Livestock Air Study “Critique” Begins

Further to our January 14th newsletter, with the completion of the National Air Emissions Monitoring Study (NAEMS), various groups are beginning to weigh in with their opinions.  One of these groups is Environmental Integrity Project (EIP).  The title of their report, “Hazardous Pollution From Factory Farms: An Analysis of EPA’s National Air Emissions Monitoring Study,” is not exactly a “politically neutral” title. 

Following their review of the NAEMS report, EIP offers the following conclusion:

Despite significant influence by the regulated community and problems with both monitoring and data analysis, the NAEMS results document high levels of air pollution around factory farms and demonstrate the need for increased public health protection for rural communities.  This study adds to a growing body of research showing that factory farms are industrial-scale polluters, and EPA’s failure to regulate CAFO pollution under the Clean Air Act and other laws runs afoul of sound science.

EPA should act quickly to use existing emissions research and the results of this study to set emission estimating methodologies that will allow for accurate, site-specific estimates of pollution emitted from the thousands of large CAFOs across the country. Once these methodologies have been established, EPA should protect communities exposed to unsafe levels of particulates, ammonia, hydrogen sulfide, and volatile organic compounds by requiring emissions reporting and the use of technology proven to reduce air pollution.

Here is a link to EIP’s report http://www.environmentalintegrity.org/03_09_2011.php

EIP’s suggestion that the EPA develop emission-estimating methodology is significant.  In the January 31, 2005, Federal Register notice, “Animal Feeding Operations Consent Agreement and Final Order,” there are specific actions required (for those who signed the Agreement) once the estimating methods are available.

(C) Respondent complies with all of the applicable requirements set forth below:

(i) Within 120 days after EPA has published Emissions-Estimating Methodologies applicable to the Emission Units at Respondent’s Source, Respondent submits all Clean Air Act permit applications required by the Permitting Authority for the Source, based on application of those Emissions-Estimating Methodologies (emphasis added).

(a)    For a Source whose emissions exceed the major source threshold in Title I, Part C or D, based on the area’s attainment status (e.g., in an attainment area, more than 250 tons per year of a regulated pollutant), this requirement includes:

(1)   Applying for and ultimately obtaining a permit that contains a federally enforceable limitation or condition that limits the  potential to emit of the Source to less than the applicable major  source threshold for the area where the Source is located; or,

(2)   Installing best available control technology (BACT) in an attainment area, or technology meeting the lowest achievable emission rate (LAER) if the Source is located in a nonattainment area, as determined by and in accordance with the schedule provided by the Permitting Authority for the Source, and obtaining a federally enforceable permit that incorporates an appropriate BACT or LAER limit…

Here is a link to the 2005 Federal Register notice http://edocket.access.gpo.gov/2005/05-1536.htm

The bottom line is the results of this study may have significant implications (economically and operationally) for large livestock operators.

PS. THIS JUST IN – CAFOs required to get CWA permits – ONLY if they discharge!  To read more, go to these links:

http://beefproducer.com/story.aspx/court/strikes/down/cafo/rule/10/47537

http://www.oklahomafarmreport.com/wire/news/2011/03/00164_CAFORuling03162011_043504.php

http://www.nppc.org/

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