described above, which prohibit winter application of
stackable manure.
Requirement: As of January 1, 2014, Maryland's Nutrient Management Manual requires 10-
foot nutrient application setback from surface waters for pastures and 35-foot nutrient application
setback from surface waters for sacrifice lots [COMAR 15.20.07.02; Nutrient Management
Manual Section 1(D)(II)(B)]. Livestock must be excluded from the setback to prevent direct
deposition of nutrients within the setback, or alternatively, a farmer can work with the soil
conservation district and develop and implement a SCWQP that includes BMPs such as stream
crossings, alternative watering facilities, or pasture management that are equally protective of
water quality and stream health [COMAR 15.20.07.02; Nutrient Management Manual Section
1(D)(H)(B)].
Observation: One farm did not have any surface waters present. The second farm already had
stream fencing and vegetated buffers in place to exclude animals from the stream. Two-thirds of
the stream had a vegetated buffer ranging from -20 feet to -200 feet, while the remaining one-
third of the stream had a vegetated buffer ranging from -5 feet to -90 feet. The buffer may need
to be increased in a few locations in order to meet the new setback requirement. The third farm
did not plan to use the lot where surface waters were present until a fence was installed, with
installation planned for spring 2014 per the farm's conservation plan. The fourth farm was not
allowing animals in the lot with surface waters present at the time of the inspection and was
considering their options to meet the new regulatory requirements. These last two farms needed
to develop and implement practices to meet the animal exclusion requirement that became
effective on January 1, 2014 in order to use these lots for livestock.
18
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Requirement: As of January 1, 2014, Maryland's Nutrient Management Manual requires 35-
foot nutrient application setbacks for application of crop nutrients using broadcast methods and
10-foor nutrient application setbacks for application of crop nutrients using directed spray
application or injection [COMAR 15.20.07.02; Nutrient Management Manual Section
1(D)(H)(B)].
Observation: All four farms land apply both commercial fertilizer and animal manure, and all
four farms appeared to be meeting this requirement already.
Requirement: As of January 1, 2014, Maryland's Nutrient Management Manual requires that
farmers move livestock from one side of the stream to the other only through stream crossings
designed to prevent erosion and sediment loss [COMAR 15.20.07.02; Nutrient Management
Manual Section 1(D)(II)(C)]. Maryland's Nutrient Management Manual requires that farmers
shall gate crossing areas wider than 12 feet [COMAR 15.20.07.02; Nutrient Management
Manual Section 1(D)(II)(C)].
Observation: One farm did not have any surface waters present. A second farm had surface
waters present but did not move livestock from one side of the stream to the other. The two
remaining farms were being temporarily managed in a manner that excluded animals from the
streams while the farmers were planning improvements. The improvements that are selected and
implemented will need to meet both the new setback requirements as well as the stream crossing
requirements.
Requirement: As of July 1, 2016, Maryland's Nutrient Management Manual prohibits all winter
application from all farms except for dairy or livestock operations with less than 50 animal units
[COMAR 15.20.07.02; Nutrient Management Manual Section l(D)(III)(E)(2)(a)]. Effective
February 28, 2020, Maryland's Nutrient Management Manual prohibits all winter application
from all farms, including dairy or livestock operations with less than 50 animal units [COMAR
15.20.07.02; Nutrient Management Manual Section l(D)(III)(E)(2)(b)]. Maryland's Nutrient
Management Manual requires farms to make plans for adequate storage to eliminate the need for
a winter application before the deadlines described above [COMAR 15.20.07.02; Nutrient
Management Manual Section l(D)(III)(D)(3)(d)].
Observation: Two farms may need to make management adjustments or upgrade storage
capacity to comply with these new requirements. One farm has land applied bed pack manure in
winter in the past due to inadequate storage capacity. At another farm, the liquid manure storage
system seemed to have insufficient capacity to make it through the winter season without
drawing down manure for land application. This farm had not previously land applied manure in
the winter, but experienced an overflow last fall.
Requirement: Maryland's Nutrient Management Manual does not appear to have requirements
applicable to feed storage areas.
19
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Observation: All four farms had some portion of their feed storage that was exposed to
precipitation, including one farm that piped silage leachate to an exercise lot adjacent to surface
waters.
Note: In many cases, it was difficult to determine whether or not farmers were meeting the
requirements of Maryland's Nutrient Management Manual. Many requirements, such as
incorporation, cover crops and setbacks, are based on field-specific conditions while EPA only
made general observations about the extent to which farmers were implementing these practices.
Other BMPs, such as animal waste storage structures, barnyard runoff controls, and mortality
management fall within a general requirement to be managed in a manner not to cause water
quality impacts. This made it difficult to determine if the potential runoff from uncovered
stockpiles or compost piles and uncollected manure in a barnyard would be from an allowable
circumstance or would have warranted correction based on the Manure Management Evaluation
Form recommended by MDA's Nutrient Management Program.
c. Antietam Creek Watershed Restoration Plan
i. Background
EPA previously accepted the Antietam Creek Watershed Restoration Plan (the "Plan") dated
September 17, 2012.6 The goal of the Plan is to identify BMPs that are necessary to meet the
Antietam Creek TMDL and to restore water quality in the entire Antietam Creek watershed. The
Plan does not require any particular farm to implement any particular BMP. Rather, the plan
serves as a guidance document to provide a roadmap for implementing BMPs by 2017 and 2025
that will meet the TMDL allocations for both the local and Chesapeake Bay TMDLs. The Plan
states that "Actions taken as part of this [Plan] are in line with Bay TMDL reduction strategies as
well and will serve to meet the TMDLs of both waterbodies."
Agriculture is one of the sectors that the Plan focuses on for addressing sediment and fecal
bacteria reductions. Watersheds identified in the Plan to be given priority for sediment and fecal
bacteria reductions include the subwatershed Antietam Creek at Marsh Run (ANT0277), which
includes the Little Antietam Creek Watershed.
One of EPA's goals in conducting the AFO watershed assessment was to observe how well
MDE and MDA are providing oversight and outreach to these farms. With the interplay of the
local TMDL development and the watershed restoration planning that has occurred for Antietam
Creek and Little Antietam Creek, the roles and responsibilities of Washington County Soil
Conservation District are also very important to the overall success of the regulatory programs
and protection of water quality.
6 http://www.conservationplace.com/Antietam%20Creek%20Plan Final%209 17 12.pdf
20
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The Plan post-dates the Chesapeake Bay TMDL and therefore incorporates the reductions
necessary to achieve the 2017 and 2025 Chesapeake Bay TMDL WIP goals in a phased
approach. The Plan outlines the type and implementation level of best management practices
(BMPs) to achieve the 2017 and 2025 goals. The Plan includes the following BMPs applicable
to agriculture in Table 20:
• Grass buffers;
• Riparian forest buffers;
• Stream protection with fencing (livestock exclusion);
• Stream protection without fencing (livestock exclusion);
• Livestock stream crossings;
• Soil Conservation and Water Quality Plans;
• Runoff Control Systems (loafing lot management)
• Animal Waste Management Systems (Manure Storage)
• Nutrient Management Planning
• Conservation Tillage
• Cover crops
• Retire Highly Erodible Lands
ii. Observations
Some of these BMPs are required under Maryland's nutrient management program, such as
nutrient management planning and livestock exclusion. In addition, some of these BMPs were
being voluntarily implemented at the four farms that EPA visited. For example, all four farms
were implementing conservation tillage practices on 50% to 100% of crop acreage. In addition,
all four farms had barnyard runoff control systems in place to some degree; three of the four
farms had gutters and downspouts on farm buildings to divert clean water from barnyards,
although some of the gutters need repairs. Finally, one farm had a SCWQP and another farm
had an NRCS Conservation Plan.
The farms visits demonstrated that farmers have done much to implement both required and
voluntary BMPs, but additional BMPs are still needed to meet both the local TMDL and
Chesapeake Bay TMDL. The farm visits support concerns about the types of activities that
contribute to the nonpoint source pollution within the watershed, such as uncontrolled runoff
from barnyards, livestock access to streams, and lack of year round vegetation. However, EPA
did find that the farms visited were implementing conservation tillage practices whether or not
they had a formal Soil and Water Quality Plan. Overall, the type of technical assistance that
WCSCD is planning to provide appears to be in line with the needs of the farmers.
WCSCD staff plan to visit all dairies in the Little Antietam Creek watershed between 2012 and
2017. The purposes of these visits is to document non-cost shared BMPs and offer conservation
planning and technical and financial assistance for BMP implementation. EPA did learn that
some of the BMPs had been installed without assistance from cost-share programs. Two farmers
said that they did not participate in cost-share programs. One expressed interest in a continued
dialogue with the regulators about meeting the requirements and flexibility in the time to be able
to fund the BMPs without cost-sharing programs.
21
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WCSCD is hoping 80% of the farms visited will accept the offer to develop or update SCWQPs.
SCWQPs will document BMPs that are needed at a particular farm. Table 2 identifies which of
the BMPs recommended by the Plan were observed at the four farms and where BMP
implementation could be increased at the four farms visited.
Table 2: Implementation of BMPs that are recommended by the Plan at four farms visited.
Practice
# of farms
implementing BMP
Potential to increase BMP implementation
at four farms visited
Grass and riparian
forest buffers
One farm
Two farms could install buffers when they
implement new setback requirements, and the
farm that currently has buffers may need to
increase the buffer size in some areas to
comply with new setback requirements.
Stream protection with
or without fencing
(livestock exclusion)
and
Livestock stream
crossings
One farm
Two farms could install stream fencing and
livestock stream crossings. The first farm has
fencing planned for Spring 2014 and will not
allow animal access to lot until fencing
installed. The second farm has partial
fencing and is considering his options. Due
to winter conditions, animals were confined
and did not have access to the stream at the
time of EPA's visits.
Soil Conservation and
Water Quality
Planning (SCWQP)
One farm had a
SCWQP, with one
additional farm having
anNRCS
Conservation Plan
Two farms could develop and implement
SCWQPs or Conservation Plans.
Runoff Control
Systems
Two farms
Two farms could install gutters and
downspouts on buildings around the barnyard
to collect and divert clean water around the
barnyard areas.
Animal Waste
Management Systems
(Manure Storage)
Four farms
Two farms may need to increase manure
storage capacity (one for bed pack manure,
one for liquid manure) in order to meet future
prohibitions on winter application of manure.
Nutrient Management
Planning
Four farms
One farm needs to update its NMP to include
bedpack manure. All four farms will need to
maintain current NMPs.
Conservation Tillage
or Continuous No-Till
Four farms
Two farms were implementing conservation
tillage at less than 100% and could increase
implementation levels.
Cover crops
Four farms
Two farms were implementing cover crops at
less than 100% and could increase
implementation levels.
Retire Highly Erodible
Lands
Unknown
Not evaluated by EPA
22
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The Plan acknowledged that future revisions will be necessary, especially when new TMDLs are
approved. For example, the phosphorus TMDL for the Antietam Creek watershed was approved
by EPA on September 25, 2013. In order to meet the phosphorus TMDL allocations, the Plan
may need to be updated to include additional BMPs to address nutrient reductions beyond those
already included to address the sediment and fecal bacteria TMDLs.
The WCSCD has done a good job identifying the type of BMPs that are needed and the general
framework of how to fund the needed BMPs. Even prior to developing the watershed Plan for
EPA acceptance, WCSCD used EPA funds to support the type of BMPs cited in the Plan. As
discussed in Section III, approximately $855,000 in 319h funds was committed to the Antietam
Creek watershed between 2003 and 2013 to support technical staff who provided design and
installation assistance for implementation of agricultural conservation practices, as well as
supported development and implementation of the Plan and other non-agricultural projects (see
Appendix B). The WCSCD identified additional funding sources to help meet those needs, but
there is no discussion as to the reasonable expectations of what might be acquired through those
sources.
23
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VI. Conclusions
Maryland's Nutrient Management Program is fairly comprehensive in addressing many potential
water quality concerns at dairies, such as requiring the development and implementation of
NMPs that address various aspects of nutrient management (e.g. cropland, pasture, livestock
confinement areas, etc.), including manure management. The farms visited were generally in
compliance with Maryland's Nutrient Management Program requirements and were
implementing agricultural conservation practices that reduce nutrient and sediment pollution to
surface waters, such as animal waste management systems, nutrient management plans, cover
crops, and varying degrees of conservation tillage and barnyard runoff controls. Although the
farms had many agricultural conservation practices in place, areas that could be improved upon
include ensuring NMPs include all manure sources and address feed storage areas and potential
silage leachate runoff to surface waters.
Maryland also encourages the development of voluntary SCWQPs to help farmers address
natural resource management on agricultural lands and utilize BMPs to control erosion and
sediment loss and manage runoff. The Nutrient Management Program allows farmers to meet
their regulatory requirements for both livestock exclusion, and incorporation and/or injection
requirements through alternative practices that are identified in an SCWQP.
Both NMPs and SCWQPs are good planning tools for farmers provided they are kept up to date
and should help protect water quality. State and soil conservation district coordination is
important to ensure quality plans, to maximize limited resources, and to effectively work with
farmers to implement agricultural conservation practices. For example, MDA is responsible for
supporting the development of NMPs, the soil conservation districts are responsible for
supporting the development of SCWQPs, and MDE relies on the development and
implementation of appropriate NMPs and SCWQPs to meet the requirements of the Maryland
AFO General Permit. Both NMPs and SCWQPs can identify various agricultural conservation
practices that are being implemented or that need to be implemented. EPA believes that NMPs
and SCWQPs are excellent tools for water quality protection and restoration, and EPA
encourages the state and local agencies to continue to coordinate their efforts in the development
of quality plans.
24
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Appendix A
MDA's Revised Nutrient Management Regulations Fact Sheet
25
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26
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Appendix B
EPA non-point source funding for projects in the Antietam Creek Watershed as
documented in Grants Reporting and Tracking System (GRTS)
27
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Project Title
Start
date
319h
Funds
% to
agriculture
technical
staff
Outcomes
Antietam Creek Targeted
Watershed Project
2003
$124,859
100%
46 Soil Conservation and Water Quality Plans (2,982 acres) and 152 BMPs,
including 1 animal waste storage structure, 2 animal watering facilities, and 4
forested riparian buffer projects with 27.4 acres of tree planting and 5,049 feet of
livestock exclusion fencing.
Antietam Creek Targeted
Watershed Project
2004
$135,217
100%
Goal to develop 35 soil conservation and water quality plans (3,000 acres),
develop 23 NMPs (3,000 acres), update 30 NMPs (4,000 acresO, install 75 BMPs
identified in the soil conservation and water quality plans, implement 2 riparian
forested buffer projects, install 2 animal waste storage structures, install 5,000
feet of stream fencing to exclude livestock, and install 2 watering troughs to
provide an alternative watering source for livestock excluded from streams.
Antietam Creek Targeted
Watershed Project
2005
$119,447
100%
7,903 feet fencing, 127.4 acres stream bank protection, and 1 waste storage
facility
MDA Antietam Creek
Watershed Project
2007
$150,471
100%
12,643 acres CNMP, 655 acres conservation tillage, 3,740 acres cover crop, 62.8
acres fencing, 1 acre grassed waterway, 0.1 acre lined waterway, 3,440 acres
nutrient management, 1 runoff management system, 2.4 acres tree/shrub
establishment, and 5 waste management systems.
MDA Antietam Creek
Watershed Project
2008
$156,544
100%
10,730 acres CNMP, 1,050 acres conservation tillage, 3,278 acres cover crop,
11,661 feet fencing, 0.1 acres grassed waterway, 2.4 acres riparian forest buffer,
4 waste storage facilities, and 4 watering facilities
Washington County Soil
Conservation District (SCD)
Antietam Creek Watershed
Plan
2008
$29,265
0%
Develop watershed plan for seeking future implementation funding
MDA Antietam Creek
Watershed Project
2010
$168,984
100%
119 CNMPs, 1,851 acres conservation tillage, 3,740 acres cover crops, 6,975
acres fencing, 0.2 acres filter strip, 0.8 acres grassed waterway, 0.1 acres lined
waterway, 8 roof runoff management systems, 2 waste storage facilities, and 1
watering facility
28
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Washington County Little
Antietam Creek Stream
Restoration
2012
$240,000
0%
Restore approximately 600 linear feet of eroded stream banks in the Antietam
watershed on the Little Antietam Creek adjacent to Greensburg Road in
Smithsburg, Maryland
MDE Targeted Watershed
Monitoring of NPS
Implementation Progress
2013
$440,088
0%
Provide assessment services that assist in identifying water quality, living
resource and habitat problems, identify pollutant source areas, and prioritize
potential restoration sites. Assess effectiveness of restoration activities and
efficiencies of BMPs being implemented to address impairments of watersheds
on the 303d list of impaired waters. Continued monitoring of the Corsica River
Watershed implementation projects.
Washington County SCD
Antietam Creek Watershed
Restoration Phase 1 - Barr
Property
2013
$148,930
0%
Stabilize severe stream bank erosion on 650 linear feet of Beaver Creek.
Source: http://iaspub.epa.gov/apex/grts/f?p=l 10:199:0::NQ. Note that most of the projects cover the entire Antietam Creek Watershed, not just the Little
Antietam Creek subwatershed.
29
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Appendix C
Samples AFO farm visit checklist
30
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MARYLAND AFO ON-SITE ASSESSMENT FORM
Form to be completed by EPA personnel
Biosecurity Measures Implemented in Addition to EPA Protocols: Yes No
Measures Taken:
Date: Time In: (AM PM) Time Out: (AM PM)
Weather:
Photos Taken: Yes (see Photo Log) No
Samples Taken: Yes (see Lab Results) No
EPA Inspector(s):
Contractor(s):
MDE Staff:
MDA Staff:
District Staff:
Other Participants:
Persons Interviewed:
Farm Name (if any):
Farm Address
GPS coordinates (entrance) Latitude: Longitude:
Owner/Operator Information
Owner Name:
Operator(s):
Phone: home work cell fax na
Phone: home work cell fax na
Email Address:
Owner Address:
Operator Address:
Mailing Address: _
Overview of Business Information
Farm Type (Primary): ~ Dairy nBeef ~ Swine ~ Layer ~ Broilers ~ Turkey
Animal Product: Sold To:
Production Level (i.e. gals/day of milk):
31
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CAFO/MAFO/AFO Status
~ Concentrated Animal Feeding Operation (CAFO)
~ Maryland Animal Feeding Operation (MAFO)
~ Animal Feeding Operation (AFO)
~ Not Applicable
Is the farm in a preservation
program? Yes No
Name:
Acres in program:
acres
Animal Inventory
Animal Type
Current No.
Weight
Animal Type
Current No.
Weight
Milking Cows
Beef Cattle
Dry Cows
Swine
Heifers >1 yr
Horses
Heifers <1 yr
Mules
Calves <2 mos
Broilers/Layers
Bulls
Other
Farm Management Documents and Plans
~ Maryland General Discharge Permit Coverage (Permit No. )
~ NOI/application submitted (Date )
~ The farm has a gross income of > $2,500 or eight or more animal units (8,000 lbs or more of live
animal weight)
~ The farm does not meet Maryland's NMP exemption requirements 7
~ Nutrient Management Plan8
(Date , Author )
~ Certified Nutrient Management Consultant
~ Certified Farm Operator
~ Other:
~ NRCS Comprehensive Nutrient Management Plan
(Date , Author )
~ Ag. E&S/NRCS Conservation Plan
(Date , Author )
~ Other Farm Management Plan(s)
Notes:
7 If an operator is subject to [Chapter 07 Agricultural Operation Nutrient Management Plan Requirements] only
because the operator earns $2,500 or more from the occasional sale of agricultural products as a result of
participating in a 4-H or other agricultural youth organization project, the operator is exempt if:
(1) Verification of active participation in the 4-H or agricultural youth organization activity is made available upon
request to the Department; and
(2) The activity is conducted so the potential for nutrient loss or runoff is minimized.
8 NMPs developed before October 15, 2012 must be updated when they expire or if changes to the operation
require modifications, whichever occurs first. Plans revised or updated after October 15, 2012 must be developed
and implemented in accordance with the revised requirements outlined in Maryland's Nutrient Management
Manual.
32
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Cropland/Pasture/Field Management
Own: Total ac
Crops:
ac Pasture:
ac
Production Area:
ac
Rented: Total ac
Crops:
ac Pasture:
ac
Rented From:
Crops Grown: ~ Corn
~ Alfalfa
ac
ac
Receive manure?
Receive manure?
Yes
Yes
No
No
~ Soybean
ac
Receive manure?
Yes
No
~ Tobacco
ac
Receive manure?
Yes
No
~ Other(s) (
) ac
Receive manure?
Yes
No
Crop Rotation:
Regular Soils Tests:
Date of last soil test:
Yes No Each field tested once every ~ 1 ~ 2 ~ 3 ~ 4 ~ 5 yrs
Laboratory results available for onsite review: Yes No
Notes:
Nutrient Sources
Stored Manure (%, Gal, or T): Used On Site Export
Yes No Import Manure?
Annual amount of imported manure: gal/tons
Source of imported manure?
Yes No Inorganic Fertilizer used?
Type:
Amount used:
Yes No Biosolids used?
Source:
Amount used:
Yes No Irrigation used?
Notes:
33
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Land Application of Nutrients and Chemical Fertilizers
Yes No Is manure spread on pastures?
Pasture acres receiving manure: acres
Yes No Manure, biosolids, and/or other organic nutrient sources is/are injected or incorporated into the
soil within 48 hours of application.9
Yes No Does the farm apply organic nutrients (except poultry litter) from March 1 through November
15?
~ Existing crop
~ Fall planted crop
~ Field that will be cropped in the spring
Yes No University of Maryland recommendations are followed for application of organic nutrients.
Fall Practices (September 1 through November 15)
Yes No The farm applies chemical fertilizer in fall.
Product or composition:
Yes No University of Maryland recommendations are followed for fall application of chemical
fertilizer.
Yes No Does fall application of N occur on small grains?
Small grain type(s):
Yes No Fall nitrate test levels are greater than 10 ppm for wheat or 15 ppm for barley?1
Field Identifier
Soil Nitrate Test Level
Sample Collection Date
ppm
/ /20
ppm
/ /20
ppm
/ /20
ppm
/ /20
Yes No Are cover crops planted when organic nutrient sources are applied in the fall?11
Notes:
9 Beginning Spring 2013, manure, biosolids, and other organic nutrient sources must be injected or incorporated
into the soil with 48 hours of application. Exceptions are made for spray irrigation on a growing crop, permanent
pastures, hay production fields, and highly erodible fields.
10 Beginning Fall 2013, fall nitrogen application is prohibited on small grains if a fall nitrate test indicates levels
greater than 10 parts per million (ppm) for wheat or 15 ppm for barley.
11 Beginning Fall 2013, cover crops must be planted when organic nutrient sources are applied in the fall.
34
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Winter Practices (November 16 through March 1)
Yes No The farm spreads manure during the winter
If yes, when was the last time:
If yes, which crops receive manure:
If yes, which fields receive manure:
Yes No Winter application of organic nutrients occurs because of inadequate manure storage.
~ Manure/waste is not stackable.
~ Land application is the only reasonable option
Yes No The farm applies chemical fertilizer in winter.
Product or composition:
~ Chemical fertilizer is applied for green up of perennial forage crops or small grains.
Best Management Practices
Yes No No-Till/Low Till
Implementation Level: ac / %
Yes No Winter Cover Crop
Current year implementation level: ac
Typical year implementation level: ac
Type of cover crop:
Does cover crop receive manure? Yes No
Amount of manure applied to cover crops: gal/tons
Yes No Stream Bank Fencing: (if applicable)
Implementation Level: ft
~ Stream banks are fenced on both sides of stream(s)
Yes No Vegetated Stream Buffers: (if applicable)
Implementation Level: ft
Average width of buffer: ft
Minimum width of buffer: ft Maximum width of buffer: ft
Yes No Is the operator familiar with the setback requirements that are effective beginning January
2014?12
Yes No Buildings/structures around the barnyard have operational gutters and downspouts?
Notes:
12 Beginning January 1, 2014:
A) farmers are required to establish a 35-foot setback for fertilizer applications adjacent to surface waters and
streams. The setback is reduced to 10 feet when directed application methods are used such as directed spray or
injection, which reduce the potential for nutrient losses. No crop plants may be grown on the 10 foot setback area
with the exception of pasture and hay. Crop plants may be grown on the remaining 25 foot setback, but may not
be fertilized unless a directed application method is used.
B) Livestock access to streams and certain surface waters is restricted by a minimum 10 foot setback. Fencing is
not specifically required to allow soil conservation district staff the flexibility to determine whether alternative
BMPs such as watering facilities, stream crossings, pasture management techniques or vegetative exclusion would
work as well as fencing in protecting water quality on a site-specific basis.
35
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Raw Materials Management
Type of feed produced by self:
Type of feed imported:
Type of feed storage:
Yes No Operator manages feed formulation to reduce nutrient content in manure
Yes No Is stored feed exposed to precipitation
Yes No Silage Leachate?
Yes No Is bedding exposed to precipitation?
Wastewater Management
Milkhouse wastewater directed to:
Mortality Management
Method of Disposal
(select all that apply)
Routine
Mortality
Catastrophic
Mortality
Comments
Compost in compost
shed
~
~
Compost in manure
shed
~
~
Outdoor composting
~
~
Burial
~
~
Incineration
~
~
Rendering
~
~
Other (describe):
~
~
Surface Water and Stormwater Management (use Site Maps to identify location)
Yes No Is surface water present? Location:
Yes No Are man-made ditches, flushing systems, or other similar man-made devices present?
Location:
Yes No Is stormwater managed throughout the AFO in a manner in which it does not come into
contact with any raw materials, products, or byproducts including manure, litter, feed, milk,
eggs or bedding?
Yes No Does water come into direct contact with the animals confined in the operation?
Notes:
36
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Manure Storage
Storage 1: Date Built: Dimensions:
Designed by: Constructed by:
Did you use any government cost-share funding? Yes No Program:
Capacity: gals months or days, Disposal Method:
Freeboard maintained (inches): Lining:
Storage Condition: ~ Good ~ Needs Improvement ~ Other
Manure Testing: ~ Never ~ Once every 1 2 3 4 5 years ~ Not Routinely
Storage 2: Date Built: Dimensions:
Designed by: Constructed by:
Did you use any government cost-share funding? Yes No Program:
Capacity: gals months or Jays Disposal Method:
Freeboard maintained (inches): Lining:
Storage Condition: ~ Good ~ Needs Improvement ~ Other
Manure Testing: ~ Never ~ Once every 1 2 3 4 5 years ~ Not Routinely
Storage 3: Date Built: Dimensions:
Designed by: Constructed by:
Did you use any government cost-share funding? Yes No Program:
Capacity: gals months or Jays Disposal Method:
Freeboard maintained (inches): Lining:
Storage Condition: ~ Good ~ Needs Improvement ~ Other
Manure Testing: ~ Never ~ Once every 1 2 3 4 5 years ~ Not Routinely
Notes:
37
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Animal Type
And Animal
Confinement Area
Animal C oufuieini'iit Area
(Bam, FreestaH Bam, Lot,
Loafing Area. Parlor, Pasture)
Time Mgmt
Waste Generated in ACA
Storage Treatment
(Storage Pond, Lagoon, Tank,
Stockpile, Manure Shed)
Milking Cows
Location;
lirs / dav
n Manure
~ No Storage
Access- To Stream
o IVi j No
Days
a Bedding
(Type )
~ Flush Tank
Covet ed
~ lev jNo
% (annual)
d Storage Location
Impen-ioiis Sit)face
j Yes j No
o Land Application
gal/T every weeks
Location:
fars / dav
a Manure
n No Storage
Access To Stream
J }
-------
Animal Type
And Animal
Confinement Area
Animal Confinement Area
(Barn, Free stall Bam, Lor,
Loafing Area. Bailor. Pasture/
Time Ifgmf
Waste Generated in ACA
Storage Treatment
(Storage Point Lagoon. Tank,
Stockpile, Manure Shed)
Milking Cows
Location:
tars / dav
o Manure
d No Storage
Access To Stream
rj Ya o No
Davs
~ Bedding
(Type )
a Flush Tank
Covered
_< It's J No
% (annual)
o Storage Location
Impervious Sin face
a Yes a No
o Land Application
gai/T every weeks
Location:
Ill's / dav
o Manure
o No Storage
Access To Stream
a Yes o No
Davs
a Bedding
(Type )
a Flush Tank
Covered
j ]«' j No
% ("annual)
d Storage Location
Impemous Surface
a Fes u No
o Land Application
gal/T every weeks
Location:
hrs / dav
a Manure
d No Storage
Acces s To Stream
j Yes _i No
Davs
o Bedding
Ovpe }
o Flush Tank
Covered
j ]« j No
% (annual)
o Storage Location
Impemous Surface
j Yes _> No
o Land Application
gal/T every weeks
Location:
fars I dav
~ Manure
o No Storage
Access To Stream
_i Yes j No
davs
a Bedding
(Type )
o Flush Tank
Covered
c Yes d No
% ("annual)
o Storage Location
Impeinotis Surface
d 1'es —i No
n Land Application
gai/T every weeks
39
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