Response
to Notice of Data Availability (NODA)
dated July 23, 2002
The National Center for Manure and Animal Waste Management is pleased to submit comments for the Notice of Data Availability published in the July 23, 2002 Federal Register. Specific comments are included here as a PDF document. This NODA Response document covers the following items.
- Review of voluntary alternative performance standards: whole farm approach.
- "No-discharge" as the Best Available Technology economically achievable (BAT) and the New Source Performance Standards (NSPS) for the concentrated animal feeding operations.
- Alternative technologies for the management of manure, wastewater and other process waters generated by the concentrated animal feeding operations.
- Economic comments.
- EQIP dollars as a cost offset.
The National Center for Manure and Animal Waste Management is pleased that EPA has responded to comments submitted by publishing the July 23, 2002 Notice of Data Availability to obtain more information for the development of the most technically sound and economically feasible rules for concentrated feeding operations. In particular we feel the information in sections on Changes to Economic Analysis, Production Area Approach and Whole Farm Approach incorporate recommendations previously made by the National Center. We feel the questions at the end of the Production Area Approach and Whole Farm Approach sections are very important and deserve carefully developed answers. Response time allowed in the NODA has not allowed the necessary gathering and evaluation of information and experiences to adequately answer these questions. The National Center therefore offers to work directly with EPA and other appropriate personnel to develop methodologies for obtaining and evaluating the information needed, which may include:
- assembling of a committee of technical experts from the land-grant universities and
- pilot field testing to determine answers to these important questions and finalization of the most technical and economically feasible rules for concentrated animal feeding operations.