Unified National Animal Feeding Operation Strategy

NACD's mission is to serve conservation districts by providing national leadership and a unified voice for natural resource conservation.

An animal feeding operation (AFO) is an agricultural operation in which animals are kept and raised in confined situations for at least 45 days within a 12-month period. The concentration of animals, manure and other potential pollutants such as sediment, pathogens, heavy metals, hormones, antibiotics and ammonia can cause serious water quality problems via storm water runoff flowing through a feedlot to a stream or by applying too much manure to cropland, resulting in excessive nutrient levels of nitrogen and phosphorus.

Although 85% of farms with livestock have 250 animal units or less, (AUs; one AU is equal to one beef cow) the potential collective contribution of about 450,000 AFOs across the country is one of the nation’s most serious nonpoint pollution problems. Of those, approximately 6,600 AFOs have more than 1,000 AUs. The concentration of 1,000 AUs or more is legally defined as a "large" operation and referred to as a CAFO (concentrated animal feeding operation) that must conform to more stringent requirements that basically treat it as a point source, such as obtaining a national pollutant discharge elimination system permit (NPDES). EPA proposed revisions to existing CAFO regulations in January 2001 and a court order requires that final action must be taken by December 15, 2002. NACD and 12,000 other organizations and individuals have provided comments.

During the Clinton Administration, the Clean Water Action Plan identified polluted runoff as the most significant remaining source of pollution. USDA and EPA developed a coordinated strategy to minimize water quality and public health impacts of AFOs. Although many aspects of the Clean Water Action Plan have been deactivated by the change of administration, the Unified National AFO Strategy is still considered the proper approach and process to solving the problems associated with polluted runoff and AFOs. USDA and EPA will work closely with states and tribes to incorporate state and tribal issues and also meet national performance goals.

The key component to the Unified Strategy is the development and implementation of a site-specific Comprehensive Nutrient Management Plan (CNMP) for every AFO. An CNMP may require: modifying animal diets and feed to reduce the amounts of nutrients in manure; proper handling and storing of manure to prevent contact with runoff; land application of manure according to nutrient management guidelines; using tillage and crop residue management to maximize infiltration of rainfall and minimize runoff in cropfields where manure has been applied; keeping good records of manure management and application rates; and, using other options as necessary when land application is limited such as selling manure to other farmers, composting manure and selling it as a garden and landscaping product and capturing methane from manure storage and converting it to electricity.

For the vast majority of AFOs, developing and implementing CNMPs will be conducted through a voluntary and locally led approach utilizing the traditional financial and technical assistance, environmental education and programs offered by USDA-Natural Resources Conservation Service (NRCS) and conservation districts or through certified nutrient management consultants for a fee. Large operations falling under the CAFO designation must meet the specified criteria of NPDES permit regulations.

The Strategy identified several action items necessary to improve the implementation of the national process. They include: building capacity for CNMP planners and implementation; accelerating voluntary, incentive-based programs; implementing and improving the existing regulatory program; coordinating research, technical innovation, compliance assistance and technology transfer; encouraging industry leadership; coordination data sharing; an establishing performance measures and accountability.

To Learn More:

Visit EPA’s AFO web page at http://cfpub.epa.gov/npdes/home.cfm?program_id=7