Government Relations Committee THE MARYLAND HORSE COUNCIL


by Jane Seigler, MHC Government Relations Committee Co-Chair It pretty much goes without saying that the last thing most horse farm


owners want to do is invest precious time going down the rabbit hole of trying to understand federal environmental regulations. One set of these regulations involves Animal Feed Operations (AFOs) and Concentrated Animal Feed Operations (CAFOs). Although it sounds like these regu- lations should apply to beef cattle feedlots and the like, and that is cer- tainly a big focus, in fact these regulations can apply to horse operations. T e regulations came into eff ect under the Clean Water Act in the 1970s, in an attempt to control the discharge of pollutants into “the waters of the United States.” T e focus on animal operations derives from the fact that manure that gets into the water of streams, rivers, bays, estuaries, etc., causes excess algae growth and depletes oxygen needed by aquatic life, and can make the water unsafe for drinking and recreational activities.


What is a CAFO? Under the regulations, and for purposes of application to horse opera-


tions, an Animal Feed Operation is any animal operation where animals are kept in confi ned situations on a property for a total of 45 days in any 12-month period and where vegetation or forage growth is not sustained in the normal growing season over any portion of the facility, i.e., no pastures or hay fi elds. Animal Feed Operations may be further designated as Concentrated


Animal Feed Operations based on a number of factors, and are cat- egorized as Small (<150 horses), Medium (150-499 horses), or Large CAFO (500+ horses). According to the American Horse Council: “No matter what size


an operation is, if it is an AFO, it may be designated a CAFO. Many diverse types of horse operations including show grounds, breeding fa- cilities, racetracks, large recreational boarding stables, and more could be regulated as a CAFO. Being defi ned as a CAFO requires you to manage wastewater and drainage, have a nutrient management plan, and repeat the permit inspection annually.”


So what’s the beef? As mentioned above, CAFO regulations were largely created with beef,


dairy, poultry, pork, and other traditional food animals in mind, and there is concern among some in the equine industry that current CAFO regula- tions place excessive fi nancial and logistical hardships on equine opera- tions. Horse operations have unique husbandry practices, diff erent from traditional food and fi ber livestock. Consequently, it is argued, horse opera- tions should have any required CAFO compliance tailored specifi cally to the circumstances surrounding equine husbandry practices. Much of the CAFO program details are administered by the states;


in Maryland, by the MD Department of the Environment (MDE). In Maryland, an AFO can become a CAFO, or a MAFO (Maryland Ani- mal Feeding Operation). According to MDE: “T e operation is a CAFO if it is designed, constructed, and operated or maintained such that a discharge of manure, litter, or process wastewater could or does occur to surface waters of the State. T e presence of a man-made ditch, fl ush- ing system, or other similar man-made device (e.g. pipes, ditches, swales, etc.) to remove water from the production area indicate that it proposes to discharge. A discharge means the addition, introduction, leaking, spill- ing, or omitting of any pollutants to waters of the State, or the placing of a pollutant in a location where it is likely to pollute. A MAFO is an AFO that is designed, constructed, and operated or maintained such that a discharge of manure, litter or process wastewa- ter will NOT occur to surface waters of the State. A large-size AFO that does not discharge to surface waters of the State, but discharges to ground waters of the State, is considered a MAFO.” If you are a CAFO or a MAFO, you will need to apply for cover-


age under the general discharge permit, have a Comprehensive Nutrient Management Plan, a Nutrient Management Plan, and a Soil Conserva- tion and Water Quality Plan, pay an annual fee, and submit to inspec- tions. More information about CAFOs and MAFOs can be found here: https://mde.maryland.gov/programs/land/RecyclingandOperationspro- gram/Documents/AFO%20FAQ%20rev%202.2021.pdf


TIME IS RUNNING OUT - PLEASE ACT NOW!


What do creating a special position within the MD Dept. of Agriculture to support horse businesses, making it easier for MD barns that off er equine assisted therapy to qualify for grants from the MD Dept. of Veterans Aff airs, and exempting horse farmers from a requirement for on farm composting permits from the MD Dept. of the Environment, have in common? They are just three of the bills that the Horse Council successfully lobbied for passage in this year’s Legislative Session in Annapolis. The next legislative session convenes at noon on January 10. We need your help to continue our


work on behalf of you and your horses. Legislators respond to PAC contributions and pay attention to organizations with robust PACs. By law, we must make our PAC disbursements to Legislators be- fore the Session opens in January. Legislators ramp up their fundraising in December, ahead of the deadline, so we need your PAC contribution NOW!


Please donate today - every dollar counts, but we need your contribution ASAP! THANK YOU!


MHC does not endorse political candidates. We support incumbents who are in a position to support, or have already supported, the horse industry on general policy issues and in specifi c pieces of legislation.


www.equiery.com | 800-244-9580 THE EQUIERY YOUR MARYLAND HORSE COUNCIL PUBLICATION | DECEMBER 2023 | 39


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