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by David White

Protecting water quality would be a lot easier if farmers never needed to apply manure when fields are frozen or covered with snow. Unfortunately, some farmers don’t have enough storage capacity to get through the winter. Even farmers with more than adequate storage facilities sometimes need to apply manure in the winter because wet fall weather or other problems delayed application.

With temperature fluctuations and sudden changes in weather patterns that are typical of late winter and early spring, manure application becomes even more risky. Uncooperative weather may lead to pollution, even for farmers who follow winter manure application standards.

For example, a couple of years ago a quick thaw led to a rash of pollution complaints and events in early March. Manure applied earlier in the winter had remained frozen in fields for weeks or even months, but after the thaw surface flow carried it into streams, which is a violation of the state’s agricultural pollution abatement laws. Depending on the size of operation, such an event could require coverage of the farm under the federal NPDES program’s rules for concentrated animal feeding operations (CAFOs), which is currently enforced by the Ohio EPA. These types of situations could be avoided by following standards established by the United States Department of Agriculture’s (USDA) Natural Resources Conservation (NRCS).

USDA-NRCS recently revised its waste utilization standard (#633) that provides recommended practices for manure application. The revised standard, which is followed by local soil and water conservation districts (SWCDs) in working with livestock farmers to develop and implement manure management plans, does not recommend that manure be applied to frozen or snow covered soil unless it becomes necessary due to storage limitations. If this condition is present, only limited quantities of manure should be applied and all of the practices recommended by the standard are to be completely followed:

1. Must have 90 percent ground cover.

2. Increase setback distance to minimum of 200 feet.

3. Limit rate of application to 5000 gallons per acre or 10 wet tons per acre.

4. Limit application area to 20 contiguous acres, separated by 200 feet.

5. Fields with slopes exceeding 6 percent – apply in alternate 60 to 200 foot strips.

Livestock farmers and custom manure applicators need to note that the standard allows for winter manure application; however, it is not recommended, particularly for operations that produce significant volumes of manure. Such operations should not plan for routine winter application, as they should only apply enough to address storage limitations until nonfrozen soils are available.

Speaking of larger operations, USDA-NRCS technical standards and guidelines also serve as the foundation for the Ohio Department of Agriculture’s (ODA) Livestock Environmental Permitting Program’s rules for issuing permits to, and regulating, large livestock farms. Additionally, ODA must be notified prior to commencing the manure application.

Increased concern over pollution events resulting from surface application of manure to frozen or snow covered grounds has caused other states to prohibit this practice, and the U.S. EPA is encouraging state delegated NPDES agencies to highly consider doing so. Although some other states have prohibited manure application to frozen or snow-covered ground, it’s still permitted under very careful management in Ohio. However, Buckeye State livestock producers and custom manure applicators are at risk of losing this sometimes-necessary option if pollution problems resulting from wintertime application of manure continue. To protect this option, farmers and applicators need to guard water quality by minimizing winter application and by following the revised USDA-NRCS standard when winter application is unavoidable.

David White is executive director of the Ohio Livestock Coalition.