Special Edition: CAFO Regulations
Current Nutrient Management Plan Good for New Permit?
Nutrient management plans on all permitted operations in Missouri must conform to the requirements of the Missouri Nutrient Management Technical Standard published in March 2009 (available at the MDNR website at http://www.dnr.mo.gov/env/wpp/permits/nutrient-management-tech-standard.pdf ).
Permitted operations must have a current nutrient management plan when they renew their permit. Your plan is current if it meets the following conditions:
1) is compliant with the Nutrient Management Technical Standard,
2) you have followed your plan,
3) your record keeping is up to date
4) the plan expiration date is after February 2013.
Many permitted operations have a nutrient management plan that meets these criteria. If you are getting the State No-Discharge General permit we recommend updating your plan based on its expiration date; you must get a new plan at least once every five years. Continue to follow the current plan and keep the appropriate records as you transition to your new permit. Please be aware that you must get a new plan before the current plan expires. Developing a new plan may take several months so plan ahead! When you get your new nutrient management plan, note that the plan has been updated in the annual report you submit to MDNR that year.
Farmers with a State No-Discharge General Permit do not need to send a copy of the new plan to MDNR but you must keep it on site and available for inspections.
Farmers who obtain the NPDES General Permit can use their current plan when they renew the permit. But you should recognize that getting a new plan part way through the permit cycle could be an involved process with the NPDES permit. With the NPDES permit, you will be required to submit any new plan to MDNR along with an updated Nutrient Management Plan Information Form. If there are any changes to the information on the Nutrient Management Plan Information Form the new plan will be considered a modification of your permit. Significant changes to this form include adding new fields, any change in spreadable acres for a field, any change in nutrient basis for a field (N or P based application), any change in the potential crops that could be planted on a field or any change in expected yields.
Permit modifications of the NPDES permit require paying the associated permit fees and undergoing an MDNR public notice process. The public notice process will likely be a 15-day posting of the revised Nutrient Management Plan Information Form on the MDNR web site (it does not include neighbor notification). Any document submitted to MDNR is public information so the general public will be able to obtain a copy of any nutrient management plan you submit to MDNR with your NPDES permit. Allow sufficient time for MDNR to approve your new plan before your current plan expires.
So farmers getting the NPDES permit have to make a choice in how they handle their nutrient management plan. They can continue to follow their current plan and get a new plan based on the expiration date of their current plan part way through the permit cycle. Farmers who use this approach will need to pay permit fees and undergo an MDNR public notice process if the new plan includes significant changes to the Nutrient Management Plan Information Form. Alternatively, farms using the NPDES general permit may choose to get a new nutrient management plan this fall or winter. This plan will coincide with the permit cycle, minimizing the need to re-open your permit due to a new nutrient management plan.
A nutrient management plan is not needed for dry manure operations that export all manure and compost off their farms. If you are an "Export Only" operation, be sure to check "yes" in section 4.2 on the permit renewal form and complete sections 5-11 of the form as this meets the requirements of a nutrient management plan for an "export only" operation.
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