Animal Feeding Operations AFO: Air Quality Issues

1
Animal Feeding Operations (AFO) Air Quality
Issues

• Regional Science Workshop on Animal Feeding
  Operations
• December 7, 2004

2
Landscape

• Animals being concentrated
• Public air quality complaints abundant
• Lawsuits increasing against farms
• CAA applicability confusing
• Fallout likely for either inaction or
  heavy-handed control

3
Air Quality and Environmental Concerns

• Pollutants
• Criteria Pollutants (e.g., PM, VOC)
• HAP Pollutants (e.g., H2S petition)
• Other (e.g., NH3)
• Health, Welfare, and Ecological
• Combined AFO Emissions

4
Goals

• Settle issues of CAA requirements
• Source definition
• Applicability cutoff (i.e., size cutoff)
• Fugitive/non-fugitive
• Emission estimation (e.g., emission factors,
  potential to emit)
• Control technology effectiveness
• Monitoring, reporting and recordkeeping
• Find an Ag-appropriate approach to Title V and
  PSD/NSR

5
Goals (cont.)

• Resolve ambient air quality issues affecting
  communities
• Provide catalyst for best management practices
  (BMP) implementation
• Maintain consistency with water rule

6
Principles

• Maximize flexibility of solutions
• Maximize USDA involvement as non-regulatory
  entity
• Minimize farmers regulatory burden
• Minimize farmers liability
• Balance financial impact with air quality gains
• Promote new technologies
• Process-based modeling per NAS

7
Issues

• Monitoring by farm not feasible
• BMP vary across the country
• Complaints usually based on nuisance, odor and
  illness
• Ammonia is not a regulated pollutant
• Pollutant mix is highly variable PM, NH3, H2S,
  gt200 VOC
• Permitting may be burdensome for smaller farms
  and result in limited environmental benefits

8
Possible Approach?

• How should we address AFO emissions?
• Should we focus on a single pollutant or a group
  of pollutants?
• Should we require nutrient management plans (NMP)
  with air quality planning component?
• NMP already required under water rule
• USDA could develop, States could review
• Include BMP appropriate to individual farm
• How can we require BMP implementation?
• Based on USDA national technical standards
• Utilize farm bill programs to help pay for
  installation of technologies as approved by USDA
• Would promote new BMP and technologies as allowed
  by USDA
• Would not require emission measurements at farms
  but work practices and confirmation of
  implementation of technology

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10
Process-Based Simulation Models Should Replace
Emission Factors

• Accounts for site-specific design and management
  practices as variables and reflects interactions
  between emission sources
• Reflects to mass balance constraints
• Scale specific (e.g., individual AFOs or
  regional/national scale)

Feed
Import/Export
Emissions
Crop
Export
Herd/Flock
Product
Emissions
Emissions
Manure
Soil
Import/Export
Fertilizer
Emissions
Emissions
11
Research Needs Are Significant

• Health and environmental impacts
• ...to understand which emissions are most harmful
• Standard measurement protocols
• ...so that research results can be directly
  compared
• Process-based emission simulation models
• ...to replace emission factors
• Transport and fate of emissions
• ...to better understand significance on local,
  regional, and national scales
• Best management practices to reduce emissions
• ...to understand the applicability, cost, and
  performance of emission control practices