Applying Alternative Technologies to CAFOs: A Case Study

The US EPA National Pollution Discharge Elimination System permit program has regulated open lot livestock production systems since the 1970’s, historically requiring collection, storage, and land application of runoff. Under the new Concentrated Animal Feeding Operation (CAFO) regulations, the effluent limitation guidelines (ELG) offer the option of Voluntary Alternative Performance Standards for beef and dairy. This potentially allows runoff management options such as vegetative treatment systems (VTS) that may perform equal to or better than our baseline system while maintaining a challenging standard for application of alternative technologies. To facilitate application of VTS, the Iowa Cattlemen’s Association (ICA) and Iowa State University (ISU), have initiated several pro-active efforts including field-based demonstration and evaluation of these technologies and development of performance models for estimating performance. They also enlisted USDA Natural Resource Conservation Service (NRCS) to assist with the assembly of the current science and access to cost share resources. This paper will 1) summarize the process used for facilitating an alternative technologies application on CAFOs, 2) review the critical issues in applying new technologies from the perspective of EPA, industry, research community, and private sector; and 3) summarize lessons learned in this process. Significant obstacles exist for alternative technology applications on CAFOs. Stakeholders in livestock environmental issues will need to play pro-active roles if alternative technologies will be permitted under the CAFO regulations. Introduction Runoff from open lot livestock production systems poises an environmental risk. Traditionally, storage ponds collect and store runoff until land applied. Technology based standards under the ELG of the CAFO regulations have defined this approach as the only currently acceptable option. VTS is proposed as an alternative technology for runoff management. A VTS approach utilizes forage or grass based production areas to filter contaminants and infiltrate runoff into the soil. Significant VTS research, typically on non-CAFO applications, has identified potential environmental benefits for this technology. The specific objectives of this paper are to: 1. Introduce by case study example (application of VTS to control of runoff from open lot systems) an effort to apply an alternative technology to CAFOs under the new CAFO regulations. 2. Introduce the perspectives of individual organizations participating in this process. 3. Share from our experiences the opportunities and challenges for implementation of alternative technologies on CAFOs. Overview of Applicable CAFO Regulations The U. S. EPA’s CAFO ELGs, published on February 12, 2003, establishes the technology-based standards that must be included in National Pollution Discharge Elimination System (NPDES) permits for large CAFOs (more than 1,000 beef feeders or dairy heifers or 700 mature dairy cattle). The 2003 final federal rule (Federal Register, 2003) states that for Large CAFOs with dairy cows or beef cattle: “(a) there must be no discharge of process wastewater pollutants into waters of the U.S. from the production area.