Comprehensive Nutrient Management Planning for Your Production Facility
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By Lara B. Moody and Robert T. Burns, Department of Agricultural and Biosystems Engineering
The Comprehensive Nutrient Management Plan (CNMP) concept has been developed by the U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) to be an overall conservation plan addressing all aspects of an animal feeding operation. Additionally, the Environmental Protection Agency (EPA) recognizes that CNMPs address the requirements of the Nutrient Management Plan necessary for the maintenance of a National Pollutant Discharge Elimination System (NPDES) permit.
The USDA requires animal production operations obtaining financial and technical assistance funds for the implementation of conservation programs to have a CNMP.
In 2002, the Farm Security and Rural Investment Act (Farm Bill) increased the amount of conservation program funds available to animal feeding operations, and introduced the certified Technical Service Provider (TSP) as a source of technical assistance for producers. Through the Farm Bill, producers can contact a TSP, request the development of CNMP and then may be reimbursed for a TSP’s services with conservation program funds, if available.
What is a CNMP?
A CNMP is a conservation system developed in accordance with NRCS planning policy that addresses all aspects of an animal feeding operation. Though there may be similarities between developed CNMPs, each one is unique to a particular production facility. The six basic elements addressed in a CNMP are:
1. Manure and Wastewater Handling and
2. Nutrient Management
3. Land Treatment Practices
4. Record Keeping
5. Feed Management
6. Other Utilization Activities
Addressing these six elements will assist the producer in meeting soil and water conservation goals as well as reducing the potential and actual threats to water quality and public health from their operations. As defined by NRCS, a CNMP is a group of conservation practices and management activities that when implemented as part of a conservation plan will help ensure that both production and natural resource protection goals are achieved. The potential impacts of soil erosion and manure on water quality are a key natural resource concern.
Elements of a CNMP
While all six elements should be considered by a producer, and documented accordingly, they do not all have to appear within the CNMP. At a minimum, the plan should address actions pertaining to a facility’s production area and the land on which the manure and organic by-products will be applied. This means that if an operator applies manure to his crop production area, the plan should at least cover elements 1-4 as listed above.
Manure and Wastewater Handling and Storage
This element addresses issues concerning structures and other areas within a production facility used for manure transfer, treatment, and/or storage. Within this section, the CNMP should identify concerns and provide documentation of adequate manure collection, storage and/or treatment to allow for land application of the material, as well as for dead animal disposal. In addressing these concerns, the CNMP should also take air quality and pathogens into consideration.
This element addresses issues concerning the land application of manures and all other nutrients amended to production fields related to the livestock operation. The CNMP will show how to implement land application procedures in a way that minimizes the potential adverse impacts to the environment and public health. Consideration should also be given to air quality, pathogens and salt and heavy metal build-up (that may result from application of manures in some regions).
Land Treatment Practices
This component addresses erosion and runoff from fields or other locations on the farm. Within this section conservation practices affecting the land application site are evaluated and implementation procedures are discussed.
This element is essential to the implementation of a CNMP. Records document and demonstrate that activities associated with the CNMP have been implemented.
It is the responsibility of production facility owner/operators to maintain the required records.
This component is not a requirement of a CNMP, but feeding strategies should be addressed if they are needed to reduce manure nutrients generated in excess of available crop nutrient requirements. A professional animal nutritionist should be consulted if feed management alternatives are being considered. Strategies may include phase feeding, amino acid supplemented low crude protein diets, the use of low phytin phosphorus grain and enzymes or simply reducing nutrients that may currently be fed in excess of animal needs.
Other Utilization Activities
When available manure nutrients exceed crop requirements or where land application of manure would cause significant environmental risk, alternative uses should be considered. Feasible alternatives should be selected that are equally as cost-effective as land application if possible. Because these alternatives are not conventional, industry standards do not always exist, and NRCS conservation practice standards may not be available.
Purpose and benefit of a CNMP to a producer
When implemented, a CNMP should help ensure that animal and crop production as well as natural resource protection goals are achieved. Because a CNMP uses conservation practices to beneficially use animal manures, it also assists animal feeding operations in meeting regional and federal water quality goals and regulations. There are many ways a producer can benefit from the development of a CNMP for his/her facility.
- A CNMP has the potential to be recognized as an EPA NPDES nutrient management plan
- The CNMP development process assists a producer to assess possible production and water quality protection concerns at the operation
- The cost of a CNMP developed by an NRCS certified TSP may be reimbursed by USDA and the CNMP can be used to meet an EPA NPDES nutrient management plan requirement
- A CNMP is a tool that will help develop a sustainable operation
In 2003, when the EPA revised the NPDES effluent limitation guidelines, it updated the rule that affects concentrated animal feeding operations CAFOs. As part of the rule change, a very clearly defined nutrient management plan is now required as part of the permit. While the defined nutrient management plan is not outlined similarly to the six possible elements of a CNMP, it does address many of the same issues. Though there may be some state specific differences between CNMPs and EPA nutrient management plans, the key difference is that a CNMP is required to be developed by an NRCS employee trained to prepare them or an NRCS certified TSP. When prepared by a TSP, fees for services may be reimbursed through guidelines outlined in the 2002 Farm Bill.
How can a producer obtain a CNMP?
A producer can choose to have a CNMP completed by an NRCS employee or a certified TSP. If a producer chooses to have an NRCS employee develop a CNMP for his or her facility, there may be a waiting period involved due to other NRCS commitments. Alternatively, a producer may choose to hire a TSP who can provide the services in a shorter time frame. To use a certified TSP whose services will be reimbursed, a producer must first sign up for NRCS’s Environmental Quality Incentives Program (EQIP). The District Conservationist in the area NRCS office will be able to assist you in the process. A Web site for the TechReg program (www.techreg.usda.gov) provides information the producer can use to select a TSP; The District Conservationist can also provide you with a list of TSPs active in your area.
Services provided by TSPs are reimbursed based on “not-to-exceed” rates (NTEs) developed by NRCS. The producer and the technical service provided can negotiate service fees. However, fees in excess of the NTE must be compensated by the producer. Not-to-exceed rates can be determined for a given service using the rate calculator on the TechReg Web site.
Additional Sources of Information
The USDA has three publications that provide more information about comprehensive nutrient management plans.
USDA-NRCS. Comprehensive Nutrient Management Planning Assistance Available from Technical Service Providers. http://www.nrcs.usda.gov/programs/afo/2003pdf/TSP%20CAFO%20Fact%20Sheet.pdf
USDA-NRCS. CNMP Fact Sheet obtained from USDA-NRCS Web site on 8/19/05. http://www.nrcs.usda.gov/programs/afo/pdf/CNMPFactSheet.pdf
USDA-NRCS. 2003. Part 600.5 - Comprehensive Nutrient Management Planning Technical Guidance. National Planning Procedures Handbook. http://www.nrcs.usda.gov/programs/afo/cnmp_guide_index.html