The following comments were submitted by IATP Dec. 23, 2024 to the U.S. Department of Agriculture Natural Resources Conservation Service. View a PDF of the full comments here.
Below are our comments on a number of practices NRCS has requested input on, namely CPS 313, 316, 367, 592, and 632. Where possible, we recommend strategies to reduce emissions from agricultural practices, cite relevant literature, and the targeting of funds toward cost-effective conservation. In assessing the emissions impacts of different practices, we recommend analyzing effects such as increase in herd size, leakage in biogas infrastructure, and increases in greenhouse gas emissions from gases such as nitrous oxide.
313 Waste Storage Facility
This comment on Practice 313 is identical to one submitted by the National Sustainable Agriculture Coalition (NSAC). This language is used with permission.
The 2024 CSAF Mitigation Activities List specifies that the climate smart status of CPS 313 applies only to the “compost bedded pack” facility where “manure is composted within the animal housing.” However, the current (2023) Standard provides no criteria for compost bedded pack and refers to “composting” only once, in a paragraph under Considerations that lists other practices that may help reduce GHG emissions, including CPS 317 Composting Facility.
CPS 313 Waste Storage Facility provides engineering and environmental protection criteria for liquid storage facilities such as lagoons and stacking facilities for solid wastes. Studies in Canada have shown that total GHG emissions (CH4 + N2O) from beef and dairy manure were greatest for liquid storage, 20-70% less for dry-stacking and 45-80% less for composting (Pattey et al., 2005). However, waste separation into liquid and solid components (CPS 632, discussed below) can reduce CH4 emissions from the liquid fraction by 55% (Edalti, 2023) and facilitate dry stacking or composting of the solids. Combining solid manure with biochar has been found to further reduce GHG emissions.
Provide Criteria for compost bedded pack systems for livestock waste storage
We recommend that NRCS contact the directors of the Alternative Manure Management Program (AMMP) at the California Department of Agriculture to inquire about the best practices for compost bedded pack systems and develop these into a set of Additional Criteria for Composted Bedded Pack waste facilities under CPS 313 Waste Storage Facility.
Expand Additional Considerations for mitigation of greenhouse gas emissions
Rename the heading for air quality as follows:
“Considerations for improving air quality and reducing greenhouse gas emissions”
Expand the second paragraph in this section as follows:
“Reduce emissions of greenhouse gases, ammonia, volatile organic compounds, particulate matter and odor, by adding other NRCS CPSs Anaerobic Digester (Code 366), Roofs and Covers (Code 367), Waste Treatment (Code 629), Waste Separation Facility (code 632), Amendments for Treatment of Agricultural Waste (Code 591), Composting Facility (Code 317), and Air Filtration and Scrubbing (Code 371) to the waste management system. Liquid-solid separation of livestock waste streams (CPS 632) can substantially reduce methane emissions from liquid waste storage facilities. Co-composting of solid waste with organic carbon materials (e.g., wood chips, straw) further reduces greenhouse gas emissions and odors, stabilizes nutrients against leaching, and yields a valuable soil amendment. Implement Composting Facility (CPS 317) *and the Additional Criteria for Composters and Composting for Animal Mortality Facility (CPS 316) to maintain aerobic conditions and minimize GHG emissions.*”
* * If and when a new Conservation Practice Standard for Composting is issued (with criteria for the composting process and for compost utilization), replace this phrase with citation of the new Standard. Until then, we recommend using the Additional Criteria for Composters and Composting for routine animal mortality management (CPS 316).
Under Considerations for Siting, add the following paragraph regarding climate change:
“Climate change has led to increased frequency and severity of floods in many parts of the US, so that future 100-year floods will likely rise significantly higher than the historical 100-year floodplain. In selecting a site for a waste storage facility, consider locating the facility above the elevation that has become the de facto 100-year floodplain in the 21st century.”
To continue reading, download a PDF of the full comments here.
