Posted: February 2, 2023
The purpose of this article is to clarify the requirements for accurately preparing Act 38 Nutrient Balance Sheets (NBS). Specifically, the requirements apply to NBS prepared as part of an Act 38 NMP and for any manure exports from an Act 38 operation including manure exported through a broker.
The Nutrient Management Regulations under § 83.301 - Excess Manure Utilization Plans describe that the land application of manure exported from an NMP operation must address the risk and impacts of nitrogen and phosphorus loss to waters.
When developing NBSs for exported manure, the NBS must include all sources of organic nutrients that will be applied to the importing operations crop management units (CMUs or fields). Examples of other organic nutrient sources include, but are not limited to, other imported manure types, manure generated by the importer's own animals, food processing residuals and biosolids. The NBSs must also include any commercial fertilizer (starter and other) that the importer utilizes.
For situations where NBSs are developed for CMUs that will receive more than one organic nutrient source, they must be treated as multiple applications in the NBS.
The guidance provided in Appendix 8 Importer/Broker Agreement and NBSs – Page 2 of the Nutrient Management Technical Manual on this issue is as follows: "Nutrient Balance Sheets (NBS) required under the Program must follow the standardized NBS form and process provided by the Commission. Supplement 3: Nutrient Balance Sheet User Guide provides the format, calculation process, and accepted figures to use when completing a NBS for an importing operation". Supplement 3 provides guidance for and examples of developing NBS with multiple manure applications to pasture and cropland.
An increasing number of NBSs are being developed that do not include all nutrient sources utilized on the importing operation. Some common examples seen by reviewers include:
- NBSs for an importer that imports manure from multiple exporting operations but each individual NBS does not account for the manure from the other source(s)
- NBSs for exported manure applied to pasture without including the uncollected manure applied by the importers grazing animals.
- NBSs that do not include commercial fertilizer that is applied by the importer.
In conclusion, NBS development must take into consideration all sources of nutrients that may be utilized on the importing operations fields. When more than one type of organic nutrient source (manure, biosolids, etc.) will be applied to any importing field, it must be planned as a multiple application in the NBS.
Planners MUST ask importing operations questions such as:
- What manure is actually planned to be applied?
- Specifically, identify all sources of nutrients that are being used.
- Does the operator receive manure from more than one source?
- Does the importer have their own animals and manure that needs to be included?
Only after all this information is gathered can a plan writer properly plan for each scenario.
For additional guidance on this topic please contact the SCC Regional Coordinator that covers the county that you are working in.
Contact Information
Jamie Ulrich
Nutrient Management Program Coordinator (Central PA), State Conservation Commission
Email: aulrich@pa.gov
Phone: 215-287-5187
