Mr. Staples was asked to respond to the following questions in his presentation (View his slide presentation):
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I really appreciate the opportunity to be here. Is there anyone here from Kansas? No? It's safe then to tell this story. It so happens that around the turn of the century there were two individuals that bought the first automobiles in Kansas. One was in Wichita and one was in Kansas City, and unfortunately, as they were traveling across the countryside, the only two cars in Kansas collided.
I use that story because I believe that this is one of the major problems that we have today with technology, with what the farmers are doing, what the regulatory agencies are doing, with the way that the general public is looking at things that we're doing. There are lots of potential collisions. Now obviously we don't want collisions. Those two individuals who had their brand new cars didn't want the collision, nor do we. I think in some areas collisions are imminent if we don't take some action. One area certainly is environmental regulation. Another is the way we're using our land, both for farmland communities as well as for commercial and public and urban areas. It is just plain hard to produce the products that we produce, to get them to the marketplace, with these loaded issues that continually come up.
Another is a change in generations. I'd like to address that by giving you a test. Does it require a rooster to produce an egg? Those who say yes, please raise your hands. [PAUSE FOR SHOW OF HANDS.] Those who say no, please raise your hands. Those who don't know, please raise your hands. Okay, therein lies the problem. It does not require a rooster for a hen to lay an egg. Few of you were sure that it doesn't. I was recently in a meeting with a group of regulators and legislators, and I asked that same question. Out of eleven there was none that knew the answer, and yet, they're the ones that help establish what we are trying to accomplish with rules and regulations. Now I'll give you one more. How many eggs can a hen lay in a day? Those that believe it's one egg, please raise your hand. Those that believe it's two eggs, please raise your hand. Those that don't know, raise your hand. It takes 26 hours for a chicken to lay an egg. So if you calculate that appropriately, she can't lay an egg a day. She'll lay an egg a day until the hours catch up to her, and then she'll miss a day. There again lies the problem. There's so much not understood by those who are writing the rules, and even by some who have to work with the rules. We need to all come back together and say, what are we doing, and how are we going to accomplish our goals and objectives? This is one of the issues the United Egg Producers took upon themselves.
We looked at the regulations, the permitting processes required for large farms and medium size, and even small farms, and asked, "How do we get a step ahead?" Some producers would say, "I don't have to be regulated, I've never been regulated, I don't want to do it." And others would say, "Look, I'm doing everything right, so I'm okay." But under the current way the rules and regulations are going today, the way that the technology is developing, it is requiring us all to take a look. How can we do a better job of what we're doing? So we got together with the US EPA and looked at how we, as producers, can be a step ahead and really be responsible for the environment. This led to the XL program [EPA's Excellent Leadership program] http://www.epa.gov/projectxl/uep/index.htm.
Key to the XL program is to get egg producers implementing EMS programs, using some guidelines that we United Egg Producers developed together with the EPA. The EMS guidelines allow us to do certain things responsibly. In order to be certain that our program is right, specific to a farm, we need the third party audit, and that's where we're using Allan [Stokes and America's Clean Water Foundation]. He'll come in and do his third party audit and determine if we really are going to be responsible with our EMS. In order to get this program into all of the states, it requires all the states to participate and become a party to what we're trying to do with the XL program.
Currently without the XL program, all large acreages would just fall under the new CAFO regulations [Concentrated Animal Feeding Operations]. Until now my own operation has operated under a Wisconsin WPDS permit, and that's an individual permit for me based on my operation's size. The XL program provides us with an expansion of that process. The critical elements to getting this permit are implementing an EMS (planning, BMPs, records, public notice) and a 3rd party audit of EMS implementation. What we want to get is a general permit, rather than having the individual permit. Because a general permit will give us a better understanding of how to operate. It also brings the involvement of multiple groups in helping us develop our EMS, so that we are responsible for our community, responsible for our farm and the nutrient management. It helps us to avoid some conflicts or collisions that could occur. So through the XL program, as we outline it, we have a planning session, we have the BMPs, we have records, we have public notice, we have the third party audit. As a result of all of those, the EMS can certainly reduce risk. It achieves risk reduction, and public acceptance by making the public a part of it.
Why would we want to develop this EMS? Obviously, it's to be responsible and to help ourselves to avoid some of those collisions that can occur. What are the benefits? Obviously, a cleaner environment. We use it as a plan, an operating plan, to operate under for the future, for protection and community support. We bring the community into our operation.
What are our EMS materials and how do we put them to use? Certainly one of the key things is the third party audit. Under this program, the first audit that is really performed on a farm is when Allan's group comes in. They'll do an audit on the farm and determine if you can meet the criteria that need to be met in order to have an EMS written for you. If you fail the test, then you have every opportunity to correct those areas so that ultimately the operation can pass the test, which obviously is what you want to do. Once you pass the test you would write your EMS, the state would endorse and support having the XL program, and all of that information that ought to become public becomes public. The public will be a part of it and they will be able to look at the EMS under which you operate.
What are the lessons to be learned by using this kind of approach? Certainly, one of the keys, and we found this to be true in our own case, is having the public involved. We have critical people and individuals involved with our operation. It helps in the relationship we have with the regular current people. So that we have them helping to support us as well. So that they are helping us to write the EMS and helping us to meet the criteria so that we are operating under a responsible way. This approach is credible by having these other agencies involved with us. We sat at the table with the EPA in looking at EMS and how it would be effective for the egg producers. These are the areas that we agreed upon, when we sat with the EPA, to help us have a responsible EMS that would not cause us to have a collision later on, further down the road. We agreed to pledge to follow a code of good practice, develop environmental objectives and plans, establish management systems for anticipating problems and avoiding mistakes, delegate authority but retain the responsibility, implement the BMPs of the EMS, maintain a public communication effort, review progress regularly and adjust as needed, and keep proper records and documents, all assembled so they can be reviewed by anyone who would want to take a look at them, because they would all be public documents.
One thing I think we learned from this experience with the UEP and the EPA developing the XL program, is that it gave us an opportunity to be a part of writing an EMS, so that it would not be written by the EPA. I can assure you, the Chicago EPA offices and producers had lots of discussion of what needed to be done, how this would be accomplished. I think it was just as important that during that process, the EPA staff came to my operation to take a look at how we were operating and what we were doing so that they could see first-hand how a farm operates. I don't know if Jim knew the answers to those questions of how many eggs does a chicken lay, and does it require a rooster to lay an egg. But I do know that when the EPA member, Jim Horne, came to our farm, he saw how we handle our manure, how we produce eggs, how we market our fertilizer. As a result of that it was much easier to have a good discussion with the EPA because they understood what needs to be done.
So today as we the egg producers go forward, our objective of course is to get every egg producer to have an EMS, and every egg producer to be responsible for the way he handles his products as it moves out to the field so it's under a proper nutrient management program. In turn this will give us every opportunity to continue operating and to stay in business and develop the support of regulatory agencies as well as the public. I think that's all I have to present.
Question: Does your system track where the manure goes after it leaves the farm?
Dave Staples: We don't have the responsibility to track it. However, we do have the responsibility to give them a manure analysis, a sheet that tells them how to responsibly put it on the land and over what area. We typically ask them what crops they're going to dress, so we can give them a nutrient reading for those crops. That is our responsibility. It isn't fresh manure. It's processed, in pellet form.
Question: How well are the EMSs being received by egg producers at large?
Dave Staples: I don't know, but many have asked for an assessment. But the way society is going, it's almost that they're being forced. It's unfortunate, because most farms are being managed well. But generally speaking, I would hope that we'd have the majority of all of our producers participating in this program. I don't know what the numbers are.
Question: [What are the benefits and costs] of individual vs. general permits?
Dave Staples: I don't know what the relative cost is of the individual permit versus the general permit. But I do know that I'd much rather have the general permit based on the criteria put forth for it. The individual permit may not be quite as detailed. The general permit gives us more bankers' assurance that we're going to be in business tomorrow. It means more community involvement. Every part of agriculture ought to be a part of the XL program.
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