A. Section 319

Section 319 of the Federal Clean Water Act (Nonpoint Source Program) has made major contributions to pollution control for surface waters. Its strengths lie in its involvement of people at the local level, the development of watershed plans, and the provision of technical and financial assistance.

The task force held that much of this program’s success rests on four key points:

1. voluntary participation,
2. based on an understanding that changing practices affect farm economics,
3. uses established delivery systems familiar to agriculture, such as soil conservation districts, and
4. supports technical and financial assistance. It recognizes that producers will be more likely to implement practices, plans, or management systems, if such changes are accompanied by net tangible benefits.

Recommendations:

1. Incorporate a more rigorous statewide prioritization to maximize program benefits of the Pollution Prevention Program.
2. Encourage continued administration on a watershed basis.
3. Explore cost savings and increased administrative efficiency by coordinating with MDA programs.
4. Assure that Best Management Practices funded by Clean Water Act, Section 319 grants are be consistent with Right to Farm GAAMPs.
5. Continue Section 319 funding with programs implemented at the local level.

B. Natural Resources and Environmental Protection Act

The Michigan Natural Resources and Environmental Protection Code, P.A. 451 of 1994, as amended, protects the state’s environmental quality and provides recourse against individuals who contribute to serious pollution problems. Through the MOU between MDA and MDEQ, producers are given an opportunity to achieve compliance, and enforcement orders are directed toward those unwilling to comply with voluntary corrective measures. The code also addresses procedures for dealing with environmental emergencies. The Agricultural Pollution Prevention Task Force acknowledges the code’s value and views it as a necessary complement to voluntary programs and good stewardship.

Recommendations:

1. Assure regulatory approaches recognize the value of GAAMPs and provide producers with clear and consistent performance criteria.
2. Develop an educational component to inform producers about the procedures to follow in an environmental emergency.

C. Soil Conservation District Act

The Soil Conservation District Act (P.A. 451 of 1994, as amended, Part 93) has made major contributions to preventing both surface and groundwater pollution by enabling local producers to adopt voluntary programs focusing on such issues as erosion control and prevention, pesticide and fertilizer management, irrigation management, energy conservation, and others. Soil Conservation Districts currently provide leadership in more than half of Clean Water Act Section 319 watershed projects and in a majority of the Michigan groundwater and freshwater protection programs.

Conservation districts have worked together in partnership with the Natural Resources Conservation Service, Michigan Agricultural Experiment Station (MAES) Michigan State University-Extension, Michigan Department of Agriculture, and the Michigan Department of Environmental Quality. The reduction of NRCS resources is dramatically impacting the kind and amount of technical assistance available to local producers.

Recommendations:

1. Encourage conservation districts to more actively lead a newly invigorated coordinated pollution prevention effort.
2. Allocate resources on a coordinated, statewide, prioritized basis.
3. Seek consistent funding for conservation districts as an important delivery system for a statewide agricultural pollution prevention program.

D. The Michigan Groundwater and Freshwater Protection Act

The Michigan Groundwater and Freshwater Protection Act assists producers in developing groundwater protection plans and provides educational resources, technical assistance, and cost-sharing. This assistance includes groundwater stewardship practices and local stewardship teams which aid assessment and problem solving. An important provision of this act is, that by adhering to groundwater stewardship practices, the farmer gains liability protection from groundwater contamination. By following groundwater stewardship practices, the producer has access to technical assistance, funding, and reduced insurance premiums. Groundwater and freshwater protection programs are funded by producers through pesticide and fertilizer registration fees.

Recommendations:

1. Focus and coordinate the Groundwater program with Section 319 and other related programs.
2. Expand local stewardship teams beyond groundwater to all water quality and pollution prevention concerns.
3. Utilize groundwater stewardship teams for the local input required under the 1996 Farm Bill.
4. Strengthen local, producer-initiated stewardship teams, while retaining farm-based decision making.
5. Groundwater stewardship practices should be consistent with GAAMPs, and Section 319 program, Best Management Practices (BMPs).
6. Assure regulatory approaches recognize the value of GAAMPs and take into consideration ground and surface water stewardship programs.
7. Continue program funding via collecting pesticide and fertilizer registration fees.
8. Provide guidance to producers on how to effectively usze self-audits to improve performance, and qualify for penalty immunity, under Michigan’s audit law (i.e., Environmental Audit Privilege & Immunity Act, P.A. 451 of 1994, as amended, Part 148).

E. Existing Delivery Systems

Existing delivery systems provide Michigan farmers technical information and support through a number of organizations. These organizations include Michigan Agricultural Experiment Station (MAES) MSU Extension, USDA-Natural Resources Conservation Service, Soil Conservation Districts, Commodity Groups, the Michigan Department’s of Agriculture, Environmental Quality and, Natural Resources, and the private sector. Each has contributed to improving Michigan agriculture and is critical to continued efforts in addressing agricultural pollution prevention.

It is recommended that existing delivery systems be better coordinated or redirected to accomplish the pollution prevention goal. A clear delineation of roles and responsibilities should be established, elucidating the three-way partnership between the producer groups and agri-business, the technical/educational organizations (NRCS, MAES, MSU-E, and conservation districts) and the state regulatory agencies (MDEQ, MDA). The producer groups and the technical/educational organizations are the intended delivery agents.

Recommendations:

1. Coordinate efforts between and within public agencies and with the private sector for more effective programming.
2. Collaborate effectively to create a tailored and targeted information system that is adjusted to meet individual farm needs.
3. Add producer and agri-business groups to this effort for a more comprehensive educational effort on Right to Farm.
4. Provide consistency and eliminate overlap and conflicting requirements, laws, and messages.
5. Use each agency’s expertise as a resource for local stewardship teams (i.e., MSU-E Emergency Management Assistance Teams).
6. Include those who have not been reached using existing delivery systems such as MSU-E, NRCS, and Soil Conservation Districts.
7. Encourage the private sector to continue to play an active role in contributing to agricultural pollution prevention efforts.

F. Voluntary Whole-Farm Planning

Whole-farm planning uses science-based information to provide management options for on-farm decision making. It can provide producers with technical and financial assistance, as well as pollution prevention education programs. The Agricultural Pollution Prevention Task Force recognized it as a potentially important tool for future pollution prevention efforts because it links environmental indicators with economic and production data.

Whole-farm planning affords the opportunity for more detailed and tailor-made programs. The concept is recommended nationally by the pork industry. Also, the Farm*A*Syst program is designed to assist producers in evaluating areas of potential environmental risk and has increased voluntary use of pollution prevention practices. Efforts are currently underway to expand from a farmstead to a whole-farm basis.

A whole-farm plan inventories all natural resources and environmental indicators affecting farm operations. It links these indicators to economic and production information to facilitate farm level decision making while simultaneously addressing economic, resource, and/or environmental needs. Whole-farm planning may be included as a component of an environmental assurance program.

Thus, within the assurance program, a farmer can combine various GAAMPs, seek out innovative solutions, change rotations, adopt integrated pest or crop management programs, change irrigation practices, and/or change livestock practices as he or she sees fit. The plan can be refined with improved information, additional management skills, changing finances, or experience. Continual participation in a farmer led, approved whole-farm planning process may serve as a basis for a farmer being in "compliance" with the voluntary environmental assurance program.

Recommendations:

1. Farm*A*Syst should be expanded from farmstead to a whole-farm basis, and along with other whole-farm planning methods, should be made available to a greater number of producers. Moreover, it should receive consistent funding as part of a statewide pollution prevention program.
2. As Michigan implements a targeted pollution prevention program, whole-farm planning efforts should be encouraged.