Gulf of Mexico Hypoxia Working Group
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management hierarchy, alternative pollution management strategies, including
recycling, treatment, and safe disposal, are to be employed only when pollution
cannot be feasibly prevented. 29/ Feed management strategies such as amino acid
supplementation offer industry leaders and policy makers an excellent opportunity
to apply this Congressional mandate in favor of pollution prevention and source
reduction to the current policy debate over animal feedlots.

As policy makers consider whether and to what extent amino acid
supplementation should be included in any programs designed to reduce the
nitrogen load in the Gulf of Mexico, the AAEC suggests policy makers allow
themselves to be guided by EPA’s own statement concerning the virtues of source
reduction and pollution prevention:

EPA has made significant progress over the last 20 years
in improving the quality of the environment by
controlling pollution with its air, water, and hazardous
and solid waste programs. The traditional approach,
however, stresses treatment and disposal after pollution
is generated. EPA now believes that reducing or
eliminating the source of pollution is a competitive,
effective way to reduce risks to human health and the
environment. is approach is also the most cost-
effective option because it reduces raw material losses,

the need for expensive “end-of-pipe” technologies, and
long-term liability, In short, pollution prevention offers

the unique advantage of harmonizing environmental
protection with economic efficiency. 30/

Like other pollution prevention techniques, the AAEC believes that
amino acid supplementation can make a significant, cost-effective contribution to
addressing environmental concerns. We encourage regulators to recognize the

29/ = Id.

30/ USEPA, “Pollution Prevention Incentives for States” at 1 (emphasis added).
(Spring 1994)

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and the number of limiting amino acids being added to the feed. By way of
example, it has been shown that supplementing swine feed with lysine, the first
limiting amino acid, reduces nitrogen levels in swine waste by 26 percent. 5/ The
nitrogen content of a swine’s waste can be reduced by approximately 40 percent by
supplementing the diet with lysine, theronine, tryptophan, and methionine, the
first, second, third and fourth limiting amino acids in pigs. 6/

In a report issued in December 1998 by EPA, the Agency concluded
that "[s]upplementing the diet with synthetic lysine to meet a portion of the dietary
lysine requirement is an effective means of reducing nitrogen excretion by pigs." 7/
Indeed, EPA cited data showing that a 12 percent crude protein diet supplemented
with lysine can reduce the nitrogen excretion in a 200 -lbs finishing pig by 22
percent and that a 41 percent nitrogen reduction can be realized with a 10 percent
crude protein diet containing lysine and three other amino acids (threonine,
tryptophan and methionine).

5/ Heartland Lysine Swine Research Report 20 (enclosed as Attachment 4). See
also National Pork Producer's Council (‘NPPC”), “Environmental Assurance
Program: Participant's Manual" (1995) at 33-34 (citing a study showing that
reducing crude protein levels and supplementing with synthetic lysine reduces
nitrogen excretion in finishing pigs by up to 22 percent) (enclosed as Attachment 5);
F. Gaetal, “Low Protein, Amino Acid Supplemented Diets for Pigs,” Feed Mix, Vol.
2, No. 4 (1994) at 33 (ow-protein diet produces reduction in urinary nitrogen of
16.4% for growing pigs and 19.1% for finishing pigs) (enclosed as Attachment 6).

6 Eurolysine Trial Report 17 (finding a 39% reduction in nitrogen wastes)
(enclosed as Attachment 7); NPPC, supra note 5, at 33-34, (citing Cromwell, NPPC
Environmental Symposium, (1993)) (reducing the crude protein content by 4% with
the use of additional synthetic amino acids would reduce nitrogen excretion by
41%).

7 See "Preliminary Data Summary: Feedlots Point Source Category Study,"

Technology Appendix (hereinafter "Feedlot Study") (December 1998) at 9-11
(relevant excerpts enclosed as Attachment 8 hereto).

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examining “low protein feed to reduce nitrogen levels in the waste” 22/ We have
been advised that the state is examining amino acid supplementation as one
component of the nutrient management plan as a means of managing excess swine
nutrients.

D. Producer Groups Recognize the Benefits of Amino Acid
Supplementation

Within the United States, there is a growing recognition that
environmental concerns associated with animal waste can be addressed by
modifying animal diets. The "Environmental Assurance Program" developed by the
National Pork Producers Council notes that "[r]educing the crude protein content of
feed through the addition of supplemental amino acids (lysine, methionine,
tryptophan and theronine (sic)) can also reduce manure nitrogen concentration,"
perhaps by upwards of 40%. 23/ The American Feed Industry Association also
recommends low protein/amino acid supplemented diets as a means of reducing
nitrogen in swine and poultry waste. 24/ Indeed, in an otherwise hotly contested
rulemaking proceeding, the references to amino acid supplementation noted above
were added to the Colorado regulations without any opposition from industry or
environmentalists.

E. The Benefits of Amino Acid Supplementation are Recognized
in Europe

The environmental benefits of low protein/amino acid supplemented
diets are well-understood in Europe. The AAEC is not endorsing adoption in the
United States of the approaches taken in Europe, but is describing these

22/ See NCDENR’s “Framework for the Conversion of Anaerobic Swine Waste
Lagoons and Sprayfields” at www.enr.state.nc.us/ENR/files/hogs/hogplan. htm.

23/ NPPC, supra, note 5 at 33-34.

24/ AFTA, “Animal Agriculture: the Nutrition Environment Relationship,” supra,
note 2, at 4-8.

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changing the ingredients fed to livestock. 10/ Significantly, in its recent revision to
the USDA model conservation practice standard governing the management of
nutrients from animal waste, USDA advised farmers to “consider ways to modify
the chemistry of animal manure, including modification of the animal's diet to
reduce manure nutrient content,” as a means of “enhanc[ing] the producer's ability
to manage manure effectively.” 11/

B. Amino Acid Supplementation May Improve Air Quality and
Reduce Odor-Causing Compounds

As regulators and producers examine various “manure management”
solutions to the “deadzone,” it will be important that such solutions not create new
and different types of environmental concerns. One advantage to amino acid
supplementation is that the same practice that reduces the nitrogen content of the
manure can also also mitigate the atmospheric deposition of nitrogen from animal
feedlots. The Report specifically cites ammonia volatization from “[i]ntensive
agricultural practices, particularly feedlots,” as a source of the nitrogen that
contributes to the deadzone in the Gulf of Mexico. 12/ To the extent regulators
determine that volatilized ammonia nitrogen from anima! feed operations is a
concern, amino acid supplementation offers a potential means for reducing
ammonia nitrogen at the source.

In one independent study, researchers found that feeding a balanced
amino acid diet to poultry broilers resulted in reductions of 12% and 22% in

10/ See D. Leuck, "Policies to Reduce Nitrate Pollution in the European
Community and Possible Effects on Livestock Production," (Economic Research
Service, Ag. and Trade Analysis Division, USDA) (Sept. 1993) at 19 (enclosed as
Attachment 12).

11/ See Natural Resources Conservation Service, Conservation Practice
Standard, "Nutrient Management Code 590" available at
www.nhgq-nres.usda.gov/BCS/nutri/590. html; 64 Fed. Reg. 19122 (Apr. 19, 1999)
(announcing revisions to Nutrient Management Code 590).

12 Nutrient Loads Report at 8, Table 1.1.

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Significant nitrogen reductions have also been observed in poultry.
For example, several researchers have shown that reducing dietary protein content
by 10% and 15%, while maintaining required essential amino acid levels within
each age period for broilers, will reduce litter nitrogen content (% dry matter basis)
by approximately 24% without impairing weight gain. 8/ Reductions in nitrogen
excretion may be even greater when low protein/amino acid supplemented diets are
used in the context of "phase feeding,” in which the producer/nutritionist changes
the feed supplied during the growth cycle to more closely meet amino acid needs,
which vary depending upon age, gender, and other factors. 9/

The United States Department of Agriculture (“USDA”) also has
previously recognized that it is possible to reduce the nitrogen content of manure by

8/ AFIA, supra, note 2, at 5; see B. Leclercq, "Reducing Nitrogen Losses of
Broiler Chicken by Using Industrial Amino Acids," (paper given at Utrecht,
Netherlands at the Viv Europe 1997) (one of the most efficient ways to reduce
nitrogen losses from non-ruminants is to better balance dietary amino acid profiles
by supplementing diets with industrial amino acids) (enclosed as Attachment 9).
See N.S. Ferguson, R.S. Gates, J.L. Taraba, A.H. Cantor, A.J. Pescatore, M.J. Ford,
and D.J. Burnham, “The Effect of Dietary and Crude Protein on Growth, Ammonia
Concentration, and Litter Composition in Broilers,” 77 Poultry Science 1481 (Oct.
1998) (supplementing broiler diets with amino acids while reducing crude protein
reduces nitrogen in litter by 31%) (enclosed as Attachment 10). Similar results
have been obtained for layers. See Schutte, supra, note 2 (reducing dietary protein
from 16.5% to 14% of layer’s diet reduced total nitrogen output by 25%) at 30.

9/ AFIA, supra note 2, at 7-8; see also J.Y. Dourmad, N. Guingand, P. Latimier,
and B. Seve, “Nitrogen and Phosphorus Consumption, Utilisation and Losses in Pig
Production: The Situation in France," (paper presented at the 48th Meeting of the
European Association of Animal Production ("EAAP")) (Aug. 1997) (use of industrial
amino acids has been proved to be efficient for reducing nitrogen output); D.
Bourbon, J.Y. Dourmad, and Y. Henry, "Reduction of Nitrogen Output in Growing
Pigs by Multiphase Feeding with Decreased Protein Level," (paper presented at the
48th Meeting of the EAAP) (Aug. 1997). Both EAAP papers are enclosed as
Attachment 11.

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Cc. State Regulatory Agencies are Recognizing the Benefits of
Amino Acid Supplementation

State regulators are now paying close attention to research on amino
acids. In adopting regulations to implement Amendment 14,19/ a voter initiative
adopted last November that imposes specific odor contro! and waste management
requirements on hog farm operators, the State’s Air Quality Control Commission
and Water Quality Control Commission both recognized the role feed management
practices, such as amino acid supplementation, could play in addressing
environmental concerns. 20/ Moreover, in a guidance document being prepared by
the Colorado Department of Public Health and Environment regarding odor
reduction technologies, CDPHE’s Air Quality Control Division identified nitrogen as
a key source of odor from swine manure and identified amino acid supplementation
as a potential odor reduction technology. 21/

The State of North Carolina has also implemented extensive
regulations on hog farms. This includes a program to convert swine waste lagoons
and sprayfields to new technologies and implementation of a state-side Nutrient
Management Plan. In developing these programs, the North Carolina Department
of Environmental and Natural Resources has specifically indicated that it is

B. Pain, R. McKay and P. Lee, “Reduction of Odorous Compounds in Fresh Pig
Slurry by Dietary Control of Crude Protein,” 71 J. Sci. Food Agric. (1996) at 508-514
(finding that low protein/amino acid supplemented diets for growing and finishing
pigs produced significant reductions in odorous compounds in pig slurries) (enclosed
as Attachment 15).

19 25 Colo. Rev. Stats. §§ 25-8-501.1, 25-7-138.

20/ 5C.C.R.§ 1001-4, Part B (odor regulations); 5 C.C.R. §§ 1002-61.13 (water
quality regulations). .

21) Draft Guidance Document for Technologies to Minimize to the Greatest
Extent Practicable Odorous Emissions from Housed Commercial Swine Feeding
Operations (Dec. 2, 1998) at 15 (enclosed as Attachment 16).

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AMINO ACID EDUCATION COUNCIL
555-13th Street, NW
Washington, D.C. 20004-1109
202/637-5926
202/637-5910 (Fax)

August 2, 1999

Attn: John Field

Gulf of Mexico Hypoxia Working Group
National Centers for Coastal Ocean Science
WS 13446 SSMC4

1305 East-West Highway

Silver Spring, MD 20910

Re: Feed Management’s Role in Reducing the Nitrogen
Content of Animal Waste

Dear Mr. Field:

The Amino Acid Education Council (‘AAEC”) is pleased to submit
these comments on the report entitled “Reducing nutrient loads, especially nitrate-
nitrogen, to surface water, groundwater, and the Gulf of Mexico” (hereinafter
“Nutrient Loads Report” or “Report”). The AAEC represents manufacturers of
crystalline amino acids, ingredients that are added to swine and poultry feeds. By
supplementing animal feeds with amino acids, farmers can formulate diets with
less total crude protein, and thereby significantly reduce the nitrogen content of the
anima! waste.

The Nutrient Loads Report examines the cause of the hypoxia zone in
the Gulf of Mexico. The Report specifically identifies excess nutrients from the
Mississippi River Basin, particularly nitrate-nitrogen, as one of the causes of this
“deadzone.” The Report lists feedlots and manure as the major sources of nitrogen
and recommends better management of livestock manure as one of the practices
that would help reduce discharges of nitrogen into streams and rivers. 1/ The
Report fails to mention, however, that feed management practices, such as amino

Y Nutrient Loads Report at 7, 22-23, 100-103 (March 1999).

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Il. THE MARKET CURRENTLY OFFERS FEW INCENTIVES FOR
PRODUCERS TO SWITCH TO ENVIRONMENTALLY FRIENDLY
ANIMAL DIET STRATEGIES

In view of the environmental benefits and savings in crude protein
costs, it is natural to wonder why producers have not already universally adopted
amino acid supplementation. The answer is that they have -- but only when it has

been economically feasible to do so.

Indeed, the degree to which swine and poultry producers utilize
crystalline amino acids depends largely on the price differential between the cost of
amino acids derived from traditional sources of crude protein (such as soy protein)
and crystalline amino acids. When an amino acid such as lysine is less expensive
than other sources of protein in the swine diet, swine producers find that adding the
amino acid and reducing the amount of crude protein in animal diets is cost-
effective. On the other hand, in today’s market, where soy protein is at near record-
low prices, the cost savings from lysine supplementation is less significant and the
swine producers have less of an incentive to reduce crude protein. Thus, in the
current market, the environmental benefits of amino acid supplementation are not
realized when soy protein prices are comparable to, or lower than, the amino acid
prices.

Moreover, to fully realize the environmental benefits of amino acids,
producers would have to supplement the diet with more than one amino acid.
Although crystalline sources of lysine and methionine are commercially available at
prices competitive with or less expensive than soy protein, two other limiting amino
acids for swine (Le,, threonine and tryptophan) are generally more expensive than
soy protein and other dietary sources of crude protein. The use of up to four amino
acids in swine and poultry diets would increase slightly the total feed costs.

Although the potential costs associated with amino acid
supplementation may appear small, particularly in light of the high costs frequently
associated with measures aimed at managing releases into the environment, these
costs may actually exceed the per animal profits that currently are being made on
each pig and chicken in today’s market. Accordingly, amino acid supplementation
will not succeed as a solution to animal waste management concerns without
appropriate incentives and support from policy makers.

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approaches to demonstrate that other countries have recognized that the nitrogen
content of animal wastes can be reduced by adjusting animal diets.

In the Netherlands, for example, livestock farmers must track
quantities of phosphate and nitrogen that enter and leave their farms. Nutrient
inputs (via feed and fertilizers) and outputs (in the form of meat, milk, or manure),
are then compared, and it is assumed that inputs that are not otherwise accounted
for have been lost into the environment. Nutrient losses in excess of prescribed
amounts are subject to penalties. The Dutch approach helps educate farmers as to
the sources of excess nutrients, and rewards those farmers that contro! nutrients by
eliminating unneeded nutrients from animal diets. Obviously, this approach also
ensures that farmers factor environmental! costs into their feed and fertilizer
purchase decisions. 25/

In France, regulators have also attempted to find ways to get farmers
to move away from overfeeding protein. As in other EU countries, French farmers
are subject to a 170 kg of nitrogen per hectare limit when land applying animal
manure in “vulnerable areas.” In determining whether these limits are met, French
regulators now use more favorable assumptions regarding the nitrogen content of
pig slurry when it is produced at farms that limit maximum crude protein
consumption as opposed to farms that do not abide by such limits. 26/

25/ See C.M.C. van der Peet-Schwering, A.W. Jongbloed, and A.J.A. Aamink,
"Nitrogen and Phosphorus Consumption, Utilisation, and Losses in Pig Production:
The Situation in The Netherlands,” (paper presented at the 48th Annual Meeting of
the EAAP) (Aug. 1997) at 13 (enclosed as Attachment 17); P. Gassman and A.
Bouzaher, “Livestock Pollution: Lessons from the European Union,” Animal Waste

and the Land-Water Interface, K. Steele (ed.) (1995).

26/ See Dourmad et al, supra note 9, at 2, 8 and Table 4; R. Pinot, "French Action
on Nitrogen Excretion from Animals," Sanofi Sante Nutrition Animale (enclosed as
Attachment 18).

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ammonia emissions, without any production loss. 13/ In a study published last
October, researchers found that reducing crude protein in broiler diets while
supplementing with amino acids reduced ammonia gas concentrations by 31 percent
and nitrogen content of litter by 16%. 14/ The researchers noted that both of these
reductions “will improve air quality within the housing facility and possibly reduce
heating costs during winter associated with higher ventilation rates required to
reduce elevated NHs gas concentrations.” 15/ Other studies have produced similar
results. 16/

Recent studies conducted by Purdue University and Pennsylvania
State University researchers have determined that supplementing hog diets with
amino acids while reducing crude protein in hog feed dramatically reduces
ammonium nitrogen.17/ Specifically, when researchers compared the manure
produced by hogs who were fed a 13% crude protein diet with the manure produced
by hogs fed a 8% crude protein diet supplemented by lysine, threonine, tryptophan
and methionine, they found that fresh manure from the second group of contained
45% less ammonium nitrogen and 61% less volatile fatty acids, as well as a lower
pH. 18/

13/ T.A. Scott, J.W. Paul, R.C. Newberry and P.K. Barton, “Balanced Amino
Acid Diets Increase Bird Health and Reduce Ammonia Emissions,” 13 WORLD
POULTRY No. 12 (1997) (enclosed as Attachment 13).

14/ Ferguson, et al, supra n. 7.
15 Id. at 1481.

16/ See Dourmad et al, supra, note 9, at 7 ("[fleeding low protein diets appears to
be an efficient way of reducing the volatilisation of ammonia").

17 A. Sutton, “Less Protein Cuts Odor Compounds,” National Hog Farmer
(March 15, 1998) at 29 (enclosed as Attachment 14).

18 Id. at 30; Feedlot Study, supra, note 7, at 11-6 ("Amino acid additions to pig
feed such as lysine allow a reduction in the total protein intake, which results in
lower excretion of total nitrogen and up to 45% less ammonia.” See also P. Hobbs,

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formation of body tissue. Although swine and poultry are able to synthesize some of
these amino acids, certain “essential” amino acids must be provided via the feed
because monogastric animals are unable to synthesize or produce these amino acids
at sufficient rates to meet the physiological needs of their bodies. During protein
synthesis, essential and “non-essential” amino acids are joined together according to
a pre-determined genetic code to form animal protein. If there is a deficit of any
essential amino acid, protein synthesis will be limited by the level of that amino
acid. Although soybean meal is a good source of protein when combined with a
cereal grain such as corn, it contains relatively low levels of certain essential amino
acids, called "limiting" amino acids, such as lysine, methionine, threonine, and
tryptophan. 3/ In corn/soybean meal diets fed to pigs, lysine is generally the “first
limiting" amino acid -- meaning that lysine is the first essential amino acid that is
likely to be in short supply, given the pig's needs and the levels of lysine found in
corn/soybean meal diets. For poultry, methionine and lysine are first and second
limiting, respectively. 4/

In light of the importance of these limiting amino acids, the challenge
has been to find a way to supply them in sufficient quantities without
oversupplying crude protein, which generally is one of the more expensive
components of the diet. Members of the AAEC have responded to this challenge by
making individual crystalline amino acids commercially available in the form of
feed supplements. By supplementing the animal diet with one or more limiting
amino acids, producers are able to reduce the amount of crude protein being fed to
their animals, while ensuring that the animals are receiving the essential amino
acids they need.

Overwhelming scientific evidence confirms that reducing crude protein
levels while supplementing animal diets with crystalline amino acids dramatically
reduces nitrogen levels in waste without any discernible impact on animal growth
or productivity. The degree of nitrogen reduction depends on the animal species

3/ “The Key to Accurate Nutrition,” Feed Mix, Vol. 2, No. 4 (1994) at 9 (enclosed
as Attachment 3). For example, corn contains .24% lysine, and sbm (48% crude
protein) contains 2.94% lysine. Id.

4 J.B. Schutte, supra, note 2, at 29.

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benefits of feed management in any programs or policies that are developed to
address the nitrogen levels discharged into the Mississippi River Basin.

kk ek we Oe

If you have any questions, or if we can provide additional information
regarding amino acid supplementation, please do not hesitate to contact the AAEC
at 202/637-5926 (Martin Hahn) or 303/899-7355 (Scott Reisch).

Oo

Martin J. ~ \

Enclosures

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formulate feeds. It is the livestock producer who is in the best position to assess
what practices should be employed to meet the environmental performance
standards established by Congress and EPA.

More detailed information about the environmental benefits of amino
acid supplementation is provided below.

L AMINO ACID SUPPLEMENTATION CAN SIGNIFICANTLY
DECREASE NITROGEN LEVELS

A. Amino Acid Supplementation Reduces Nitrogen Levels in Pig
& Poultry Waste

Animals are fed large quantities of crude protein (typically in the form
of corn and soybean meal-based feeds) in order to supply amino acids, which play a
critical role in the maintenance of health and tissue integrity, and in production of
muscle, eggs, skin, and feathers. Dietary crude protein is broken down during the
digestive process into amino acids. These different amino acids are used by the
animal to maintain metabolic processes and synthesize body protein. If the diet
contains excess amino acids, they are converted into energy, and nitrogen is
produced as a by-product of this conversion. The nitrogen is then excreted as urea
in mammals and uric acid in poultry. 2/

Animals do not have a crude protein requirement, per se; they have
requirements for amino acids. Twenty-two different amino acids are used in the

2/ See generally, American Feed Industry Association (“AFIA”), “Animal
Agriculture: the Nutrition Environment Relationship” (March 1998) at 4-9
(enclosed as Attachment 1). It is estimated that only 40% of the nitrogen in poultry
feed is used for production of eggs or meat, and the remainder is excreted; J.B.
Schutte, “Controlling Nitrogen Pollution: Practical Applications of Free Amino
Acids in Poultry Diets,” Feed Mix, Vol. 2, No. 4 (1994) at 29 (enclosed as
Attachment 2). See also S. Klausner, “Nutrient Management Planning,” Animal
Waste and the Land-Water Interface, (K. Steele, ed., 1995) at 386 (feed
management is a key to reducing nutrient loss).

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acid supplementation, can significantly reduce the nitrogen content in the manure
of monogastric animals such as pigs and poultry.

Overwhelming scientific evidence demonstrates that amino acid
supplementation can significantly reduce the level of nitrogen in swine and poultry
waste. The degree of reduction will depend on the type of livestock and the number
and quantity of amino acids that are supplemented in the diet, with a greater
number and quantity of amino acids resulting in a greater reduction of nitrogen.
Supplementation of swine and poultry diets with four commercially available amino
acids has been shown to reduce the nitrogen content of swine and poultry waste by
about 40 percent and 24 percent, respectively. Amino acid supplementation also
has been shown to have other environmental benefits in that it reduces ammonia
emissions and odor from swine and poultry waste.

The benefits of amino acid supplementation were recently recognized
by the Environmental Protection Agency (“EPA”) in a report issued in December
1998, in which the Agency concluded that amino acid supplementation is an
effective means of reducing nitrogen excretion by pigs. In addition, the
environmental benefits of amino acid supplementation are recognized in the
domestic agricultural community, by at least one State, and in Europe.

Despite obvious benefits, amino acid supplementation has not been
universally adopted to date because it has not always been economically feasible to
do so. Supplementation of the animal diet with up to four amino acids increases
feed costs. Although these additional costs may be slight, particularly when
compared to the high costs ordinarily associated with environmental control
measures, the costs may exceed the profits that are being realized in today’s
market.

In light of the magnitude of nitrogen reductions that can be achieved
through amino acid supplementation, the AAEC believes that programs and policies
that are developed to address the dead zone in the Gulf of Mexico should allow, and
perhaps even encourage, livestock producers to utilize pollution prevention
practices such as amino acid supplementation and other feed management practices
that reduce the nitrogen content of animal manure. However, the AAEC opposes
any government effort to mandate specific feed management practices and believes
that it would be inappropriate for regulators to interfere with a producer’s ability to

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I. THE BENEFITS OF FEED MANAGEMENT SHOULD BE
RECOGNIZED AS POLICIES ARE DEVELOPED TO ADDRESS
REDUCING NITROGEN LOADING OF THE GULF OF MEXICO

The Nutrient Loads Report identifies animal manure as a significant
source of nitrogen. Indeed, animal manure is listed as the fourth largest
contributor of nitrogen following fertilizer use, mineralized soil nitrogen and legume
nitrogen-fixation. 27/ Although the Report makes several recommendations on how
manure could be applied to minimize the loss of the nitrogen into waterways, no
mention is made of the technologies that are available to reduce the nitrogen
content of the manure. The AAEC believes that the Report should recognize the
benefits of feed management, including amino acid supplementation, in reducing
the nitrogen content in manure, and that producers should be encouraged to utilize
scientifically proven pollution prevention technologies such as amino acid
supplementation.

The AAEC opposes mandatory use of amino acids or of any feed
management practice. Amino acid supplementation and other feed management
practices that have been scientifically proven to reduce the nitrogen content of
animal manure should be identified as acceptable pollution prevention technologies
and individual producers should be given the flexibility of determining how to
achieve any necessary reduction in their discharges of nitrogen into the
environment. This approach serves both the environment and agriculture, because
producers are in the best position to assess the most cost-effective means of
achieving environmental objectives at their individual farms.

IV. CONCLUSION

In the Pollution Prevention Act of 1990, Congress established a
national policy which requires that "pollution should be prevented or reduced at the
source whenever feasible." 28/ Under the Pollution Prevention Act’s pollution

27/ Nutrient Loads Report at Table 1.1.
28/ 42. U.S.C. § 13101(b) (emphasis added).

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