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 10th 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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