The controlled biological decomposition of organic matter results in compost. Manure that is not managed by generally accepted compost production standards is just decomposing manure.

By Charles Gould and and Steve Mahoney

Compost has many uses and benefits in a cropping system. It encourages the formation of appropriately sized aggregates that protect the soil from erosion and compaction, enhances soil fertility through the slow release of macro- and micronutrients, and improves the availability of nutrients to growing crops. Most importantly, because compost is a living biological system, it infuses the soil with beneficial microorganisms that suppress or control soil-borne plant pathogens.

The Michigan Right-to-Farm (RTF) Act requires the establishment of generally accepted agricultural management practices (GAAMPs) to provide uniform, statewide standards and acceptable management practices based on sound science. On a livestock farm, these practices are implemented through a manure management systems plan, found in the GAAMPs for Manure Management and Utilization (commonly referred to as the manure GAAMPs; see www.michigan.gov/gaamps). In order to have RTF coverage, a farmer must develop, implement and sufficiently document an MMSP.

Biological Treatment Method. According to the manure GAAMPS, a biological treatment system converts organic matter such as feed, bedding and other agricultural byproducts to a more stable end product. Composting is a biological treatment method and therefore, is part of a farm’s MMSP.

Compost Production Scenarios. There are a number of ways that manure can be composted and distributed on a farm. The feedstocks used to make the compost, the scale of the farm operation, the composting method and the final utilization of the compost will determine whether the material and activities are covered under RTF or regulated by the Michigan Department of Environmental Quality (MDEQ) Waste and Hazardous Materials Division (WHMD) and/or Water Bureau (for farms under a National Pollutant Discharge Elimination System permit).

Scenario I. In general, manure generated and composted on a farm may be used on that same farm or taken off that farm for off-site utilization at another farm under RTF and managed according to GAAMPs.

Scenario II. Manure generated on one farm and taken to a different farm for composting may be used on the farm where it is composted under RTF, if managed according to GAAMPs. Any distribution of the composted manure from the farming operation means the operation will be considered commercial composting and subject to the Natural Resources and Environmental Protection Act part 115 rules, as administered by MDEQ WHMD.

Scenario III. Similarly, yard clippings (i.e., grass clippings, leaves, small brush, etc.) taken to a farm for composting may be used as a soil amendment on that same farm under RTF. In most cases, the farm will need to have and follow a compost operation plan (COP) approved by MDA. A COP includes a site plan, inventory of amount(s) of material(s) received, a description of how the materials will be composted, a description of storm water and runoff management practices, and a description of how the finished compost will be used.

For MDA to make a GAAMPs determination under this scenario, the farm needs to:

• Submit a COP to MDA.
• Allow MDA to conduct an on-site inspection.
• Produce adequate records to document adherence to the COP and conformance to GAAMPs for Nutrient Utilization (different from the manure GAAMPs but found at the same Web site).

Scenario IV. If yard waste is taken to a farm for composting (not as a form of treatment) and distributed from that farm in any form -- raw yard waste, partially composted compost or finished compost – the farm is considered a commercial composting facility and is solely under MDEQ jurisdiction. A farmer has no RTF coverage under this scenario.

Conclusion. RTF coverage extends to all farms that make compost for their own use, as long as it is managed according to the GAAMPs. Anything beyond this designation is considered commercial composting and does not receive RTF coverage. These operations fall under the purview of the MDEQ. If a farm is used as a commercial composting site, permits may be obtained from the MDEQ. Contact your local MSU Extension office by calling 1-888-MSUE-4MI (1-888-673-3464) for more information on the permit process or RTF questions.

Click here to read the full issue of the November 2008 Scoop.