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Environmental Planning

What is a CNMP?

A Comprehensive Nutrient Management Plan (CNMP) is a conservation plan developed in accordance with Natural Resource Conservation Service (NRCS) planning policy that addresses all resource aspects of an animal feeding operation. As defined by NRCS, a CNMP is a grouping of conservation practices and management activities that, when implemented, will ensure that both production and natural resource protection goals are achieved. A CNMP should identify and address natural resource concerns in regards to soil, water, air, plants, animals and people on the farm. The potential impacts of soil erosion and manure on water quality are a key natural resource concern.

Six Elements of a CNMP

A key objective of a CNMP is to document the plans of an animal feeding operation owner/operator to manage manure and organic by-products in combination with conservation practices and facility management activities to protect or improve water quality. NRCS has listed six elements of a CNMP that should be considered during preparation of the plan, though a CNMP is not required to contain all six elements. The components that should be considered are:

• Manure and Wastewater Storage and Handling
• Land Treatment Practices
• Nutrient Management
• Record Keeping
• Feed Management
• Other Utilization Activities

A complete description of these elements, and what each element specifically covers, is included in the USDA-NRCS National Planning Procedures Handbook (Part 600.5).

Use of a CNMP for an NPDES Nutrient Management Plan (NMP)

In February 2003, the US EPA released its revised National Pollutant Discharge Elimination System (NPDES) and Effluent Limitations Guidelines (ELG) rule affecting Concentrated Animal Feeding Operations (CAFOs). While this rule is still being amended and is not yet finalized due to recent court rulings, one item that will remain is the requirement for an NPDES nutrient management plan (NMP). In general, the contents of a CNMP and NPDES NMP are similar; most of the differences are in the reporting requirements. For complete details on the contents of an NPDES NMP see the documentation provided by the US EPA Managing Manure Guidance for CAFOs. US EPA recognizes that an NRCS defined CNMP addresses the requirements of the NPDES Nutrient Management Plan. Technical and financial assistance is available through the EQIP program to USDA program participants to help them implement a CNMP at their CAFO.

Who can prepare a CNMP?

Unless otherwise specified by State or local law, a CNMP may be developed by an agricultural professional, NRCS employee, Technical Service Provider (TSP), or by the producer. TSPs may be located through TechReg.

What options are available through NRCS to meet the EQIP contractual requirements for a CNMP?

The NRCS State Conservationist determines what options are available to meet conservation program requirements. If the producer chooses to use the services of a TSP, part or all of the cost of that service may be reimbursable, depending on the terms of the Environmental Quality Incentives Program (EQIP) contract.

One or more of the following options may be available to complete the CNMP:

1. Specially certified NRCS conservation planners may complete all or part of the CNMP
2. The NRCS State Office may contract with a technical service provider to complete all or part of the CNMP
3. The producer may contract with a TSP to complete the entire CNMP. The TSP must be certified in either CNMP Plan Approval or CNMP Plan Development – Total Plan
4. In addition to contracting with a TSP certified in CNMP Plan Approval or CNMP Plan Development – Total Plan, the producer may also contract with a TSP certified in one of the CNMP component categories, such as CNMP Plan Development – Nutrient Management, in order to complete individual elements of the plan.

When can a producer be reimbursed for the preparation of a CNMP?

EQIP contracts are specific to the needs of the individual producer and land unit. Depending on the contract language, the producer may be reimbursed for all or part of the preparation of a CNMP. A producer, or the contracted TSP, may elect to subcontract one or more additional TSPs to complete the specific CNMP elements. For the producer to qualify for reimbursement, each TSP who works on the plan must be correctly certified in the specific CNMP area in which they are working. Due to the length of time needed to certify in CNMP categories, the TSP must be certified in one of the above categories prior to beginning work for the producer. A list of certified TSPs can be found at “Find a Technical Service Provider” on the TSP TechReg Website.

How can an individual become certified to write CNMPs?

CNMP Plan Approval and CNMP Plan Development are the two certification categories which allow individuals to qualify for CNMP certification. Each certification category has two or more certification options. Individual States may have additional requirements based on State law or local regulatory policy. The NRCS State TSP Coordinator will verify that the specific category option criteria have been met prior to certifying the individual. Both categories require completion of online conservation planning coursework as listed in the NRCS General Manual, Section 180, Part 409.10, as well as any course prerequisites available on AgLearn, the NRCS educational website. Additional certification information may be found on individual NRCS State websites, the TSP TechReg website, Iowa State University TSP certification website, and CNMP Watch.

Certification Options for CNMP Plan Development

There are two options for becoming a Technical Service Provider (TSP) in the area of CNMP Plan Development. Option 1 is referred to as “Knowledge and Training” and Option 2 is to certify through a certifying organization. A certifying organization has a Memorandum of Understanding with NRCS to certify individuals as TSPs. TSPs certified through that organization can then submit themselves to TechReg as TSPs. The requirements for certification are the same for both options. The difference is that a TSP using Option 1 is responsible for tracking his own certification materials and providing evidence to NRCS that he or she meets the requirements, while a TSP using Option 2 can work through the process with assistance from the certifying organization.

What standards must be met in preparing a CNMP?

In addition to meeting State specific requirements, each element of a CNMP must be developed in accordance with the NRCS conservation planning policy found in the NRCS General Manual, Section 180, Part 409.10. The planning process and established conservation practice standards for completing a CNMP are found in the USDA/NRCS National Planning Procedures Handbook Part 600.50-600.54. CNMP planners must use the conservation practice standard and Statements of Work (SOW) as developed by the State in which the CNMP practices are to be implemented. This insures that all state and local criteria, which may be more restrictive than national criteria, have been met.

Individual conservation practices must conform to the USDA/NRCS eFOTG practice standards and specifications. The conservation practice standard contains information on why and where the practice is applied, and provides the minimum quality criteria that must be met during the application of that practice.

In addition to containing the practice standards and specifications, eFOTG provides conservation practice SOWs. The SOW describes practice deliverables and performance requirements. Deliverables, including supporting data, must be provided to NRCS upon completion of the practice. Supporting data is to include a record of planning, design, installation, checking, and maintenance necessary to insure an effective practice. There are five additional national NRCS templates for SOWs that are not directly associated with conservation practices: 1) Conservation Planning, 2) Comprehensive Nutrient Management Planning, 3) Cultural Resources Archival Research, 4) Cultural Resources Identification Surveys and 5) Cultural Resources Evaluations. Individual State SOWs may be more restrictive than the national templates.

Additional information about CNMPs

There are several sources for additional information about CNMPs. Many land grant universities and other commodity/producer organizations provide informational literature and websites. Additionally, state NRCS offices often maintain CNMP/TSP informational web pages. A source of information about CNMPs is the CNMP Core Curriculum training modules maintained by Iowa State University and available through the Midwest Plan Service. The CNMP Core Curriculum is also a good resource for educators interested in providing training on CNMP development. Also, the breadth of information covered in the topic areas make the curriculum a good source of materials for smaller scale trainings, such as shorter, topic specific extension programs. The CNMP Core Curriculum provides a consistent background and framework from which state or regionally specific CNMP courses can be developed. There are ten sections in the Comprehensive Nutrient Management Plan (CNMP) Core Curriculum. The section topics are:

• Introduction to a Comprehensive Nutrient Management Plan
• Conservation Planning
• Land Treatment Practices
• Manure and Wastewater Storage and Handling
• Nutrient Management
• Feed Management
• Record Keeping
• Air Quality
• Alternative Utilization
• TSP Certification

Author: Lara Moody, Iowa State University