Farm planner has faith that state's system works

by Citizen Staff

Saturday, August 18, 2007 11:33 PM EDT

By What's in a Concentrated Animal Feeding Operation, or CAFO? Certified Agricultural and Environmental Management planner Brian Boerman of Agricultural Consulting Services, Rochester, recently answered some questions by e-mail.
Q: What does a state-certified planner like Agricultural Consulting Services do for farmers? What general areas does ACS cover?

A: Companies (ACS) are not AEM certified planners in New York, individuals are. Professional agronomists (certified crop advisors) undergo training and an extensive planner review process to receive recognition from the state Department of Agriculture & Markets and U.S. Department of Agriculture Natural Resource Conservation Service as a certified agriculture environmental planner. ACS employs several AEM certified planners..

Q: To help people better understand how Comprehensive Nutrient Management Plans, or CNMPs, work, what general principles are applied to most or all concentrated nutrient management plans? What are some examples of practices included in CNMPs?

(A CNMP is developed using USDA Natural Resources Conservation Service guidelines.)

A: The USDA NRCS lists a waste management system/storage, crop rotation, residue management, filter strips, nutrient management, feed management, manure transfer, waste utilization, barnyard water management system and record keeping.

There are some general practices that apply like nutrient management planning, which in general balances all fertilizer inputs with crop needs and environmental indices are captured by (state code).

A CNMP is not in itself a CAFO permit. A CNMP can serve as the backbone of a State Pollutant Discharge Elimination System (SPDES) permit for a CAFO but would not meet what the state Department of Environmental Conservation requires for SPDES coverage. Two examples of the differences would be that a CAFO permit is developed by an AEM certified planner and the extensive record-keeping is required by a CAFO permit.

Q: Concentrated animal feeding operations have been required to follow CNMPs in New York for about a decade now. In your experience and opinion, how can the general public be assured these plans are working to protect the environment?

A: The DEC is employed by the general public to regulate and enforce CAFO permit law and administer the Clean Water Act on CAFOs in New York.

Cornell University (the land grant university for New York) and USDA NRCS along with others have developed standards specific to New York and the CAFO permitting process that serve as the basis for CNMP development in New York.

Q: What state or federal agencies oversee private contractors like ACS? Do representatives of those agencies conduct regular evaluations of CAFO planners or do some type of independent inspections?

A: Oversight is given to AEM certified Planners through several sources. One is the requirement that all planners are also members of the Certified Crop Adviser program (CCA), one of the professional certification programs offered by the American Society of Agronomy (ASA). CCA is a voluntary program providing a base level of standard through testing and raising that standard through continuing education.

Each CCA had to pass two exams (international and local) and submit credentials detailing their education, crop advising experience plus two references. They must sign and adhere to a code of ethics. The exams cover four major competency areas: nutrient management, soil and water management, integrated pest management and crop management. Continuing education must also fall into one of these four areas to be valid for CCA Continuing Education Units. To maintain the certification, the CCA must earn 40 hours of continuing education every two years. The program has averaged a 94 percent renewal rate.

The New York state Department of Agriculture and Markets and USDA NRCS certify individuals as agricultural environmental planners after required classroom/field training and a three-plan review process.

In addition, ongoing certification as an AEM planner is contingent upon maintenance of CCA status and the recertification through the AEM Planner Quality Assurance Review Program on a yearly basis. Direct oversight for this program is provided by the AEM Certification Subcommittee, a partnership of the New York state Soil and Water Conservation Committee, Cornell University, NRCS, DEC, CCAs and the northeastern region of the American Society of Agronomy and other AEM stakeholders.

Q: New York is often recognized as one of the strictest states in terms of environmental protection from agriculture. What puts the state a cut above others in terms of regulations?

A: Administration/regulation of the Clean Water Act is the job of each state and states have chosen to regulate livestock facilities differently. New York chooses to regulate all facilities greater than 200 cows, 150 horses, 2,000 sheep, or 750 swine, while many states set regulatory levels of 700 cows, 500 horses, 10,000 sheep and 2,500 swine. In so doing, a greater percentage of livestock operations in New York have been required to have CNMPs developed and are regulated than in other states.

The state Agricultural Environmental Management Program is the huge strength of the CAFO permitting process. New York's AEM program is a required piece of CNMP development, which helps farm operators make common-sense, cost-effective and science-based decisions that help meet business objectives while protecting and conserving the state's natural resources. Strong partnerships at the local, state and federal levels have led to the growing success of AEM, linking existing agricultural and natural resource service agencies together with the farmer as a cooperative team. As the umbrella program for all of New York's agricultural conservation efforts, AEM also lays the groundwork for participation in other state, federal and locally administered programs. With close to 10,000 farms enrolled in 54 counties across the state, AEM is continually expanding as new assessment tools are tailored to meet the needs of all types and sizes of agricultural operations.

The evidence that New York state is adhering to some of the most strict interpretation of the Clean Water Act is all around us. Perhaps the most recent example is with the U.S. Environmental Protection Agency's decision last month to roll back full implementation for CAFOs to Feb. 27, 2009. The DEC was against the further rollback of implementation dates from the onset and still has not recognized this move by the EPA. New York currently requires full implementation for large size CAFOs as of March 31, 2006, over two years ahead of EPA standards.

In addition EPA won't commit to any deadline for implementation on medium-size livestock facilities (less than 700 cows, 500 horses, 10,000 sheep or 2,500 swine) while New York state expects these facilities to be in compliance by June 30, 2009.

The Citizens' Say

There are 1 comment(s)

Farmer's Gal wrote on Aug 20, 2007 7:56 AM:

" Answer these if you can: Why are CNMPs secret documents? If they are so good and safe, why do CAFOs hide them? In Vermont, they are public documents. How often does the DEC actually inspect CAFOs? What does the inspection prove -- the CAFO's self-kept records can be checked against their self-kept CNMP, but how can anyone say if the information in the records are accurate? How can citizens protect themselves against the overspreading of manure if we are not allowed to know how much has been deemed safe for a given field? We are supposed to trust the people who have decided that spreading human waste on fields is OK? We're supposed to trust Cornell, who is in the back pocket of the CAFOs in NYS? Give us a break and have a little more respect for our intelligence. Again I say -- the regulatory process at its best doesn't work, and when it is kept secret from the public, it's even worse than that. Let's have a little sunshine on those NMPs, like they have in Vermont.... "

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