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Air Regulations in California--the good, the bad and the ugly Deanne Meyer email@example.com Department of Animal Science University of California, Davis Attention to the increased impact of animal facilities to atmospheric conditions has already caught the attention of local and State regulatory agencies. California is located in US EPA Region 9. The California Air Resources Board (CARB) oversees implementation of the Clean Air Act and California Air Quality Regulations. There are 15 independent Air Management Districts (AMD) that provide more local restrictions, enforcement actions, etc. Local AMD are responsible for submitting a State Implementation Plan (SIP) when Ambient Air Quality Standards are not met. The Good: As with many things in life, the good old days WERE. Attention to ammonia emissions has been a key focus in one or more parts of California since the mid 1980s. The Bad Citizen lawsuits began the need for the State to develop a SIPs to address air quality in the South Coast Air Quality Management District (SCAQMD) and the Sacramento Metropolitan Air District. The SCAQMD is obligated to reduce Particulate Matter (PM) and Volatile Organic Compounds. The major contributor to PM during much of the year is particulate nitrate; hence the focus on ammonia emissions. More recently, Environmental Impact Reports (EIR) written as a component of the California Environmental Quality Act (CEQA) have described that significant negative impact on the environment from planned dairy facilities include ammonia emissions and volatile organic compounds. The Ugly In California, dairy operators in the Chino basin have braced for new regulations (implementation anticipated in 2004) to reduce ammonia emissions. The previously developed plans to reduce ammonia emissions relied heavily on relocation of animals from the basin. If sufficient relocation of dairy cows and other animals does not occur before January 1, 2004 and ammonia emissions are identified as greater than the carrying capacity of the basin then ammonia control measures will be imposed. The level of control will be set by the emission reductions still required to meet the ammonia “carrying” capacity, after crediting emission reductions due to relocation. Control measures to reduce ammonia emissions were identified in 1996 as: Dietary manipulation, reduced volume of wet/moist manure, composting and/or removal of manure to composting facilities, enhanced biodegradation (enzymatic and microbial applications), optimize pH for standing manure, improve aeration of stockpiled manure, and other control methods. More recently, a new study has re-emphasized almost all of the previous list of management practices to reduce ammonia emissions. Also included in the new list was use of rBST and three times a day milking in lieu of twice a day milking. The consultant who prepared the report assumed that if the goal of dairy production was a specified volume of milk, then if each cow produced more, fewer cows would be needed to produce the equivalent milk. And the assumption continued that there would be less manure (and ammonia) produced. Due to unforeseen problems associated with relocation, many of the dairy animals remain in the basin. As such, the South Coast Air Quality Management District will need to promulgate and enforce regulations in late 2002 to reduce ammonia emissions from dairy animals by 50% of the estimated 1995 values. The District will need to re-evaluate emission factors used for dairy animals, and support research to quantify anticipated ammonia emission reductions depending on management practice implemented. They currently hope to be able to certify technologies for ammonia emissions reduction. A Hearing was held in September, 2000 to address the contribution of dairy animals to the San Joaquin Air Pollution Control District air emissions. The preliminary report indicated that ammonia emissions from dairy cattle in each of the counties in the basin ranged from less than 40% to greater than 60%. Clearly, one of the key issues is the actual values used for emissions per animal and animal inventories. The CEQA process requires that CEQA be addressed when a discretionary land use permit is issued by a government agency. Currently, the permit process for animal feeding operations is being modified (most operations in the State are regulated through a Waiver of Waste Discharge Requirements). The Waiver policy sunsets in December as a result of legislation passed previously. For a new Waiver policy to be developed, or actual Waste Discharge Requirements to be written, CEQA will need to be completed. This is an expensive (one facility has spent more than $750,000) and time consuming process and requires public input. There are numerous Counties interested in developing their Programmatic Environmental Impact Report. Two key issues resulting from these reports are normal and cumulative impacts to air. Counties are finding themselves faced with reports that will arbitrarily cap herd size based on assumed values for gaseous emissions. If a facility owner (existing or proposed) would like to increase their herd size, they will need to provide sufficient mitigation measures to reduce impact to air quality below significant levels. The County has the right to accept environmental impacts. However, this will inevitably result litigation from concern citizen groups. (Litigation that began in 1999 has not been resolved and has almost completely halted the permitting process for dairy facilities). Further Reading Baseline Consulting. 1999. Screen administrative draft #2 environmental impact report for Borba Farms Dairy. Kern County. July 12. Emeryville, CA. Dickson, R.J. and S.R. Tate. 1988. Evaluation of emissions from selected uninventoried sources in the State of California. Final Report. AR Contract No. A5-147-32. Halberg, E.D. 1984. South Coast Air Quality Management District Engineering Division Report on area source emissions for c/v 1983 from agricultural livestock waste CES. No. 66605. October 6. Diamond Bar. KVB, Inc. 1978. Control of hydrocarbon emissions from stationary sources in the California South Coast Air Basin. Final Report, Volume I (Volume II Appendix). Tustin, CA. Contract ARB 5-1323. South Coast Air Quality Management District. 1996. Draft appendix IV-A. Stationary and mobile source control measures. CM#97WST-01. August. Diamond Bar, CA.
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