NRCS Updates Nutrient Management Standard
December 19th, 2011
Last week, USDA’s Natural Resources Conservation Service (NRCS) released an updated version of its nutrient management standard, also known as conservation practice standard 590 (CPS 590). NRCS practice standards delineate the steps that a producer may or must take in order to receive payments for a particular conservation practice under NRCS conservation programs.
According to the NRCS press release, “Proper management of nitrogen and phosphorus, including the use of organic sources of nitrogen such as animal manure, legumes and cover crops, can save producers money. The nutrient management standard provides a roadmap for NRCS’s staff and others to help producers apply available nutrient sources in the right amount, from the right source, in the right place, at the right time for maximum agricultural and environmental benefits.”
NRCS state offices have until January 1, 2013 to implement the new standard; however, NRCS national headquarters will begin to apply the changes immediately. The new standard will be applied to this fiscal year’s Environmental Quality Incentives Program (EQIP) and Conservation Stewardship Program (CSP) signups, including the current CSP signup period that ends on January 13, 2011.
NRCS put a significant amount of work into reducing a number of rather arbitrary criteria in earlier versions of the standard. Many of the major changes made in the updated version add nutrient risk assessment procedures to the standard. The nutrient management requirements for participants differ depending on the results of the risk assessment for nutrient pollution from their operations.
The standard has a number of important improvements over the previous version, which was issued in August 2006, as well as the version issued for public comment in January 2011. We were pleased to see organic farming systems recognized in the standard, a first for conservation practice standards. While still oriented to conventional application, the newly revised standard also does a better job of addressing alternative sources of nutrients and the incorporation of biological soil activity, green manures, legumes, cover crops, compost, and other similar options. We are also pleased to see additional factors required to establish realistic yield goals in the revised standard.
The new standard generally prohibits the application of nutrients, including manure, on frozen and saturated ground but also creates exceptions, with undefined criteria and conditions that can vary from state to state. This new “exception to the rule” provision is cause for concern. Without firmer requirements, states where large-scale CAFOs are abundant will be the most likely to weaken the standard. This is of particular concern in states which use CPS 590 as the nutrient management plan standard for CAFO Clean Water Act permits. In addition, the standard continues to ignore assessment and control of of heavy metals which may be found in manure and other organic waste from CAFOs.
The updated standard will tailor nutrient management requirements based on NRCS-approved nitrogen and phosphorous risk assessments, so the full impact of the changes to CPS 590 will depend in part on the nutrient risk assessment policy and procedures outlined in NRCS’ General Manual and National Instruction. We will review those documents and issue an additional report at a later date.