Saturday, 15 July 2006

Participatory Process to Develop a General Permit for Regulation of Concentrated Animal Feeding Operations (CAFOs) in Connecticut.

Thomas Morris1, Walter Smith2, Joseph Neafsey2, and Joseph Wettemann3. (1) Univ of Connecticut, Dept of Plant Science, 1376 Storrs Rd, Storrs, CT 06269-4067, (2) USDA, Natural Resources Conservation Service, 344 Merrow Road, Suite A, Tolland, CT 06084-3917, (3) Connecticut Dept of Environmental Protection, 79 Elm Street, Hartford, CT 06106

Nonpoint pollution is difficult to regulate with the methods traditionally used for point source pollution. There are two primary reasons for the increased difficulty of regulating nonpoint pollution. First, reducing nonpoint pollution requires changes in behavior by many people while reducing point source pollution usually requires changes in behavior of only a relatively few people, and second, measurement of reductions in pollutants from nonpoint sources is complex and expensive compared with the measurement of most pollutants from point sources. Because of these differences in the decision-making processes between nonpoint and point source pollution, different, more participatory methods are needed to regulate nonpoint source pollution. Our first step to develop regulations for Animal Feeding Operations (AFOs) and Concentrated Animal Feeding Operations (CAFOs) in Connecticut involved a participatory process to develop a general permit. The Connecticut Department of Environmental Protection (DEP) has the authority to issue general permits for environmental protection. This authority allows the Commissioner to develop and issue a single permit to cover similar minor activities throughout a prescribed geographic area. A general permit sets terms and conditions for conducting an activity that, when complied with, are protective of the environment. The Connecticut General Permit Advisory Committee participatory process was initiated to obtain the best terms and conditions for a general permit for CAFOs. The process involved the participation of farmers, agricultural industry groups, USDA-Natural Resources Conservation System (NRCS), the DEP, Cooperative Extension, university scientists, EPA, nonprofit environmental groups, and farmer groups. We met regularly for a two-year period, and all groups and individuals participated in the development of the permit. Connecticut's general permit requires the collection of field-by-field records of manure and fertilizer applications, use of the field-by-field records to educate the farmers, soil and plant tissue testing to help verify amounts of nutrients applied, annual feedback of information to the farmers, and a review of the program every five years to improve and revise the recommendations contained in the permit. The permit is completed and awaits implementation. The permit has not been implemented because information about the amount of surplus manure in the state was estimated as part of the permit process, and this new information prompted DEP to begin a new process to develop solutions to the surplus manure before implementing the general permit. The participatory process was important for the development of a mutual understanding among the regulatory community, the farm community, and the environmental community about the difficulties our society faces trying to minimize pollution of soil and water while producing meat, eggs and milk in a world economy. The participatory process also allowed the creation of a general permit that was flexible and had the confidence of the environmental and farm community. Without the confidence of the farm community - the affected stakeholders - effective implementation of the permit would be difficult because most of the information required by the permit is self-reported data by farmers.

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