Unified National Strategy for Animal Feeding Operations Cost and Capability Assessment

Principles of Collaboration

Background

In September 1999, the Senate directed the U.S. Environmental Protection Agency (EPA) "to conduct with the U.S. Department of Agriculture (USDA) a cost and capability assessment of the Unified National Strategy for Animal Feeding Operations and report the results to Congress by May 15, 2000." (Senate Report 106-161). The House of Representatives Conference Report 106-379, dated October 13, 1999, echoed the Senate direction, but provided for completion and delivery of the report by May 2001 (congressional language from both reports is attached).

Current Status

To date, USDA and EPA have been conducting studies to determine the costs and capabilities of developing and implementing CNMPs.

EPA, in coordination with USDA, is conducting studies on two pilot watersheds. The case study sites chosen are the Eucha Spavinaw watershed in Oklahoma and Arkansas and the Upper Makoqueta watershed in Iowa. These sites were selected because they had a number of desirable characteristics: a concentration of animal feeding operations; active stakeholder groups; available data, such as the size and number of AFOs; and nutrient management practices already in place. In conducting these studies, EPA worked with local stakeholder groups, including AFO operators, local NRCS and extension personnel, conservation district staff, local and state environmental officials, and non-profit organizations. The studies address the public and private costs of developing and implementing comprehensive nutrient management plans at each AFO in the two watersheds.

USDA is conducting a national scale cost and capability assessment that looks at: technical assistance in both the public and private sectors to develop and implement CNMPs; information and education programs; and research needed to support development of successful alternative uses of manure. The assessment is based on 1997 Agricultural Census data on animal feeding operations, estimates of on-farm manure handling capability, and prototype CNMPs for each model farm. USDA expects to complete its draft report in late summer of 2001.

Objective

The congressional language clearly directs EPA to coordinate with USDA. The watershed analysis led by EPA is a micro-analysis of the costs and capability of CNMP development and implementation in two watersheds. The national scale effort led by USDA is a macro-analysis assessing nationwide costs and capability of the Unified National Strategy for Animal Feeding Operations. The integration of these efforts will produce a more comprehensive and accurate analysis of the costs and capabilities of developing and implementing CNMPs on a national scale.

The objectives of this agreement are: 1) to develop an assessment and summary report that accurately portrays the public and private sector costs to address the conservation and environmental needs of animal feeding operations (AFOs), and the existing public and private sector capability to meet these needs; and, 2) to ensure that a collaborative effort is used in developing the assessment and summary report so that both USDA and EPA can support its findings.

By satisfying these objectives:

• USDA and EPA will have a more precise and comprehensive analysis of the national impacts of the Unified Strategy for AFOs. This analysis will also assist EPA as the Agency moves toward finalizing the concentrated animal feeding operations revised regulations;
• Both agencies will be in a better position to formulate budget proposals to address customer and stakeholder needs associated with AFO-related conservation and environmental efforts; and,
• Both agencies will be able to provide information to policy makers to facilitate informed decisions associated with future approaches and needs to address the key AFO-related conservation and environmental issues.

Principles of Collaboration

To ensure that EPA and USDA will support the AFO Cost and Capability Assessment and Summary Report, both agencies will concur in the following:

• The level of data sharing and the representation of that data in the assessment and summary report;
• The scope and methodology of data analysis, including reconciling or justifying any key methodological differences between the individual USDA and EPA efforts;
• Key assumptions used in performing the assessment, including any associated algorithms and reconciling or justifying differences;
• The broad themes and conclusions drawn from the assessment;
• The summary report content and presentation; and
• Timeframes for the assessment and summary report completion.

Approach to Development of the Collaborative Report

A summary report will be developed collaboratively by EPA and USDA, in a manner that is consistent with the principles of collaboration outlined in this agreement, and that addresses the combined effort and its final conclusions. USDA and EPA each will identify a co-leader and additional staff resources to support the effort. The co-leaders will develop a project plan that identifies roles, responsibilities, and a schedule to guide the activity; coordinate development of the collaborative report; and serve as team leaders and points of contact.

The aforesaid Principles of Collaboration for the EPA and USDA Cost and Capability Assessment of the Unified National Strategy for Animal Feeding Operations are hereby agreed to on this 10^th day of May, 2001.

Jeff L. Lape
Acting Director
Water Permits Division
Office of Water
U.S. Environmental Protection Agency

Thomas W. Christensen
Director
Animal Husbandry and Clean Water Programs
Natural Resources Conservation Service
U.S. Department of Agriculture

Congressional Language

House of Representatives Report 106-379

Making Appropriations for the Departments of Veteran's Affairs and Housing and Urban Development, and for Sundry Independent Agencies, Boards, Commissions, Corporations, and Offices for the Fiscal Year Ending September 30, 2000, and for Other Purposes

October 13, 1999

Adopted by the House of Representatives on October 14, 1999
Adopted by the Senate October 15, 1999

"Consistent with the Senate Report, the Agency is directed to conduct in conjunction with the Department of Agriculture a cost and capability assessment of the Unified National Strategy for Animal Feeding Operations. The conferees agree this report should be completed and submitted to the Congress by May 15, 2001. Similarly, consistent with the House Report, the conferees expect the Agency to solicit and consider additional public comment regarding exemptions from the rule on "plant pesticides" as suggested by the Consortium of Eleven Scientific Societies."

Senate Report 106-161

Departments of Veterans Affairs and Housing and Urban Development, and Independent Agencies Appropriations Bill, 2000

September 16, 1999

Adopted by the Senate September 16, 1999

"Unified National Strategy for Animal Feeding Operations Cost and Capability Assessment - The Committee directs EPA to conduct with the U.S. Department of Agriculture (USDA) a cost and capability assessment of the Unified National Strategy for Animal Feeding Operations and report the results to the Congress by May 15, 2000. The assessment will be conducted as a pilot project in affected states and shall determine the costs, both public and private, to plan, implement, monitor and enforce the Unified National Strategy for Animal Feeding Operations, with a focus on Comprehensive Nutrient Management Plans (CNMP). EPA and USDA shall work with local committees including conservation districts, state agencies, producers and public interest groups, which will provide the local oversight and guidance to making the cost and capability determinations. The results of this pilot project shall be summarized by the committees and included in the final report which the EPA and USDA will prepare and submit to the Congress."

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