Nutrient Management Plans and Fit with Organic Systems Plan

The National Organic Program Regulation Sets Goals for Nutrient Management

Nutrient management plans are only part of the planning needed for organic certification. When producers manage their land properly, they can cultivate not only high quality crops, but a quality soil with favorable biological, chemical, and physical properties for better nutrient management. National Organic Program (NOP) final rule (USDA, 2000), Section 205.203, ‘Soil fertility and crop nutrient management practice standard’, establishes the objectives for tillage and crop rotation practices, and requirements for inputs used to amend nutrients in organic systems. In summary, NOP Rule Section 205.203 requires that organic producers:

• (a) select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of the soil and minimize soil erosion;
• (b) manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials; and
• (c & d) manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to the contamination of crops, soil or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.

The NOP regulation outlines principles for soil management in fairly general terms, but leaves the details for producers and certifiers to work out. The emphasis for soil management is placed on rotation and not on fertilizer additions. For more information on allowable amendments see Can I Use This Input on My Organic Farm. Producers are required to provide details on how they achieve organic goals in their Organic System Plans (OSP). The OSP is a detailed outline that explains how you intend to operate your farm or ranch to satisfy the requirements of the NOP regulation. The OSP must include:

• a description of farm practices and procedures to be performed and maintained, including the frequency with which they will be performed;
• a list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, and documentation of commercial availability, as applicable;
• a description of the monitoring practices, including the timing of procedures to be performed and maintained, to verify practices;
• a description of the record keeping system implemented to comply with record keeping requirements ( §205.103)
• a description of the management practices and physical barriers established to prevent commingling of organic and conventional products in split operations, steps taken to prevent contamination of products with prohibited substance, and any additional information about the production and handling practices deemed necessary by the certifying agent to evaluate compliance with the regulations and,
• evidence that it is written by the producer and agreed to by the certifier.

There are a variety of planning or budgeting tools that can help growers satisfy these requirements. For more information on these tools please see Whole Farm Nutrient Balance. The National Sustainable Agriculture Information Service (ATTRA) provides templates for Organic System Plans. Most of the tools now available for nutrient budgeting are developed for conventional farming systems, so organic practitioners need to understand how biological management practices common to organic agriculture fit into the proposed nutrient budget. For an overview of budgeting and how if fits with organic farming, see Nutrient Budget Basics for Organic Farming Systems, and for more on how fertility is managed organically, see Soil Fertility in Organic Farming Systems: Much More than Plant Nutrition. The practitioner should also consider the regionality of these tools. That said, you will find that there are many professionals involved in organic agriculture willing to direct you to reliable regional resources. Don't be afraid to send your state expert (Extension agent, University faculty, Department of Agriculture employee, area conservation staff, private consultant, or non-government organization employee) a quick email.

Nutrient Management Plans

A Nutrient Management Plan (NMP) is a documented record of how nutrients will be used for plant production that is prepared for reference and use by the producer or landowner. Plans help managers document the nutrients on their farms, and serve to regulate application of manure to satisfy plant needs and determine how to safely import manure into the farming operation or, manage it on farm. The goal is to apply enough but not too much manure. While they are not required by the NOP, nutrient management plans can be a useful addition to a farm’s Organic System Plan. They are most commonly used for livestock farmers where manure stockpiling can become a problem.

The most common issues related to agricultural nutrients include sediment erosion (or surface erosion), which can result in losses of nitrates and phosphorus, and groundwater leaching of nitrate. Organic growers must document how their systems are designed to prevent such losses. Nutrient management plans can help farmers do this. Nutrient planning arose to address the economic and ecological issues that have arisen as a result of eutrophication of water bodies and contamination of ground and surface water. The resulting water quality issues can compromise local fishery industries, recreational areas, and in some cases, directly affect human health.

Nutrient management plans were first developed to support the National Pollutant Discharge Elimination System (NPDES) created for point sources discharged into United States waters. EPA expanded regulations in 1976 to supply permits to livestock and poultry operations that maintained concentrated animal feeding operations (CAFO) and so were considered point sources for pollution. A comprehensive nutrient management plan has six components. Four are necessary and two depend on the individual operation.

1. Proper storage of manure and maintenance of the storage structure
2. Proper land application of the manure
3. Appropriate site management that looks at the risks on a particular field, such as sinkholes, streams running through the field, shallow groundwater, or erosion that needs to be controlled
4. Record keeping that documents land practices, so that if anyone has questions, there is proof of what is being done and why
5. Feed management to improve feed efficiency so that nutrient content of manure is reduced (optional, depending on operation)
6. Alternative uses for the manure. This is required for operations that generate more manure than can be applied on their own land (optional, depending on operation)

The Natural Resources Conservation Service developed its own Nutrient Management Standard (590) to help manage the amount, source, placement, form, and timing of the application of nutrients and soil amendments. Producers must complete a satisfactory plan to be eligible for voluntary programs. The purpose of the 590 standard is to meet the nutrient needs of the crop while minimizing the loss of nutrients to surface and ground water. Specific goals are:

1. To adequately supply nutrients for plant production
2. To properly utilize manure or organic by-products as a plant nutrient source
3. To minimize agricultural non-point source pollution of surface and ground water resources
4. To maintain or improve the physical, chemical and biological condition of soil

The requirements for a nutrient management plan vary tremendously from state to state. To find out more information about your state’s regulations, see State Specific Manure Nutrient Management Information. Common elements include:

1. Aerial site photograph(s) or site map(s)
2. Soil survey map of the site
3. Location of designated sensitive areas or resources and the associated, nutrient management restriction
4. Current and/or planned plant production sequence or crop rotation
5. Results of soil, water, manure and/or organic by-product sample analyses
6. Results of plant tissue analyses, when used for nutrient management
7. Realistic yield goals for the crops
8. Complete nutrient budget for nitrogen, phosphorus, and potassium for the crop rotation or sequence
9. Listing and quantification of all nutrient sources
10. CMU specific recommended nutrient application rates, timing, form, and method of application and incorporation
11. Guidance for implementation, operation, maintenance, and recordkeeping

Producers may add the nutrient management plan component to their current Organic System Plan. Certifiers, NRCS officials, and/or local third party technical service providers (such as Certified Crop Advisers) are all good resources for better understanding the requirements for a nutrient management plan. It is likely that your certifier can recommend third party technical service providers if they do not have one in-house.

References and Citations

• Natural Resources Conservation Service. 2008. Conservation practice standard for nutrient management (Ac). Code 590. (Available online at: ftp://ftp-fc.sc.egov.usda.gov/NHQ/practice-standards/standards/590.pdf) (verified 10 March 2010).
• Organic System Plan (OSP) Templates for Certifiers [Online]. ATTRA - National Sustainable Agriculture Information Service. Available at: http://attra.ncat.org/attra-pub/summaries/OSPtemplates.html (verified 10 March 2010).
• United States Department of Agriculture. 2000. National organic program: Final rule. Codified at 7 C.F.R., part 205. (Available online at: http://www.ecfr.gov/cgi-bin/text-idx?SID=a6a0935ddf00e166695f4c2138bd58d...) (verified 10 March 2010).
• United States Environmental Protection Agency. 2003. National pollutant discharge elimination system permit regulation and effluent limitation guidelines and standards for concentrated animal feeding operations (CAFOs): Final Rule. Codified at 40 CFR parts 9, 122, 123, and 412. (Available online at:http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2002-0025-0058) (verified 10 March 2010).

Additional Resources

• Natural Resources Conservation Service. 2006. Nutrient management plan checklist. NRCS–Indiana. (Available online at: http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs144p2_030692.doc) (verified 10 March 2010).
• SNAP-Plus nutrient management software [Online]. Available at: http://snapplus.wisc.edu/ (verified 10 March 2010).