Region III AFO/CAFO Initiatives

Farm, Ranch, and Rural Communities 

Committee

September 30, 2010

David McGuigan, EPA
Outline

• Animal Agriculture and Bay Impacts

• Three Priority Geographic Areas

• Conclusions
Animal Agriculture and Bay 

Impacts


Three Priority Areas

• DELMARVA - Poultry

• Lancaster – Dairy 

• Shenandoah – Dairy and Poulty
EPA’s Goals

• Make sure that facilities that need NPDES 

CAFO permits have them

• Framework in place to ensure compliance 

with NPDES permit

• Enhancement of State Agricultural 

Programs
DELMARVA

• Universe: Poultry

• Objective: Ensure that poultry operations obtain the 

required permits and comply with them

• Strategy: Multi-facetted 

– Universe Identification

– Stewardship - Perdue 

– Inspection and Enforcement

– Compliance Assistance - DPI

• Result – Over 850 farms have applied for permit 

coverage

• Future work ensuring compliance with Permit 

requirements
DELMARVA

• Partnership with Perdue

– Training for growers and flock supervisors

– Regular Assessments

– Deviation Response

• Partnership with DPI

– Sponsored out reach to the farm community

– Three meetings with over a 1000 farms
Conclusions

• Flexibility is not always desirable - farmers 

wanted clear and understandable 

information and guidance

• One-on-One interaction a powerful tool

• Enrolling the support of industry is critical: 

Partnerships with DPI and Perdue
Lancaster

• Universe: Small Dairy and CAFO operations

• Objective: Ensure compliance Federal and state 

requirements and evaluation of state program

• Strategy: Targeted sub-watershed investigations 

and targeted inspections

– Sub-watersheds targeted for surface and ground 

water contamination

– Partnering with Conservation Districts, State, and 

Plain Sect Community
Lancaster County has...

• Highest number of impacted drinking 

water systems

– One of two areas in EPA Region 3 with the 

highest nitrate pollution levels

– Multiple systems with nitrate MCL violations 

and on treatment

• The highest number of agriculturally 

impaired stream reaches in PA’s portion of 

the Chesapeake Bay watershed
Overview of Watson Run

• Watershed is 2.74 mi2

• Listed in 2004 on Pennsylvania’s 303(d) 

List of impaired streams

• Impaired due to:

– Nutrients

– Organic Enrichment/ Low Dissolved Oxygen

– Siltation

• Source of impairments identified as 

agriculture
24

19

6

20

4

13 12

23

10 8

25

22

5

1

17 7

14

3

15 16

9

11

18 21

Map of Watson Run with Unique Facility Identifiers
Watson Run Hydrologic Connectivity
Overview of Sites

• 24 farms visited

– 20 Animal Feeding Operations (AFOs)

• 2 Concentrated Animal Operations (CAOs)

• 18 dairies; 1 pullet farm; 1 dairy/swine farm

– 20 with cropland; 4 lease out all cropland

– 23 Plain Sect; 1 English

– 19 Sampled Drinking Water
Outreach and Partnerships

• Close cooperation with the LCCD

– Acted as the interpreter to the farm 

community

• Majority of Farms Plain Sect

– Established Working Relationship with 

Bishops

– Established Inspection Protocols

– Leadership arranged inspection schedule

– Farmers pres and post inspection
Type of Farm Practices

17

4

1

18

20

2

19

15

3

0 10 20 30 40 50 60 70 80 90 100

Cover Crops

No-till/ Low-till

No Winter Spreading

Manure Storage >4 months

Regular Soil Testing

Percentage

% with

% without
Chesapeake Bay BMPs

1

1

4

20

1 9

10

20

15

0 10 20 30 40 50 60 70 80 90 100

Stream Fencing

Riparian Buffers

P-Based Nutrient Management

Cover Crops

Manure Storage >4 months

Percentage

% with

% with some

% without
PA Baseline Compliance*

*Pennsylvania Clean Streams Law, Title 25, Chapter 83, Chapter 91, Sections 91.33 through 

91.36, and Chapter 102

Needs additional analysis

34

15

15

66

85

85

0 10 20 30 40 50 60 70 80 90 100

Properly Designed, Installed,

Operated, and Maintained

Manure Storage

No Discharges to Surface or

Ground Water

Manure Management for

Environmental Protection

PA Chapter 102 Conservation

Plan

Percentage

% with

Not applicable

% without

Needs additional analysis
Watson Run

• Next Steps

– Schedule for E&S finished by July 1

– Manure Management Plans by September

– Modeling on Pollutant Loads: Pre-inspection, Plan 

Implementation, Water Quality BMPs

• Next Steps 

– Discussion with Conservation Districts and State on 

improving compliance assurance program

– Depending on findings of modeling study base 

program enhancements

– Farm Community Drinking water is a concern
Conclusions

• Partnership with CD and Community 

Leaders critical to success

• Lack of evalutions has lead to high noncompliance rate and unlevel playing field.

• CD role should be expanded to keep 

farmers out of harms way and to achieve 

water quality goals

• Farm Community Drinking Water is a 

concern
Muddy Run

• Approximately 100 farms

– Traditional inspection and follow-up

• Strategy

– Farmers given an opportunity to sign up for required 

plans

– Inspection priority to those who have not signed up

• Meetings have occurred with farmers

• Inspections scheduled to start in December 
Shenandoah

• Universe: Dairy and Poultry

• Objectives: Evaluation of state program 

and compliance with federal and state 

requirements

• Strategy:

– Outreach to Stakeholders

– Traditional enforcement response

• Inspections and Enforcement

– Inspections conducted in May
Shenandoah

• Traditional Compliance Assurance 

Approach

• Farm Selection Criteria

– Combined operations

– Water Quality

• 7 farms (dairy, turkey, beef, broilers) 

inspected
Shenandoah

• Findings

– State VPA Program appears to be effective

– 95% of Swine and 90% of Poultry under state or 

federal regulation

– 10% of Dairy

– Dairy issues were similar to Lancaster findings

• Next Steps

– Discussions with state on addressing Program Gaps

• Small Dairy should be in VPA program 
Conclusions

• VPA’s Program has a high rate of 

compliance

– Annual Inspection critical element

• Lack of dairy integration makes out reach 

difficult

• VPA program should be expanded to 

small dairy
Summary Conclusions

• Inspection programs realize programmatic 

goals – Important component of 

reasonable assurance

• Effective programs must be developed to 

deal with small dairy in the Bay Watershed

• Partnership with industry and community 

leaders are important

• Farm Community drinking water is a 

significant concern