If individuals have concerns about the CNMP, they should pursue additional information from the permittee. Conservation districts are most concerned with the need for resources to implement the program at the state and local levels. The need for additional technical personnel for the Natural Resources Conservation Service and districts to prepare the comprehensive nutrient management plans far exceeds their existing capacities. Many of our districts will view this as another unfunded federal mandate. Even though there are a limited corps of consultants who can provide technical services to prepare CNMPs, conservation districts and their partners will usually be the first organization approached for this service because of their 60 years of working with farmers.
Additional resources are essential for implementation of a successful program.
There are issues which need clarification or improved definitions before the document is finalized. Districts appreciate the opportunity to provide these comments and hope that the information is useful in preparing the Guidance. Individual districts, state associations of districts and state conservation agencies are expected to make additional comments for your use.