Testimony of Jim  Moseley
on behalf of the
National  Pork  Producers  Council

concerning animal waste  management

before the
Senate  Agriculture, Nutrition, and Forestry Committee
April 2, 1998
 


Introduction

Good morning, Mr. Chairman and members of the Committee.  I appreciate the opportunity to testify on behalf of the National Pork Producers Council (NPPC) on this important issue.  My name is Jim Moseley.  I am the owner and managing partner of Infinity Pork and AgRidge Farms located in Clarks Hill, Indiana.  My wife and I began farming 28 years ago on a loan from the Farmers Home Administration.  Taking a break from full-time farming, I served as the Agricultural Advisor to Administrator William Reilly of U.S. Environmental Protection Agency from 1989-1990.  From 1990-1992, I was Assistant Secretary of USDA for Natural Resources and the Environment.  From 1993- 1995, I was Indiana's Director of Agricultural Services at Purdue University before returning to farming full time.

Also with me today is Glen Keppy from Davenport, Iowa.  Glen farms 1,000 acres and runs a 200 sow farrow-to-finish operation.  He is a past member of the Board of Directors and Federation Council of the National Pork Producers Council and served a one-year term as president of that organization from 1994-1995.

For the record, I would like to submit the following documents and materials: National Pork Producers Council Environmental Assurance Program; NPPC's Environmental Resource Guide (which includes a state-by-state comparison of livestock operations environmental regulations); and USDA/ARS Manure Production and Nutrient Maps.

Pork Industry's Social-Economic Issues vs. Real Environmental Concerns

The environment is the single largest issue facing the U.S. pork industry.  We believe it threatens not only our future growth and profitability of new and expanded operations, but impacts every pork producer in business today.
 
The rise of large scale hog farms in the United States is a complex subject, one that's attended by all sorts of economic, social and political considerations.  NPPC wants the Committee to understand some of the forces that are driving the structural changes in our industry and give you some information that will help place these changes in perspective.  We need to distinguish the politics and emotions of the economic/social issues from the real environmental concerns related to pork production.  In addition, any legislation and/or regulations that are written at both the federal and state levels must make the distinction of these issues as well.

Like every other major agricultural sector, the number of individuals involved in pork production has declined over time.  It seems that the number of agricultural producers is cut in half every generation.  For example, between 1950 and 1970, the number of pork producers dropped from 3.1 million to less than nine-hundred-thousand. During that time, hog production increased from 79 million head to 87 million head. In the nearly thirty years since then, the number of producers has declined to about one- hundred-forty-thousand and production is expected to set a record this year of 104 million head.  According to the U. S. Census of Agriculture,  50 percent of pork producers have left the pork industry every decade since the 1930's regardless of prices received. So, pork producers, like others in agriculture in general, continue to become fewer and larger.

Pork production has been the single most profitable of the traditional farm enterprises in the past ten years.  That fact, and the fact that pork producers recognize we are in an information age, has been the reason for the more rapid development of new, larger pork operations.  Pork production rewards attention to detail and information better than almost any other segment of agriculture.  For example, let's look at just one measure of efficiency, the amount of pork produced per breeding animal.  Since 1964, the amount of pork produced per breeding animal has jumped from thirteen-hundred pounds to more than twenty-five-hundred pounds per head.  In fact, our most efficient breeding operations are producing 5,000 pounds per breeding animal annually.

Taking advantage of information and implementing it has altered the way pork operations look.  Today, instead of one operation being the site of all phases of production from birth to marketing, many operations consist of only one phase of production.  Separating the phases of production yields dramatic improvement in herd health, reducing input costs and boosting growth efficiency.  That increase in efficiency makes it cost-effective, for example, to have a breeding herd in North Carolina or Colorado and ship the pigs to the Corn Belt where the corn is much less expensive and where most of the slaughter and processing plants are located.  Economics therefore dictates that these very specialized, single phase production sites will be larger and will be professionally managed.

The other key economic driver for larger, specialized operations is consumer demand for low-fat, consistently high-quality pork.  Producing consistent, lean pork requires specialized genetics, which in turn requires specialized housing, feed and management. It's been very effective and beneficial to consumers.
 

These trends toward larger specialized operations mean that about 70-percent of hogs are produced by operations with more than one-thousand head of inventory, about twelve-thousand producers. For perspective, about the same percentage of the nation's cattle are fed by less than two-thousand feeders.  The consolidation figures are even more dramatic in the poultry industry.

It's very important to recognize that the structural changes in the pork industry are toward a vertically-coordinated model, not simply a monolithic, vertically-integrated type of organization. This is what makes the pork industry a great opportunity for young producers. It's becoming very common for a group of individual farmers to cooperatively build a specialized breeding, gestation and farrowing (birthing) facility to make use of the high quality genetics needed to produce the type of pork consumers demand.  Each of the farmers in such a system receives consistent quality pigs to finish on their own farms and then markets those high quality animals at a premium.

This trend is illustrated very well by USDA hog inventory reports. The largest category of producers, five-thousand head and larger, grew by only 80 people last year. The mid- sized category, two-thousand to five-thousand head grew by five hundred people. These are individuals and family operations that are making the jump from three-hundred to six- hundred sow breeding herds taking advantage of specialized facilities and professional management to produce a superior product. These are the kind of operations that are an attractive, viable career choice for a young person who has many potential career choices off the farm.  There is not just one production model to follow.  That's the new frontier of the pork industry.  Frankly, it's the new frontier of agriculture.

So, the result of consumer demand, economic forces and information-driven producers is larger, specialized hog production facilities.  Are there environmental and odor issues for these facilities?  Yes. Producers of every size need to assess the critical environmental control points for their operation.  State and federal regulations already establish a zero-discharge, standard for the largest livestock feeding operations.

Environmental incidents involving pork operations get a lot of attention today. Pork operations are under a microscope from citizens, the media and regulators.  However, for perspective, in Iowa, the largest pork production state there were environmental enforcement actions against 13 livestock operations of all species in 1996.  That's about one enforcement action for every 8,000 livestock enterprises in the state.
 

We are not telling you this to suggest our industry should not be responsible for environmental management.  Far from it.  Our industry produces about twelve-percent of all the animal manure in this country and we are committed to taking care of our share.

Manure is a valuable resource.  It has been estimated by Dr. Alan Sutton of Purdue University, that the fertilizer value of swine manure may range from $2.50 to $3.50 per market hog sold.  That would equate to a value of $250 to $350 million worth of fertilizer from the expected 100 million head of hogs marketed in the U.S. in 1998.

There are numerous technologies today applied by the pork industry to make the nutrients and  by-products of manure profitable.  Such technologies include: methane gas recovery from lagoons to generate electricity; "bio-covers" to control odor and increase nutrient values  of the manure for use as a fertilizer; composting of manure, which also includes recycling of dead animals in an environmentally sound manner; red worm farming to treat the nutrients and sustain a valuable red worm export industry; solid separation systems where the water is reused and the solids will be applied as valuable fertilizer; and "Hoop-Structures" which are production systems that utilize manure, mixed with straw,  to provide dry bedding material that serves as a heat source for the animals in the structure and is a nutrient rich material to be used as fertilizer.

Pork producers are applying the same information and technology-based approach to environmental management as we have to every other aspect of the industry.  This information and technology is inevitably driving us toward a very efficient match-up of fertilizer nutrients with our land resources. I'm confident we will be as successful in environmental management as we have become in production management.

Anyone who's even a casual observer of our industry will recognize that policy discussions about changes in the pork industry often combine scientific environmental concerns with social or industry structure concerns.  It is very important to recognize you can't solve one with the other.  It's family operations like mine that will be hit the hardest by industry social structure laws disguised as environmental regulations.

Ten years ago, Europe was the epicenter of the world, as far as pork production information and technology.  Now, we are.  Our industry is the most efficient in the world because we have become information-, economics- and technology-driven.
 
 

Our industry is highly mobile. Other countries want our industry because of its proven track record of profitability.  I see our challenge, our new frontier if you will, as keeping businesses like mine in the United States, producing a desirable, value-added product in an  environmentally-friendly way.

NPPC's Position on the Legislation Pending Before the Committee and Current Administration Clean Water Efforts

NPPC opposes the legislation before your committee.  The bill does not focus on science-based, sustainable and affordable solutions to improve the environment.  Instead, the bill focuses on ways to address social and economic issues, as well as, environmental concerns.  Many of the provisions in the bill attempt to stop our industry from changing as I have highlighted previously.

It is clear that the pork industry, is rapidly moving toward one that is highly regulated.  Pork producers have recognized over the past three years that this regulatory change was on the horizon.  The industry responded, and through NPPC's environmental and other educational programs, it gave the pork industry a headstart on finding solutions to our environmental problems.  This is being done with producers' dollars and with cooperative efforts with USDA, EPA, state and local officials.

The President and his Administration have underway efforts to implement his recently announced Clean Water Action Plan (CWAP).  We believe this effort will address environmental concerns in a way that is science-based, sustainable, affordable, and achievable.  Based on the President's announcement, we believe that legislation is premature at this time.

According to the "Draft Animal Feeding Operations (AFOs) Strategy" published March 4, 1998, which is a subset of the CWAP, EPA intends to re-write the "effluent limitation guideline (ELG) for livestock."  The ELG information collection process is already underway.  EPA has met with our organization to learn more about our industry.  The ELG will become the national floor which all states will be required to incorporate into their respective state livestock regulations.  States can set more stringent standards if they choose.  EPA has indicated it intends to consider many of the recommendations included in the Comprehensive Environmental Framework for Pork Production Operationsissued by America's Clean Water Foundation in December 1997. I will discuss this effort later in this statement.
 

Under the bill before you, small operations (down to about 100 sows farrow-to-finish) would be classified as Concentrated Animal Feeding Operations (CAFOs),  and would be required to:  1) Obtain an operating permit, 2) limit to crop phosphorus uptake any manure application (applies to any person), 3) not apply manure to any soil already high in certain elements (applies to any person), 4) not construct any concrete manure storage pits below the water table, 5) close any existing concrete pits below the water table, 6) close any lagoons which do not meet new separation distance or other requirements established by the Secretary of USDA, and 7) construct secondary containment around existing containment structures in order to obtain an operating permit.

While NPPC agrees with some of the general environmental provisions in the bill  such as mandatory nutrient management plans,  the way the legislation attempts to implement the requirements is flawed and unworkable.  A large number of existing operators would be required to close their existing manure storage structures.  This, and the secondary containment provision would require substantial capital outlays by producers in a very short period of time.  It would also require control of more land to accommodate the phosphorus limitation.  It is unclear whether the engineering expertise, either public or private, the construction contractor capacity, or the testing lab capacity exists to implement the requirements of the bill in the time frame envisioned.

The bill gives USDA a regulatory and enforcement role which since 1972 has been the jurisdiction of EPA. Though many operators would likely prefer dealing with local USDA personnel, it is unclear whether the agency has capacity to carry out this function.  Additionally, this bill would make USDA a regulator - not helper - of livestock farmers.  USDA's   role  has been solving and correcting on-farm problems, not  enforcing against farmers.  Split jurisdictions between USDA and EPA or state regulatory agencies could require an operator to obtain multiple permits from different agencies for the same operation. It's important to note this bill specifically does not pre-empt additional regulations at the state or local level.

The bill's CAFO provisions nominally apply to animal "owners." However, the operator of a facility can be considered an animal owner if he/she does not own the animals.  A definitive legal review is necessary to determine which party ultimately is the permit holder under the proposal..

I would also like to address the inaccuracies and omissions in the Senate Agriculture Committee's Minority report of December 1997 dealing with livestock nutrients. The report justifies broad, new laws regarding concentrated animal feeding operations by compiling manure tonnage figures from all concentrated animal feeding and grazing systems.  The report states that 10,000 pounds (five tons) of animal manure is produced for every American. The report clearly implies that all collectible manure from concentrated cattle, hog and poultry feeding operations is equal to 10,000 pounds per person.  The truth is only 700 pounds per capita of such manure is collectible and of that, only 100 pounds comes from pigs.  Further, this nutrient source is recycled as a valuable fertilizer for growing U.S. farm crops. I want to reiterate that manure is a valuable resource and not a liability if handled in an environmentally sound manner.

The truth is that two-thirds of all manure is from cattle and two-thirds of thatamount is distributed widely and in low concentration over 650 million acres of pasture and grazing land just as it has been for more than a century.  For perspective, 650 million acres is an area ten times the size of the state of Colorado.

The truth is, for every pound of nitrogen in manure produced by pigs in this country and applied to cropland as fertilizer, two pounds of nitrogen are piped directly into our rivers and streams by municipal and industrial waste water treatment plants and 4 pounds of nitrogen are released into the atmosphere, primarily from industrial fuel combustion and transportation.  As we discussed above, we are regulated as a zero- discharge industry.  We are aggressively working with pork producers at every level to ensure we are not discharging manure into our lakes, bays, estuaries, oceans, groundwater, rivers, streams and drinking water supplies.

There are about 15,000 publicly owned municipal waste water treatment facilities processing more than 31 billion gallons of waste water each day.  They, along with industrial facilities, discharge 3.2 billion pounds of nitrogen directly into surface waters each day. This does not count the hundreds of so-called by-pass situations where, because of heavy rains, flooding and equipment failure, raw sewage is discharged directly into surface waters.  EPA does not have a system for gathering information about these by-pass situations so the extent of this type of pollution is difficult to even estimate.  It is known that during the 1996 hurricane season, 68-percent of North Carolina's municipal waste water treatment facilities malfunctioned and discharged 270 million gallons of raw, untreated sewage.  That compares to less than one-percent of livestock lagoons with discharges during the same period.  In 1997, 52 municipal treatment facilities in North Carolina exceeded their limits for flow, or for nitrogen or phosphorus.  Many of the facilities had multiple events where limits were exceeded.  A total of 168 events were reported by Department of Environment, Health and Natural Resources, North Carolina.  This does not include spills.

Manure spills from livestock facilities are unacceptable. However, those that have resulted in fish kills are rare and have not increased substantially in recent years in states like Iowa, the largest pork production state. In 1995, there were 5 swine manure spills that resulted in fish kills in Iowa.  In 1997 there were 6.  In the words of the Iowa Department of Natural Resources Information Director, "…there is increasing interest in this issue, (but) we do not necessarily think the number of fish kills is increasing."  Iowa DNR assessed more than 10,000 miles of streams in the state and only 3-percent were classified as not supporting designated uses because of pollution from all sources.  The same survey showed the water quality of 91-percent of Iowa's 115 significant publicly-owned lakes was either improving or stable.

We don't bring this information to light to justify a "do-nothing" policy.  As I will describe now, the pork industry is the leader in advocating progressive regulation and effective management programs.  However, misrepresenting the industry's environmental impact is wrong, counter productive, and cannot be allowed to stand uncorrected.

NPPC Policy and Regulatory Efforts

Faced with growing public criticism and state and local censure, the pork industry has had to move quickly to protect its current success and safeguard its future by encouraging development of an improved national policy for environmental protection.  This national approach has to be environmentally sound, affordable, achievable and sustainable for pork  producers of all sizes.

The pork industry is experiencing growing social and political measures which threaten pork production in the U.S.  These threats include:
 
 
 
 
 
 
 
 
 
 

 
A growing trend to use local zoning, land use, and health department controls to preempt state and federal rules, for example: (1) South Dakota: counties may adopt zoning regulations, including up to a four-mile setback distance for new hog operations;
(2) North Carolina: counties may issue special use restrictions;
(3) Indiana: CAFO's must comply with local zoning requirements if more stringent than state requirements;
(4) Colorado, Utah, Georgia, Michigan, and Kentucky:  counties may adopt zoning regulations;
(5) Mississippi: a local judge has invalidated a water pollution permit granted to a swine operation because the operator had not also obtained an air pollution permit, in spite of the fact the state regulatory agency has no procedure to require an air permit;
(6) Kansas: about half of the two dozen counties which had earlier voted to exempt themselves from the state corporate farm law restrictions have responded to political pressure and reversed their exemptions.
  TV programs and newspaper series have trumpeted our industry's environmental problems, for example:
(1)  60 Minutes TV program shown in 1996 and 1997;
(2) The Raleigh News and Observer newspaper won a Pulitzer Prize for its Boss Hog series attacking the pork industry;
 (3) At the same time, the stories fail to focus on the billions of gallons of raw sewage which flows into our nation's rivers from human septic and municipal facilities.
  Public opinion leaders, state regulators, legislators, local government leaders and local activists are freezing industry growth with poorly thought out, unscientific, and overly broad moratoriums, for example:
(1) North Carolina moratorium enacted and may ban lagoons;
(2) proposed moratorium in Nebraska, Minnesota, and Illinois;
  (3) Kentucky and Oklahoma moratorium enacted.
  State legislatures are enacting stringent emergency legislation producing an inconsistent patchwork of regulations, for example:
(1) permits are required for farms with as few as 50 animal units in Minnesota but as many as 1000 animal units in Wisconsin.  In Nebraska, operations of any size require a permit if they have potential to discharge;
(2) Minnesota has proposed local health ordinances to regulate exposure to hydrogen sulfide gas from hog operations;
(3) A South Dakota petition drive was successful in placing on the state's November, 1998 ballot a constitutional amendment to ban non-family farm corporations and syndicates from raising livestock.
  National environmental groups working with local activists are pursuing aggressive anti-pork production legal strategies, for example:
(1) ACCORD, a Texas group, has sued Texas Farms over alleged water pollution and nuisance;
(2) CLEAN, a Missouri group, has sued Premium Standard Farms over alleged water pollution and nuisance;
(3) The Missouri Attorney General has threatened to sue Premium Standard Farms over alleged clean air and water violations.
  EPA and USDA have announced new phosphorus nutrient standards.  These could be applied nationwide to phosphorus-impaired watersheds or wherever agricultural soils are determined to have excess phosphorus.
  An hypoxic (lack of oxygen) zone in the Gulf of Mexico is associated with nutrient runoff from farmland into the Mississippi River.  EPA is coordinating a multi- agency effort to reduce farmland runoff of nutrients in bordering states. Livestock, human sewage, row crop agriculture and commercial fertilizers are being blamed.
  A potential health-threatening microbe called Pfiesteria is linked to excess agricultural nutrients.  Because it has killed millions of fish in North Carolina, Virginia and Maryland, and is being blamed for causing injury to people, those states and U.S. EPA will likely adopt stringent controls on phosphorus and other nutrients. Livestock, row crops, commercial fertilizers and human sewage are being associated directly with the problem of the microbe.
  EPA and states are aggressively enforcing livestock pollution problems:
(1) U.S. EPA announced in Kansas City, MO in May, 1997, a national enforcement and compliance effort against livestock producers of all sizes;
(2) Vice President Al Gore, on October 18, 1997, announced in the Federal Register, a national effort by all federal agencies to:
(a) expedite development of a strategy for animal feeding operations of all sizes,
(b) identify sources of nitrogen and phosphorus in waters and improve water quality monitoring, and
(c) assure that all 29 coastal states have coastal nonpoint pollution control programs fully approved by June, 1998;
(3) U.S. EPA announced in Wye River, MD in October, 1997, a comprehensive nonpoint pollution control initiative that will include livestock controls and the development of nutrient criteria for numerical water quality standards.
  Clean Water Act Total Maximum Daily Load settlements or lawsuits in 20 states or more (e.g., Georgia, Kansas, North Carolina and Alabama) could put federal judges in charge of dictating how pork producers and others in agriculture farm. In Oregon, for example, farms located in impaired waterways must be responsible for reducing a percentage of the water pollution that is due to nitrogen, phosphorus, bacteria, sediment, water flow or water temperature changes.  This means mandatory best management measures.
  EPA Office of Water Assistant Administrator Robert Perciasepe announced on November 13, 1997 to The America's Clean Water Foundation's sponsored National Environmental Dialogue on Pork Production that the Agency plans to rewrite the livestock effluent guideline: In early December 1997, EPA announced its intention to issue new effluent guidelines for livestock production.  These guidelines form the basis for state water quality permits and will affect the manner in which state livestock permits are written and enforced.  EPA has said it intends to drastically lower the threshold livestock operations which will be required to comply with the guidelines.
 
Pork producers, by necessity, are leading the way in pursuing environmentally sound and comprehensive, updated regulations. As you know, not everyone in American agriculture supports the actions we have taken.  We are also at the forefront of promoting new technologies to address air and water quality.  In the words of Environmental Protection Agency Administrator Carol Browner on March 6, 1998, pork producers have "just been wonderful in working with us promoting environmental stewardship across your industry.  You have literally been out front bringing people together to find creative, cost-effective ways to protect the quality of our water.  We are very, very heartened that you have stepped forward and so willingly taken on these difficult issues and worked so hard to find solutions."

Pork producers have actively sought progressive reform of laws and regulations to more closely govern the production, handling and land application of manure. Pork producing farmers joined with the EPA, the USDA and state regulatory agency personnel in the historic 1997 policy dialogue entitled "National Environmental Dialogue on Pork Production" convened by America's Clean Water Foundation (ACWF).  The Foundation is a Washington, DC-based non-profit organization created in 1989 as a Forum for citizen involvement, youth education and technical program exchange.  The founding leaders of ACWF include: Former President Jimmy Carter; former Senators and Representatives Edmund Muskie, Howard Baker; William Harsha and John Blatnik, the principle House and Senate authors of the 1972 Clean Water Act.

A summary of the Comprehensive Environmental Framework for Pork Production Operations follows:

The National Environmental Dialogue on Pork Production was convened early in 1997 by America's Clean Water Foundation to address environmental concerns and issues related to hog farming. The Dialogue met for 24 days over eight months to visit farms and research institutions, hear from concerned citizens and scientific experts, and share their own experiences and perspectives.  On December 12, 1997, the Dialogue participants -- federal officials from the U.S. Environmental Protection Agency (USEPA) and U.S. Department of Agriculture (USDA), seven heads of regulatory agencies and five alternates in seven States, and five pork producers and two alternates from five States -- issued a Comprehensive Environmental Framework For Pork Production Operations.

The Framework proposes effective, affordable, and scientifically-based standards and procedures that would be applicable to all aspects of pork production in the United States.  The Dialogue members believe that -- if these standards and procedures are ultimately adopted -- they will promote the protection of the environment, public health, and welfare from the environmental impacts associated with the breeding and raising of hogs while providing consistency in the regulation, and preserving the sustainability, of the pork production industry.

The Framework makes recommendations for regulation of the pork production industry.  Those recommendations will have no effect unless and until they are enacted into law or otherwise adopted by federal, State, and local jurisdictions.  If they are adopted, they would broaden and strengthen existing federal regulations, establish more rigorous and consistent State regulatory programs, and ensure a constructive role for local government.

The Framework is indeed "Comprehensive."  It calls for the permitting of both new and existing pork production operations of all sizes.  The Framework proposes regulation of all aspects of pork production (immediately for new or expanded operations and over a five-year phase-in period for existing operations).  It recommends:
  public participation procedures for the permitting of new or expanded operations;
  management and location requirements to prevent pollution of surface and groundwater and control odor, including a cumulative effects analysis and specific setbacks for new lagoons and other new facilities where manure and wastewater are stored and for areas where manure is applied to land;
  standards for the design, construction, and operation of all facilities;
  restrictions on rates and methods for land application of manure and wastewater, including the requirements to do soil and manure testing, to prepare nutrient utilization plans, and, in certain circumstances, to employ a phosphorous-based standard;
  preparation of emergency response plans, and compliance with emergency response and notification procedures;
  certification of all operators;
  training of supervisors and employees who are engaged in land application activities or are responsible for emergency responses;
  provision of financial guarantees by operators of new or expanded operations;
  record keeping and inspections;
  closure standards for manure storage facilities;
  civil and criminal enforcement, with stringent penalties for "bad actors" (including permanent cessation of operations);
  various forms of financial and technical assistance to enable pork producers to comply with the Framework's recommendations; and
  additional research to be conducted on certain environmental and public health questions which the Dialogue participants believe have not yet been adequately answered.
 
If these recommendations are followed, they provide assurance that pork producers can operate and increase production from their farms at the same time they protect the environment. Producers from 44 states voted overwhelmingly on March 6, 1998 at the Annual National Pork Industry Forum to support the regulatory framework. Today we are working cooperatively with EPA as it develops the key components of the Administration's Clean Water Action Plan. NPPC believes that if the Dialogue recommendations are adopted by EPA, they will provide sustainable, affordable science- based approaches to environmentally sound pork production.

NPPC's Environmental Programs

In addition to its leadership in the policy arena, NPPC and the pork industry have taken bold steps to implement odor and water quality management strategies directly on the farm.

I.  On-Farm Odor/Environmental Assistance Program: The public is demanding the odor performance of the U.S. pork industry be significantly improved.  Pork producers, private industry and the federal and state government are committing millions of dollars to odor research efforts. At the same time, it is estimated that at many operations, as much as half of the odor from the operation can be reduced through improved management.  The On-Farm Odor/Environmental Assistance program, launched by the National Pork Producers Council, is designed to provide producers with a cost-free, neutral, third-party audit/assessment of their operation's odor and environmental management effectiveness and identify areas where improvements are possible.

The On-Farm Odor/Environmental Assistance program was developed by several of the nation's most experienced professional agricultural engineers along with engineers from USDA's Natural Resources Conservation Service and the Cooperative Extension Service.  A private environmental consulting firm with extensive experience in third-party verification of major EPA environmental assessment projects, Tetra Tech EM Inc., was retained to document that sound scientific principles and quality control measures are adhered to in every step of the process.

The On-Farm Odor/Environmental Assistance program requires the active involvement of the producer as a team of trained engineers/technicians makes a detailed, on-site assessment of the operation's buildings, manure handling and storage structures, manure management plans and overall facility siting, operations and maintenance.  The engineer develops a written report detailing areas or practices which may be having an impact on odor and environmental performance.

The program has been pilot tested on 24 swine farms in Minnesota, Iowa, Missouri and North Carolina. Using the results of the pilot phase, the development team, along with Tetra Tech EM Inc., will refine the assessment process to ensure appropriate air and water quality management issues are addressed in the final assessment template. An additional module is under development to provide a pre-construction assessment of a proposed building site and its odor and environmental management plans.  The program is scheduled to be available through state producer associations outside the pilot states beginning this summer.

II.  Environmental Assurance Program:  The EAP is a comprehensive, continuing education program delivered at the local level.  The program focuses on classroom training in key environmental management areas, including: nutrient management, air and water quality, facilities management, federal and state regulatory requirements, manure treatment, storage and application, pollution prevention strategies and community relations. Approximately 12,000 producers have already participated in a local EAP workshop.

III.  Odor Solutions Initiative (OSI): The National Pork Producers Council, through funding from the National Pork Board, has launched a $3.5 million initiative to aid the development of odor control technology by private industry and individuals.  The Odor Solutions Initiative is designed to identify and evaluate biological, chemical, mechanical and management technologies to abate odor and reward individuals for bringing this technology forward.

In recent years, the pork industry has supported scientific research at the university level to improve the basic understanding of the chemistry of odor, transport of odor and methods of controlling odor.  While this basic research is ongoing, hundreds of individuals and private companies are developing and aggressively marketing products or devices which are claimed to reduce odor at pork production facilities. These products include biological or chemical additives for buildings or manure storage/treatment structures, feed additives, aeration or ozonation equipment, solids separators, digesters and composters. The types of technologies range from treatment with beneficial bacteria, earthworms, ultraviolet light, ozone or methane capture systems.  Some technologies are designed to have application in certain production systems but not others.  Many of these products were developed for use in other industries and the developers are now searching for additional applications. The majority of these products have little to no independent research data to substantiate their effectiveness claims in pork production applications.  This makes it extremely difficult for pork producers to sift through the hundreds of potential products and find one that has applicability to the conditions of his or her own operation.

The Odor Solutions Initiative is designed to assist producers in this process by providing an independent, replicated, on-farm evaluation of odor technologies.  Beginning later this month, the OSI program will solicit entries from individuals and private industry for products that will be tested on three to five farms per technology.  Installation or application of the technologies will begin in July, 1998.  Odor and water quality will be continuously monitored at the farm sites while the technology is in place.  Odor will be measured by olfactometry, chemical analysis and any other documented method.  Third- party verification of odor measurement and laboratory procedures will be provided.  Final evaluation will be against the technology providers' claims.  Information about the effectiveness of the technologies will be provided to producers throughout the industry to assist them in making decisions.

IV.  Environmental Stewards:  This program recognizes those producers who are leading the pork industry toward an environmentally sound and profitable future. The Stewards Program recognizes five regional stewards who are doing an outstanding job of environmental management in five key areas: manure management systems, financial management, aesthetics and neighbor relations, wildlife management and innovation.  An independent selection committee comprised of experts from various pork industry and natural resource organizations reviews all applications.

V.  Environmental Research:  In addition to its commitment to farm-level programs to ensure excellent environmental performance, pork producers are funding scientific research in key environmental areas.  Research projects include: protecting water quality in areas of manure applications, technology to reduce odor from swine facilities and manure application, altering pigs diets to reduce odor, development of an electronic nose to measure odor and evaluating groundwater impacts from manure storage structures.  Through 1998, more than three-quarters of a million dollars in producer funds have been committed to environmental research projects at 17 universities.  This is in addition to the $3.5 million allocated specifically for odor research through the Odor Solutions Initiative and the millions of dollars spent by state pork producer associations on environmental and odor.

What the Federal Government Can Do to Provide Financial and Technical Assistance to the Industry

Since the enactment of the 1972 Clean Water Act, more than $125 billion has been spent by the federal and state governments to implement the law.  The focus has been overwhelmingly on "point source" pollution control.  It is only appropriate that the federal government along with the appropriate regulatory authorities and other federal or state agencies should endeavor to provide incentives such as financial and technical assistance to pork production operations to adopt practices necessary to meet the existing and future regulatory mandates, including the construction of stormwater diversion structures, vegetated filter buffer areas, secondary containment basins, grassed waterways, wastewater wetlands, emergency spillways, odor and insect controls, or the construction or improvement of manure and wastewater storage facilities.
Pork  production operations should be eligible to seek financial or technical assistance to adopt environmental practices necessary to meet the existing and new environmental  requirements. Examples include the following sources:
1. Conservation programs administered through the U.S. Department of Agriculture including, but not limited to: the Environmental Quality Incentives Program; Conservation Reserve Program; Wildlife Habitat Incentives Program; Wetland Reserve Program; Conservation Farm Option; Conservation Technical Assistance; and Small Watershed and Flood Protection Program.
2.  Programs administered by the States under delegation from U.S. Environmental Protection Agency: Section 319 program of the Clean Water Act;  and Source Water Protection Program of the Safe Drinking Water Act.
3.  State assistance programs

Research Needs of the Pork Production Industry

1.  Research Subjects:  Government, academia and the pork production industry should encourage and support research on at least the following subjects:

Odor measurement and control:
  development and validation of prediction models for off-site odor transmission [Note -- NPPC, through the Odor Solutions Initiatives, has taken the lead in a cooperative effort to bring together leading scientists and establish an effective method of gathering air samples.  This work is taking place this winter and spring in several states.];
  validation of electronic nose technologies to evaluate methods for odor reduction;
  development of precision land application machinery to meet odor and nutrient objectives;
  development of odor abatement products and methods for swine containment facilities, manure and wastewater storage facilities, and land application areas;
  evaluation of release and dispersion of volatile organic compounds and trace gases from manure and wastewater storage facilities;
  development of covers for swine manure and wastewater storage facilities to reduce odor;
  measurement of odors from manure and wastewater storage facilities under various facility management regimes and climatic conditions;
  evaluation of animal diet manipulation and bacterial treatment of manure and wastewater storage facilities to reduce odorous compounds in swine manure and wastewater; and
  odor and dust reduction in ventilation exhausts from swine confinement buildings.

Atmospheric deposition of pathogens and nitrogenous compounds:
  measurement of volatilization of nitrogen-based compounds from swine containment facilities, manure and wastewater storage facilities, and during land application of manure and wastewater by irrigation and other methods;
  evaluation of water quality impacts of atmospheric deposition of nitrogenous compounds;
  development and validation of prediction models for atmospheric deposition of nitrogenous compounds; and
  measurement of distribution distance and patterns of pathogens and dust from ventilation exhausts of swine confinement buildings.

Manure and wastewater storage facility improvements:
  evaluation of advanced materials and technologies for lagoon construction and performance; and
  evaluation of alternatives to lagoons for storage and treatment of swine manure and wastewater.

Improved monitoring technologies:
  development of technologies to determine the origins of nutrients and pathogens; and
  development and validation of predictive models and analytical techniques for  determining individual and cumulative impacts of various pollutants and pollutant sources on watershed impairment.

Determination of soil nutrient threshold capacities:
  development for each major soil type of an understanding of the capacity to adsorb phosphorus and other key agronomic nutrients;
  determination and validation of predictive models of phosphorus threshold levels for each soil where adsorption capacity is exceeded and solubilization occurs;
  evaluation of the impact of various management measures and land application techniques on off-site phosphorus movement on different soils, slopes and climatic conditions.
2.  Innovative Technologies Center: The federal government should  establish a national center for the development of innovative technologies for pork production, to review research proposals, and to provide research and development grants.

Conclusion

As pork producers, we must manage our operations in an environmentally responsible manner.  We are working closely with EPA to develop more detailed regulations that closely match the varying production systems in place today and allow producers to make maximum use of the crop growing nutrients in hog manure as a part of a sustainable agriculture system.  We are aggressively implementing on-farm programs to speed implementation of new environmental management and technology.

We oppose the legislation before this Committee because more comprehensive regulatory action is already taking place at EPA.  We urge the Committee to support needed research in several key areas, including odor control and manure nutrient management.  NPPC urges the Committee to support the use of existing cost-share and technical assistance programs and a level equal  to the importance of this issue and consistent with the level of resources historically committed to point- source pollution programs.

We believe strongly that misinformation about the pork industry's environmental impact should be corrected.  Therefore we urge the Committee to assist the industry in accurately communicating about the bold steps pork producers have taken in seeking progressive  regulatory reforms and effective environmental management programs at the farm level.  The Committee could help provide leadership in this regard.  We must work together in order to find sustainable environmental solutions.  Your help and cooperation would be greatly appreciated.

U.S. pork producers are the most efficient in the world.  We are dedicated professionals producing the highest quality and environmentally sound meat protein one can find, whether in New York City or Tokyo.  Only environmentally sustainable production systems will allow us to continue to grow and meet the expanding demand for what is the most popular meat in the world.
 
 
 
 
 
 
 
 
 
 

NPPC is a national association representing 44 affiliated states that annually generate approximately $11 billion in farm gate sales of hogs.  According to a recent Iowa State University study conducted by economists Otto and Lawrence, the U.S. pork industry supports an estimated 600,000 domestic jobs and generates more than $64 billion annually in total economic activity.  U.S. pork producers feed over a billion bushels of corn annually, valued at $2.558 billion.  Feed supplements and additives represent another $2.5 billion purchased from U.S. suppliers that help support U.S. soybean prices, the U.S. soybean industry, local elevators and transportation services based in rural areas.