Posted: March 11, 2022

How do alternative sources of nitrogen and phosphorous (non-manure and non-commercial fertilizer) relate to your Act 38 Nutrient Management Plan (NMP) obligations?

As you are aware, farm production costs continue to soar due to COVID-19 supply chain disruption, inflation and other factors in the world today. Fertilizer costs will be as much as 80% higher this year than last, according to a study by Texas A&M University's Agricultural and Food Policy Center. National Corn Growers Association President Chris Edgington has said "Fertilizers and other inputs have been at an all-time high, and the war in Ukraine promises to drive up the price of products even more".

Manure has been and will continue to be an excellent source of nitrogen (N) and phosphorous (P) for crop production. Continue to work with your clients to confirm that their Nutrient Management Plans (NMPs), Nutrient Balance Sheets (NBSs), and Manure Management Plans (MMPs) are up to date. Most importantly ensure that all sources of nutrients are considered when balancing nutrient needs for crop production.

Understand that not including alternative or new sources of nutrients into plan documents puts the operation at risk of being out of compliance and facing possible enforcement. The regulations are clear at 83.203 (1) (purpose):

Assure the proper utilization and management of nutrients on CAOs, VAOs and operations required to develop compliance plans under section 506(j) of the act (relating to nutrient management plans).

The use of Food Processing Residuals (FPR) as an alternative source of N and P has become popular in Pennsylvania. The State Conservation Commission (SCC), its partners, and DEP developed Supplement 21 to the Technical Manual that provides clear detail on how Food Processing Residuals are to be handled in Nutrient Management Plans.

In addition, please confirm if your clients will be planning any new incorporation timings or injections, as these practices will affect the amount of nutrients available and will change the balanced manure rates which will require plans to be updated or amended.

It has been recommended that operations consider using 15-20 pounds less N than normal in order to maintain favorable economics of production. If operations follow this, recording keeping is important, as the Commonwealth can receive credit in water quality models (i.e. the Bay model).

Additional Pennsylvania specific information, provided by PSU extension, can be found at:

If you should have any questions, feel free to reach out to the program contacts at the SCC, DEP or Penn State Extension.

Frank Schneider|Director of Nutrient Management & Odor Programs, State Conservation Commission|fschneider@pa.gov|717-705-3895