December 3, 2002

Pandor Hadjy
Assistant Deputy Administrator
Business Programs
RBS
Room 5050 South Agriculture Building
Stop 3220
1400 Independence Avenue, SW
Washington D.C. 20250-3220

Mr. Hadjy;

The following comments are offered for the implementation of provisions of Section 
9006 of the Farm Security and Rural Investment Act of 2002.  These comments have 
been prepared by the Methane Recovery Work Group, which is comprised of 
representatives of Public Power Districts, the Nebraska Department of Environmental 
Quality, the University of Nebraska, USDA, and the Nebraska Rural Development 
Commission.  

The Methane Recovery Work Group has been actively promoting development of 
methane recovery from anaerobic digesters to be located at animal confinement 
operations in Nebraska.  Animal confinement operations are critical to Nebraskas 
economy and to the continued production of high quality meat, milk and egg production 
that is competitive nationally and globally.  Acceptance of the increasing number and size 
of animal confinements is meeting increasing resistance in Nebraska and many other 
locations.   It is imperative to the agricultural economy in Nebraska and many other states 
to develop improved waste management processes that reduce the environmental impacts 
of animal confinements and increase the acceptance of these operations.

Please consider the following comments when developing provisions of Section 9006:
1.	Anaerobic digesters with methane recovery to provide fuel for electrical 
generation should be included as a renewable energy system in Section 9006 due 
to the energy production and the environmental benefits of capturing methane and 
odors and converting to energy.  These projects should receive priority in order to 
protect the animal confinement industry that is critical to providing high quality 
and low cost food in Nebraska and the nation.  Technologies exist that can 
achieve renewable energy production from confinement wastes and it can be 
improved technically and economically given support for its increased use.  
2.	Deployment and improvement of existing technology can best be achieved by 
grants that can be applied toward a portion of the cost of a methane recovery 
system.  Confinement developers and operators need an incentive that directly 
impacts their bottom line in the near term in order pursue a more costly waste 
management option.  Direct loans and loan guarantees can also provide incentives 
that are more applicable to the long term perspective of confinement developers 
and operators.
3.	a) In order to achieve greater value for the money provided under Section 9006, 
the type of renewable energy system to be purchased should consider 
environmental benefits, protection of the agricultural economy and the security of 
retaining high quality and low cost food production in the United States.  

b) The quantity of energy produced would vary depending on the confinement 
type and size.  In general, a dairy could provide most of the energy needed to 
operate the dairy.  A hog confinement would likely produce some amount more 
than the energy the confinement requires.  A poultry confinement may produce 
more than the energy the confinement requires.  Each confinement will have 
different renewable energy production and energy requirements depending on its 
design, location, size and other site-specific factors.

c) The environmental benefits of a methane recovery system include:
*	Control of odors emitted from anaerobic digestion of wastes
*	Capture and use of methane (global warming potential in 100 years 
of 21) for fuel converting it to CO2 (global warming potential in 
100 years of 1)
*	The liquid effluent from the anaerobic digester retains most of the 
fertilizer value of the waste stream and can be applied to farm 
ground in manners that reduce fertilizer runoff
*	Reduction of solids to be disposed of on farm ground
*	Offsets energy produced from non-renewable resources
*	Offsets fertilizer that is produced from non-renewable resources

d) Methane recovery systems would be replicable throughout Nebraska and the 
nation as confinements reside in many areas of the state and the nation.  There 
are several vendors and consultants with the expertise necessary to design 
systems that have been successful over the long term.  This necessary 
expertise can expand given support for methane recovery.

e) The amount of energy savings are reflected in item b) above.

f) The amount of time necessary for the energy savings to equal the cost of a 
methane recovery system will depend on a number of factors.  The cost of the 
system, the cost of electricity and the cost to operate and maintain the system 
are all site-specific factors.  A reasonable estimate would be five to ten years 
for the energy cost savings to equal the additional cost of a methane recovery 
project compared to other waste management options.

g) Other factors to consider should be requirements for feasibility studies.  Also a 
review of the success of consultants and vendors should be required in order 
to assure the necessary expertise is available for a methane recovery project.

-	The types of methane recovery projects targeted should be those that utilize 
proven technology and expertise that has demonstrated successful 
installations.  Incremental innovations and improvements in technology 
should be encouraged and supported when the appropriate background 
research has been completed.
The geographic areas to be targeted for methane recovery should be those areas 
with significant numbers of animal confinements and the attendant grain 
production and meat packing industries necessary to support the confinements in 
the most economical manner.  

Another important factor to consider is the use of the anaerobic digester effluent 
as fertilizer.  Center pivot irrigation systems provide an excellent means to apply 
the liquid affluent as fertilizer.  The anaerobic digester liquid effluent is 
essentially odorless and is typically stored in retention lagoons until it can be 
applied to farm ground.  Center pivots can apply the effluent when the crops can 
best use the fertilizer and when the soil is dry.  This distinct advantage of center 
pivot irrigation systems can best be realized in Nebraska since there are more 
center pivot systems in Nebraska than any other state.

Another factor to consider in Nebraska is the wide spread support of methane 
recovery.  The Methane Recovery Work Group has a diverse membership, which 
includes utilities, regulators, university of Nebraska, local zoning officials and 
agricultural groups.  The Methane Recovery Work Group has presented two 
workshops on methane recovery that have been well attended by utilities, 
economic development representatives, agriculture producers and other 
stakeholders in agriculture in general and confinement operators in particular.

4.	Potential sources of additional funding are the Nebraska Environmental Trust 
Fund, Pork Producers Association, National Cattlemens Association, the 
Sustainable Agriculture Research and Education program and the National Rural 
Electric Cooperative Association.

Please let me know if you have any questions or comments are the above information.  
We appreciate the opportunity to provide comments on implementation of this 
important program.

Frank Thompson
Team Leader NPPD
flthomp@nppd.com
402-563-5696