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Class 25 -- Chapter 9

Quizzes 6, 7

Anita
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Class 25 -- Chapter 9

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    1. Class #25 -- Chapter 9 Lexis Exercise due today? Nov. 3 Topic and outline (how you handling the topic) for research paper due. Appeals Court Argument on Monday?? Cases page Student ? EPA 220– action, issue & facts –Jaret law, holding & rule – Amanda Jordan Pork Motel 222 – action, issue & facts – Jeanna law, holding & rule – Kristen Daniel United States 228 – action, issue & facts -Brett law, holding & rule – Tom Tom Woodbury, 234 –action, issue & facts – Daniel law, holding & rule – Jordan Brett

    3. Quiz #8 1. A farmer who has taken up an escaped animal has a duty to care for the animal. 2. In Indiana “non-agricultural landowners,” whose land is facing each other, outside cities, do not have to build a “partition“ fence. 3. Generally, farmers may irrigate in Indiana without a special permit. See site below for more study http://www.in.gov/dnr/water/water_availability/14-25-4.html 4. Indiana DNR can shut down an irrigation activity, in a selected area--to allow the water table to restore. 5. The common enemy rule says a landowner may act reasonably in ridding his property of surface water.

    4. Butler v. Bruno S. Ct. of RI, ’75 Action? for damages due to the deflection of surface water Issue? Is Bruno liable for Butler’s loss in property value? Is the common enemy rule the law?

    5. Butler Facts: Plaintiff seeks damages for the deflection of surface water by the defendants 3 foot wall and fill. Before Bruno built the wall and fill, the water flowed across his lot west to east. After Bruno developed his lot, Butler had considerable damage to his property value due to flooding.

    6. Butler Trial court judge held for the defendant, Bruno. Bruno was held to not be liable since he had not violated a law. While there was damage, Bruno had used reasonable care in developing his property. Holding: For the pl, Butler, case remanded. Remand?

    7. Butler Holding: For the pl, Butler, case remanded. The common enemy rule says a landowner may act reasonably in ridding his property of surface water. Common enemy rule has been followed because it supported the development of property and was consistent with the right to use property in a way best suited to a landowner’s needs.

    8. Butler Holding: If Butler followed Bruno’s development, his neighbor to the west may make Butler the def in a suit. Other courts have followed a “civil-law” rule, first in Louisiana with roots in Roman Law and the Napoleonic Code.

    9. Butler Civil Law Rule: an easement of natural drainage so that the owner of the lower land must accept water from the upper land owner, but the upper land owner may do nothing to accelerate the water, or to interfere with the natural flow to the detriment of a neighbor, But this rule impedes development and it may be difficult to establish proof of what was the natural flow before a complained of project.

    10. Butler Courts have tended to modify both of the above rules to get an equitable result. Common enemy jurisdictions (states) such as Indiana (at least historically) recognize an absolute right to fend off surface water but the improvement must not cause “unnecessary harm”—specifically in Indiana water may not be collected and channeled so as to do harm. Rule of Reasonable Use (RRU) Liability is decided on the basis of the reasonableness of ones actions in dealing with surface water.

    11. Butler This rules does not depend on negligence or malice. RRU rests on the nuisance branch of tort law Under RRU there is said to be liability for an action when surface water interference is “unreasonable. ” Rule of Reasonable Use from a MN case, factors: 1. Is there a reasonable necessity for drainage? 2. Has reasonable care been taken to avoid unnecessary injury to the land receiving the water?

    12. Butler-- Reasonable Use 3. Does the benefit accruing to the land drained reasonably outweigh the resulting harm? 4. Is the diversion accomplished by reasonably improving the normal and natural system of drainage system, or if a procedure is not practicable, has a reasonable & feasible artificial system been installed? Rule of Reasonable Use (RRU) is adopted! Case back to (fact finder) lower court for consideration under the above RRU.

    13. Butler Dissent: Judge says, the RRU does not supply the landowner with a meaningful set of guidelines. The RRU is not well defined as a standard-- it is no rule at all. Under RRU landowner must proceed at his peril and resorting to the courts is an excessive burden!

    14. Related Drainage Laws Drainage Dist.- County Drainage Boards DBs are provided for in each county by Indiana law (See, Drainage Board Code at IC 36-9-27) County Board of Supervisors or their appointees are the Drainage Board. Board may establish and reconstruct regulated drains with the assistance of the surveyor. Landowners in a watershed are billed according the proportion of acres benefited.

    15. Drainage Boards Modern rules may require the drainage board to get a “permit” before cleaning out an existing drain. (See the my “Indiana Drainage Law” paper). Several entities may have a say: -- Indiana Dept of Natural Resources -- Army Corp of Engineers -- Others ?? Permitting depends on which waters are impacted and how the “ditch cleaning” is to be carried out.

    16. “Drain Obstruction Removal” law IC 36-9-27.4 (see the IC code handout) An Addition to the County Drainage Board Code. Surveyor must investigate a stopped private drain on private property. Drainage Board must rule on the facts the surveyor provides”

    17. Obstruction Removal Law Board can order the repair If there is a “responsible” (caused the problem) party he or she may be required to pay the bill, Or those benefited ( by the fix) may be required to pay. This new law is untested, and its full scope is yet to be ascertained.

    18. Drainage Case law! And, in a 2003 Indiana Court of Appeals case, Romines vs. Gagles, (782 N.E.2d 369), the Court concluded that the “drain obstruction removal” law speaks to a situation where Gagles’ natural flow drainage was impeded. The Romines added several loads of dirt to their lot blocking what was the channel that handled drainage from the Gagles’ lot. The result was long periods of standing water on the Gagles’ lot. In this case, the parties were dealing with a natural water course and the “drain obstruction removal” law applied to provide a remedy. Indiana law differentiates surface water control (to which the common enemy rule may still apply) from natural water courses. Related to homework #4?? How does natural flow differ from diffused surface water? Query: Does this case imply “common enemy rule” is dead!

    19. 2001 addition to Indiana drainage code—Developer’s Drainage Plan IC 36-9-27-69.5 Unless otherwise required by ordinance in the county, A person who lays out a subdivision of lots or lands outside the corporate boundaries of any municipality must submit plans and specifications for the drainage of the subdivision in accordance with this section. The county drainage board must approve the drainage plan before the person may proceed with development of the subdivision.

    20. Subdivision Drain Plan Standards 1. The plan must maintain the amount of drainage through the tract that existed when the tract was created. 2. If any tiles are cut, broken down, or rendered useless during the construction activity on the tract, the landowner will be responsible for the repair, replacement, or relocation of the tile. 3. The plan may not change the locations where surface water enters the tract and exits the tract from the locations that existed when the tract was created.

    21. Subdivision Drain Plan Standards 4. Water which sheds off of a new structure, especially when the new structure is elevated or near a property line, or both, must exit the tract in the same location where it did when the tract was created. 5. The county drainage board may approve an alternate plan that does not comply with the standard in three (3) above.

    22. IC 25-39-4      Chapter 4. Regulation of Water Well Drilling IC 25-39-4-1 Records; copy of record to department      Sec. 1. (a) Each water well driller shall keep accurate records for each well drilled. The record for each well must contain the following information:         (1) The location of the well.         (2) The depth and diameter of the well.         (3) The date the contractor completed the well.         (4) The character and thickness of materials or formations drilled.         (5) The static water level and performance data of the well.         (6) Any other information required by rule.     (b) Each water well driller shall, within thirty (30) days after the completion of a well, forward a copy of the record of the well to the department on forms prescribed or approved by the department. As added by P.L.262-1987, SEC.4. And Well drillers must be licensed.

    23.    Sec. 3. IC 25-39-3 and IC 25-39-4 do not apply to the following: (Exceptions) IC 25-39-1.5-3 Application of IC 25-39-3 and IC 25-39-4      Sec. 3. IC 25-39-3 and IC 25-39-4 do not apply to the following:         (1) A person who installs a well that:             (A) is for personal use; and             (B) is not greater than one and one-fourth (1 1/4) inches inside diameter and not greater than twenty-four (24) feet deep.         (2) A plumber who:             (A) is licensed under IC 25-28.5;             (B) is registered with the department under section 4 of this chapter; and             (C) installs wells that are not greater than one and one-fourth (1 1/4) inches inside diameter and not greater than twenty-four (24) feet deep. As added by P.L.262-1987, SEC.1. Amended by P.L.20-1991, SEC.10; P.L.120-1993, SEC.17.

    24. Protecting the Environment and the Productivity of Agr. Land, Ch.9 Pollution is not a new problem. But its importance has been growing in the past 30 years. Pollution arises from the non-farm industries, and consumer products, e.g. Manufacturing processes, cars, and from agriculture. Attitude is important -- farmers should not view various rules and regs. as restrictions on them, but as beneficial. Note, research shows compliance pays and does not cost jobs! IDEM site: http://www.in.gov/idem/land/cfo

    25. Water Pollution Water is the key pollution area for agriculture. Point sources: from an identifiable outlet such as a pipe. Non-point sources: not from a pipe, but off the land--from a watershed Clean Water Act of 1972 identified national goals. Goals are in terms of max. amounts of certain contaminants ( e.g., nitrates, phosphates), and effluents. (Effluents are wastes in flowing water.) See: http://www.in.gov/idem/water/index.html And for the sites to many laws relating to water management: http://www.in.gov/dnr/water/statute_rules/index.html

    26. Water Pollution Enforcement Water quality standards and effluent limits are handled with the National Pollutant Discharge Elimination System (NPDES) But for exemptions, all persons discharging pollutants from a point source are required to obtain an NPDES permit. That is the law! And, in response to a law suit brought by “Save the Valley” U.S. District Judge Barker, ruled in Sept. ’02 Indiana DEM has “four months” to begin keeping hog waste out of Indiana rivers and streams or else they would loose authority over “the pollutant!”

    27. Water Pollution Enforcement Specifically, she ruled, IDEM had 4 months to bring its NPDES program into compliance the Clean Water Act, or EPA would withdraw approval of IDEM’s program. To get a permit to discharge into the waters, the party must show that they will not adversely impact the water quality of a particular stream, river or lake. Originally the regional offices of the EPA handled the permits, generally, states do now. See Table 9.1 for situations in ag that require NPDES permits, but changes are coming.

    28. NPDES -- Overview Water pollution degrades surface waters making them unsafe for drinking, fishing, swimming, and other activities. As authorized by the Clean Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Point sources are discrete conveyances such as pipes or man-made ditches. Individual homes that are connected to a municipal system, use a septic system, or do not have a surface discharge do not need an NPDES permit; however, industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters. In most cases, the NPDES permit program is administered by authorized states. Since its introduction in 1972, the NPDES permit program is responsible for significant improvements to our Nation's water quality. States Authorized: http://cfpub.epa.gov/npdes/statestats.cfm

    29. Livestock Waste Feedlots may be designed to minimize or prevent pollution. States have developed standards for feedlots and animal waste handling, and have or will tighten these standards to satisfy stiffer CAFO rules. Indiana CAFO rules are at: http://www.in.gov/idem/land/cfo/

    30. Livestock Waste States have set up environmental protection laws and agencies to enforce them IDEM in Indiana Such agencies administer not only state laws, but assume responsibility for enforcing federal laws.

    31. http://www.in.gov/idem/land/cfo/ At this site you will find: Links Definitions CAFO Regulations And more Also go to: http://cfpub.epa.gov/npdes/

    32. National Pollutant Discharge Elimination System (NPDES) A national program under Section 402 of the Clean Water Act for regulation of discharges of pollutants from point sources to waters of the United States. Discharges are illegal unless authorized by an NPDES permit.

    33. Water pollution degrades surface waters making them unsafe for drinking, … As authorized by the Clean Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Point sources are discrete conveyances such as pipes or man-made ditches. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters. In most cases, the NPDES permit program is administered by authorized states. Is a field for manure disposal a “point source?”

    34. IDEM’s Responsibilities IDEM is responsible for reviewing confined feeding operation approval applications. An application is needed for new confined feeding operations, And for any expansion of existing confined feeding operations, And for existing confined feeding operations never before approved.

    35. History of Regulations for CAFOs 1971 Confined Feeding Control Law Created Indiana General Assembly 1997 Confined Feeding Control Law Revised Indiana General Assembly 1997 IDEM starts CAFO Rule Writing Establishment of CFO Workgroup March 2002 – Indiana CAFO Rule Effective

    37. What is a CFO? Statutory Requirements – IC 13-11-2-40, 327 IAC 16-2-6 Pursuant to Confined Feeding Control Law confined feeding operation defined as: Confined Feeding of at least: 300 Cattle - OR 600 Swine - OR 600 Sheep - OR 30,000 Fowl (including Ducks) Combinations of species are not required Operation that causes a water quality violation

    38. Rule Sets Standards for CAFOs Performance Standards Design Standards Operational Standards Land Application Requirements Closure Requirements

    39. Performance Standards - All Operations Be managed to avoid a discharge into waters of the state Design, construct, and maintain waste management systems to minimize leaks and seepage and prevent spills Conduct operations to minimize non-point source pollution to waters of the state

    40. EPA v. Loveless, Ill. Pollution Control Board, ’76 Action? Jaret Contamination of streams Issue? Has Lovelace complied sufficiently to end runoff violations? What penalty if any should be given to Loveless?

    41. EPA Facts: Cattle feedlot is alleged to have contaminated two different streams In total, the runoff had violated several sections of the Illinois EPA with dissolved materials Opinion: Loveless argued he had a complete defense since he was issued an NPDES permit after the date of the alleged offenses.

    42. EPA Amanda Loveless has essentially “cleaned up his act.” No penalty under the circumstances. Loveless ordered to “cease all violations.” Rule/Law: You can’t pollute the water (and get away with it)!

    43. Pork Motel Corp Facts: when constructed the Pork Motel had approx. 40 families in a five mi. radius. after the 4,400 head facility began operation odor complaints were registered with the KD HE. There was an order in May1977 to abate the odor which was modified after a public hearing. Mar. ‘78 Pork Motel submitted an acceptable plan of operation.

    44. Pork Motel Corp. Facts: When the permit was up in ‘79 the limitations were imposed for significant nuisance odor control, and imposed a penalty of discontinuance of accepting new animals if the odor was not controlled! Complaints continued as to odor followed by an order from the KDHE to reduce animals at the facility… and demanded other specified steps aimed at odor abatement. After a hearing, a District court affirmed the order.

    45. Pork Motel Corp. Holding? Kristen An administrative agency, like KDHE, is an instrument of the legislature, And KDHE can rule only based on the statutory authority it is given. Valid rules must be within the agencies authority under the governing statute --- and appropriate, reasonable and consistent with the law.

    46. Pork Motel Corp. Holding: Pork Motel argued that the KDHE could not incorporate air pollution limits within a water pollution permit, but the Court disagreed. The water pollution permit was with a design that limited odor which was within the agencies responsibility under the law. Odor has a significant effect on health and welfare.

    47. Non-point Sources of Pollution Results from sources that diffuse and discharge pollutants to water by way of widely dispersed pathways. Usually involves large land areas Non-point source pollutants include: sediments, nutrients, minerals, pesticides, oxygen-demanding wastes, and pathogens Sediments carried by soil erosion is the greatest polluter of the waters.

    48. Non-point Sources of Pollution Nutrient elements such as phosphorus and nitrogen enter waters in: municipal discharges, urban storm runoff, and combined storm and sanitary sewer overflows. And, from lands managed for intensive livestock and crop production. Phosphorus and nitrogen lead to lake eutrophication and the pollution of ground water drinking supplies.

    49. Non-point Sources of Pollution Run-off from ag lands is a major contributor to nutrient levels of phosphorus and nitrogen. Pesticides are transported from soil to water in runoff and sediment. Certain pesticides in the aquatic environment are accumulated by fish and other organisms, causing damages to wildlife high in the food chain (see Rachel Carson’s Silent Spring, 1962). Non-point runoff of organic materials has essentially the same effects as point sources due to industry, municipalities and feedlots.

    50. Section 208 of the Clean Water Act Deals with area-wide management of waste treatment As interpreted by the U.S. EPA, Sec. 208 only applied to complex water pollution problems arising from municipalities, and industry. CWA Litigation in 1977established this law in all areas, and that states were responsible for the planning! Sec. 208 process was used in an attempt to identify all agricultural sources of non-point pollution.

    51. Section 208(j), the Culver Amendment, 1977 Authorized a program of assistance to landowners and operations for installing best management practices for - pollution control. With appropriations via the Sec of Ag to assist landowners. SCS could enter into 5 to 10 year contracts with landowners and tenants to provide cost sharing and technical assistance for BMPs Federal grants were made to states with approved Section 208 plans.

    52. Section 319, CWA, 1987 Another program aimed at non-point source pollution and provides funds to states for development and implementation of effective plans. Required an assessment report to identify water that could not meet or maintain quality standards without additional non-point source pollution control. EPA had to approve before funding. Agriculture must prepare for more stringent water quality management!

    53. Wetlands Policy Wetlands are important to water quality! Wetlands are good for erosion control, and are habitat for fish and wildlife. Wetlands filter sediment and contaminants from runoff and provide ground water recharge. The policy for protection of wetlands was strengthened in ’85 Farm Bill leading to controversy inside and outside of ag on property rights! In particular, what is a wetland and who is to decide?

    54. Wetlands Laws Sec. 404 of CWA said a permit from the Army Corp (COE) was required to discharge dredged and fill material into navigable waters. This Sec. 404 authority has been broadly construed by the COE and a major impediment to development and drainage activity! Drainage ditch reconstruction; new drainage activity---modification of land for changed use. Sec. 404 exempted “normal farming” … activities

    55. Wetlands Laws However, Food Security Act of 1985 brought farm and ranch land into the press for maintaining wetlands under the “swamp buster” provisions. Violations of wetland protection rules may bring loss of price and income support benefits for the “guilty,” forever or penalties of $750 to $10,000! How to define “wetlands” became a major issue, and whose definition! “NRCS” staff, and converted wetland “Sodbuster” provisions in FSA’85

    56. U.S. v. Akers U.S. Ct. of Appeals, 9th Cir. ’86 Action? Brett Wetlands protection Issue? Can Akers convert wetlands? Is Akers with in an exemption in the Clean Water Act and Regulations? Facts: Jan. ’84--Akers bought 9,600 acres of which 2,889 acres were wetlands—”Big Swamp” in California. Big Swamp was an important wildlife habitat. Ash Creek went through Big Swamp and into Pit River. The Army Corp (COE) learned of Akers’ plan to convert the wetlands to farmland by grading, leveling …

    57. U.S. v. Akers The COE determined that about 1/3 of Akers’ project was under their jurisdiction, and that a Section 404 permit was required. May 4, ’84--Akers sued the U.S. Government for declaratory and injunctive relief. July 16, ‘84--Akers dismissed his suit after his motion for preliminary injunction was denied, and proceeded with his earthmoving activity. Early Aug. ’84—Corp. issued a “cease and desist” order by the time the project was finished.

    58. U.S. v. Akers Sept. ’84--COE by fly-overs established that the Akers had done substantial damage to the wetlands by diking and ditching. Oct. 3,’84--US sued Akers seeking declaratory and injunctive relief, civil penalties and restoration. Oct. 5, ’84--District Court issued a temporary restraining order (TRO) forbidding Akers from depositing fill material in waters on his property, except in certain channels with the COE permission. Oct. 25, ’84—Dist. Court granted the U.S.’s motion for a preliminary injunction.

    59. U.S. v. Akers Jan. 14, ’85—Oral arguments by “interested” parties on both sides of the issue. They probably filed amicus curiae -- "friend of the court" briefs. Jan. 15, ’85—District Court issued conclusions of law confirming the earlier oral preliminary injunction—prohibiting Akers from depositing dredge and fill into the waters, channels and wetlands delineated by the COE without first having a COE “Sec. 404 permit” …

    60. U.S. v. Akers ? Tom Law: Clean Water Act, Sec. 404 requires a permit from the Army Corp. (COE) when dredge or fill is placed in “waters of the United States,” and, “waters” includes wetlands. Holding: Akers has to comply with the Clean Water Act. Upland farming has not taken place on the subject land on a regular basis, therefore Akers can not rely on an “exemption” in the law.

    61. U.S. v. Akers By Akers’ admission his activities require substantial hydrological alteration to Big Swamp, and run afoul of Clear Water regulations. The “minor drainage” exception does not include altering drainage associated with the immediate or gradual conversion of a wet-land to a non-wetland. Preliminary injunction affirmed. Rule: A COE permit may be required before altering “wetlands.”

    62. Soil and Water Conservation 1936 Standard State Soil Conservation District Law lead to soil & water conservation districts in all 50 states. See history SCDs at: http://www.nrcs.usda.gov/about/history/articles/conservationdistricts.html SWC Districts set-up programs with land owners to adopt subsidized soil and water conservation plans, Generally, state laws had no penalties for failure to comply. Iowa was an exception! Note, since the 1985 Farm Bill some farms have a “conservation plan” requirement in order to avoid losing entitlement to govern’t program payments!

    63. Woodbury County SC Dist v. Ortner, S. Ct. of Iowa ’79 Action? Daniel Compliance with local soil conservation law Issue? Is this soil conservation law an unconstitutional taking from the farmland owners or a regulation under the police power of the state? Facts: Ortner and another were in violation of soil conservation law. SCD issued an order to comply. Ortner failed to act in time.

    64. Woodbury County SC District Law? Jordan Conservation law is constitutional! Holding? Reversed the trial courts holding for the def., and decided the policy for soil conservation was valid. Conservation law is constitutional. The law’s provisions are reasonably related to carrying out an announced legislative purpose of soil conservation. For the protection of leading industry--a proper exercise of police power.

    65. On the History of State Soil Conservation (SCD). “With the assistance of Philip M. Glick, a lawyer in the U. S. Department of Agriculture, Wilson's ideas were embodied in the "Standard State Soil Conservation District Law.“ The conservation district, as outlined in the standard law, was a new device in American federalism. It was classified as a "special district" because it had limited purposes and was not a local unit of general government as is the county or city. A few of the powers of the district:: it could conduct surveys and research, disseminate information, conduct demonstrations, carry out prevention and control measures, acquire land and property, sue and be sued, and promulgate land-use regulations.” http://www.nrcs.usda.gov/about/history/articles/conservationdistricts.html

    66. History of local soil conservation dist. Organization of districts proceeded after state legislatures passed a law based on the "standard law. If the local people then voted for the district in a referendum, they elected directors and supervisors of the district and districts signed an agreement with USDA. The working relationship that has developed over the years is for the districts to sign agreements with individual farmers and ranchers. Then trained soil conservationists from the Soil Conservation Service field offices worked individually with them on conservation problems.

    67. SCS to the NRCS --- The Food Security Act of 1985, more commonly called the 1985 farm bill, linked farmers' eligibility for USDA programs to conservation performance. The highly erodible lands provision, sometimes known as conservation compliance, required farmers to use conservation measures on erodible land in order to remain eligible for USDA programs such as price support payments and crop insurance. NRCS also became responsible for identifying wetlands that farmers could not alter without also losing benefits.

    68. The Birth of the NRCS The reorganization, accomplished by a USDA Secretary’s memorandum on October 20, 1994 changed the agency’s name from the Soil Conservation Service to the Natural Resources Conservation Service; ostensibly to focus on the fact the agency’s conservation mission encompassed water, air, plants, and animals in addition to soil.

    69. Development of the NRCS reorganization also moved many of the financial assistance programs to NRCS. Previously, most financial assistance programs had been located in the predecessors to the newly created Farm Service Agency--namely the Agricultural Stabilization and Conservation Service, Production and Marketing Administration, Agricultural Adjustment Administration. The overall trend in the 1990s was to link technical assistance for conservation more closely with the financial assistance for conservation and to concentrate on critical problems.

    70. NRCS--modern conservation measures. The Environmental Quality Incentives Program, authorized in the 1996 farm bill, brought several financial assistance programs under one umbrella Also, Congress, in the 2002 farm bill, created the Conservation Security Program which was designed to reward land owners doing good conversion work; motivate other farms to adopt conservation measures; and to provide incentives for higher levels of conservation performance.

    71. During the 1990s water quality increasingly occupied the agency. Reducing the off-site impacts of chemicals used in agricultural production had been on the agency’s agenda since the initiation of the Rural Clean Water program in the late 1970s. During the 1990s production of animals for meat and milk became increasingly concentrated in large operations. NRCS staff worked with producers to write comprehensive nutrient management plans so as to maintain and improve water quality.

    72. NRCS philosophy Assess the resources on the land, the conservation problems and opportunities. Draw on various sciences and disciplines and integrate all their contributions into a plan for the whole property. Work closely with land users so that the plans for conservation mesh with their objectives. Through implementing conservation on individual projects, contribute to the overall quality of life in the watershed or region.

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