Reports are scheduled for 2011, but in the case of livestock and poultry operations, only methane or nitrous oxide releases musts be declared. According to calculations performed by Hebert, the 723,600 hen limit is academic since there is no complex in the U.S. which could conceivably exceed the 25,000 metric ton reporting threshold (dry manure).
UEP is currently in communication with EPA to develop a detailed table converting methane and nitrous oxide into carbon dioxide equivalents that form the basis of the 25,000 metric ton greenhouse gas limit. Calculations may have to be developed for large operations using anaerobic lagoons to ensure they conform.
Hebert also commented on the Clean Water Act and the new CWA enforcement plan. According to Lisa Jackson, EPA Administrator, “where facilities with large numbers of animals are discharging without a permit or in violation of their permits, they can cause significant pollution problems of concern to communities.”
According to Herbert, CAFOs must register and should be in compliance with respect to storage and spreading of manure.