How to Convert Existing NRCS Comprehensive Nutrient Management Plans (CNMP) to an EPA-Required Nutrient Management Plan (NMP) Glorieta Geoscience, Inc. PO Box 5727 Santa Fe, NM www.glorietageo.com

BACKGROUND NRCS CNMP vs EPA NMP Everyone, including us said it was going to be easy…………………… Lets see how easy it is……

BACKGROUND NRCS CNMP vs EPA NMP NRCS CNMP A grouping of conservation practices which helps makes sure that the production and natural resource protection goals are achieved EPA NMP A regulatory document, an NMP is used to determine the suitability of fields to receive manure as well as rates and timing of applications

CNMP vs NMP Requirement CNMP vs NMP Requirement A CNMP is not a regulatory document. Required by NRCS to meet the requirements of EQIP (Environmental Quality Initiatives Program) contract An NMP is a regulatory document. Required by EPA to be submitted with NOI for obtaining coverage under Region 6 CAFO General Permit

CNMP vs NMP Sections NRCS CNMPEPA NMP 1Facility Information 2Safety and Emergency Action Plan Safety and Emergency Action Plan (EAP) Additional EAP language need to be added, for Lower Pecos, Middle and Lower Rio Grande dairies 3Objectives and Resource Concerns Not a specific requirement major emphasis on proximity to Surface Waters 4Inventory Analysis and Alternatives Storage Site specific Conservation Practices Manure, Litter, Process wastewater and soil testing 5Plan Summary of decisionsAdditional details need to be added to Nutrient Management section; choice between liner an d narrative approaches 6Job sheetsNutrient Management 590 with Summary and projections 7Operation and Maintenance Plan Required

CNMP vs NMP Sections CNMP vs NMP Sections NRCS CNMPEPA NMP 8Record KeepingRecord Keeping, Animal Mortalities 9PermitsAddressed in record keeping 10Not a specific requirement, handled in Inventory Analysis section, Weekly inspections not specifically required Diversion of clean water (weekly inspections records) 11Not a specific requirementPrevention of Direct animal contact with Waters of the Unites States (measures to prevent) 12Not a specific requirement, handled in Emergency Action Plan Chemical Handling 13Certification required in Facility Information section Certification is a separate section

New Sections need to be added to a CNMP Chemical Handling Prevention of Direct Animal Contact Diversion of clean water Emergency Action Plan for Lower Pecos and Lower and Middle Rio Grande CNMP sections that require additional information Nutrient Management Emergency Action Plan CNMP vs NMP Sections

Level of difficulty for updating CNMP sections Fairly straight forward sections Chemical Handling Prevention of direct animal contact Emergency Action Plan Fairly complicated sections Nutrient Management

EPA Nutrient Management Plans Nutrient Uptake in Land Application Areas The “linear approach” expresses field-specific maximum rates of application in terms of the amount of nitrogen and phosphorus from manure, litter, and process wastewater allowed to be applied The “narrative rate approach” expresses the field- specific rate of application as a narrative rate prescribing how to calculate the amount of manure, litter, and process wastewater allowed to be applied.

EPA Nutrient Management Plans Select a nutrient management approach Linear (maximum application rate) –Prepare additional 590 NM jobsheets for all possible cropping patterns in the next five years Narrative (narrative application rate) –Prepare a summary of 590 Nutrient Management jobsheets per the selected approach

EPA Nutrient Management Plans The linear approach sets fixed rates of nutrient application based on a cropping system that is fixed in the plan. Just about any change: crops grown, soil fertility or manure nutrient analysis results will require that the NMP be resubmitted for further review and re-approval. The narrative rate approach requires the CAFO to specify in their NMP as a term of the permit the method by which they will calculate the year-by-year actual manure application rates for each field, using up-to-date field specific information and consistent with sound agronomic use. As long as the producer applies manure to those fields using year-by year field-by-field analysis, and these methods and crops are specified in the original NMP, no subsequent NMP review and approval is needed.

Who is Eligible to Prepare NMP? NMPs need to be prepared by a NRCS certified technical service provider –CAFOs located in NM (except Indian Country) shall use a “Certified Conservation Planner – CNMP” to develop and/or modify NMP. (Part III A.8 NMG010000) –Applicable documents to prove that the CNMP developer had the qualifications of a certified planner need to be included.

Conclusions Converting an existing CNMP to an NMP is a work intensive process especially for those CAFOs that have land application Choosing between Narrative and Linear approaches must be done carefully considering all factors specific to your CAFO

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