The
Agricultural
Sector
and
Air
Quality
Sally
Shaver
Associate
Counselor
for
Agricultural
Policy
Office
of
Air
and
Radiation
September
9,
2005
2
Urban
sprawl
has
raised
public
awareness
of
agriculturally
generated
pollution,
leading
EPA
to
develop
a
strategy
which
may
require
air
emissions
reductions.
3
While
a
number
of
environmental
statutes
and
programs
potentially
apply
to
agricultural
operations,
traditionally,
the
CAA
and
CERCLA
have
not
been
applied
to
these
sources.
4
EPA's
goal
would
be:

To
develop
and
implement
a
mix
of
voluntary
and
regulatory
policies
that
will
adequately
address
environmental
pollution
while
supporting
a
healthy
agricultural
sector.
5
Environmental
Statutes
Potentially
Impacting
Animal
Production
°
Clean
Water
Act
(
CWA)

 
sources
must
get
a
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
prior
to
discharge
of
pollutants
 
authorizes
EPA
to
develop
guidelines
(
i.
e.,
Feedlot
Effluent
Limitation
Guidelines)

°
Comprehensive
Environmental
Response
Compensation
Liability
Act
(
CERCLA):

 
requires
reporting
of
releases
to
the
National
Response
Center
if
equal
to
or
greater
than
the
"
reportable
quantities"

°
ammonia
 
100
lbs/
day
°
hydrogen
sulfide
 
100
lbs/
day
6
Environmental
Statutes
Potentially
Impacting
Animal
Production
 
cont.

°
Clean
Air
Act
(
CAA)

 
establishes
limits
for
criteria
pollutants
(
e.
g.,
PM
and
ozone)
and
hazardous
air
pollutants
and
requires
State
plans
on
how
to
meet
the
limits
 
requires
"
major
sources"
to
obtain
title
V
permits
 
requires
new
source
review
permits
prior
to
new
construction
or
modification
of
a
site
 
requires
States
to
address
their
contributions
to
visibility
impairment
in
Class
I
areas
7
Impacts
of
CAA
Statutes
and
Programs
on
Animal
Production
°
PM
and
ozone
State
implementation
plans
 
If
area
is
nonattainment,
State
has
to
designate
area
 
3
years
after
designation,
SIPs
are
due
which:

°
demonstrate
attainment
°
provide
enforceable
requirements
for
reductions
sufficient
to
reach
attainment
°
provide
for
attainment
in
X
(
5­
10
)
years
°
Title
V
permits
 
Many
States
are
evaluating
applicability
of
title
V
to
the
various
operations
at
farms
 
In
California,
the
permit
program
approval
was
withdrawn
for
the
agricultural
exemption,
resulting
in:

°
litigation
against
EPA
for
approval
of
a
deficient
program
°
EPA
settled
the
suit
and
agreed
to
administer
the
title
V
program
for
agricultural
sources
in
California
 
permit
applications
due
for
diesel
engines
in
May
2003
 
permit
applications
due
for
nondiesel
engine
agricultural
sources
(
e.
g.,
CAFOs)
by
August
2003
8
Impacts
of
CAA
Statutes
and
Programs
on
Animal
Production
 
cont.

°
New
source
review
 
If
a
major
source
alters
its
operation
such
that
emissions
are
increased,
then
a
permit
is
required
 
The
amount
of
increase
in
emissions
varies
with
an
area's
nonattainment
status
 
For
attainment
areas,
PSD
permits
are
required
for
increases
>

250
tpy
PM10,
NOx
or
VOC
°
Office
of
Enforcement
and
Compliance
Assurance
 
A
number
of
enforcement
actions
have
been
initiated
since
1996
 
Recent
enforcement
actions
were
initially
driven
by
violations
of
the
Clean
Water
Act
9
Air
Quality
Issues
°
Emissions
of:

 
volatile
organic
compounds
(
VOC)

 
hydrogen
sulfide
 
ammonia
°
PM2.5
from
emissions
of:

 
particles
(
ammonia
as
precursor)

 
direct
emissions
(
dust)

°
Nutrient
over­
enrichment
of
aquatic
systems
from
emissions
of:

 
ammonia
°
Acidification
of
the
environment
from
emissions
of:

 
ammonia
°
Global
climate
change
from
greenhouse
emissions
of:

 
methane
 
nitrous
oxide
10
Scientific
studies
related
to
health
and
environmental
effects
EPA
Criteria
Document:

integrative
assessment
of
scientific
studies
EPA
Staff
Paper:

policyrelevant
assessments
leading
to
staff
recommendations
on
standards
Scientific
peer
review
of
published
studies
Reviews
by
CASAC
and
the
public
Reviews
by
CASAC
and
the
public
Public
hearings
and
comments
on
proposal
EPA
proposed
decision
on
standards
EPA
final
decision
on
standards
Interagency
review
We
are
here
PM
NAAQS
Review:
Process
11
°
Final
PM
Air
Quality
Criteria
Document 
October
2004
°
Completion
of
PM
Staff
Paper:

 
Second
draft
released
for
CASAC
review
and
public
comment
January
31,
2005
 
CASAC
review
meeting
April
6­
7
and
May
18,
2005
 
CASAC
recommendations
submitted
to
EPA
June
6,

2005
 
Final
PM
Staff
Paper
by
June
30,
2005
°
Rulemaking
on
PM
NAAQS:

 
Federal
Register
proposal
to
be
signed
by
December
20,

2005
 
Public
comment
period:
90
days
 
Final
Federal
Register
notice
to
be
signed
by
September
27,
2006
PM
NAAQS
Review:
Schedule
12
PM2.5
Implementation
Guidance
°
Final
PM2.5
implementation
rule
­
Sep
2004
°
Final
PM2.5
designations
­
Dec
15,
2004
°
Proposed
guidance
developed
 
Apr
2004
°
Submitted
for
Office
of
Management
and
Budget
review
 
Oct
2004
°
SIP
are
due
for
PM2.5
nonattainment
areas
(
3
years
after
designation
date)
­
Dec
2007
13
Counties
Designated
Nonattainment
for
PM10
Contigusa.
shp
Serious
Moderate
States.
shp
01/
2002
Classif
ication
For
convenience
the
entire
county
is
shown
as
nonattainment;

however,
only
a
portion
of
many
counties
are
designated
nonattainment.
14
County
Classification
Rural
Urban
1
Urban
2
15
Tons/
yr/
sq
mi
0.0000512
­
0.00230
0.00231
­
0.00515
0.00516
­
0.0120
0.0121
­
0.0191
0.0192
­
0.0289
0.0290
­
0.0432
0.0433
­
0.0582
0.0583
­
0.103
0.104
­
0.273
0.274
­
1.80
2001
PM2.5
from
Wildfires
(
Tons/
Yr/
Sq
Mi)
16
Ozone
Implementation
Schedule
RACT
SIPs
due
June
15
06*
Final
Phase
2
Implementation
Rule
(
in
OMB
review
>
90
days)

Summer
05
Ozone
attainment
demonstration
SIPs
due
June
15
07*
EPA
issued
final
designations
&
Final
Phase
I
Implementation
rule
April
04
Range
of
attainment
dates
2007­
2024
Effective
Date
of
Designations
June
15
04
Action
Date
*
proposed
17
Ozone
NAAQS
Review
°
1st
draft
ozone
criteria
document
Jan
2005
 
CASAC/
public
review
May
2005
°
2nd
draft
ozone
criteria
document
Aug/
Sep
2005
°
1st
draft
ozone
staff
paper
Sep
2005
 
CASAC/
public
review
Dec
2005
°
Final
ozone
criteria
document
Feb
28,
2006
°
2nd
draft
ozone
staff
paper
Apr
2006
 
CASAC/
public
review
Jul
2006
18
8­
hour
Ozone
and
PM2.5
Nonattainment
Counties
Final
April
5,
2005
PM2.5
Only
Both
8­
hour
Ozone*
and
PM2.5
8­
hour
Ozone*
only
*
Note:
Ozone
counties
are
shown
as
whole
counties;
however,
in
some
cases,

only
part
of
the
county
was
designated
as
nonattainment
PM2.5
Unclassifiable
Areas
Greenville­
Spartanburg,
SC
19
The
Path
Forward
°
To
improve
our
understanding
of
environmental
issues
related
to
the
agricultural
sector,
EPA
has
developed
a
threepronged
strategy
and
is
working
closely
with
USDA
and
others
to
reduce
emissions
and
improve
air
quality
while
supporting
a
sustainable
agricultural
sector.
20
Air
Quality
Strategy
for
Agriculture
°
Basic
elements
of
strategy
will
include:

 
Scientific
assessment
 
Outreach
and
education
 
Implementation/

compliance
21
Scientific
Assessment
°
Currently,
we
do
not
have
adequate
emissions
estimates
for
this
sector
°
Develop
understanding
of
emissions
profiles
°
Establish
monitoring
and
measurement
protocols
°
Technology
transfer
°
Research
agenda
Ensure
that
we
are
all
driven
by
a
fundamental
shift
in
thinking
and
practices
based
on
sound
science.
22
Outreach
and
Education
°
Encourage
partnerships
between
EPA,
USDA
and
their
established
partners
°
Utilize
existing
USDA
infrastructure
(
e.
g.,
Extension
Service,
NRCS,
land
grant
colleges
and
universities,

and
Farm
Bill
programs)

°
Offer
annual
workshops
°
Active
dialogue
with
Ag
community
Instill
a
long­
term
commitment
to
working
with
the
agricultural
community;
build
respect
and
trust;
and
identify,
promote
and
quantify
new/
existing
control
technologies
23
Implementation
°
Appropriate
mix
of
voluntary
&
regulatory
programs
°
Utilize
USDA
infrastructure
to
implement
air
quality
programs
and
compliance
assistance
°
Strategy
where
EPA
sets
air
quality
targets
and
USDA
provides
technical
assistance
Fully
institute
policies
and
practices
to
ensure
that
farming
and
land
management
communities
continue
to
consider
air
quality
as
an
integral
part
of
resource
management.
