Large Non-Farm Horse Operations Should Review New USDA-EPA Strategy On Water Pollution

On March 9, 1999, the U.S. Department of Agriculture and the U.S. Environmental Protection Agency released their “Unified National Strategy for Animal Feeding Operations.” The agencies have been working on this strategy since President Clinton released the Clean Water Action Plan in February 1998. The strategy is an implementation and enforcement plan for existing Clean Water Act (CWA) regulations and does not introduce any new regulations on livestock or horse operations.

The main purpose of the strategy is to prevent water pollution from large animal feeding operations, such as cattle feed lots, hog confinement facilities, and large poultry operations. Nonetheless, the strategy could affect some large horse operations, such as racetracks, large show facilities, or similar collection points.

Under existing CWA rules, an Animal Feeding Operation includes any lot or facility where animals are stabled or confined for 45 days or more in any 12 month period and on which no crops, vegetation, or forage grow.

The new strategy will require large operations, perhaps 5% of the approximate 450,000 animal feeding operations nationwide, to obtain National Pollutant Discharge Elimination System permits. This will require the development of a Comprehensive Nutrient Management Plan to address waste storage and water discharge. Generally, such a plan identifies actions or priorities that will be followed to meet clearly defined nutrient management goals. These larger operations are considered “concentrated animal feeding operations” or CAFOs.

When considering horse operations, a CAFO is defined as a feeding operation where more than 500 horses are confined; or more than 150 horses are confined and 1) pollutants are discharged into navigable waters through a man-made ditch or flushing system; or 2) pollutants are discharged directly into waters that originate outside of and pass over, across, or through the facility or come into direct contact with the confined animals.

While these rules have been in effect for a number of years, the “new strategy” will likely bring increased attention to these large operations. Horse operations with horses above these threshold numbers should begin to evaluate their manure handling practices.

For the remaining 95% of feeding operations, voluntary efforts will continue to be the principal approach to assisting owners and operators in developing methods to reduce possible water pollution. Comprehensive plans cannot be required for an operation participating only in voluntary programs, however, they are strongly encouraged as the best possible means of managing potential water quality and public health impacts.

—American Horse Council

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