This report is a "living" document and it is expected that members of the

Poultry Industry Environmental Dialogue participants will meet again in

18 to 24 months to assess whether any updates are needed.

Further, every attempt was made to avoid conflicts between this

document and the attachments; however, in the event a discrepancy or

contradiction appears between the two, this framework document

will supercede the information in the attachments.

Copy of document provided courtesy of U.S. Poultry & Egg Association.

Protection of the environment and in particular the protection of the nation's water quality is important to the poultry industry. As the industry has developed and grown over the last several years, the industry has recognized its role in and has taken proactive steps to protect the environment. Both the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Agriculture (USDA) are encouraging a voluntary approach to handling non point source issues related to animal agriculture. The voluntary strategies outlined in this overall program will ensure that the industry is taking a lead role in promoting the protection of the environment and water quality through the implementation of Litter Management Plans.

The implementation of Litter/Manure Management Plans by all independent and contract poultry producers will ensure that the nutrient value of the poultry litter is managed in an environmental friendly fashion. It would be difficult for the poultry industry to dictate to private contract producers and farmers how they should manage the nutrients on their whole farm operation. However, it is entirely feasible for the poultry industry to accept their contribution to the overall nutrient issue through a Litter/Manure Management Plan. The development and implementation of Litter/Manure Management Plans in poultry production operations will ensure that the litter/manure is properly used on the land for its nutrient value or is transferred to an alternative use program.

The industry has instituted both company and academic research on feed formulation to ensure better utilization of the feed by the bird, encouraged and in some cases required the use of litter storage facilities and dead bird composters, the modification of watering devices in the grow out operations to eliminate liquid run off and ensure optimum litter control and the implementation of improved ventilation to reduce mortality. While these steps have been taken on a voluntary basis by the industry, the industry recognizes that additional measures need to be taken to ensure the continuation of and the enhancement of the nation's environmental protection and water quality improvement efforts. It is anticipated that the program outlined in this document will build on the existing strengths of the poultry industry and will assist in the obtainment of the national water quality goals set forth in the Clean Water Act. At the same time, it builds in the sustainability of the poultry industry.

The poultry industry is like a three legged stool made up of the companies, the individual producer and the American grain farmer. Each is dependent on the other. The strategies outlined in this document focus the companies' technical and financial assistance, in cooperation with various government and private agencies, with the environmental stewardship of the individual poultry producer and the grain farmer. It also indicates to the general public and to the government regulatory agencies that the industry has its own expectations when it comes to environmental protection.

This environmental framework and implementation strategy for poultry operations is a voluntary program. It is not designed nor intended to replace, substitute, or supersede for any local, state, or federal statutory or regulatory program. Moreover, each company must enter into contractual and other commercial relationships independently. Companies may not agree upon individual contractual terms, nor may any industry association require that companies incorporate or implement any of the specific recommendations embodied in this voluntary program.

Poultry litter/manure are excellent sources of organic nutrients and can be incorporated into most farming operations when properly managed. For poultry producers, the proper management of litter/manure is a major consideration in their daily operations. Whether the material is utilized as a nutrient source on land controlled by the producer, or it is provided as a nutrient source on other lands or is offered as a material in an alternative use process, the proper management of the litter/manure is essential. Storage, transportation, application, disease prevention and proper documentation are just a few of the items that need to be factored into the litter/manure management decision making process.

It shall be the policy of the poultry industry to develop producer contract language and incorporate into their company operations a Litter/Manure Management Plan. This policy is effective on the date of adoption and should apply as follows:

It is the intent of the Litter Management Plan to address the nutrient value of the litter/manure produced in the poultry operation and to effectively plan for its use. The Litter/Manure Management Plan should be designed, written and implemented as either a component of or within an approved Nutrient Management Plan meeting or exceeding NRCS standards or as a stand alone document that utilizes third party land application or alternative use programs.

Proper litter/manure management is an essential component of a successful poultry operation. Many elements make up a Litter/Manure Management Plan. Elements that should be included in a Litter/Manure Management Plan are:

* land application amounts; fields applied to; when applied; crop grown; crop yield

• soil testing values

At the time litter/manure clean out is conducted, the litter/manure is often required to be placed in storage. While litter storage does present an additional expense, it is a useful tool in a comprehensive Litter/Manure Management Plan. Litter/Manure storage facilities can be divided into two basic categories, temporary structures and permanent structures. It is desirable to have a permanent structure for litter/manure storage.

Whether the structure is temporary or permanent, the siting of the facility is important. The following general guidelines should be implemented in siting and construction of a litter storage facility:

Litter stored for a period of three months or longer should be kept in a permanent storage facility. Litter that is utilized in a land application program and is applied directly from a poultry production house during a clean out operation does not have to have storage capabilities.

Recordkeeping is an essential and a critical part of a well run Litter/Manure Management Plan. Accurate records are important as a tool in the development of future plans and assist in demonstrating the effectiveness of the plan. Records should be maintained for at least three years. Records should be kept at the farm site.

Records should be maintained in the following areas:

* amount of litter produced/stored

* clean out time/schedule

* third party land application agreements if applicable

* alternative use agreements if applicable

* amount of litter/manure shipped to the alternative use program

* the name of the alternative use program

* the location of the alternative use program

* the type of alternative use

* land application

* soil test results

* amount/rate of manure applied

* fields applied to

* when applied

* crop grown

* crop yield (where applicable)

Examples of recordkeeping documents are provided as a reference. Exact copies of these example recordkeeping forms are not required to meet the recordkeeping portion of a Litter/Manure Management Plan.

Proper management of mortality is a routine component of poultry production. Effective mortality management assists in disease prevention, nutrient management and environment control. The use of composting, rendering or incineration or other methods that are legally approved are acceptable methods of normal mortality management. Catastrophic mortality may be handled by one of these methods or with burial that meets all federal, state and local regulations. However, dead bird burial for normal mortality should be eliminated by January 1, 2002. Any mortality plan should be incorporated in the overall Litter Management Plan.

Litter/manure should be sampled for its nutrient value. Sampling of litter should occur no greater than 90 days prior to land application. The nutrients of principle concern are nitrogen and phosphorous. This is especially critical for any land application litter management program. Records should be kept of all nutrient tests, including date of test, type of litter sampled and the nutrient value of the litter/manure.

The use of poultry litter/manure as a direct source of nutrients in an agricultural setting is an excellent method of recycling nutrients back through the crop or animal production chain. However, there are some lands which cannot responsibly receive poultry litter due to existing high levels of nutrients. The nutrients of concern are primarily nitrogen and phosphorous. Economically sound alternative uses of poultry litter/manure need to be implemented. These alternative use programs can be established on a regional basis, a statewide basis or at the individual company level.

It is critical to note that the issue of alternative uses of poultry litter/manure does not fundamentally change the issue of nutrients or pollution. To date, any alternative use program merely changes the form and the environmental media in which the nutrients need to be dealt with. Both nutrients of concern, nitrogen and phosphorous are elemental and cannot be destroyed. Changing the form of the nutrients may allow for more feasible uses such as golf courses, landscaping areas, energy production and nutrient recovery.

In the case of burning litter from poultry operations for BTU value and generating electrical power or steam, the residual ash contains highly concentrated levels of elemental phosphorous. Emissions from the burning process could also contain elevated levels of NOx, a leading contributor to air pollution. Even if the NOx is "scrubbed" out of the emissions, the nitrogen is contained in the waste water stream of the air control equipment. The use of poultry litter as a fuel source in electrical generation is an extremely capital intensive alternative use method.

Two other often suggested alternative uses of broiler litter are composting and pelletization. Both of these methods still rely on the litter for its nutrient value. Whether the compost is used in organic farming or as a soil amendment in garden soils, the nutrients go back on the land. Whether the pelletized litter is used as a fertilizer source in growing grain crops or in landscaping, the nutrients go back on the land. In either case, the effective management of the elemental nutrients is essential.

It shall be the policy of the poultry industry to engage in, facilitate, or in some other fashion, research and where economically feasible and without any detriment to the health of the bird or to the bird to effectively metabolize the feed formulation, implement nutrient reduction strategies in feed formulation. This can be accomplished by the addition of enzymes, reduction in nutrient concentrations, modifications in existing formulations or by any other reasonable method.

In a effort to quantify the effectiveness of this nutrient reduction strategy, the industry shall establish a baseline measurement of nutrients in feed stocks. On an annual basis, until January 1, 2005, the industry will measure the reduction of nutrient levels in feed produced. This information shall be reported in a unified national report submitted to the U.S. Environmental Protection Agency, Assistant Administrator, Office of Water.

It shall be the policy of the poultry industry to aggressively facilitate the education of producers, service personnel, other segments of the poultry industry, government regulators, and the general public on the environmental issues related to poultry production and processing. This education should include the value of poultry litter/manure and mortality and their proper management and their impact on the environment. Education and training are also considered to include innovative technology transfer, and research outreach programs.

The industry can implement this strategy through broad based interaction with the state land grant universities, other institutions of higher learning, government agencies (USDA Resource Conservation Service), poultry associations and public service announcements.

Implementation of any new program, either voluntary or regulatory, will require additional funding. The poultry industry has historically used several avenues, both private and public, to finance the implementation of new programs. This environmental framework and strategy is no different.

Producers will continue to utilize, to the fullest extent possible, the federal and state cost share funding programs for water quality Litter/Manure Management Practices.

USDA will continue its support for and more favorably, increase its support and request additional funds under the Environmental Quality Incentive Program (EQUIP), the Conservation Reserve Program (CRP), and the Small Watershed Protection Program (PL 83-566).

The poultry industry fully supports the President’s Clean Water Action Plan as it relates to funding of capital improvements needed by producers to implement water quality related litter/manure management practices.

EPA should, at a minimum, continue its support for and more favorably, increase its support and request additional funds under the Clean Water Act 319 Program (Non point Source Management Program) and the Clean Water Act Waste Water Treatment and Drinking Water State Revolving Funds (SRF).

EPA should encourage the States to evaluate the use of state funds, both matching and non-matching, to redirect state spending to agricultural non point source efforts.

All interested parties should be seeking additional funds to support poultry industry environmental management efforts, including efforts to remove barriers in Federal and state legislation to allow use of available funds for construction of needed facilities, use of Transportation Department buffer and wetland conservation funds, and other funds that may be available to meet environmental objectives.

Integrators will continue to fund projects through their traditional channels and will increase funding as needed to meet the national goals of water quality improvement and protection. Avenues of funding available to the integrators include, but are not limited to:

A voluntary program needs to have a strong component of compliance assurance. To the extent industry has committed to have each producer and company owned operation operate under a Litter/Manure Management Plan, it is incumbent on the industry, both the integrators and the individual producers, to do their part in compliance assurance.

Under this voluntary framework and implementation strategy, there are three components to compliance assurance. Each must function to have a successful program.

Each producer should have a Litter/Manure Management Plan, in accordance with the time schedule noted above in the section, titled: "Litter/Manure Management Plan."

Each producer should report, on an annual basis, to the appropriate state agency:

Each integrator should facilitate the education and training of their grow out personnel, producer service personnel or any other integrator employee that interacts on the farm with the producer, in the principles of litter management.

The integrator service personnel should request to verify if each producer has the required Litter/Manure Management Plan and that the producer has submitted an annual report to the appropriate state agency.

The integrator should report, for each of the integrator owned operations, on an annual basis, to the appropriate state agency:

The regulatory agencies reserve the right to inspect the producer's Litter Management Plan and any records relating to the Plan during reasonable and routine business times and within the scope of the agency's statutory authority.

The regulatory agencies reserve the right to investigate any and all complaints related to the producer's operation or the integrator's operation within the agency's statutory authority.

Attachments

The following procedure should be considered in selecting sites for poultry facilities.

Farms should be willing to implement a "Water Quality Management Plan" to protect the water resource. A Water Quality Management Plan is identified in the NRCS Field Office Technical Guide section 3. It protects the identified resource for sustained use.

In a typical Poultry production unit consideration should be given to the following:

* Houses above 100 year flood plain

In cropland areas, consideration should also be given to the basic erosion concerns and tillage practices.

A site specific water quality management plan consists of a unique set of conservation practices planned for the conditions, resources and production goals of the land user. Practices should be installed according to NRCS standards. A listing of national NRCS technical standards, including practice codes, can be found on the NRCS Homepage at "www.nrcs.usda.gov" under "Technical References". NRCS state and field offices adopt and supplement these standards, as necessary, to accommodate local conditions. These localized standards can be found in Section IV of the Field Office Technical Guide (FOTG) which is maintained in each NRCS field office.

As environmental pressures continue to increase the poultry industry will do its part with regard to overall watershed planning. We expect others to do likewise. Total Maximum Daily Loads (TMDL) will be used to monitor water quality in a particular watershed.

We recognize that concentration of large numbers of poultry farms and an increase in the size of individual farms has created a situation in some areas where there are more nutrients in the manure than can be utilized by the row and forage crops grown in the area. On such areas, application of manure may need to be reduced or stopped for a time to remove excess nutrients from the soils through crop uptake. In locations where manure cannot be applied, alternative locations to apply the manure or alternative uses will need to be found. These alternatives can rarely be addressed by individual farmers. Group action, led by Soil and Water Conservation Districts (SWCDs) in cooperation with the poultry industry and other stakeholders, is needed to address such watershed or community problems.

The Poultry Industry Environmental Dialogue’s recommendations on manure management are based on the premise that it is easier to prevent pollution and other environmental problems than it is to correct them after they occur. This section of the dialogue report provides an overview of manure management issues that should be considered by every poultry producer. Specific recommendations for action are printed in bold face type.

Poultry manure is a valuable organic soil amendment and an important source of plant nutrients. When properly managed these materials contribute to successful crop and forage production and improved soil quality. When improperly handled, stored, or utilized the organic matter, nutrients, and biological organisms in the manure can cause water, air, and soil pollution, and threaten human health. Fortunately, most poultry farmers, and the companies they are affiliated with, properly manage manure and protect the nation’s natural resources.

There are some irresponsible producers, however, who have caused environmental degradation as a result of improper handling, storage, and application of manure and the inappropriate disposal of dead birds. Mis-management has caused odor, water quality, and both public and animal health problems. Industry and government actions need to be taken against those that carelessly cause damage to the environment.

Planning is necessary for proper manure and byproducts management. Manure management plans, which are part of nutrient management plans, guide poultry producers and others in the handling, storage, and utilization of manure, and help identify when different or additional actions need to be taken to reduce the risk of pollution.

A manure management plan should be site specific and be written for a maximum of five years. The plan should be immediately revised and changes implemented if the facility increases in size or changes its method of manure management. These plans should be developed by the poultry producer with assistance, as needed, from qualified company staff, government agency specialists, and private consultants. Manure management plans should be voluntary, and not required as part of a regulatory program. A good plan, fully implemented, should, however, help a poultry producer minimize adverse environmental impacts, maximize the benefits of using manure, and meet the requirements of a regulatory program.

The most important objectives addressed in a manure management plan are (1) safe handling and storage of the material to ensure that pollutants are not directly released into the environment, and (2) nutrient management to minimize undesirable nutrient loss, and to balance the nutrient content of the manure with crop needs.

We believe the following components should be considered in the manure management planning process: facility location, in-house manure and input management, mortality management, clean-out, transportation, storage, and land application.

In-house manure and input management. Where manure is stored in the production facility, floors and walls should be constructed to ensure that manure is retained in the houses and that nutrients and other potential pollutants do not come into contact with ground water. It is essential in all facilities that water systems do not leak and increase the amount of moisture in the manure above what is planned.

Adding certain materials to the manure while it is in the poultry house may reduce loss of nitrogen and the solubility of phosphorous. Maintaining the nitrogen in the manure increases its value as a fertilizer. Reducing ammonia in the production facility may improve bird health and productivity, and reduces the potential for air pollution from the production facility. Reducing the solubility of phosphorous reduces the likelihood that it will be carried in runoff from fields after land application.

Feed additives may improve the ability of the birds to digest nutrients in the feed, thus modifying the nutrient content of the manure. For example, various compounds are being studied as a way to increase the birds’ digestion of phosphorous, thus reducing the phosphorous in the manure.

It is our hope that through in-house manure management, feed additives, and manure treatments, poultry producers can produce a manure with a nutrient content that is in balance with crop needs.

Mortality management. A certain percentage of birds will die during a production cycle. Dead birds should be properly disposed of shortly after removal from the production houses. With the exception of catastrophic mortality due to events such as an avian influenza outbreak, management of mortality generated by our poultry operations will be done through rendering, composting, and incineration. Catastrophic mortality may be handled with burial that meets all federal, state and local regulations. Dead bird burial for normal mortality should be eliminated by January 1, 2002.

Clean-out. "Clean-out" is the term used to describe the removal of manure from a poultry house. The manure management plan should take into account the amount of manure to be removed and the time of removal so that sufficient land is available for proper land application shortly after removal, or to ensure that storage facilities are available for the quantity of material that must be handled. Whenever possible, manure removal should be planned so that fresh manure, containing the maximum amounts of nutrients, can be immediately applied to meet crop or forage plant growth needs.

Transportation. Effective immediately, we ask all who transport poultry manure to cover or sufficiently contain manure when being moved along public roads and highways. to prevent spillage or loss of the manure/agricultural waste. This will prevent accidental spillage of manure and improve the industry’s biosecurity efforts.

Manure storage. We encourage the use of litter storage facilities by poultry producers and others who routinely handle manure. Storage facilities must be built on an impermeable base to prevent seepage of manure constituents to ground water. Facilities should be protected from flooding by proper site selection and/or appropriate floodwater diversion. Storage facility size should be sufficient for the amount of manure that may be removed from the production house, but because of field, weather, crop stage, or other conditions cannot be safely applied on crop or pasture land until some later time. This may be the volume equivalent to a complete clean out or an accumulation of manure resulting from several partial clean outs. Litter storage facilities also allow management of manure for alternative uses. All siting requirements outlined by the "Location and Siting Workgroup" shall be followed.

Temporary out-of-doors storage of dry manure is acceptable if it is protected from precipitation and wind. Such storage will usually be in or near the fields where the manure will be land applied. Such storage sites should be located away from drainage ditches (including road ditches). Manure in temporary storage should be protected from runoff or flood water. Poultry producers should heed these recommendations and should ask all persons who accept dry poultry manure to pay close attention to where it is stored and to cover it prior to its use.

Land application is the most common, and usually most desirable method of utilizing manure because of the value of the nutrients and organic matter. Basic requirements of the manure management plan to ensure that material applied on the land does not cause pollution include (1) calculations to determine the proper amount of manure to be applied to meet, but not exceed, crop nutrient needs, and (2) land management practices to prevent runoff and erosion of material applied to crop or pasture lands. As noted on page 3 of the main body of this report, a manure/litter management plan should be designed, written and implemented as a component of or within a nutrient management plan meeting or exceeding NRCS standards and specifications.

Nutrient management. The primary purpose of nutrient management is to balance the nutrients required to grow the planned crop with the nutrients that are already in the soil and those that will be applied in manure and other types of fertilizer. Nutrient management should address how much manure and other fertilizer should be applied, when, where, and by what method. Timing and method of application should be done to prevent the loss of nutrients to ground or surface water and to minimize loss of nitrogen to the atmosphere.

Manure and agricultural by-products shall be applied in conformance with a plan developed following NRCS nutrient management policy current at the time of plan development. It is best to avoid applying manure in areas of considerable human activity unless the manure can be applied at a time or in a way that will reduce possible effects such as odor on the human activity. It is best to advise neighbors and others that may be affected by manure application when such activities will occur. It is important to be a good neighbor.

In order to develop and implement an effective litter/manure management plan as part of an overall nutrient management plan, Ssoils should be tested initially (within one year of plan development) and every five years thereafter. Manure should be tested initially, and then a minimum of at least once every 5 years, unless there is a significant change in animal rations or operation management (for example, a change in the size or type of birds that are being raised). Separate soil samples should be taken where there are known differences in the soil that could lead to unintended pollution (such as an area of particularly shallow soil) or observed differences in past production. The amount of manure applied on these areas should be adjusted to address site specific problems that are indicated by the soil samples.

Generally, nutrient management should be based on crop nitrogen needs because this is the most sensitive nutrient for crop production. A problem with manure as a fertilizer is the nutrients are not generally balanced with crop needs. When manure is applied to meet crop nitrogen needs, excess phosphorus and potassium are almost always applied. This imbalance is increased if much of the nitrogen has been lost during manure handling and storage, or will be lost between the time of land application and crop growth.

Some nutrients applied in excess of crop needs can accumulate in the soil, and at certain levels may cause water pollution. High soil phosphorus levels have been linked to negative water quality impacts. On such fields, application of manure may need to be reduced or stopped for a time to remove excess phosphorus from the soils through crop uptake or by other management actions. Nutrient management should be in conformance with applicable NRCS standards or, if more stringent, state or local criteria. In locations where manure cannot be applied, alternative locations to apply the manure or alternative uses will need to be found.

Because of the serious implications for manure management related to the possible accumulation of phosphorus, we ask that USDA and EPA and others work together to develop a (1) better understanding of how phosphorus and other nutrients function in the environment, (2) national guidance for phosphorus management, and (3) uniform approach for determining environmental impacts of phosphorus.

Manure application equipment should be calibrated on site at least once a year, for each type of material/manure applied, to ensure that the quantity of material being applied is what is planned.

Conservation practices. Proper land management following manure application can increase infiltration and nutrient movement into the soil, and reduce runoff and loss of nutrients to overland flow. Conservation practices that should be included as part of a land application plan are conservation tillage, grazing management, buffers, and other practices that will prevent runoff, erosion, and the washing of organic matter and nutrients from fields. Taken together with nutrient management, these practices will help to ensure that the right amount of nutrients are applied to the field, that the nutrients stay on the field, and that any potential pollutants that might be washed from the field are captured before they reach a stream or lake.

Land application of manure and other nutrients can also impact ground water quality. Proper timing, rate, and frequency of application to maximize crop uptake are the primary management practices used to reduce this impact. However, other practices such as crop rotation, cover cropping, residue management and maintenance of proper soil pH can also help. Application of manure and other nutrients in close proximity to environmentally sensitive areas that might easily contribute to ground water contamination such as sink holes, wells, gullies, ditches, surface inlets or rapidly permeable soils should be avoided. All setback distances required by state and local regulations shall be followed.

Records should be kept by the poultry producer of the amount of manure removed from poultry houses, when the manure was removed, and how it was utilized; the amount stored, the dates of storage, and how it was utilized; and, when applied to fields under the producers control, the amount applied to each field, its nutrient content, and the date of application.

Much of the manure produced on a poultry farm is sold or given to other farmers and applied on their farms. While the poultry grower has limited control on how the manure is utilized on other farms, the farmers purchasing and land applying manure should be encouraged to follow the same management practices that are applied on a poultry farm where manure is produced. The purchasing or receiving farmer should be encouraged to address issues associated with storage, transportation, nutrient management, and field or pasture management.

The purpose of this section is to outline the practices that a poultry farmer and others utilizing poultry manure as a soil amendment should consider as they develop a site specific management plan. Each plan must address the needs of the particular farm. With effort by all involved in the poultry industry and a good manure/litter management plan that addresses on- and appropriate off-farm issues, every poultry farmer can protect and even enhance the environment.

Section 1 Introduction

Section 2 Principles

Section 3 Overview

Section 4 Scope

Section 5 Registration

Section 6 Location

Section 7 Public Participation

Section 8 Operation, Design, Construction & Mgmt

Section 9 Land Application

Section 10 Emergency Response

Section 11 Record Keeping

Section 12 Operator Certification & Training

Section 13 Closure

Section 14 Inspection, Enforcement, and Nuisance Defense

Section 15 Financial & Technical Assistance

Section 16 Research

The Poultry Industry Environmental Dialogue was initiated in early 1998 to address environmental concerns and issues associated with poultry production. The efforts of the dialogue were broken down into nine (9) work groups, as follows:

Wet processing was placed into a separate work group in recognition of the fact that poultry and egg production has two distinct categories:

This document summarizes the major environmental issues and supporting rationale for wet processing facilities.

In preparing this document, six basic principles have been followed:

This document generally addresses:

5. Certification of operators and training of personnel.

Appropriate and sound environmental management should apply to all commercial wet processing facilities, regardless of the size of the operation.

All wet processing facilities, regardless of size, have a responsibility to protect the environment. Further, no direct correlation between the size of a wet processing operation and its environmental impact has been clearly identified. Small, poorly located and poorly managed operations can have significant environmental effects while large, well located and properly managed operations can have negligible effects. It is important to account for the cumulative effects of all activities in a watershed. If it is decided to establish a threshold for regulation, based on size of an operation, it is recommended that the authority apply this framework to:

Sound environmental management requirements should be applied immediately to all new or expanded wet processing facilities. Existing operations should have a minimum of five years to meet all the recommendations of this document, and should undertake the use of BMP’s, and certain interim compliance planning and reporting steps before that time.

New or expanded operations are the most able to meet recommendations through the prior planning and investment in the operations. Existing operations, however, will need time to adjust to the recommendations. In some cases, requiring existing facilities to meet these recommendations immediately could put producers out of business. Faster action may be needed in cases where a serious environmental problem exists. Deadlines recommended here should be adjusted if there is an existing watershed plan in place that stipulates schedules for action as agreed to by stakeholders.

Flexibility should exist to waive any of the specific recommendations of this document, if alternative approaches or innovative technologies will achieve equivalent levels of environmental protection. Flexibility should also exist to waive recommendations or extend time periods for existing operations based on hardships that may render conformance impracticable.

Technical innovation and experimentation will be critical, in the long-term, to harmonize all agricultural production with the environment. It is essential that any recommendations encourage, reward, and support such technical innovation.

Registration of operations should be handled on a state-by-state basis through the appropriate state regulatory authority.

It is important to consider the cumulative impacts of the siting of all potential sources within a watershed. An inventory of agricultural operations would be helpful in assessing such cumulative impacts. Registration is a way to complete such an inventory. It is recommended that all wet processing facilities register so that planning decisions can be made with more complete knowledge of the extent of all types of potential point and nonpoint sources within the watershed.

Any wet processing operations and any new manure and wastewater storage facility at an expanded operation should be located based on an evaluation of the cumulative effects of site specific environmental factors and the presence of neighboring wet processing operations.

Setbacks from waterbodies, residences, schools, health facilities, or churches should be used:

.

Construction of new residences, schools, health facilities, or churches adjacent to existing wet processing operations should follow setback recommendations comparable to those imposed on the siting of new and expanded wet processing operations.

Public notice, prior to approval or disapproval of a new or expanded wet processing operation, should be given to local residents and others in the community. The public should be invited to comment on the proposed operation and the appropriate regulatory authority should have the discretion to hold public hearings regarding the proposed operation.

Each new manure and wastewater storage facility on any new or expanded wet processing operation should be consistent with the engineering standards and specifications provided by the Natural Resources Conservation Service (NRCS) or the American Society of Agricultural Engineers (ASAE). These facilities should be designed to have sufficient storage capacity to meet their utilization schedule or handle 6 months of waste, and to accommodate a 25-year, 24-hour or a 10 year, 10 day precipitation event, whichever is greater. New or expanded lagoons or earthen basins should have emergency spillways and vegetated buffer areas, or secondary containment basins.

Existing manure and wastewater storage facilities which:

should be considered to meet acceptable standards.

Manure should be applied only to lands with adequate soil sampling and nutrient testing and approved nutrient utilization plans.

Full protection of the environment cannot be achieved in the absence of good management of manure and the land to which the manure is applied. Any new or expanded operation should conduct soil tests and manure nutrient tests every two years and prepare a nutrient utilization plan for all land application areas. Existing operations should have five years after to complete plans. Soil and manure testing, coupled with good nutrient utilization planning, is a good business practice and essential for environmental protection, and should be practices by all wet processing operations.

Acceptable rates of land application of manure should be based on phosphorus rather than nitrogen requirements of crops where soil tests indicate that soil phosphorus has accumulated to levels that are environmentally unsound.

The U.S. Department of Agriculture, in cooperation with State land grant colleges, should establish the maximum, or threshold, phosphorus levels for all major soils based on their capacity to retain applications of phosphorus. If soil tests show that these phosphorus thresholds are exceeded, additional applications of manure should not be made to these lands, beyond the amount that can be taken up annually by the crop or other plants. If soils do not exceed the established phosphorus thresholds, then manure may be applied based on the nitrogen requirements of the crop or other plants growing on the land on which manure is applied.

When soil phosphorous thresholds are established, all operations should have two years to evaluate their soil test results for possible exceedence of the appropriate thresholds. If exceedence, or the likelihood of exceedence within a two year period is observed, new or expanded operations should immediately employ the phosphorous standards to those soils. Existing operations should be given an additional five years to make the adjustments needed to conform with the phosphorus threshold standard.

All wet processing operations should prepare and keep current an emergency response plan.

Even the best designed operations are subject to accidents or weather events that can lead to spills. Planning ahead to avert or manage emergency or catastrophic events is a good business practice and an effective way to protect the environment. New or expanded operations should prepare emergency response plans immediately. Existing operations should have the plan in place within one year.

Each wet processing operation should keep records for the operation of facilities, manure management plans, nutrient utilization plans, and emergency response plans, for a period of three years.

The operator and contractors of each wet processing operation should be certified and should train employees that are involved in management of facilities, land application of manure, and emergency responses.

Even the best designed facilities or nutrient utilization plans can fail if they are not maintained, operated, or implemented properly. Better trained operators and staff mean better environmental performance. Certification of operators and training of employees and contractors are a good business practice, as well as sound environmental management. New or expanded operations should meet the recommendations for certification and training immediately. Existing operations should have two years to meet the certification and training recommendations.

Permanent abandonment of a lagoon or earthen basin by a wet processing operation should be prohibited. Any wet processing operation that ceases operation should close all lagoons, basins, and other manure and wastewater storage facilities, as established by NRCS standards.

Wet processing operations should be inspected regularly.

Periodic inspection of wet processing facilities and records is an effective way to maintain accountability and ensure the public that the environment is being protected.

Federal and State agencies should strive to provide financial and technical assistance to wet processing operations to adopt practices needed to comply with the recommendations of this working document.

Public research institutions and the wet processing operations should encourage and support research on:

Improving the science basis on which regulatory decisions are made, facilities are designed, and management systems are developed is critical to enhancing the environmental performance of wet processing operations in the long run.

ATTACHMENT D

Workgroup Objective - Identify, assess, and promote alternatives to manure management practices based on technical, economic and environmental considerations.

Introduction

It is important to stimulate market-driven strategies to manage manure utilization. There are many opportunities to use market-based strategies (such as market development, tax incentives, education, etc.) which generally rely on adding value to manure. These opportunities are lost when manure policy is driven by a waste disposal strategy.

Future manure management practices will be different from current management practices. Traditionally, any value that has been credited to manure utilization has been related to on-site land application. However, there are numerous alternatives, including emerging processing technologies and utilization options (Appendix 1, "Matrix of Manure-Derived Product Technologies). One dimension in defining manure use is whether the manure is raw or processed. Processed manure typically has a lower environmental risk and also has a greater economic value. The key to successful adoption and deployment of these alternatives is expansion and development of markets for the manure-derived products. (It should be noted that 15 years ago there was no existing demand nor even any projected demand for personal computers. The current demand was a large result of marketing efforts and existing consumers realizing that here was a product that they previously knew nothing about but now must have. Similar scenarios can be envisioned for manure-derived products such as composted litter).

Excess quantities of nutrients in areas of concentrated poultry/livestock production are causing or have the potential to cause environmental problems. Comprehensive strategies are needed for management of nutrients -- including manure-derived nutrients in such areas of concentrated production. Concerns regarding management of these excess nutrients are accelerating interest in alternative uses for manure materials. Effective utilization of manure and other animal byproducts into other processes will remove manure from the environment and reduce the risk to water quality.

Immediate concerns of regulatory and environmentalist constituents call for quick action which is not consistent with the development of effective long-term solutions. (There ar no silver bullets). There are inherent economic risks and environmental risks with both conventional and alternative uses of the product (i.e. there are no "zero risk" management options).

The principal constraints to widespread adoption to innovative/alternative uses are primarily economic, and are based largely on inadequate demand for manure-derived products. Thus, efforts to pursue alternative uses should focus primarily on expanding or developing demand for manure-derived products. In many instances, this will entail "pre-market development efforts" such as increasing the awareness and appreciation of the existence and benefits of manure-derived products to potential users and customers.

Overview: Manure producers have difficulty coordinating raw material with manure product users. There is a need for material aggregation and coordination.

Overview: There are seasonal variations in raw material supply which create a barrier to meeting the product demand cycle.

Overview: A lack of consistent product quality from facility to facility is a barrier to manure product acceptance. There are not well defined characterizations of litter as a product.

Overview: Manure is generally the most problematic when available supplies exceed demand. Resulting policies which enable efficient cost-effective livestock production and sound environmental practices, facilitate industry growth without raising regulatory barriers.

Overview: Manure statutes and regulations must complement industry efforts, not compete. This can occur by shifting from mandating practices to focusing on outcome-based standards.

Overview: We must level the playing field among all states by minimizing the regulatory overhead for all producers.

Overview: The perception that manure is a waste has encouraged rules which link manure producers to the manure transported off-farm. This extended liability is unnecessary and cost prohibitive.

Appendix 2

Jim Wimberly, Foundation for Organic Resources Management

In the past thirty years, poultry and livestock production in the United States has evolved toward larger, confined production facilities. Through rational economic decisions, producers have tended to cluster together in relatively small areas where they can benefit from targeted infrastructural support and, in some cases, incentives used to attract poultry and livestock industries for local economic development. During this period, there have been increasing concerns regarding manure management, particularly in the areas of concentrated poultry and livestock production.

To address these concerns, poultry and livestock producers, working with state and federal assistance agencies and regulatory authorities have developed a spectrum of "best management practices." These efforts have focused almost exclusively on managing manure--or more specifically, the nutrients in the manure--at the farm level. However, there is growing realization that such practices are not always adequate for avoiding water quality impacts in areas or watersheds of concentrated livestock production and high nutrient loading. Innovative strategies are needed to better manage the excessive or problematic portion of the manure/nutrients out of the watershed or area of concentration. Such strategies must be technically viable, environmentally sound, and, to the extend possible, cost-effective.

One option is composting. Through composting, manure is converted into a pathogen- and odor-free, value-added material that is more readily transported off-site and sold into commercial markets--thereby exporting the "problematic" nutrients out of the production area. The feasibility of this strategy is proven, as there are several such operations currently in existence around the country. Thus composting should be recognized and embraced by both public and private interests as a viable strategy for addressing livestock waste management concerns and reducing the potential for nonpoint source pollution in areas of concentrated poultry and livestock production.

Widespread adoption of composting as a livestock waste/nutrient management strategy will entail several steps. Recognizing that production of consistent, high quality compost products is essential for commercial marketing of such products, poultry and livestock producers should work together--perhaps by forming a feedstocks cooperative--to create a large composting enterprise that can realize economies of scale. Whether centralized or de-centralized, the regionally coordinated enterprise should engage professional composting expertise for the production and marketing functions. Moreover, establishment of a professionally managed composting operation will provide opportunities to obtain other organic wastes that can be co-composted. Many such feedstocks, e.g., agricultural or food processing residues, have negative values ("tipping fees") which will enhance the economic viability of the overall operation. In addition, coordinated composting operations may be able to benefit from state/federal assistance programs, such as the USDA's Environmental Quality Incentive Program. As an organics waste management strategy, coordinated composting operations can provide significant economic and environmental benefits to poultry and livestock producers and their surrounding communities.

Appendix 3

Andy Walker, West Virginia Soil Conservation Agency

The steps to be taken in the development of a litter marketing operation should be:

Mark W. Jenner, American Farm Bureau Federation

Traditionally water quality policy has focused on excessive deposition of pollutants, or wastes, in the waters of the United States. For the U.S. livestock industry, this was defined through Concentrated Animal Feeding Operations (CAFO). The National Pollutant Discharge Elimination Systems (NPDES) permits monitor and control the pollutants discharged into the waters of the U.S. for CAFOs, the base standard for discharge was set at zero.

Our nation's overnight public policy on all animal manure treats it as an environmental liability. This acceptance of manure as a liability creates a chronic problem for the industry. Complying with regulatory demands that view manure as a liability costs the industry dearly. Manure rules that focus narrowly on controlling manure as a waste, create a barrier to developing manure into a revenue-generating resource.

While Clean Water Act livestock policies are directed at limiting pollution, excessive discharges, and wastes from the waters of the United States, these policies are the direct result of the animal agriculture's under-developed manure utilization strategy. The livestock and poultry industries have designed very effective least-cost waste disposal systems, but those systems are focused more on the concepts of disposing and containing manure rather than using it. Without an associated positive value, manure is only viewed as a liability.

Waste-oriented public policy, compounded by industry reliance on a least-cost disposal, perpetuates manure's image as a chronic liability. To make matters worse, expansion of current clean water regulations related to livestock (CAFO and AFO policies) will codify manure into law as an environmental liability, with little or no opportunity to transform manure into a beneficial resource.

Waste disposal is an important component of public policy, but must not be the only policy thrust. To truly be successful, the central thrust on manure management must be on resource development and on incentives to fully utilize manure.

Policies which reduce compliance costs. Waste disposal policies based on cost reduction, take on a number of forms. Tipping fees are one mechanism for which waste handlers receive payment for taking responsibility for disposing of wastes. Permit trading is another policy tool which allows operators with little environmental risk to be rewarded by operators with greater environmental risk. Tax incentives and cost share programs are cost management policies. The use of penalties for committing environmental crimes increases the cost of production and is a disincentive to pollute for cost minimizing producers.

Policies which add value and enhance utilization. The solution to livestock environmental risk reduction is to develop public policies which completely utilize all organic residuals as resources into new products. Policies that characterize manure components of concern will also create new information about the composition of various manure products.

As the end-use value of manure increases, the ease of transportability also increases. One Virginia manure broker reported that he could haul fertilizer-grade broiler litter 150 miles, while he could afford to haul feed-grade broiler litter 300 miles. It was recently reported (Andy Walker) that West Virginia litter is successfully processed (composted) and marketed to the mushroom industry in Pennsylvania more than 500 miles away from the poultry house, point-of-origin.

All manure products do not have value. Quality compost or methane for energy has more value than anaerobic lagoon effluent or odor. All are manure products. To gain the most value, three things must happen: 1) manure producers must have a quality product, 2) manure consumers must have a mechanism to know the value of available manure products, and 3) the regulations and statutes must champion this market not create a barrier to manure market transactions. With these factors in place, manure will be utilized and environmental risk will be reduced.

When a manure producer follows a resource maximization strategy rather than a waste minimization strategy, opportunities for revenue emerge.

Technology standards or practices are ineffective. Prescriptive practices or technology standards, are input policy controls. In cases where information is limited, control of inputs is chosen to influence a desired output. This innocent, historical strategy is easy to incorporate into rules, but is also inefficient.

Technologies and practices are tools of management, but rules based on animal units (AU) or best management practices (BMP) don't work the same. As rules, these management tools serve only as proxies for water quality objectives, build scale effects, codify management, create a disincentive for innovation, and in the end, may not even come close to enhancing water quality.

When these practices are used in conjunction with a waste disposal policy strategy, manure is codified as a waste and innovative, on-farm research becomes criminal.

Outcome-based performance standards reflect policy objectives. Performance standards shift the focus to an outcome, rather than an input. "Zero discharge" is a performance standard. With a performance standard, a business or enterprise can manage their activities and balance their resources to meet that performance standard.

Performance standards create useful information. Whether the information is positive or negative it is still useful. It creates local flexibility and opportunities to innovate. Used in conjunction with value-adding manure policy programs, performance standards can inspire creativity. This useful information created, can enhance market development. The regulations and standards that define commodities and feed labels are outcome-based performance standards.

Currently, there is a lack of product quality guidelines and standards, particularly regarding manure-derived soil amendment products (e.g., pellets and compost). Absence of such standards enables inferior quality to compete with superior quality products in the market. This creates an economic disincentive to produce quality products, and at the same time, erodes consumer confidence in purchasing additional manure derived products.

There is a richer understanding about effective water quality policies, now than 25 years ago. It is imperative, for the survival of our livestock and poultry industries to enhance water quality policy by adding value to manure resources rather than codify manure as a waste.

Jay Sennett, Gulf-Tex (Virginia)/Bay Saver Inc.

Litter and manure has many uses in commercial and consumer markets. A solution to the problem will be in identifying the potential end markets and uses for the manure and litter. No one solution will be effective in moving the problem from a waste control issue to one of a commodity product. Production of blended natural organic fertilizers, manure and soil amendment products are one part of the solution. The US lawn and garden market in 1997 totaled $27 billion in 1997, an 18% increase over 1996. Participation in lawn and gardening was up 5% in 1997 to 68 million households with an increase in average expenditures up 9% to $385. Outdoor Fertilizer use increased to 24 million households in 1997, up from 23 million in 1996. Use of soil amendments/mulch remained flat at 31 million households. Home and Garden Centers continued to be the leaders in point of consumer purchases.

Lawn and garden retail sales increased in all US markets except New England and East Central.

The major demographics of lawn and garden retail purchasers are as follows:

Poultry litter and other animal manure can be processed for the lawn and garden retail market under a few categories: Manure; Natural Organic Fertilizer: Topsoil (compost). 5.4 million households purchased manure classified as outdoor fertilizer. 2.6 million households purchased natural organic fertilizer. 14.4 million households purchased topsoil. 15.3 million households purchased Peat Moss/Soil Amendments. Furthermore, purchasers of all the above products were most prevalent among city and rural dwellers, college-educated households, households with $30,000 or more in income, Midwest and West households (East and South purchasers were also significant but were lead by the Midwest and West). This data is summary and more specific information is available for companies seeking to conduct an in-depth evaluation. However, based on the above data, it can be assumed that with effective processing, packaging and marketing, the consumer lawn and garden market holds excellent potential for absorbing a portion of the animal manure generated in this country. This accompanied with industry sponsored promotions could very well be effective in expanding the markets for these products. More detailed research is needed for the commercial lawn and garden market as well as the feed markets both domestically and internationally.

*All data provided above was provided by the national Gardening Association and Gallup Organization from their report The 1997-98 National Gardening Survey.

Educational and training programs for members of the poultry industries (this term includes the allied industries), as well as for university and government personnel, are necessary to ensure all participants are fulfilling their environmental responsibilities to the best of their ability. Formalized communications between members of the poultry industries, between these industries and the general public, and between these industries and government personnel are essential to the creation of a team approach to solving our ever-changing, yet persistent, environmental challenges. Education is a time consuming, and potentially costly process. For example, best cost estimates for education, training and communications programs for all segments of the industry be several million dollars, or they could achieve this level through the value of in-kind support.

As the world continues to demand greater quantities of high quality animal based foods, there will be even greater concentration of animal units, and thus even greater environmental challenges. The USA is in a position to not only develop programs that protect our environment for future generations, we can positively influence the environmental policy for the rest of the world.

The Education, Training and Communications Workgroup has provided guidelines for the development of aggressive and effective programs on issues defined by the other workgroups. Because situations change from issue to issue, and over time, specific methods and other details should be part of the programming defined by the other workgroups. All activities are intended to be on-going and long-term, so are provided in general terms. Specific details as to what projects or educational efforts need to be provided in a particular watershed or other area (e.g., who will be responsible for various activities), and the time-frame in which items will be completed is often site specific and thus outside the purview of this committee. The important consideration is development of advisory committees and an overall council to make these decisions. Construction of a communications plan/time-line example is provided within this Appendix, but specific details would need to be established by regional or other advisory councils or committees, or individual companies. Significant professional assistance is available from the land grant university system to aid in development of programs.

To support the generic ideas for the education, training and communications programs, and to initiate independent discussions by the proposed advisory committees and the national advisory council, an example process for program development has been provided. A section on electronic databases (CRIS, and AGRICOLA) has also been included to ensure familiarity with these educational resource options.

The industry actively promotes effective programs to address environmental issues, which include:

There have been instances where confusion has existed within the regulated community regarding the interpretation of federal and state environmental regulations and base legislation. A few states are ahead of the curve regarding compliance issues, and some regulations impact the poultry and animal industries more than others. Educational meetings held with the industry to explain the regulatory process, as well as environmental protection concepts, from both the state and federal perspectives would greatly enhance the industry's comprehension and capacity to fulfill their responsibilities.

The need to educate all poultry personnel--growers, independent operators, integrators, and allied industry--is paramount. A convenient and practical way to do this can be through the integrated companies, because they typically have environmental personnel on staff who can disseminate facts and materials. Independent producers must also be provided relevant and timely information, with the understanding that their time and other resources may be more limited than vertically integrated companies. The Cooperative Extension Service (CES) and Natural Resources Conservation Service (NRCS) can take a large role in this process. Government officials and the public are other important audiences of educational programs.

Information presented by the print and electronic news media must be science-based, and not an automatic accusation of wrong-doing by the industry. The industry must provide the media with objective, science based information, facts about the industry's environmental track record, and maintain open lines of communication for honest exchanges of information. As an industry that recognizes its role in being environmentally friendly, we must do a more effective job in communicating that commitment. The media needs credible sources of information to avoid oversimplifications and errors.

Educational and training programs, backed by fair and effective regulatory action, will help to reinforce high credibility and to create trust in our agricultural system. The media must be educated about our industry and its commitment to environmental protection. Response Teams must be the source of objective and accurate information, both proactively and to correct misinformation.

In addition to explaining to the public what agriculture is doing to minimize pollution (as well as what we have to do)--we must help government officials at all levels understand and appreciate the efforts and progress agriculture has made for years. We need to focus on specific successes and challenges. Communicating our long-term successes to agency personnel and the general public is essential. Some agency personnel believe that voluntary programs are not as effective as regulations. If true, it's time to discuss changes that would encourage greater compliance to ensure environmental protection.

USDA and EPA must cooperate in understanding the environmental problems farmers face and their individual contributions (this assumes the ability to partition the nutrient load and the existence of baselines for various nutrient sources). To answer this issue, EPA, USDA, other agencies, and agricultural industries must work together to define needed legislative changes to improve maximum and long-term environmental protection. For example, successful lagoon maintenance must be tied to a regular inspection and maintenance system, which may require legislative changes.

Effective Nutrient Management Plan regulations that address long-term protection of the environment--- as opposed to strict reliance on current laws---demand a systematic approach to nutrient management. All sources of nutrients must be accounted for on each farm. It is crucial that we get information out to media, regulators, and citizens on the numbers and kinds of programs that train farmers in NMP design and compliance. Other pollution prevention measures and successes also must be communicated. The goal for compliance with NMPs is 100 percent of all farms, regardless of size or source of nutrients used as fertilizer.

Another area of concern that appears to many as antiquated and inherently inaccurate, is the Animal Unit designation. Other countries have instituted a system of defining animal units (by species and age) by nutrient output levels for each animal. This system has stimulated innovative responses to reduce nutrient loading of waterways, something not possible under the current USA system. The output based option of defining animal concentrations will stimulate the use of alternative management practices and rations provided the animals, with the intent of reducing nutrient output by the animals. This reduction in nutrients in the manure and urine of animals will reduce the nutrient loading on available land and reduce the amount of land required to raise animals. There is agreement that agriculture in the USA needs the stimulative effect of conversion to outcome-based programs, as opposed to the current reliance on in-put based regulations. Under current regulations, animal units are input-based,

making it difficult (if not impossible) to develop outcome-based recommendations and programs. A strong research program is necessary to evaluate this option, and a strong communications and educational program is necessary to train personnel and to discuss the results of using these programs.

We must be proactive and positive when communicating the industry's position on environmental issues, presenting success stories, or addressing our failures honest