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Comprehensive Nutrient Management Plan Program

Origins of the Program

The TSSWCB Comprehensive Nutrient Management Planning Program was developed in response to a control measure recommended by the Implementation Plan for Soluble Reactive Phosphorus in the North Bosque River Watershed (PDF, 2.16 MB). The implementation plan recommended that dairy producers in the watershed voluntarily develop and implement a Comprehensive Nutrient Management Plan (CNMP). This program is currently confined to the North Bosque River watershed by rule.

What is a Comprehensive Nutrient Management Plan?

A comprehensive nutrient management plan (CNMP) is a resource management plan containing a grouping of conservation practices and management activities which, when combined into a conservation system, will help ensure that both agricultural production goals and natural resource concerns dealing with nutrient and organic by-products and their adverse impacts on water quality are achieved. A CNMP incorporates practices to utilize animal manure and organic by-products as a beneficial resource. To be certified, a CNMP must cover all lands that constitute the conservation management unit.

Does my CNMP need to be certified by the TSSWCB?

Texas Administrative Code, Title 30, §321.42(s) states "All dairy CAFOs in a major sole-source impairment zone shall develop and operate under a comprehensive nutrient management plan (CNMP) certified by the Texas State Soil and Water Conservation Board. This CNMP shall be implemented not later than December 31, 2006." The only applicable "major sole-source impairment zone" in Texas is the Upper North and North Bosque River watershed. No other animal feeding operations in the state are required to have a CNMP by law.

What's the difference between a CNMP and WQMP?

A Water Quality Management Plan (WQMP) is a site specific plan for agricultural or silvicultural lands which includes appropriate land treatment practices, production practices, management measures, technologies or combinations thereof which when implemented will achieve a level of pollution prevention or abatement determined by the TSSWCB in consultation with the local SWCD and Texas Commission on Environmental Quality (TCEQ) to be consistent with state water quality standards. To be certified, a WQMP must cover all lands whether contiguous or non-contiguous that constitute an operating unit for agricultural or silvicultural purposes. A WQMP can be developed for an AFO, however, only a specialized subset of that WQMP would be considered a CNMP. The WQMP would be required to cover and address all the property and resource concerns on the agricultural or silvicultural property that a producer owns or operates, whereas the CNMP would only address the AFO's production activities and land application areas. The CNMP is not a WQMP, but a WQMP may contain a CNMP in cases where a WQMP is developed for an AFO. A "stand-alone" CNMP developed in accordance with this criteria and guidance, and CNMP integrated as a "component" of a WQMP, are identical in general criteria but different because of the extent to which the criteria is required to be implemented. WQMPs are broader in scope than a CNMP. However, the criteria the two have in common is implemented to a greater extent in a CNMP.

What's the difference between a TSSWCB CNMP and NRCS CNMP?

The CNMP is aUSDA Natural Resources Conservation Service (NRCS) concept. The TSSWCB adopted the entire NRCS Field Office Technical Guide as the criteria applicable for WQMPs, consequently the NRCS technical criteria for CNMPs is also adopted by the TSSWCB. However, the TSSWCB requires a certification by a professional engineer that all wastewater retention ponds meet or exceed the retention capacities required by a producer's permit, the soil sampling be done for the express purpose of developing the CNMP, and the specific format of the CNMP must meet a programmatic requirement. The TSSWCB CNMP Program uses the NRCS CNMP as a baseline. Many other requirements may be applicable as a result of the permitted nature of an operation. For example, any permitted operation in the North Bosque River watershed must have soil sampling performed by a Texas Certified Nutrient Management Specialist (CNMS).

What does EPA say about CNMPs?

In response to public concern about contamination of rivers, lakes, streams, coastal waters, and ground water from livestock manure and other animal wastes from livestock operations, the U.S. Environmental Protection Agency and USDA developed the Unified National Strategy for Animal Feeding Operations in March 1999. The strategy includes a national goal that all "AFOs should develop and implement technically sound, economically feasible, and site-specific CNMPs to minimize impact on water quality and public health."

How should a CNMP be prepared? And who can develop a CNMP?

Producers who wish to obtain a CNMP certified by the TSSWCB should contact their local SWCD. Currently, the TSSWCB CNMP Program is only available in the areas of the Cross Timbers SWCD and Upper Leon SWCD that are within the North Bosque River watershed. The TSSWCB has adopted the NRCS Technical Service Provider Program as the qualifications system for individuals who wish to develop CNMPs intended to be submitted for TSSWCB certification. If you are interested in becoming certified to perform the various required components of a CNMP, please visit the NRCS TechReg website.

Is my CNMP a Pollution Prevention Plan (PPP)?

Each permitted CAFO is required to develop and maintain a PPP by the TCEQ CAFO Regulations. A PPP is required to be prepared in accordance with good engineering and agronomic practices and must include measures necessary to limit the discharge of pollutants into or adjacent to waters in the State. A PPP must describe the operator's implementation of practices that will assure compliance with limitations and conditions of the TCEQ CAFO Regulations. In general, a PPP is a document that covers the general requirements of the rules, any structural and non-structural controls, any retention/treatment facilities, land application activities, nutrient management/utilization activities, required best management practices, education and training requirements, inspection and record keeping requirements, and monitoring and reporting requirements.

The TCEQ CAFO Regulations state that if a NRCS plan has been prepared for the facility, the PPP may refer to the NRCS plan when the NRCS plan documentation contains equivalent requirements for the facility. When the operator uses a NRCS plan as partial completion of the pollution plan, the NRCS plan must be kept on site. Because a TSSWCB certified CNMP is based on criteria contained within the NRCS FOTG it is an "NRCS" plan. However, the act of possessing a TSSWCB certified CNMP does not excuse the producer from maintaining the document in such a way that it continues to meet the requirements of a PPP. The producer ultimately bears that responsibility.

Will my CNMP result in the need for a permit amendment?

The development of a CNMP may result in the determination that some aspects of the current operation are no longer feasible within certain constraints of an existing permit or registration. For example, developing a nutrient management strategy within the requirements for Nutrient Utilization Plans may result in the need for additional land application acreage. The addition of such acreage would require an amendment to the permit or registration. Contact the TCEQ Agriculture Team for questions regarding other situations that may or may not require amendments to permits or registrations.

Can I obtain financial assistance to develop and implement my CNMP?

Producers who receive TSSWCB certification of their CNMP may be eligible for cost-share through their local SWCD. Financial assistance may also be available from some Texas universities and institutes. The NRCS Environmental Quality Incentives Program (EQIP) also provides cost-share for the development and implementation of conservation measures. Contact your local NRCS Field Office for information.

Process for Obtaining a TSSWCB Certified CNMP

In order to obtain a TSSWCB Certified CNMP, producers must first declare to their local SWCD their intention to submit a CNMP for the district's approval. This is accomplished by completing TSSWCB Form CNMP 001 (found at Page 5 of Section 5 within the TSSWCB Technical Criteria and Programmatic Guidance for CNMPs (PDF, 225 kB) and submitting it to the local SWCD. The district will assign the CNMP a number and await the submission of the CNMP. After submission the CNMP will be reviewed by the SWCD and, if approved, forwarded to the TSSWCB for review and certification. Any TSSWCB cost-share, if available, should be applied for by completing TSSWCB Form CNMP 002 (Section 5, Page 6) after the CNMP is certified. If TSSWCB cost-share is available, the SWCD will have a list of practices that are eligible for cost-share funding.

CNMP Technical Resources