| What question or concern is most pressing for you right now concerning the use of Environmental Management Systems to manage environmental issues related to livestock agriculture? | |
| Response | Affiliation |
|---|---|
| GOVERNMENT/AGENCY PERSPECTIVES | |
| 1. Terminology - EMS makes use of the "comprehensive nutrient management planning" terminology for one of its modules. While the module includes some components of the CNMP (i.e. nutrient management, feed management and off-site transfer), it does not include storage, land treatment or record keeping, which are contained in other modules. This could create some confusion for AFO owners/operators in undertaking their Tier I self-assessment or Tier II assessment where owners/operators may incorrectly believe that they only need to complete one module to determine their need for a CNMP. | USDA/NRCS |
| 2. How will a system be certified? What are the components? | USDA/CSREES |
| 3. How will producers handle the economics ($) to make changes in their operations to meet the new EPA regulations? There isn't a source of funds identified to assist these producers. | CSREES |
| 4. What standards/criteria will the EMS try to achieve? How can this EMS system link to the regulatory requirements? | Government Regulatory Agency |
| 5. System designed needs to be flexible for the ag community yet include clear and concise environmental objectives and measures to achieve water quality improvement and public health protection. | US EPA |
| 6. Develop a system that is rigorous enough to be meaningful, but flexible enough to be adaptable to individual situations and incorporate new information. | USDA |
| 7. [My concern is] That the EMS be science based and performance (outcomes) measured. | Government |
| AGRICULTURAL INDUSTRY PERSPECTIVES | |
| 8. How our producers are going to remain competitive with global producers and still adopt an EMS? | Poultry Industry |
| 9. [I'm concerned] That the assessment tools be practical and considered to be useful/advantageous to the grower and poultry companies. What will be the motivation to participate? | Poultry Trade Association |
| 10. How will the final product be channeled to producers and how will progress be monitored? | Poultry association |
| 11. Validation of plans when using an EMS? Who? | Producer with a Production Company |
| 12. I believe the project on EMS is beneficial in working with the animal concentration issue that has become a problem nationally. My concern is that USDA funding should be also guided to working with sustainable farm systems. | Farm organization |
| 13. I consider EMS to be a proactive approach to an end product that hopefully will better the farmer and the environment. However, with the current CAFO proposals EMS seems to be pointless. If implemented CAFOs will end animal production as we know it. | Producer |
| 14. Will EMSs be able to delay and correct the unreasonable items of the proposed CAFO (EPA) rules? | Producer |
| 15. Confidentiality. | State Farm Bureau |
| 16. Attracting producers to become involved. | State Farm Bureau |
| 17. Developing educational materials to help livestock producers, in cooperation with NRCS, SWCDs, consultants, etc., develop CNMP's. | State commodity organization |
| 18. How to get all producers to participate? Producers already doing a good job are the first to work at improving. How can we encourage/educate others to the point that they would also improve? | Producer |
| 19. How will EMS plans be "marketed" to state regulatory agency and how will this affect state regulations? | Producer |
| 20. What incentives do farmers have? | Livestock producer group |
| 21. Will self-assessment data be confidential? | Livestock producer group |
| 22. Who judges adequacy? | Livestock producer group |
| 23. Will the development and implementation of an EMS stay voluntary or will it become a requirement and if so at what level of government or third party? | Private consultant |
| 24. Implementation: I am concerned that most producers do not see social/environmental concerns as part of their bottom line. The must see value in this process to be committed to making the process more than just paperwork and another thing to spend money on. | Private consultant |
| 25. What incentives are there or will there be for producers to implement EMS systems? In states with comprehensive regulatory schemes producers will not likely embrace EMS without state recognition and validation of EMS programs. | Ag industry |
| 26. The result of EMS on the application of nutrients and other inputs to farmers' fields? | Ag Retailers |
| UNIVERSITY FACULTY PERSPECTIVES | |
| 27. How do we create the proper incentives necessary to get producers to proactively use EMSs? Can a producer self-regulation provide solutions (i.e. farmers inspecting other farms and reporting bad actors - this requires educated producers). | Land Grant University |
| 28. How to change environmental management from process to results based. | State University Extension |
| 29. Make sure it is usable by the producers and benefits their operation. | State University Extension |
| 30. Will this EMS be recognized by all entities, state and national, as a reliable measure of Environmental Management Success? | State University Extension |
| 31. Development of sound economics to assure sustainability of various/selected environmental management options/technologies/systems. | Land-grant university |
| 32. My concern is that we maintain Quality standards. | State University Extension |
| 33. Point of departure should be one of hope (not guilt). | State University Extension |
| 34. How can these be accessible tools while being sufficient enough to be credible/relevant to protect natural resources? | State University Extension |
| 35. How can an EMS be unique to a permit by a state or federal agency? | State University Extension |
| 36. How to make it available and used by a large number of farmers as an educational tool and as a priority setting tool? | Land-grant University |
| ENVIRONMENTAL ORGANIZATION PERSPECTIVES | |
| 37. Management and prevention of anti-microbials, pathogens, and anti-microbial-resistant traits from moving into the environment. | Environmental Organization |
| 38. EMS as a voluntary, single-operation based assessment. What are the cumulative impacts to watershed? What is the scale of waste? Will it nullify standards? Is the information available to the public or local community? What is the level of confidence? | Ag/environmental organization |
| 39. Creating appropriate incentives that guide us to desired environmental outcomes at the least cost to producers. | Ag & environmental organization |
| 40. In order to provide an adequate, timely level of technical assistance to operators, there need to be significant increases in staff and incentive programs. | National Association of Conservation Districts |
| 41. How effective will [livestock EMSs] be at reducing water quality pollution and GHG emissions? | Environmental policy organization |
| 42. How can we assess how successful the EMS is at meeting environmental goals? | Environmental policy organization |
| UNIDENTIFIED AFFILIATION | |
| 43. How do we get industry, processors of these raw materials, engaged in this process, i.e. consumer driven and paid for? What is the economic incentive for producers/farmers? | |
| 44. Need to address total manure management not just the land application component. EMS must address issue of excess manure. | |
| 45. How to provide the right mix of incentives to help livestock agriculture move forward? | |
| 46. [My concern is] That EMS guidelines and regulations be designed by individuals/groups with an understanding of agriculture. That the cost:benefit be economically practical and in balance with municipal regulations. We need to find "win-win" solutions. | |
| 47. Regulatory Compliance interaction (will the assessment also tell producers if they're in compliance with environmental regulations?). | |
| 48. How will producers be able to get information about environmental management systems? | |
| 49. Getting information following EMS implementation on changed environmental performance. | |
| 50. How to build in incentives at the front end to encourage EMS implementation taking into account views of farmers, state staff, and NGO's. | |
| 51. Feasibility/applicability of EMS as a viable voluntary approach. Assurances of environmental protection (missing elements). | |
| 52. Recognition of a new institutional system. Support for that system. | |
| 53. The impact of the proposed CAFO rule. How to change the perception of animal manure as waste to a valuable resource. | |
| 54. What are the policy mechanisms we can employ to ensure that all stakeholders maintain agreement on the definition of "sound science"? | |
| 55. Systems/requirements must be science-based; i.e. true realized benefits to environment. | |
| 56. Systems/requirements must be practical | |
| 57. Systems/requirements should be economically optimized. | |
| 58. To ensure that EMSs are not an excuse to delay compliance with regulations. EMSs should facilitate compliance. | |
| 59. How is this system going to be sustained for the long term financially? | |
| 60. Odor on dairy farms and livestock operations is a growing concern for the public. How do we create a safe harbor for livestock operations that are doing things right? | |
| 61. The impact of the proposed CAFO rule. | |
| 62. How to change the perception of animal manure as waste to a valuable resource? | |
