There has been much discussion and confusion about the impact that comprehensive nutrient management plans (CNMPs), will have on production agriculture. At press time, the farm bill, which will impact CNMPs, isn't finalized.

CNMPs will require multi-discipline activities involving animal producers, crop producers, agronomists, animal nutritionists, practicing engineers, soil conservationists and environmentalists representing both the public and private sectors. In Missouri, the Department of Natural Resources (DNR) will be responsible for some phases of CNMPs, and the Natural Resources Conservation Service (NRCS) will be responsible for other phases.

Many people and organizations are warning that CNMPs will be implemented overnight. There is generally a 2-year lag phase for EPA programs to be initiated through DNR. Also, the interrelated responsibilities of voluntary CNMPs from the NRCS and regulatory Permit Nutrient Plans (PNPs) from EPA are still being discussed. The bottom line concerning plans is to not panic. Seek out as much information as possible from the NRCS and DNR, and prepare appropriately.

Comprehensive nutrient management planning means different things to different people. From an agronomic viewpoint, it is simply a plan developed to utilize plant nutrients from all sources in a responsible manner. Simple crop nutrient mass balance is the agronomic core of CNMPs. However, the total CNMP will be much more complicated. To date, the plans are required to have six major components.

Six major components of a CNMP:

1. Feed management
2. Manure and wastewater handling/storage
3. Nutrient management/land application
4. Land treatment practices/erosion control, etc.
5. Record keeping
6. Alternate manure utilization options

Who will be responsible and authorized to write and manage CNMPs? It all depends on the scale, use and program involved. For example, a CNMP used to fulfill a voluntary program like the Environmental Quality Incentive Program (EQIP) allows certified crop advisors to write the plans only if commercial fertilizers are the crop nutrient source. If manure is involved, then a whole different set of requirements is needed. The EPA and NRCS may both be responsible for some administration of CNMPs. EPA, through the DNR, is responsible for Confined Animal Feeding Operations (CAFOs) permit procedures. Through this permitting process, CAFOs have already gone through much of the NRCS CNMP requirements.

Let's look at the six CNMP components. The feed management component will be based upon inputs from the animal producer and will not directly affect plan management. In other words, the plan does not dictate feed management, but must respond to animal wastes influenced by a feed program. Efforts like adding phytase to feed rations, something MFA's feed division is currently doing, is a proactive, environmentally sound way to lower the nutrient level of some animal wastes.

A certified practicing engineer must approve the manure and wastewater handling and storage component of a CNMP. Currently, the NRCS has a few engineers that they use for this purpose. That number may not be enough to handle a high workload, especially if minimum CAFO animal unit CNMP requirements drop.

As mentioned earlier, the nutrient management/land application component can be managed through CCAs if manure is not used. Only people trained and certified in nutrient management through a cooperative university/NRCS educational program can write the nutrient management/land application section.

Certified NRCS employees are the only individuals who can write the land treatment practices section of a CNMP. Therefore, they need to be a part of any plan development, regardless of whether some sections are written by the private sector. The NRCS is also responsible for plan acceptance and application.

The record-keeping section is technically the simplest, in terms of flexibility, affordability and certification/skill level. There are computer programs or written-form spread sheets available to accomplish this task. The NRCS has endorsed a computer program from Purdue University. This program is available online at: ww.agry.purdue.edu/software. You can review it to get an idea of the record-keeping component of a CNMP.

The alternate manure utilization option may not be required for each plan. Currently, this section does not require specific certification.

As you can see CNMPs require planning and expertise. When planning a CNMP, my first advice is to visit DNR and NRCS personnel. Secondly, work through your MFA Agri Services Center to obtain complete production agriculture-based agronomic, animal management and environmental service support.