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USDA and EPA were mandated to determine the cost to the livestock industry of implementing Comprehensive Nutrient Management Plans. The USDA chose to estimate a national cost with a strategy that involved the use of the 1997 Census of Agriculture, three National Animal Health Management System Surveys for dairy, swine, and layers, and the Agricultural Resource Management Survey for swine.

One of the major tasks in the USDA effort was the grouping of livestock into 25 representative farms for the fattened beef, dairy, veal, confined heifer, broiler, layer, pullet, and turkey livestock sectors. A USDA team looked at similarities in handling manure as the basis for the representative farm selection. The representative farms were then used to identify 121 model farms, where a model farm was a representative farm of a given size at a specific location that adds a regional perspective for costs.

All total there were 151,233 livestock operations with more than 35 animal units divided among the 121 model farms. The model farms were the basis for identifying components of a CNMP and associated costs.