-Jane Seigler, president, Maryland Horse Council
The Maryland Horse Council applauds Governor Larry Hogan’s effort to reduce “overburdensome and out of control regulations” by establishing the Regulatory Reform Commission. To this end, we have recently asked the Commission to consider the requirements of COMAR 15.20.07.02, Nutrient Application Requirements, as set forth in the Maryland Nutrient Management Manual, Nutrient Application Requirements, Section III, (D) and (E). Specifically, we ask that the rule’s prohibition of winter spreading of manure be abolished as it applies to spreading of horse manure on horse farms.
According to the most recent Maryland Equine Census, the state’s 79,100 horses reside on 16,040 separate properties that total 587,000 acres. The nutrient management regulations were conceived primarily to address nutrient runoff from large poultry and grain operations. We question whether their application to horse farm owners who rarely fertilize and whose manure piles consist primarily of hay, straw and wood shavings/sawdust is justified.
We believe that the ban on spreading horse manure mixed with bedding on fields during the winter months is not only a burden on farms that have limited appropriate stacking sites, but also is a threat to our waterways. Horse farm owners have been educated for years to harrow their pastures and thus spread manure droppings so that the nutrients can benefit the soil. Likewise, they have been taught that the mix of manure with straw or shavings that is evenly and lightly spread across pastures by their manure spreaders is good for soil and better for our streams than stockpiling the manure and creating rivers of brown water during heavy rains.
It makes little sense that during the winter there is no proscription against keeping horses outside on the pastures where they deposit their manure, but there is a rule against spreading that same manure mixed with straw or shavings from stall kept horses evenly across the ground with spreaders where it can soak into the soil under light winter rains and melting snow to improve soil quality for spring and summer pasture growth. The heavier manure spreading that farmers would need to do in early spring in order to dispose of the full winter’s manure stockpile is an environmental threat when heavy spring rains wash the manure into adjacent streams.
For the majority of small horse farms that do not have appropriate places to stockpile a winters’ worth of manure, this regulation is a threat to the viability of their operations. The cost of transporting manure by trucks to off-site composting facilities is prohibitive for most farms and the impact to the environment of this additional truck traffic is arguably quite negative.
We are unaware of any evidence in the scientific or environmental community that there is any difference in environmental benefit or detriment between leaving horses out on the fields during the winter on the one hand, and spreading the bedding and manure that comes form those same animals when kept off the fields in barns on the other. Indeed, MHC representatives have been told on numerous occasions by MDA officials that horse manure is “not really an environmental problem,” and that therefore, for example, horse farms are not eligible to participate in the benefits of the Manure Transport Program. Until research has shown a negative impact from winter manure spreading, we believe that forcing horse farm owners to truck or stockpile their manure is bad public policy. Horse farm owners should be allowed to spread manure year-round with reasonable limitations on spreading rates.
Forcing farmers to stockpile or truck manure that could otherwise improve the quality of the soils is an expensive and pointless exercise that works only to discourage farm owners from working with their soil conservation districts and investing in the kinds of best management practices that are known to prevent erosion and sediment loss, the most common conservation issue arising on horse farms.
We join the Maryland Farm Bureau and others in the agricultural community in a continuing commitment to advocating for compliance with reasonable Nutrient Management Plan regulations and the promotion of BMPs on horse farms to improve our chances of meeting the goals set in all of our county Watershed Implementation Plans. However, we feel that the prohibition against winter spreading of horse manure has no basis in scientific evidence, is overly burdensome, and may even have a negative environmental impact, as stated above.
The Maryland Horse Council is working hard to preserve the land and the jobs that the horse industry maintains in Maryland, and will continue to advocate in good faith with our partners in state government toward that end.
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