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ogbudha 05/23/2009 - 15:07 Friends of MDfishing.org Roll Your Own
White Paper
Virginia’s Pending End-User Poultry Litter Regulation
Prepared By: Jeff Kelble –Shenandoah Riverkeeper
Virginia is about to take its biggest step ever in regulating the poultry industry. For anyone who uses the Shenandoah for drinking water and recreation, this also represents the greatest opportunity you may ever see to help improve the health of the Shenandoah River, Eastern Shore and the Chesapeake Bay. I urge you to take the time to read this paper, and then file comments on the pending regulation.
Please email me at: jeff@shenandoahriverkeeper.org and include:
1) Your Name
2) Your Full Address
3) How you are connected to rivers affected by poultry in Virginia
4) What you think about the pending regulation
The Basics:
80% of all poultry waste created by growers in Virginia is sold or given to neighboring farms which are not subject to regulation. This is the biggest environmental loophole in the Commonwealth and this regulation is poised to close it up tight. If passed as drafted, the regulation will require all significant poultry waste end users and poultry brokers to do soil testing and will guide their application rates to prevent the accumulation of phosphorous. It will provide windows of proper application to minimize application out of growing season and on frozen ground. It will also finally end the practice of storing litter in huge piles out in the rain applying litter right down to the stream-banks, and into or around environmentally sensitive areas.
I worked for nearly a year on the development of these regulations along with industry representatives, farmers and agency staff. Mostly my job was to counter opposition to this regulation by providing on the ground, real observations about poultry litter use and storage. As you can imagine this regulation is extremely unpopular with the industrial farming interests and unfortunately with farmers as well. I believe they are going to work very hard to kill it. So, if you want this regulation to have a prayer of being adopted, then we need your favorable comments, in fact, I believe we are going to need OVERWHELMING public support. I wrote this paper help interested citizens by providing a little of the history and information on some of the problems.
An Inevitable Problem
Shenandoah Riverkeeper believes that the land over-application of poultry litter in the Shenandoah Valley is among the river’s single greatest issues, and the single largest source of nitrogen and phosphorous pollution in the Shenandoah Valley. Runoff from fields where poultry litter is applied introduces unsafe bacteria, chemical and nutrient runoff, and creates fish health problems, dead zones and toxic algal blooms.
When I learned that the industry’s entire supply of animal feed (approximately 2 billion pounds annually) is imported by railroad from the mid-west and the waste is kept here, as it is, to be used as agricultural fertilizer in the Shenandoah my first thought was “this problem is virtually inevitable”. The Mid-Atlantic Regional Water Program reports that manure phosphorus production in the region exceeded regional crop phosphorus uptake by over 8,000,000 pounds annually in Rockingham County and over 2,600,000 and 2,400,000 tons annually in Augusta and Page Counties, respectively.
Poultry litter is an imbalanced fertilizer which contains several times more phosphorous than crops use when it is applied at the rate needed to meet nitrogen needs of the crops. Litter in the valley has proven to be more economical than commercial fertilizer in meeting nitrogen needs due to its abundance and low cost. Recent rises in the cost of commercial nitrogen has only reinforced this.
The File Room
During 2007, I personally reviewed over 100 Virginia Pollution Abatement Permit Files, at random, for poultry farms ranging in scale from 20,000 to over 545,000 birds on site. Almost without exception the files showed that farm operations planned their litter application at tonnages designed to meet nitrogen requirements, without regard to the chronic accumulation of phosphorous. Industry admitted during the regulatory process that many operations applied poultry waste without regard to risky application areas like steeply sloped fields, sinkholes and fields with streams running through them (most of which completely lack streamside buffers.)
The very core of the phosphorous issue is not irresponsible farmers, or intentional or accidental litter over-application. The problem is that the great majority of farmers have and will continue to apply poultry litter to their fields in the tonnage required to meet nitrogen needs, thereby grossly over-applying phosphorous. The other issues is that without regulatory guidance many farmers will apply from riverbank to riverbank. I have seen this countless times with my own eyes.
Here’s What This Regulatory Action Will Help Solve:
In 1999 House Bill 1207 passed which required Virginia to regulate poultry growers, but not farmers who bought litter or who were given litter. The regulations that came out of that bill mandated that growers perform soil testing, and apply litter at rates that crops will use without creating soil and water pollution. The result of that regulation was that a very large percentage of growers were disqualified from using litter because of the soil pollution they’d already created with past litter use. So those growers began giving the litter away and then later, selling it. Currently 80% of all poultry waste created in the Shenandoah Valley is transported off the farm where it was created and outside of regulatory guidance. Further, DEQ records indicate that of the 350,000 tons of poultry litter moved off poultry farms in 2004, approximately 75% remained in the Shenandoah Valley. Unfortunately, the new end-users of that litter are repeating the same mistake that the growers made in previous decades by again applying poultry waste for its nitrogen.
The file room work confirmed what was known: regulation from House Bill 1207 created a need for litter to be exported to “off-site” from poultry farms. It is estimated that 80-90% of litter produced by poultry farms in the Shenandoah Valley is being transported off site, and outside of any regulatory guidance.
Virginia’s Pending End-User Poultry Litter Regulation
Prepared By: Jeff Kelble –Shenandoah Riverkeeper
Virginia is about to take its biggest step ever in regulating the poultry industry. For anyone who uses the Shenandoah for drinking water and recreation, this also represents the greatest opportunity you may ever see to help improve the health of the Shenandoah River, Eastern Shore and the Chesapeake Bay. I urge you to take the time to read this paper, and then file comments on the pending regulation.
Please email me at: jeff@shenandoahriverkeeper.org and include:
1) Your Name
2) Your Full Address
3) How you are connected to rivers affected by poultry in Virginia
4) What you think about the pending regulation
The Basics:
80% of all poultry waste created by growers in Virginia is sold or given to neighboring farms which are not subject to regulation. This is the biggest environmental loophole in the Commonwealth and this regulation is poised to close it up tight. If passed as drafted, the regulation will require all significant poultry waste end users and poultry brokers to do soil testing and will guide their application rates to prevent the accumulation of phosphorous. It will provide windows of proper application to minimize application out of growing season and on frozen ground. It will also finally end the practice of storing litter in huge piles out in the rain applying litter right down to the stream-banks, and into or around environmentally sensitive areas.
I worked for nearly a year on the development of these regulations along with industry representatives, farmers and agency staff. Mostly my job was to counter opposition to this regulation by providing on the ground, real observations about poultry litter use and storage. As you can imagine this regulation is extremely unpopular with the industrial farming interests and unfortunately with farmers as well. I believe they are going to work very hard to kill it. So, if you want this regulation to have a prayer of being adopted, then we need your favorable comments, in fact, I believe we are going to need OVERWHELMING public support. I wrote this paper help interested citizens by providing a little of the history and information on some of the problems.
An Inevitable Problem
Shenandoah Riverkeeper believes that the land over-application of poultry litter in the Shenandoah Valley is among the river’s single greatest issues, and the single largest source of nitrogen and phosphorous pollution in the Shenandoah Valley. Runoff from fields where poultry litter is applied introduces unsafe bacteria, chemical and nutrient runoff, and creates fish health problems, dead zones and toxic algal blooms.
When I learned that the industry’s entire supply of animal feed (approximately 2 billion pounds annually) is imported by railroad from the mid-west and the waste is kept here, as it is, to be used as agricultural fertilizer in the Shenandoah my first thought was “this problem is virtually inevitable”. The Mid-Atlantic Regional Water Program reports that manure phosphorus production in the region exceeded regional crop phosphorus uptake by over 8,000,000 pounds annually in Rockingham County and over 2,600,000 and 2,400,000 tons annually in Augusta and Page Counties, respectively.
Poultry litter is an imbalanced fertilizer which contains several times more phosphorous than crops use when it is applied at the rate needed to meet nitrogen needs of the crops. Litter in the valley has proven to be more economical than commercial fertilizer in meeting nitrogen needs due to its abundance and low cost. Recent rises in the cost of commercial nitrogen has only reinforced this.
The File Room
During 2007, I personally reviewed over 100 Virginia Pollution Abatement Permit Files, at random, for poultry farms ranging in scale from 20,000 to over 545,000 birds on site. Almost without exception the files showed that farm operations planned their litter application at tonnages designed to meet nitrogen requirements, without regard to the chronic accumulation of phosphorous. Industry admitted during the regulatory process that many operations applied poultry waste without regard to risky application areas like steeply sloped fields, sinkholes and fields with streams running through them (most of which completely lack streamside buffers.)
The very core of the phosphorous issue is not irresponsible farmers, or intentional or accidental litter over-application. The problem is that the great majority of farmers have and will continue to apply poultry litter to their fields in the tonnage required to meet nitrogen needs, thereby grossly over-applying phosphorous. The other issues is that without regulatory guidance many farmers will apply from riverbank to riverbank. I have seen this countless times with my own eyes.
Here’s What This Regulatory Action Will Help Solve:
In 1999 House Bill 1207 passed which required Virginia to regulate poultry growers, but not farmers who bought litter or who were given litter. The regulations that came out of that bill mandated that growers perform soil testing, and apply litter at rates that crops will use without creating soil and water pollution. The result of that regulation was that a very large percentage of growers were disqualified from using litter because of the soil pollution they’d already created with past litter use. So those growers began giving the litter away and then later, selling it. Currently 80% of all poultry waste created in the Shenandoah Valley is transported off the farm where it was created and outside of regulatory guidance. Further, DEQ records indicate that of the 350,000 tons of poultry litter moved off poultry farms in 2004, approximately 75% remained in the Shenandoah Valley. Unfortunately, the new end-users of that litter are repeating the same mistake that the growers made in previous decades by again applying poultry waste for its nitrogen.
The file room work confirmed what was known: regulation from House Bill 1207 created a need for litter to be exported to “off-site” from poultry farms. It is estimated that 80-90% of litter produced by poultry farms in the Shenandoah Valley is being transported off site, and outside of any regulatory guidance.
