Animal Feeding Operation Rule
The proposed rules are “Command and Control” style with little hope of achieving the stated goal
- Conflicting objectives – to apply at low rates, surface application necessary but surface application increases probability of runoff.
- Negative incentives – a market for manure needs to develop but classifying it as a pollutant stymies the development of markets.
- Not transparent - Covering lagoons is an attempt to eliminate lagoons without actually banning lagoons.