AOPA Concern #6: Winter spreading

Winter application is still permitted

Research indicates that winter spreading poses significant risk for surface water contamination.

NRCB discretion

A provision in the regulations gives the NRCB the "discretion" to allow CFO operators to spread manure on frozen or snow covered soils if manure storage is inadequate.

Municipalities participation disallowed

Municipalities with water quality concerns are not allowed to participate in the approval process beyond their CFO guidelines within their Municipal Development Plans (Manure is deemed a technical matter under the 2004 AOPA amendments)