Introduction: The second Pennsylvania CAFO Stakeholders Workgroup meeting for updating the current Program to meet the new EPA requirements was convened at 9:05 a.m. After an introduction of participants and an open comment period, the summary of the March 19, 2003 meeting was accepted. The discussion primarily focused on the operation categorization. Here is a listing and discussion of the main points.
Large CAFOs: A report was given on the Animal Numbers Subcommittee activities, which included a framework for dealing with large CAFOs. The framework includes concepts from PA’s current Program and the new EPA rules. The exact proposed framework wording is as follows:
Large CAFOs:
- Determine the operation’s AEUs
per PA's nutrient management regulations for all finishing and nursery swine,
all poultry, and veal located on the operation; if the total AEUs are greater
than 300, this operation is a large CAFO.
- If the above-calculated AEUs are less than 300 and the total AEUs for all
animals located on the operation is less than 1,000 AEUs, this operation may
be a medium CAFO.
- If the above-calculated AEUs are less than 300 and the total AEUs for all
animals located on the operation is greater than 1,000 AEUs, this operation
is a large CAFO.
Many participants appeared to accept this approach as being workable. Several additional comments were provided. The EPA representative said that many of the public comments during EPA’s rule development were against the idea of mixing animal types and groups; doing the large CAFOs as written and customizing the medium program would be a good approach; pullets and other small chickens did not have to be directly addressed; using AEUs and the current methods instead of the new animal numbers needed more review; and an important aspect of the new EPA rules is dealing with excess manure and P better. Other participants stated that program should “avoid backsliding” and maintain current coverage levels; the practice of mixing animal types and groups is much more common in Pennsylvania than in other states; it is important to maintain coverage in “Special Protection” watersheds; the new rules provided an opportunity for change, such as more equitable targeting and addressing water quality problems; the need to better identify problems and affected operations; the proposed PA Program will deal with exported manure and P better.
Medium and Small CAFOs: A proposal for medium and small operations was provided that initiated a wide ranging discussion. Several participants thought dealing with medium and small sized CAFOs was important. Concepts included focusing on operations with discharges, particularly from unimproved barnyard areas (a.k.a. exercise lots, brown pastures, loafing areas or animal concentration areas). It was pointed out that the current program deals with the medium group by utilizing the Nutrient Management Act resources and its CAO definition. The EPA definition of a medium CAFO includes a discharge. EPA said the state could customize its program for addressing medium and small CAFOs.
Program Resources: Several participants mentioned that bringing in large poultry operations would consume current resources and that addressing medium operations and discharges may require additional resources. Better identification of actual problems may help to equitably focus program activities and resources. Also, phasing in program changes was mentioned. Related agencies and the farm community would have to understand and deal with the changes to the Program. Using available or additional resources to install BMPs or for compliance efforts to eliminate discharges was advocated as a way to correct problems and avoid obtaining permit coverage. The current Program utilizes the existing Nutrient Management Program to minimize duplication and confusion.
Subcommittee Assignments: The animal numbers subcommittee was assigned to better define the potential number of large and medium sized operations; describe potential permitting/ compliance strategies; and to define the term “discharges” as it would relate to the Pennsylvania CAFO program.
EPA Obligation: EPA will provide feedback on the acceptability of the proposed large CAFO category animal number/AEU definitions.
Next Meeting: Friday, May 23, 2003 at 9 a.m.; DEP Southcentral Regional Office, Susquehanna Room B.
Participants:
Charlie Abdalla, Professor, Penn State University, College of Ag. Science
Bill Achor, Environmental Coordinator, Wenger’s Feed, Inc.
Bill Adams; Pa. Farm Bureau
Dan Alters, Program Manager, DEP Northcentral Regional Office
Amy Bradford, PennAg Swine Council
Doug Brennan, Attorney, DEP Office of Chief Counsel
Karl Brown, Executive Secretary, State Conservation Commission
Alissa Dodd, Ext. Assoc., Penn State University
Martin Ferry, Permits Chief, DEP Southcentral Regional Office
William Fink, Team Ag Inc.
Don Fiesta, Prof. Geologist, DEP Central Office
Chris Frame, Hostetter Management Co.
Barry Frantz, Resource Conservationist, NRCS
Bob Gibson, Section Chief, DEP Central Office
Doug Goodlander, Program Mgr., SCC-Nutrient Mgmt. Program
Tom Juengst, Program Specialist, DEP Central Office
Cedric Karper, Division Chief, DEP Central Office
Lori Mohr, DEP Policy
Tim Murphy, Conservation Engineer, USDA-NRCS
Kelly O’Neill, Ag. Policy Analyst, Pa. CBF
Walt Peechatka, Executive Vice President, PennAg Industries Assoc.
Bill Plank, Bedford Conservation District
William Rogers; Private Consultant
Tom Schmick, DEP Northcentral Regional Office
Kevin Seibert, Lancaster CD, PACD
Brenda Shambaugh, Pa. State Grange
Kim Snell-Zarcone, Staff Attorney, Penn Future
Jim Spontak, Operations Chief, DEP Southcentral Regional Office
Sue Weaver, DEP Policy
James Wheeler, Pennsylvania State Association of Township Supervisors
Hank Zygmunt, USEPA