Stay ahead of the environmental curve

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Society is demanding that more attention be placed on environmental stewardship. To meet this increasing demand, environmental regulations are evolving across the country.

Dairy producers in the San Joaquin Valley of California are working to meet some of the most stringent water-quality and waste-discharge regulations. In Oregon, dairy producers are required to have a National Pollutant Discharge Elimination System permit to operate, no matter the operation size. Idaho dairy producers are required to manage phosphorous applications to the soil.

Regulations vary state by state, but no matter where you are located they can be challenging. A tool to help you navigate the road to compliance is a comprehensive nutrient management plan, or CNMP.

Have a plan

You may argue that you already have a plan to manage the nutrients from your manure, you already do a good job, and a CNMP isn’t necessary. However a nutrient management plan and a comprehensive nutrient management plan are not the same. “A nutrient management plan is a term used very loosely in the industry, and is literally a plan to manage your nutrients,” says Joe Harrison, dairy scientist at Washington State University. “A comprehensive nutrient management plan is a detailed plan that looks at your entire operation. And, regardless of your herd size, you can benefit from having one.”

Historically, only the crop nutrient management component has been considered in most environmental plans. Yet, a CNMP addresses these six areas: manure and wastewater handling and storage, land treatment practices, nutrient management, record-keeping, feed management, and other utilization options.

“This systematic approach to evaluating your operation identifies if there are environmental issues on your operation — both potential and actual threats,” says Jennifer Zwicke, environmental engineer with USDA Natural Resources Conservation Service in Oregon. “Once the issues have been identified, you can develop a plan of action to address them — a proactive instead of reactive approach to regulations.”

“A CNMP moves beyond individual field management and looks at improving efficiencies on the entire operation,” Zwicke says.

Meet and exceed regulations

“When the new waste-discharge regulations in California came into effect, dairy producers who had a CNMP already met some of the new requirements,” says Dan Johnson, an engineer specializing in waste management with the USDA Natural Resources Conservation Service in California.

“We were definitely ahead of the game when it came to the new regulations,” says Len Baker, owner of VL Furtado Dairy Facility in Hanford, Calif. Baker developed a CNMP for his 850-cow dairy four years ago.

“A CNMP goes a long way in meeting environmental regulations,” Johnson says. In fact, the U.S. Environmental Protection Agency recognizes the value of CNMPs and how they address the requirements of the Nutrient Management Plan necessary for the maintenance of a National Pollutant Discharge Elimination System permit.

Wym Matthews, confined animal feeding operation program manager with the Oregon Department of Agriculture, says if you are going to go through the effort to develop some type of nutrient management plan, develop a CNMP — you only stand to benefit.

The feed-management portion of a CNMP will become increasingly important as environmental regulations continue to evolve. Feed management can assist with reducing the import of nutrients to the farm and reduce the excretion of nutrients in manure. Feed management is not a required component of a CNMP, but it can be an effective approach to reducing nutrient excretion.

Environmentally sustainable

Nutrient management on dairy operations has become more complex.

“If you are looking at being in the dairy business long-term, you have to look at the long-term sustainability of your operation, and a CNMP will help you do this,” Harrison says.

A CNMP should serve as the environmental operation plan for a dairy. It should detail the management practices for minimizing the impact of nutrients and manure on soil, water and air resources. It can also be used to guide management decisions and convey desired outcomes to all participants in your operation (owner, manager, employees and advisers. This same plan should also convey the management strategies employed to appropriate regulatory agencies.

Actual data can be very powerful. “Instead of saying you’re doing the right things, the record-keeping with a CNMP provides documentation that you are doing the right things,” says Matthews.

A tool to grow your business

If you are considering an expansion or building a new operation, a CNMP can answer manure-management questions, Zwicke says. How will waste be handled? Where should the manure-management system be located on the operation? What is the most efficient design? The answers provided with a CNMP will help you minimize your risk with regard to nutrient management, air quality and water quality.

Financial benefits

In addition to environmental benefits, a CNMP creates financial benefits as well. Financial benefits accrue from improved operational efficiencies, improved utilization of nutrients from manure, reduced fertilizer costs, improved feed production, and possible funding from the Environmental Quality Incentives Program (EQIP) program.

“We have benefited in many ways since developing a CNMP for our operation,” Baker says. “Financially, we have gained because we have been able to cut back our commercial fertilizer purchase by more than 20 percent. The cutback came as a result of soil and wastewater testing. We are no longer guessing on the amount of fertilizer we need to grow our crops, but applying based on the needs of the crop.”

“In addition to improving our nutrient management, we have been able to apply for EQIP dollars,” Baker says. “We have received EQIP dollars on four different occasions. Each time, EQIP paid for 50 percent of the project, giving us the opportunity to make improvements on our wastewater storage at a much lower cost.”

EQIP funds can be used to make improvements on your operation, and a CNMP is required for participants seeking funding. “If you work with your local Natural Resources Conservation Service office to develop a CNMP, the plan is generally done at little to no cost to the dairy producer and you work with a team of experts who will bring ideas to the table,” Zwicke says.

“The financial benefit we’ve gained is nothing compared to the knowledge that we have developed an environmental plan that will allow us to be in existence for the next 25 to 30 years,” Baker says.

Don’t let environmental regulations overwhelm you. Develop a comprehensive nutrient management plan to help you navigate the road to compliance.  


How to develop a comprehensive nutrient management plan

The process will vary to meet local needs and individual operations, but it will typically include:

  • A dairy producer requests assistance to develop a plan.
  • A planner (who may be a Natural Resources Conservation Service staff member or someone else selected by the dairy producer) visits the dairy to gather information and to discuss the producer’s objectives. This typically takes two or more visits.
  • The planner develops maps of fields and facilities and completes initial evaluations.
  • The planner meets with the producer to discuss: (1) Initial evaluation results; (2) Alternatives to address potential problems; (3) Actions the dairy producer chooses to implement. This may take multiple visits.
  • The planner makes any needed revisions and assembles the plan into a user-friendly format.
  • The planner and the dairy producer review the comprehensive nutrient management plan and make plans for implementation.


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