An open letter to the Maryland Department of Agriculture regarding proposed changes to the Nutrient Management Plan Requirements

by Steuart Pittman, president of the Maryland Horse Council 

[Editor’s note: click here to read prior articles on the proposed changes to the nutrient management regulations; click here to read the editorial posted Aug. 19. To read the proposed changes you can either click here for the official Maryland website, but you will need to hunt and scroll for it, or you can click here to read the proposal on the website for the Maryland Farm Bureau. To learn more about the proposed changes to the manure and nutrient management laws, attend the Maryland Horse Council meeting tomorrow night, Tuesday, August 21st at the New Market Grange Hall at
14 South Alley
(South Alley & 7th Alley)
New Market, MD 21774. Refreshments will be served at 
6 p.m., the meeting starts at 7 p.m. Sen. David Brinkley will be in attendance to address this topic. Click here for more information, or e-mail  The meeting is open; membership is not required.]

The Maryland Horse Council represents the 40,000 Maryland citizens who are part of the state’s horse industry. Our Farm Stewardship Committee is an effort by horse farm owners to better understand the impact of their farms on the environment, improve environmental practices, and demonstrate to the public that well managed horse farms and the pastures and hay fields that support them make a positive contribution to efforts to reduce nutrient runoff into the Chesapeake Bay.

It was an honor to be asked by Governor O’Malley to participate as one of the five representatives of agriculture in his staff’s attempt to forge a consensus on these regulations with five representatives of environmental organizations. While that effort did not change opinions on the regulations at hand, our hope is that it helped to forge relationships that will be the foundation for future cooperation.

The state’s 79,100 horses reside on 16,040 separate properties that total 587,000 acres. While these regulations are primarily an attempt to address nutrient runoff from large livestock and grain operations, the largest number of individuals who will have to comply are small horse farm owners who rarely fertilize  and whose manure piles consist primarily of hay and straw.

Many horse farms owners have not yet come into compliance with existing nutrient management requirements. Small horse farm operators do not often participate in government farm programs of any kind, and convincing them that a nutrient management plan is a useful tool that can improve their pastures was difficult before the proposed changes. If the new regulations take effect the incentive for farms to stay outside the program will be much greater.

Limitations on winter spreading of straw or shavings mixed with horse manure 

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 no appropriate stacking sites, but also is a threat to our waterways.

Horse farm owners have been told for years that harrowing their pastures spreads manure piles 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.

These new regulations tell us that we can no longer use our manure spreaders during the winter months that our animals are kept in barns and our pastures turn to mud.

We are allowed to keep our horses outside, where they destroy the roots of our pastures and deposit their manure, but we are not allowed to keep them in stalls and put that same manure mixed with straw or shavings evenly across the ground with spreaders where it can soak into the soil under light winter rains and melting snow and improve soil quality for spring and summer pasture growth. The heavier manure spreading that farmers would 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, the new version of the Nutrient Management Program 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 is negative.

Nobody in the scientific or environmental community has shown that leaving horses out during the winter is better for water quality in adjacent streams than spreading the bedding and manure that comes form those same animals when kept off the fields in barns. Water quality testing in years when manure is  spread in winter months could easily be compared to water quality tests from years when manure is not spread in winter months. Until such comparative testing has shown a negative impact from the 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.

Fencing Horses Out of Streams 

Horses do not wallow in streams any more than deer or other wildlife. Any trail rider will swear to the fact that horses hate putting their feet in mud.

A number of horse farm owners have calculated the cost of separating their horses from streams that run through their pastures but that they never enter. These tend to be the large farms with the best pastures.  These are the farms that fertilize the least and are an asset to the waterways that run through them.  Nobody believes that fencing these streams out of the pastures will make the water in them any cleaner, but the proposed regulations would force these farm owners to do just that at $8 per foot. One of the best-managed farms in our state had an estimate of $60,000 to fence out its streams, and others in the same county came in at over $100,000.

Soil Conservation District staff can tell when animals are causing erosion problems in streams and affecting water quality. We support efforts to address those problems. We do not, however, support a regulation such as the one proposed that arbitrarily states that every farm that has a stream running through a pasture is outside the law.


We understand that politics drives policy, and that non-farmers have made an argument that farm animals are polluting our waterways. Those well-meaning advocates are demanding that laws be passed to criminalize farm practices that have not been shown to have a negative impact on the environment.

We applaud Governor O’Malley’s defense of farmers when we are blamed for pollution and we applaud his work to preserve both farmland and the Chesapeake Bay. We are working hard to sell the Nutrient Management Plan as an effective pasture management tool for horse farm owners. We understand that horses can create erosion and that overgrazing is the real issue that horse farm owners must address if we seek to shrink our environmental footprint.

Forcing us to fence out streams that our horses never step in and stockpile or truck manure that could improve the quality of our soils are both expensive and pointless exercises that 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.

We join Maryland Farm Bureau and others in the agricultural community in asking that the state of Maryland continue its present efforts to bring farmers into compliance with the more reasonable Nutrient Management Plan regulations already in effect and work with the MHC Farm Stewardship Committee to promote BMPs on horse farms and thereby improve our chances of meeting the goals set in all of our county Watershed Implementation Plans.

Please call on the Maryland Horse Council for input on these and other issues that affect horse farms. We are 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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