The Economic Value of Applying Fall Poultry Litter

by: Jordan Shockley, University of Kentucky Assistant Extension Professor

Spring application of poultry litter is ideal for maximizing the economic value of poultry litter but faces challenges that include wet soil conditions, lack of time to spread litter near planting, and availability of poultry litter in the spring. Therefore, it is a common practice in Kentucky to apply poultry litter in the fall. While not optimal from an economic, agronomic, or environmental perspective, producers still need to understand the economic value from applying poultry litter in the fall.

Poultry litter applied in the fall to fallow cropland will suffer from ammonium volatilization and leaching resulting in little to no nitrogen available to the crop come spring. This results in an economic value less than if applied in the spring. To evaluate the economic value of poultry litter applied in the fall, first assume that soil test recommendations indicate the need for phosphorus and potassium. Also, assume that “as received” poultry litter has a nutrient content of 50 lbs of nitrogen, 56 lbs of phosphorus, and 47 lbs of potassium (average for Kentucky). With current fertilizer prices of $399/ton for anhydrous ($0.24/lb N), $418/ton for DAP ($0.36/lb P2O5) and $316/ton for potash ($0.26/lb K2O), the expected value of poultry litter applied to fallow cropland in the fall is $29/ton. This value should cover the price paid for the poultry litter, transport, and application to compete with commercial fertilizer when applied in the fall. The value of poultry litter increases to $33/ton if it is spread in the fall to cropland that has a cover crop planted. Both fall poultry litter prices are lower compared to 2016. This is directly attributed to the decrease in nitrogen prices from $0.32/lb to $0.24/lb. This decrease value was slightly offset by small increases in both phosphorus and potassium prices.

If availability of poultry litter in the spring is a concern, stockpiling litter purchased in the fall can be an option if local, state and federal regulations allow. With the correct storage techniques and a properly staked litter pile, producers can expect minimum nutrient loss for spring application. If the same commercial fertilizer prices hold, the average poultry litter in Kentucky would have a value of $36/ton if properly stored and applied in the spring.

The value of poultry litter differs in the fall if applied to pastures or land for hay production. If applying poultry litter to an established stand of alfalfa with a legume mix of <25% of the stand, the average poultry litter in Kentucky at current commercial fertilizer prices has a value of $40/ton. The value of poultry litter will vary based on grass type, established stands vs. new seeding/renovation, and whether the land is used for hay, pasture, or silage.

Since the value of poultry litter is dynamic and always changing, decision tools have been developed so producers can enter soil test data, nutrient content of measured litter, commercial fertilizer prices, and management practices of poultry litter applied to determine the value. Tools for applying poultry litter to both grain crops and land in hay/pasture/silage are available and can be found on my website at the following link: http://www.uky.edu/Ag/AgEcon/shockley_jordan.php

Farms Must Begin Reporting Air Releases of Hazardous Substances from Animal Wastes

Peggy Kirk Hall, Assistant Professor, Agricultural and Resource Law
Ellen Essman, Law Fellow

Beginning November 15, 2017, many livestock, poultry and equine farms must comply with reporting requirements under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) section 103. The law requires entities to report releases of hazardous substances above a certain threshold that occur within a 24-hour period. Farms have historically been exempt from most reporting under CERCLA, but in the spring of 2017 the U.S. Court of Appeals for the District of Columbia Circuit struck down the rule that allowed reporting exemptions for farms. As long as there is no further action by the Court to push back the effective date, farmers and operators of operations that house beef, dairy, horses, swine and poultry must begin complying with the reporting requirements on November 15, 2017.

Farmers and operators, especially of sizeable animal operations that are likely to have larger air emissions, need to understand the reporting responsibilities. The Environmental Protection Agency (EPA) has published interim guidance to assist farms with the new compliance obligations. The following summarizes the agency’s guidance.

What substances to report

The EPA specifically names ammonia and hydrogen sulfide as two hazardous substances commonly associated with animal wastes that will require emissions reporting. Each substance has a reportable quantity of 100 pounds. If a farm releases 100 pounds or more of either substance to the air within a 24-hour period, the owner or operator must notify the National Response Center. A complete list of hazardous substances and their corresponding reportable quantities is here.

Note that farmers do not have to report emissions from the application of manure, and fertilizers to crops or the handling, storage and application of pesticides registered under federal law. However, a farmer must report any spills or accidents involving these substances when they exceed the reportable quantity.

How to report

Under CERCLA, farm owners and operators have two compliance options—to report each release or to follow the continuous release reporting process:
•For an individual release that meets or exceeds the reportable quantity for the hazardous substance, an owner or operator must immediately notify the National Response Center (NRC) by phone at 1-800-424-8802.
•Continuous release reporting allows the owner or operator to file an “initial continuous release notification” to the NRC and the EPA Regional Office for releases that will be continuous and stable in quantity and rate. Essentially, this puts the authorities “continuously” on notice that there will be emissions from the operation within a certain estimated range. If the farm has a statistically significant increase such as a change in the number of animals on the farm or a significant change in the release information, the farm must notify the NRC immediately. Otherwise, the farm must file a one year anniversary report with the EPA Regional Office to verify and update the emissions information and must annually review emissions from the farm. Note that a farm must submit its initial continuous release notification by November 15, 2017.

No reporting required under EPCRA

The litigation that led to CERCLA reporting also challenged the farm exemption from reporting for the Emergency Planning and Community Right to Know Act (EPCRA). EPRCRA section 304 requires facilities at which a hazardous chemical is produced, used or stored to report releases of reportable quantities from the chemicals. However, EPA explains in a statement issued on October 25, 2017 that the statute excludes substances used in “routine agricultural operations” from the definition of hazardous chemicals. EPCRA doesn’t define “routine agricultural operations,” so EPA states that it interprets the term to include regular and routine operations at farms, animal feeding operations, nurseries, other horticultural operations and aquaculture and a few examples of substances used in routine operations include animal waste stored on a farm and used as fertilizer, paint used for maintaining farm equipment, fuel used to operate machine or heat buildings and chemicals used for growing and breeding fish and plans for aquaculture. As a result of this EPA interpretation, most farms and operations do not have to report emissions under EPCRA. More information on EPA’s interpretation of EPCRA reporting for farms is here.

What should owners and operators of farms with animal wastes do now?

  1. Review the EPA’s interim guidance on CERCLA and EPCRA Reporting Requirements, available here.
  2. Determine if the operation may have reportable quantities of air emissions from hazardous substances such as ammonia or hydrogen sulfide. The EPA offers resources to assist farmers in estimating emission quantities, which depend upon the type and number of animals and type of housing and manure storage facilities. These resources are available here.
  3. A farm that will have reportable emissions that are continuous and stable should file an initial continuous release notification by November 15, 2017. A guide from the EPA for continuous release reporting is here. Make sure to understand future responsibilities under continuous release reporting.
  4. If not operating under continuous release reporting, immediately notify the National Response Center at National Response Center (NRC) at 1-800-424-8802 for any release of a hazardous substance that meets or exceeds the reportable quantity for that substance in a 24-hour period, other than releases from the normal application or handling of fertilizers or pesticides.
  5. Learn about conservation measures that can reduce air pollution emissions from agricultural operations in this guide from the EPA.

Note that the EPA is seeking comments and suggestions on the resources the agency is providing or should provide to assist farm owners and operators with meeting the new reporting obligations. Those who wish to comment should do so by November 24, 2017 by sending an e-mail to CERCLA103.guidance@epa.gov.