There’s a phone call that poultry lenders hope to avoid. It goes something like this: the closing is scheduled, the loan package is built, the integrator contract is in hand, and everything has been moving toward a close. Then someone checks the environmental permits.
“We cannot close an FSA guaranteed loan without a current operating permit or certified nutrient management plan. If they are expired, it can push a closing out as much as several months.”
That’s Michael Barnes, one of First Financial Bank’s poultry lenders, on one of the most overlooked issues in the entire poultry growing lifecycle. It’s also an easy one to avoid if growers know what to keep an eye on!
Most growers aren’t tracking renewal timelines.
Michael states: “These permits are good for as many as 5 years, but may vary from state to state, so it’s not on their mind. Very few of them start the process before the permit expires.”
It’s a long enough window that growers can finish one renewal cycle, file the paperwork, and forget about it until the next one is already on top of them. Unlike monthly bills or annual insurance renewals, environmental permits don’t generate the same regular reminders. They sit quietly until expiration is months, weeks, or days away.
By then, it’s often too late to handle the renewal without disrupting something else, especially financing.
The renewal process may be complicated.
“Both the nutrient management plan and the operating permitting processes are complicated, and the time to renew can be lengthy.”
For context, poultry growers generally hold two key environmental permits. A Comprehensive Nutrient Management Plan (CNMP), developed in coordination with the USDA’s Natural Resources Conservation Service (NRCS) or an NRCS approved technical service provider, addresses how nutrients from poultry operations are managed on the land. The state-level Department of Environmental Quality (DEQ) permit governs water, air, and waste discharge compliance for the operation.
Neither one is paperwork you fill out over a weekend. Both involve coordination with agencies or private parties, documentation gathering, site reviews (in some cases), and processing time that varies depending on staffing and workload at the agency level. The further out a grower starts, the smoother the process. The later they start, the more likely they are to run into delays they can’t control.
Where compliance shows up in your financing
For poultry growers planning a financing transaction, permit status isn’t a side issue. It’s a hard requirement.
“We cannot close an FSA guaranteed loan without a current operating permit or nutrient plan.”
That’s not an FFB policy; it’s a federal requirement on FSA-backed loans, and similar compliance documentation requirements show up in other lending contexts as well. From a lender’s perspective, the math is simple: if the permits and plans aren’t current, the deal doesn’t close.
Michael’s point about timing matters. “If they are expired, it can push a closing out as much as several months.”
Several months are not a rounding error. A poultry grower planning to refinance, expand their operation, or acquire a new farm has usually built that transaction around a specific timeline. Integrator commitments, contractor schedules, construction windows, and bird placements all run on calendars that don’t bend (easily). It’s a problem that’s frustrating precisely because it’s so preventable.
Where do you stand?
If you’re a poultry grower and you’re not sure where your current permits stand, the good news is that finding out is straightforward.
“In most states, they are required to keep copies of these permits on hand. They are dated.” The permits should be physically on hand at the operation, and they’ll clearly show their issuance and expiration dates.
If the copies are missing/ unavailable, both agencies maintain records you can access:
- For the CNMP, please contact the NRCS office or NRCS approved technical service provider that handles your farm. They can confirm the status of your plan and what’s needed for renewal.
- For the DEQ permit, the state DEQ tracks all existing permits, including expiration dates.
One state-specific note worth mentioning: in some states, DEQ permits operate on a shared expiration cycle, meaning every permit in the state expires on the same date each year. If that’s how your state structures it, you’ll want to know which year is the renewal year for everyone, since agencies get particularly backed up when the renewal volume hits all at once.
The cost question
Here’s a piece of good news that not enough growers know about.
“If using the state, there are currently no costs other than their time.”
The renewal itself doesn’t carry a direct filing fee in most circumstances. The cost is in the time required to compile documentation, work with the agency, and complete the process.
The landscape is shifting – with recent reductions in agency staffing at USDA, processing times have stretched, and some states have responded by approving third-party contractors who can assist growers with the paperwork and processing.
“The state recently approved the use of third-party contractors to assist with the processing of these permits if the farmer needs help. This is in part due to the loss of staff at the USDA due to early retirement offerings. If they so choose, there is a fee charged by the third-party contractor. This is a new service, and we haven’t seen final estimates for the fee.”
For growers who are short on time or want professional help managing the renewal, that third-party option is worth knowing about. The cost will vary, and as Michael notes, the pricing on the new service is still settling in.
But the broader point: the dollar cost of renewal is low. The cost of not renewing and pushing a closing back several months as a result is significantly higher.
