Volume 3 Number 3
USDA/EPA Release Draft on Unified National Strategy for Animal Feeding Operations
CAFO Training in December
CSREES
Develops New National Initiative in Animal Waste Management
AWARE Team
Welcomes New Extension Specialists
AWARE Team
Sponsors Session at Georgia Water Resources Conference
SARE PDP and SSWAG Meetings
Winter School Training
GLCC Conference
North
Carolina Hog Farms Do Well on Environmental Inspections
Positions Available
USDA/EPA
Release Draft on Unified National Strategy for Animal Feeding Operations
In September, the USDA and the EPA released their draft National Strategy
for Animal Feeding Operations. This 35 page plan outlines how both
agencies intend to work together to address problems created by Animal
Feeding Operations (AFOs). The plan defines AFOs as agricultural
enterprises where animals are kept and raised in confinement – feed is
brought to animals rather than grazing. It estimates that there are
450,000 AFOs in U.S. and that 85% of these have fewer than 250 Animal units
(AU). It also states that in 1992 there were 6,600 AFOs with more
than 1,000 AU – (calls these CAFOs) and that by today's estimates there
are 10,000 CAFOs in the United States. This rapid growth in large
operations, coupled with EPA figures on the water quality impairments that
they cause are the primary reasons the strategy was developed.
The Unified National Strategy reflects several guiding principles:
1. Minimize water quality and public health impacts from AFOs.
2. Focus on AFOs that represent the greatest risks to the environment
and public health.
3. Ensure that measures to protect the
environment and public health complement the long-term sustainability
of livestock production in the United States.
4. Establish a national goal and environmental
performance expectation for all AFOs.
5. Build on the strengths of USDA, EPA,
State and Tribal agencies, and other partners and make appropriate
use of diverse tools including voluntary, regulatory, and incentive-based
approaches.
6. Foster public confidence that AFOs are
meeting their performance expectations and that USDA, EPA, local governments,
States, and Tribes are ensuring the protection of water quality and public
health.
7. Coordinate activities among the USDA, EPA, and related agencies.
8. Focus technical and financial
assistance to support AFOs in meeting the national performance expectation
established in this Strategy.
USDA and EPA's goal is for AFO owners and operators to take actions
to minimize water pollution from confinement facilities and land application
of manure. To accomplish this goal, this Strategy establishes a national
performance expectation that all AFOs should develop and implement
technically sound and economically feasible Comprehensive Nutrient Management
Plans (CNMPs) to minimize impacts on water quality and public health.
In general terms, a CNMP identifies actions or priorities that will be
followed to meet clearly defined nutrient management goals at an agricultural
operation. CNMPs should address, at a minimum, feed management, manure
handling and storage, land application of manure, land management, record
keeping, and management of other utilization options. While nutrients are
often the major pollutants of concern, the plan should address risks from
other pollutants, such as pathogens, to minimize quality and public health
impacts from AFOs. CNMPs should include a schedule to implement the management
practices identified. Development and implementation of CNMPs is the ultimate
responsibility f the AFO operator, with assistance as needed from certified
industry staff, government agency specialists, private consultants and
other qualified vendors.
The Strategy suggests both voluntary and regulatory programs to insure
that CNMP's are developed. Voluntary measures include development of comprehensive
nutrient management plans (CNMP) for all AFOs. USDA and EPA are proposing
in this Strategy incentives to further the voluntary development and implementation
of CNMPs. Regulatory measures focus on CAFOs first (>1,000 AU or >300 AU
and discharging pollutants). The Strategy also states that all poultry
operations with stacked manure exposed to rainfall and >1,000 AU will be
classified as a CAFO. Beginning in 1999, the plan will require States
to issue three types of permits; general permits for existing CAFOs (>1,000
AU) and AFOs (300-999 AU) with unacceptable conditions, individual permits
for exceptionally large existing operations, operations with historical
compliance problems, or operations with significant environmental concern,
and watershed general permits for operations in impaired or sensitive watersheds
– would apply to AFOs only if they are individually designated as "significant
contributors". In 2005, the strategy will incorporate new requirements
developed by EPA including primarily P-based nutrient management plans
The strategy also proposes seven key strategic issues and methods for
addressing them. Several action items are included. Among these
are:
ÀÀ Facilitate and encourage participation of private
sector consultants and technical advisors through certification, training,
and other activities to ensure private sector sources of assistance can
be effectively utilized by AFO owners and operators to develop and implement
CNMPs..
ÀÀ Increase funding within the USDA NRCS Technical
Assistance (CTA) Program and Cooperative Extension System to increase technically
qualified field staff, train existing Federal and nonfederal staff, and
provide enhanced technical support.
ÀÀ Develop and revise National practice standards.
ÀÀ Continue and increase the USDA-EPA collaboration
on AFO issues particularly at the field level, to better target and leverage
available resources from all applicable programs to assist AFOs in addressing
water quality issues.
ÀÀ Target Federal financial assistance to existing
AFOs who need to develop or revise CNMPs and work to obtain additional
Federal support through existing programs such as EQIP.
ÀÀ USDA and EPA will develop a coordinated AFO research
plan by October 1999. This plan will establish priorities for future research.
ÀÀ USDA and EPA will develop a coordinated AFO technology
transfer plan by October 1999,
ÀÀ USDA and EPA will work with industry, in particular
integrators, to identify opportunities for greater industry involvement
in pollution prevention.
ÀÀ USDA and EPA estimate by January 2000 a baseline
of nutrient loads watersheds with potential excess nutrients from animal
waste using data from fertilizer sales, USGS/EPA nutrient loading analysis,
Census of Agriculture, permit limits, and other estimates.
In all there are over 40 different action items that are just too numerous
to list here. I would encourage those interested to get a copy of
the strategy and review it on your own. We have linked the Strategy
to our webpage (http://www.engr.uga.edu/service/extension/aware/) or copies are available
by phoning the EPA's Water Resource Center at 202-260-7786.
Several organizations and groups have already made public comment on
the strategy. These range from the Farm Bureau, which questions its
scientific basis and the data used to create it, to public interest groups
that don't think it goes far enough. The EPA and USDA are currently
conducting "listening sessions" in which public comments can be presented.
The closest one to Georgia will be held in Chattanooga, TN on December
9. Contact James Ford of the NRCS at 615-736-5471 for the details.
Written comments on the draft will also be accepted until January 19.
I encourage everyone to make their opinions known as now is the time that
they will have an impact. Earlier this year the USDA released a draft
standard for organic certification and got so many negative responses that
the policy was substantially revised so your input can make a difference!
Committee Recommends New Animal Waste Regulations to Georgia EPD
In our last newsletter we told you about a stakeholders group that
the Georgia Environmental Protection Division had established to provide
them with information sufficient to guide them in drafting new regulations
for Georgia Animal Feeding Operations. This stakeholders group assembled
by EPD in June 1998 included livestock producers, environmental activist
organizations, academics, and State and Federal agencies. The group
had a total of about 90 members including 9 members from UGA (6 from AWARE
team). It was asked by EPD to recommend new regulations for animal
feeding operations in Georgia that considered several size categories that
would require different regulations. It should be noted that if the
stakeholders refused to participate, the EPD would develop new regulations
on their own.
Four subcommittees were formed of 14-15 members each with representation from each group including agricultural producers, agricultural interest groups, academia and consultants, State regulatory agencies and technical assistance providers, and Federal agencies. The four subcommittees addressed the following areas.
ÀHÀ size classification and regulatory system
ÀHÀ location restrictions, odors, and setbacks
ÀHÀ nutrient management and monitoring
ÀHÀ design and administration
Each subcommittee was asked to find consensus for new regulations or give different sides where there was disagreement. The full committee met on 5 occasions and subcommittees met about 6-8 times each. Many of these meetings lasted most of the day and the dialog within them was often heated. The results from each of the subcommittees is given below.
The size classification and regulatory system subcommittee was asked to determine regulatory levels and how the regulations would be administered. Four-tier classification much like that proposed in the National Strategy was proposed.
I 100-300 AU
II 300-1,000 AU
II 1,000-2,000 AU
IV 2,000 AU
There was considerable disagreement about what would be required at
each level. Public interest groups wanted group I to be required to "register"
with the EPD, group II to be required to obtain a general permit, and have
a nutrient management plan and a trained operator, group III to obtain
an individual permit with site specific requirements, and group IV to have
public meetings, no lagoons, additional buffer requirements, and additional
compliance assurance and enforcement measures. The agricultural groups
recognized only groups II (require nutrient management plan and a trained
operator but no permit) and III (require individual permit). There
was also considerable disagreement over how to include dry manure poultry
operations. Public interests groups want the groups to be
I (>10,000 birds), II (20,000-80,000 birds), III (80,000-160,000 birds),
and IV (>160,000 birds). The agricultural groups only agreed to include
dry manure poultry if > 455,000 birds (1,000 AU) were housed on one operation.
Both groups agreed that these regulations should be phased in over a 3
(environmentalists) or 5 (producers) year period and that the EPD should
grandfather existing buildings.
The location restrictions, odors, and setbacks subcommittee explored
a wide variety of issues. They agreed that a 100 ft vegetated buffer
should be required between manure application fields and streams/wetlands
for wet or dry manure systems with greater than 300 AU. They could
not agree on the details of this buffer. They agreed that lagoons
should be prohibited within 100-year flood plain and that setbacks for
lagoons and confinement buildings for odor control should be required under
these conditions:
ÀÀ for wet manure operations >1,000 AU must have setback
distance around lagoon and confinement buildings determined specifically
for site
ÀÀ distance computed using scientific methods that
provide distances in different directions
ÀÀ consider prevailing wind direction and frequency,
land topography, number, age, and type of animals, etc.
ÀÀ could not agree if setback should be measured to
property line or residences.
The groups also agreed that there should be location restrictions that
usually included requiring the operation to meet the regulatory requirements
of the next higher size classification for groundwater recharge areas,
deep sands and wet soils, in endangered species habitat, in the 11 counties
of Coastal Management Area, and near impaired streams, and wild/scenic
rivers.
The nutrient management and monitoring subcommittee agreed that nutrient
management plans must consider the infiltration rate and water holding
capacity of the soil, feed alternatives, and an"increased focus on P".
Essentially they decided to adopt the NRCS definition of nutrient management
plans. They agreed to keep the current groundwater monitoring well requirements
for operations with more than 1,000 AU, but the public interest groups
want this lowered to 300 AU. In addition, the public interest groups wanted
soil and lagoon tests to be submitted to the EPD and include TKN, NH4,
NO3, TP, K, Cu, P, K, Ca, Mg, Zn, and Mn while the agricultural groups
wanted tests to be used for crop management and not reported to EPD
Both sides agreed that lagoon design
should meet NRCS standards but the public interest groups wanted certification
by a Professional Engineer while producers wanted certification by the
contractor. There was also considerable discussion of atmospheric
emissions of N from lagoons where one side wanted to limit emissions from
lagoons using covers and other technologies and the other thought we should
wait for more scientific evidence that a problem exists.
The design and administration subcommittee agreed that the State needed
a training and certification program for all operations with more than
300 AU. The training of these operators would be conducted by the
Extension Service which would offer training specific to size and type
of operation. There would also be some continuing education requirement
but there was general disagreement on the amount. This subcommittee also
agreed that all operations with more than 300 AU should be required to
keep on-farm records for the past 3 years that included nutrient management
plans, annual waste and soil tests, application amounts and locations,
lagoon freeboard, emergency plans, inventory numbers, and mortality.
For operation with more than 1,000 AU pollution prevention plans
would also be required. These records would be available for inspections
that the EPD would require annually for operations with more than>1,000
AU. The groups also agreed that all operations with 300 AU should
prepare a closure plan that meets NRCS standards prior to abandoning a
lagoon and that these operations must demonstrate financial responsibility
for closure through bonds, secured accounts, or some industry developed
instrument. None of the above changes are possible without funding
and this group addressed that issue as well. In general, this plan
would request 10 inspectors and four permit writers for the EPD, one specialist
and 8 district agents for the Extension service, a State cost-share program
for small existing operations, and additional funds for research on the
effects of animal operations on water quality, lagoon alternatives, &
odor control.
It is important to remember that these were only recommendations to
the EPD and that there was considerable discussion on many of these issues.
The EPD is in the process of making decisions on many of the issues and
will have draft regulations for public comment in December. We will
probably also see more legal action when the legislature convenes in January.
Once these drafts are available your input will be essential. We
will make these drafts available on our webpage (http://www.engr.uga.edu/service/extension/aware/)
so that you can download them and get them to producers or public interest
groups in your area. It is important to remember that you comments
will be more likely to have an impact if they are based in fact and they
show both the positives and the negatives. Do not hesitate to tell
them what you do like along with what you don't like.
CAFO Training in December
As the size and economic and environmental impact of animal feeding
operations continues to grow, conflicts between those who oppose and support
these operations will continue to make headlines. During the last year,
Georgia has seen these conflicts in both Taylor and Tatnall Counties where
large swine operations have attempted to locate in traditionally rural
counties. Often, individuals from both sides of the fence turn to
the University of Georgia for research based support. To address
this issue, the University and the AWARE team have developed a training
workshop to equip participants with some necessary tools for dealing with
this sensitive community issue. The workshop on Concentrated Animal Feeding
Operations: Dealing with a sensitive community issue will be held
December 16, 1998 at the New Animal Science Auditorium, just off College
Station Road and the Bypass in Athens, Georgia. The purpose of the
workshop is to better prepare University of Georgia Employees for dealing
with the controversy and conflicts surrounding large animal operations.
The cost is $10 per person which will be collected at the door and cover
your lunch. You should contact your district head (extension agents)
or Dr. Mark Risse (mrisse@bae.uga.edu) or Cathy Felton (706-542-3086) if
you plan to attend so that we can get an accurate head count for the lunch.
The program is listed below:
9:30 Registration
10:00 Problems Concerning Large Animal Operations- An Overview
10:20 Questions from an Agent that's been there, Lannie Lanier,
Jenkins CEA
10:30 The County Agents Role in Conflict Management, Gale Buchanan,
Dean CAES
10:45 The Legal and Land Use Planning Issues, Laurie Fowler, Institute
of Ecology
11:15 CAFOs: What research there is. David Radcliffe, Glen Harris,
& Mark Risse
12:00 Lunch, served on site
1:00 Facts, Values, and beliefs-impacts and public policy, Roy Carriker,
The University of Florida
1:30 Handling Conflict-What are your Resources? Gail Cowie, ICAD
1:45 A Crash Course in Conflict Management, Peggy Herman, Carl Vinson
Institute of Government
3:45 Evaluation, future activities, adjourn by 4:00
CSREES Develops New National Initiative in Animal Waste Management
ECOP and CSREES recently approved Animal Waste Management as a new national initiative. The initiative team is co-chaired by Mary Ann Rozum, CSREES and Frank Humenik, North Carolina State University. This initiative will assist livestock producers, agricultural businesses and federal, and state and local officials to maintain animal production and meet environmental standards.
In order that the national initiative team can work closely with states
and keep states informed, each state extension service will name a State
Animal Waste Initiative Contact. For more information on the Animal Waste
Initiative, see
http://www.reeusda.gov/nre/water/ANWASTE/
This Web page has the complete initiative plan as well as names and
addresses of initiative team members.
AWARE Team Welcomes New Extension Specialists
The AWARE team would like to welcome two new employees that may be able to help Georgia's producers in dealing with animal waste management issues. Ms. Julia Gaskin was recently hired as an educational program specialist in the area of land application of by-products. She will be developing a statewide extension and applied research program focusing on the utilization and environmental impacts of the land application of municipal, industrial, and agricultural by-products. Julia is will be located in the Biological and Agricultural Engineering Department in Athens. She has a background that includes a MS in Forest soils and hydrology and ten years of experience working with Nutter, \Overcash, and Associates, a firm that specialized in forest land application programs. Mr. Tim Schell is our new Extension swine specialist in Tifton. Tim's background includes a BS from Auburn and MS and PhD degrees from Virginia Tech in animal science. Before coming to Georgia, Tim worked for four years with Continental Grain in Chicago doing nutritional and marketing research. Tim will be conducting research and extension in the areas of swine waste management and nutrition. Please give these new specialist a call or e-mail to welcome them to our group.
AWARE Team Sponsors Session at Georgia Water Resources Conference
The AWARE team will be sponsoring at least one session on animal waste
management at the 1999 Georgia Water Resources Conference. The sixth
biennial conference will be held on March 29-31, 1999, at the University
of Georgia. This is a forum for the discussion of current water policies,
research, studies, and water management in Georgia. It provides:
(1) a forum for exchange of ideas and information for water resources professionals,
(2) an update on the current water resources situation in Georgia, and
(3) transfer of data, technology and management information.
At least six members of the AWARE team have submitted abstracts for
the conference so it should contain some interesting research and extension
updates. Early registration for conference participants is approximately
$110 including two lunches and proceedings. Students receive a reduced
rate. For information about conference, call the Georgia Center for Continuing
Education at 706-542-6364 or contact Kathryn Hatcher by E-mail (khatcher@ecology.uga.edu).
The SARE-PDP Meeting will be held January 14-15, 1999 at the Clarion
Resort Buccaneer Hotel on Jekyll Island before the SSAWG Annual Conference.
The SARE Professional Development Program seeks to train extension agents
in the area of sustainable agriculture. The focus of this years workshop
is "Putting Sustainable Agriculture Principles into Practice". Sessions
will include applying sustainable principles to traditional agriculture,
value-added marketing approaches, successful interaction of 1862 and 1890
landgrant institutions, NRCS sustainable agriculture programs, applied
sustainability on the farm, and successful PDP projects which address current
issues on the farm. The keynote presentation, Global Agricultural
Sustainability, will be delivered by Jules Pretty, Director of the Centre
for Environment and Society at the University of Essex, UK. The Georgia
Sustainable agriculture program has limited funding for scholarships for
extension agents and other trainers in Georgia (Contact Mark Risse for
more information). For more information or to register for their
entire 2 day program, contact Rosanne Minarovic, North Carolina State University,
at
(919) 515-3252 or rminarov@unity.ncsu.edu.
The 8th Annual Southern Sustainable Agriculture Working Group (SAWG)
Conference and Trade Show will be held immediately following the SARE PDP
program. The theme this year is "Revitalizing Family Farms."
This conference is open to everyone, and we hope you'll take this opportunity
to network with hundreds of farmers, farm advocates, agricultural service
providers, and trade show vendors from the sustainable agriculture community.
This conference will target farmers as opposed to trainers and include
presentations on issues such as Adding Value to Your Products,
Revitalizing the Family Farm, Pasture Management with Forage Animals,
Overview of Soil Management, Steel in the Field: A Guide to Weed Control
Tools, A Systems Approach to Sustainable Pest Management, and Integrating
Livestock on the Farm. For more information about the conference
contact Chris Campany at (225) 336-9532 or via e-mail at BREADA@aol.com.
Winter School Training
The AWARE team will offer a technical training session on animal waste
management at Extension Winter School on Thursday, January 21 from 1:30
to 5:30 at Rock Eagle in Eatonton. This training will cover some
of the basics on nutrient management planning, provide an update on national
and state regulations, and include discussions on odor control, water quality,
and environmental concerns. We will also use this as an opportunity
to get feedback from the agents on the types of training that they will
need in the future.
GLCC Conference
The Georgia Grazing Lands Conservation Coalition is sponsoring a one-day
Statewide Forage Conference on Tuesday, December 15 at the Georgia Center
for Continuing Education, Athens. The Georgia Grazing Lands Conservation
Coalition is a committee of producer group representatives with an interest
in addressing grazing lands issues. Speakers making presentations
at the conference include Bob Drake, Chairman of the Grazing Lands Conservation
Initiative National Steering Committee; Warren Thompson, ABI Alfalfa; Pat
Bagley, North Mississippi Research and Education Center; R.L. Dalrymple,
Noble Foundation; and Joe Burns, University of Tennessee, retired.
Breakout sessions will be conducted by Carl Hoveland, Mark McCann, and
Julia McCann, UGA; Don Ball, Auburn University; Gary Lacefield, University
of Kentucky; Will Getz, Ft. Valley State University; Allen Verner, commercial
hay producer; and Jean Bertrand, Clemson University. Forage
and animal production practices for beef, dairy, goats, sheep and horses
will be discussed. If you are interested in attending the conference
please contact the Georgia Center at (706) 542-2134 or (800) 884-1381.
You can register by email at Register@gactr.uga.edu.
North
Carolina Hog Farms Do Well on Environmental Inspections
During 1997 and the first three months of 1998, North Carolina's much
maligned hog farms have performed well on inspections performed by the
N.C. Department of Environment and Natural Resources. According to information
obtained from DENR, Division of Water Quality (DWQ) and Division of Soil
and Water (DSWC) personnel performed 5,839 inspections and performance
reviews on over 2,500 hog farms during 1997.
According to the inspectors reports, less than 1/3 of 1% (19 farms)
of the hog farms had discharges that reached the surface waters of the
state. This compares with 6.53% for cattle operations and 1.31% on poultry
farms. During the same time period (1997) municipalities reported 1,255
illegal spills of some 12.6 million gallons of mostly untreated municipal
waste into the waters of the state. In addition, the inspectors found that
on less than 1% of the farms were there any adverse impacts to the waters
of the state other than from a discharge; that on only 2.43% of the farms
was there evidence of past discharge from any part of the operation; that
only 1.64% of the farms showed physical evidence of over application of
swine manure to the land.
During the first quarter of 1998, hog farms continued to do well even
though this three month period was one of the wettest on record. According
to DENR inspections reports 18 swine farms had discharges that reached
the surface waters of the state and 87 farms showed evidence of over application
of swine manure to their land. Even though some individuals feel that the
waste systems that farmers use is inferior to that used by many municipal
systems, the supposedly superior municipal systems reported 971 illegal
spills of almost 74 million gallons of mostly untreated municipal sewage
to the waters of North Carolina during the same 3 month period. Not included
in this number is the recent massive 12 million gallon spill from a Greensboro
waste treatment plant or the 14 thousand gallon per day spill in Rich Square
that may have taken place every day for over 20 years. While the data clearly
shows that hog farms have performed well, farmers continue to invest in
research and new technology development to help them do an even better
job in the future in managing the organic byproducts produced by their
animal operations. (Source: North Carolina Pork Council, Inc. Raleigh,
NC, July 2)
The Clean Water Network and the Natural Resources Defense Council are seeking an energetic, well-organized person to coordinate a national campaign to advocate for stronger federal policies to stop pollution from animal factories. The coordinator will work 50% for NRDC and 50% for the Clean Water Network's Feedlot Work Group. Responsibilities include planning and implementing a two-year campaign to influence the development of federal policy, be a primary contact for grassroots members, and develop campaign publicity ideas. Start date ASAP. Salary is mid-thirties, depending on experience. Generous benefits package. The position will be located at NRDC/CWN's offices in Washington, DC. To apply email, fax or mail a letter of interest, resume, and short writing sample to Clean Water Network Coordinator, 1200 New York Avenue, NW, Suite 400, Washington, DC 20005, email: knemsick@nrdc.org, fax: (202) 289-1060.
The University of Nebraska publishes a newsletter titled "Manure Matters." Farmers and farm advisors and encouraged to sign up for the resource. Subscribe by sending an email message to: listserv@unl.edu and in the message field, type subscribe manurematters. Past newsletters may be reviewed by visiting the following web site: http://ianrwww.unl.edu/manure/
"Nutrient Management: More Than an On-Farm Priority." Free. This
8-page bulletin, produced by the Northeast Region SARE Program, reviews
characteristics of nutrient flows in agriculture, explores opportunities
forenhanced nutrient cycling through sustainable farming methods,
and examines how social policies and economic factors influence the
nutient management agenda. To receive the
bulletin, send your name, address, and
quantity to email: nesare@zoo.uvm.edu.
Events
December 9, AFO Listening Session, Chattanooga, TN.
Contact: James Ford (615)-736-5471.
December 15, Georgia Grazing Lands
Coalition Forage Conference, Athens, GA.
Contact the Georgia Center at (706) 542-2134
December 16, UGA CAFO Training Workshop, Athens, GA.
Contact: Mark Risse, (706) 542-9067.
January 14-17, SARE PDP/SSWA
Sustainable Agriculture Meetings, Jekyll Island, GA.
Contact: Mark Risse, 706-542-9067.
January 20-22, Extension Winter School, Rock Eagle.
January 27-28, Animal Waste Management
Symposium, Raleigh, NC.
Contact: Marie Cummings, 919-515-2626.
March 29-31, 1999 Georgia Water Resources
Conference, Athens, GA.
Contact: the Georgia Center for Continuing Education at 706-542-6364.
April 18-22, Southern Region Extension
Water Quality Conference, Raleigh, NC.
Contact: Bill Segars at 706-542-9072.
Co-editors: Glen Harris
Extension Agronomist
Mark Risse
Extension Ag Engineer
cc: Dr. Gale Buchanan
Dr. William Lambert
Dr.Bob Isaac
District Directors