The Devil is in the Details......Don't Forget To.....

Adapted by Deanne Meyer, Livestock Waste Management Specialist, UC Davis

Spring is in the air and forage is being ensiled.  Dairy producers need good records of how much forage is harvested from each field and its moisture content.  This is important both from a feed management perspective but also from a regulatory compliance perspective.  Yield and moisture content, as well as nutrient content of forage are needed for every crop on every field for all dairies within the Central Valley for water quality regulatory compliance.  The results for moisture may also be used to document moisture content of forages for Air District compliance.  For those dairies in the San Joaquin Valley, it’s important to be sure the mil thickness of the plastic covering used on silage piles is documented and records are maintained for Air Quality Compliance. Be sure that either the invoice for covering or your silage operation and maintenance plan documents the thickness of the plastic and/or presence or absence of an oxygen barrier.  You’ll also need to note that the each pile was covered within 72 hours of the last addition of forage.  An example operation and maintenance plan acceptable to meet District requirements can be found at: http://www.valleyair.org/busind/comply/forms/4570operationalplan-silage.pdf.

All producers in the San Joaquin Valley who received permits from the District more than a year ago now need to be implementing those permits.  There are several new requirements for feed management (specifically silage management) that must be implemented.  Basic record keeping templates are available at the District website (http://valleyair.org/busind/comply/compliance_forms.htm).  To locate information on the dairy program and the sample templates, scroll down to the Dairy section.  The record keeping checklist is in Excel to allow operators or their consultants to personalize the record keeping checklist to actual permit needs.  Once completed, these documents serve as an excellent resource during an inspection.  Count on having District staff at the dairy conducting inspections once every 15 months or so.

For the Central Valley, dairies that have not had an inspection from the Regional Water Quality Control Board since May, 2007 can expect to see an inspector between now and the end of June. Staff have more than 225 inspections to conduct and are on target to complete their task. Once these inspections are completed it is understood that the ever growing pile of Individual Waste Discharge Requirements will be processed.

General Order WDR Annual Reports for 2012 are due by July 1.  Please note that all modifications to facilities for nutrient and waste management purposes should have been done and the nutrient management plan (specifically the budget) should be fully implemented.  Central Valley Water Board staff intend to prioritize enforcement of failure to complete modifications or implement nutrient management, and to check for instances of inaccurately certifying either.  Although there is no immunity from enforcement, the Regional Board strongly recommends that if any of these areas are lacking, it is in the producer’s best interest to begin correcting now, rather than wait for Board staff to find and issue a notice of violation.

Link to PDF Version: The Devil is in the Details- Don't Forget To