9/01/02
By CAROL KINSLEY
On Aug. 22, the Delaware Nutrient Management Commission again formally asked EPA to adopt rules allowing the First State to regulate Confined Animal Feeding Operations (CAFOs) as one component of a comprehensive statewide nutrient management program that addresses nutrient applications from all sources.
The commission also requested a meeting with EPA to demonstrate Delawares comprehensive approach to large animal feeding operations and nutrient management. The DNMC requested that enough flexibility be created to provide an off ramp for farmers who are rigorously regulated by state programs that exceed or functionally outdo the proposed federal requirements.
EPA also is considering whether the 1,000 Animal Unit (AU) equivalent for broilers should be 100,000 broilers or 125,000, and whether the 1,000 AU equivalent for laying hens should be 100,000 or 82,000 hens.
The DNMC cited the comments made by the poultry subcommittee between the Federation of Animal Science Society and American Society of Agriculture Engineers. The subcommittee concluded that the broiler farm equivalence to a 1,000 head beef farm is no less than 165,000 broilers. The subcommittee also stated that 180,000 pullets and 84,000 layer hens are equal to 1,000 AU. The conclusions were based on phosphorus excretion equivalency and do not consider the volume or stack-ability of manure generated.
Delawares program addresses a much wider universe of the known sources of excess nutrients and the environmental impacts those nutrients cause, the DNMC noted.
The DNMC also cited the Natural Resource Conservation Service definition of 1,000 AU as 400,000 broilers.
This wide-ranging difference in defining a farm that needs a national permit to pollute is beyond common sense and sound government policy development, the commission wrote.