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The View from Here: Comprehensive nutrient management plans, part two

Mike Gangwer Published on 10 April 2013

In this column, once again I visit the development of the comprehensive nutrient management plan (CNMP). The point of reference is a recent visit to a dairy farm in northern Michigan.

The reference CNMP notebook is 600 pages long. Yet from my perspective, it is of no use to the landowner and of little value to the NRCS field office case file. Here are three reasons why.



1. The writer does not have a single paragraph describing the farm family. Readers of this column know I have covered this topic already. The farm family is the human environment, the people on the farm that operate, maintain, manage and invest their lives on the physical assets of the farm: land, animals, barns, equipment and so on. Why is this important?

On many farms we have two or maybe three generations working on the farm, and with each, a certain financial investment and approach for the future. On this reference farm, the older generation was in their late 60s, the second generation in the early 40s and the third generation still in school.

The CNMP writer did not adequately describe the roles, especially of generation one and two. Our interviews with each of these men certainly told the story that one had a relatively short timeline and the other, the young man, had a much longer timeline.

The CNMP should capture this timeline … the investment of expensive installations to mitigate a resource concern like surface water quality or groundwater requires a long-term vision. Except on this farm, the young man was off doing chores and not at the kitchen table discussing the future with us.

Nor had the CNMP writer attempted to capture the farm family dynamics in the CNMP. We made a point to go find the young man and get his perspective. The 60-something-year-old gave us permission to do so.


The young man had different ideas and basically told us he was in a holding mode until his father retired. Nevertheless, he did have a lot to say about the CNMP in the few minutes we had with him.

The take-home is this: The dynamics of the farm family is the most important part of the human environment of any farm. We (NRCS) and our contractors (technical assistance providers) cannot begin to write a CNMP, which is based on the future, until the people involved have been included.

We identify this step by identifying the goals and objectives. We cannot jump into the inventory and evaluation of the production area site until we sit down at the kitchen table and talk. And, on many farms, that talk will include asking the older generation to include the next-in-line to sit there and contribute.

Why? Because the transfer of responsibilities and decision-making usually takes time … sometimes a lot of time (years), so this step helps smooth that transfer.

2. An important role, maybe the critical role of the CNMP writer, is identifying the resource concerns on the entire farm. Why? Because water, soil, nutrients and contaminants move off the farm and thus enter the public space.

We know that many landowners apply for Environmental Quality Incentive Program (EQIP) funding to help pay for many of the conservation practice standards on their farm because federal (taxpayer) dollars are spent for the public good.


Soil does not blow away, water is kept clean, manure nutrients are kept in the root zone, and contaminants such as fecal coliform are degraded and killed on the farm, not apart from it.

On the reference farm, the CNMP writer did not identify the two primary resource concerns. Instead the writer made the case for a change in management, a cultural change, which was not based on a resource concern.

We (USDA-NRCS) will not help this farm family pay for a structure on the production area site that shifts only the management of how manure is handled unless this change mitigates a resource concern. Unfortunately, the CNMP writer made the mistake of writing a document stating that we would help pay.

On our site visit, we addressed this mistake in the first 10 minutes. We (NRCS) are attempting to fix this common mistake by requiring a post-contracting meeting with the landowner.

After the CNMP contract has been awarded and the landowner has identified and selected the writer/planner, the NRCS district conservationist from the local field office will join them. Their goal is defining the roles and responsibilities of the landowner, the writer/planner and NRCS.

If such a meeting were held on the reference farm before the CNMP was developed, I am certain the district conservationist would have made it clear to the other two that indeed, NRCS funds (EQIP) are spent only to mitigate a resource concern that is in the public’s best interest to mitigate.

Let me be clear: The landowner can install anything he or she wants if a change in manure-handling management is desired. But the farm family pays for it or them, with the caveat that the change does not degrade a resource. In other words, changes on the farm must maintain the resources to their current level or improve them.

The take-home is this: CNMP writers must build a working relationship with a local NRCS field office and the personnel working there.

If the CNMP has NRCS conservation practice standards in the schedule of implementation (nearly all do), then participation in EQIP is via the NRCS field office personnel … the district conservationist. Include them on the post-contracting meeting, and the CNMP I had in front of me in Michigan would have been quite different.

3. I am known for making the case that a well-developed CNMP that is useful to the landowner and useful for the NRCS case file can be written with a pencil, on a pad of paper, with a calculator.

Or written another way, if the CNMPs we are writing are based on fitting what we need to do into a prescriptive set of software, then we will probably fail in our attempts at writing anything useful.

Why? My premise is we are not doing a good job at identifying and evaluating the resource concerns on the farm, and therefore we use data in our software based on the answer we want. This is not good for anyone.

In the reference CNMP, at least one-half of the notebook, well over 300 pages, is software printout from several software programs. Nearly all of it is of no value. Data in just software output form is simply information restated mathematically.

The software integrates a number of algorithms into more data. We have too much data, in fact, which increases the end result of our mathematics by distorting the simple in favor of the complex.

I am a scientist, and all scientists love data. But a greater data pool increases the likelihood of distortions that can be used to get the answer we want. For instance, I do not remember a single CNMP that showed our water erosion model, RUSLE2, with a greater result than acceptable T soil loss.

For our reference CNMP, the model we use to determine if winter spreading can be done shows that over 70 percent of the large cropland base is ranked in the low-risk category. Yet on the day of the site visit, the landowner made a deliberate case for the fact that this was not true.

He pointed to the topographic map and told us that given the slope on nearly all fields, he did not like to spread manure in winter. So here is a case where the CNMP writer filled out a software program, and yes, it is filled out correctly, with one exception.

The slope category was built with nominal slopes on many of the crop fields, making the case the landowner can apply manure on the (nearly) level portions of the field instead of the steeper sloped areas.

Yet there was no narrative explaining how the field data for slope were selected. The CNMP software output shows most of the crop fields have a low risk for winter spreading, but the planner did not qualify the end report with a narrative that mirrors what the landowner knows and has known for dozens of years.

One not good outcome of this one model is the failure of the planner to identify a resource concern on the crop fields. This is a classic case of using a software program or model to answer a question of risk, and therefore the likelihood of a resource concern, instead of properly discussing winter spreading practices with the landowner.

Yes, software and models have their place, but what is more important than these tools in the computer is the empirical evaluation of what the landowner sees, what the writer/planner sees and what the district conservationist sees.

Nothing, not anything at all, can replace the step of walking and looking and accounting for what we see on the farm. We cannot do that from a computer screen.

The take-home is this: The CNMP writer cannot build a useful document on data and mathematics alone. I have much angst over the many CNMPs that cross my desk with computer software printouts with little meaningful text and no narratives to explain what these reports mean.

Often, I make the case as a planner to pick a path and then justify it based on good science and common sense. If that path does not include a prescribed set of software or model, then keep going anyway … but always include your rationale for the path you took and how this path is just right for the landowner and the NRCS field office personnel.

If we back up a step, then we might posit here that the CNMPs we (NRCS) receive are a product of how the CNMP writer was taught to write them. I agree, and I want to change that.

We owe the landowner and ourselves a more useful document. To have one, we must rethink how we train our planners, especially those in the private sector that write nearly all of these CNMPs.

Three outcomes help get us there: First, a closer examination of the farm family dynamics helps smooth the transition of decision-making across the entire group that sits at the kitchen table. There is no software to do this. Instead we must use our brains and our ability to engage with people.

Second, the CNMP planner/writer must be smart enough to ask for help, putting a team of people together so the landowner is given good options and some understanding of what parts of a CNMP fall in the domain of contracting through our EQIP.

Third, rather than total reliance upon software, the writer/planner uses his or her insight and perspective based on what is empirically seen with eyes on the site.

Delivering this kind of training is much harder to do than delivering a series of PowerPoint slides on how to fill out a particular software or model.

But if we can do this, we gain a lot, and the greatest gain is what I consider to be our most important task: delivering a CNMP to the landowner that is useful so that farm efficiency, economics and the environment are all improved.

These are the big three E’s: If we start with them, we end up with them. The only way I know to get there is getting out of the office and into the kitchens, the barns, the feedlots and the fields of the client.

And if I had the authority, no CNMP would be 600 pages long. PD

  • Mike Gangwer

  • Agricultural Scientist
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