MARYLAND HORSE COUNCIL
P.O. BOX 141
DAMASCUS, MD 20872
February 10, 2014
Ms. Hilary Miller, Deputy Director
Land Management Administration
Maryland Department of the Environment
1800 Washington Blvd., Suite 610
Baltimore, MD 21230-1719
RE: proposed regulations 26.04.11 Composting Facilities
Dear Ms. Miller:
The Maryland Horse Council (MHC) is a membership-based, umbrella trade
association of the entire horse industry in Maryland. Our membership includes horse
farms, horse related businesses, individual enthusiasts, and breed, interest and
discipline associations. As such, we represent over 30,000 Marylanders who make
their living with horses, or just own and love them.
MHC is pleased to submit the following comments regarding the above referenced
regulations that are being proposed by the Maryland Department of the Environment
(MDE).
The proposal would establish a broad and complex new scheme for regulating
composting facilities, which - at least in the non-farm context - have been largely
unregulated previously. However, agricultural composting has been facilitated and
overseen by the Maryland Department of Agriculture (MDA) and the local Soil
Conservation Districts for decades, and that history and practice should be used to
inform how these new MDE regulations would affect agricultural composting,
especially where manure is the primary feedstock.
As we understand it, under MDE’s proposal on-farm composting facilities must be
permitted unless:
1) the composted material is produced and used on-site or at a facility controlled by
the same operator, (hereinafter “on-site”) (section .05 B (2)), or
2) the composting facility is located on a farm that is required to register with MDE
because it uses greater than 5000 square feet “in support of composting,” accepts
materials from off-site, and uses that compost on-site (section .05 B (3)), or
3) is a Tier 1 (primarily yard waste) or Tier 2 facility (certain other materials
including animal manure and bedding) under 5000 square feet “in support of
composting,” that complies with certain specified general environmental standards
and whose windrows or piles are lower than 9 feet (Section .05 B (04)). It is not
clear whether this particular provision also includes horse farms that compost
animal manure and bedding, or whether it is intended to refer only to non-farm
Tire 1 and Tier 2 facilities. This confusion is also implicated in the provisions of
section .11 (General Permits)
MHC respectfully submits that the proposed regulations fail to take into account the
unique characteristics of composting as it typically occurs on horse farms.
• Many horse farms compost the manure and bedding that is removed from barns and
sheds during regular cleaning. This material is produced on-farm, although the
straw, wood shavings or other bedding material is typically purchased off-site.
Although the proposed regulations state that manure including bedding is a Type 2
feedstock, they do not make clear whether use of bedding that is purchased off-site
would preclude application of exemptions for feedstocks produced on-site. The
regulations should be clarified to state that animal manure that contains animal
bedding used on-site (regardless of its source) constitutes a feedstock that is
produced on-site.
• According to NRCS information, a 23 horse operation will use an 80’ x 60’(4,800
sq ft) pad for 180 days composting capacity. Thus, any operation with 24 or more
stalled horses will require a pad of greater than 5,000 square feet. There are dozens,
if not scores of horse farms in Maryland that meet this threshold. The proposed
regulations should be amended to increase the 5,000 square foot limit to
accommodate larger horse operations.
• The proposed regulations do not discuss what is perhaps the most typical model for
horse farm composting regulations, i.e., only on-farm generated materials (manure
and bedding) are composted, and the resulting compost is sold or given away to
other local farms, residences, landscapers, etc. The regulations should be amended
to make clear that composting facilities that use only materials generated on-site,
but distribute them off-site are exempt from the permitting requirements as long as
they are in compliance with applicable MDA regulations.
• In some cases, horse farms take in manure from other farms not owned or
controlled by them, who do not have the capacity to compost their own manure.
These facilities may distribute the final composted material to other farms,
residences or landscape companies. The regulations should be amended to increase
the 5,000 square foot limit for these facilities to, for example, 40,00 square feet as
consistent with the Forest Conservation Act, and exempt them from the permitting
requirement as long as they are in compliance with applicable MDA regulations.
Composted horse manure is a valuable and as yet under-utilized resource. According
to a 2010 equine census,* Maryland is home to 79,100 equine animals housed at
16,000 locations with 188,000 acres devoted strictly to horses. At an average rate of
55 pounds of manure excreted per horse per day,** Maryland’s horses produce an
estimated 1,443,575,000 lbs of manure per year. Horse manure is a good substrate to
use for compost. First, it’s drier than other livestock feces, therefore it’s easier to
transport from one location to another. Second, it has a 5:1:2 ratio of nitrogen,
phosphorous, potassium** and thus is relatively balanced in nutrients when it’s
applied as a soil amendment. Third, when the feces include animal bedding products
such as sawdust or wood shavings it is close to an ideal 25:1 carbon to nitrogen ratio.
It is in the best interest not only of horse farm owners, but of all Maryland citizens
and of our environment to ensure that this product is recycled to its highest and best
use, by minimizing barriers to that use. Unreasonable restrictions on manure
composting and distribution of the composted end product as a soil amendment will
only result in more manure ending up in landfills, rather than benefitting our soils,
crops, gardens and roadsides.
MHC appreciates the opportunity to comment on these proposed regulations, and
urges MDE to adopt the recommendations set forth here.
Respectfully submitted,
Jane Seigler
President
MARYLAND HORSE COUNCIL
P.O. BOX 141
DAMASCUS, MD 20872
* MASS (Maryland Agricultural Statistics Service). 2002. Maryland Equine: Results
of the 2002 Maryland Equine Census. Annapolis, MD: Maryland Department of
Agriculture.
** Lawrence, L., J.R. Bicudo, and E. Wheeler. 2003. Horse manure characteristics
literature and database review. In Proc. International Anim., Ag. Food Processing
Wastes Symp., Research Triangle Park, NC, Oct. 12-15., 277-284. St. Joseph, MI:
Am. Soc. Ag. and Biol. Engineers.
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