USDA Comments on PM2.5 RIA:

Based on previous discussions with EPA personnel, it is USDA’s
understanding that EPA’s current policy regarding ammonia emissions
from animal operations is to postpone determinations of the
appropriateness of regulation and control of these sources until
emissions data from the EPA/CAFO National Air Emissions Monitoring Study
(NAEMS) is complete.  It is also USDA’s understanding that EPA’s
current policy regarding ammonia emissions is directly attributable to
EPA’s recognition that data regarding the adequacy and accuracy of
ammonia emissions estimates (and the resulting air quality impacts) from
these sources are currently lacking.  However, in contrast to the above
observations, the RIA indicates that ammonia controls for swine and
dairy operations will be necessary to meet the proposed standards for
several nonattainment areas in the Midwest.  Therefore, USDA proposes
the following comments to revise the RIA to more closely reflect EPA’s
current policy regarding ammonia emissions from animal operations:

Page 1-2 (Section 1.2.2) – Add the following language to this section:

“Data on ammonia emissions from animal operations are currently
inadequate for making regulatory and/or control decisions for these
emissions.  EPA anticipates that the National Air Emissions Monitoring
Study (NAEMS) for animal operations will provide a more scientific basis
for estimating emissions, as well as defining the scope of air quality
impacts, from these sources.  As such, an appropriate strategy for
estimating and regulating emissions from animal operations will be
developed as a result of the NAEMS, and further guidance regarding the
need for, and scope of, potential ammonia controls from these sources
will also be developed at that time.”

Page 1-3 (Section 1.3) – Add the following language to this section:

“As mentioned in Section 1.2.2, potential ammonia controls for animal
operations are not included in this analysis.  The current emissions
data for these sources is not adequate for understanding the
quantification of emissions or air quality impacts, and therefore the
potential mitigation of emissions and impacts, from these sources.”

Page 2-2 (Section 2.1) – Add the following language to the first
paragraph after the bullets on this page:

“As mentioned in Section 1.2.2, potential ammonia controls for animal
operations are not included in this analysis.  The current emissions
data for these sources is not adequate for understanding the
quantification of emissions or air quality impacts, and therefore the
potential mitigation of emissions and impacts, from these sources.”

Page 2-23 (Section 2.3.3) – The first two bullets on this page are
rendered moot by our comments and should be removed.

Page 3-9 (Section 3.2.2) – The last bullet on this page is rendered
moot by our comments and should be removed.

Page 3-17 (Table 3-5) – The two rows regarding emerging animal feeding
operation control technologies should be removed.

Page 3-28 (Section 3.3.4) – The sentence beginning with “Another 24%
of the reductions…” in the last paragraph should be removed.

Page 3-29 (Section 3.3.4) – The last sentence of the first full
paragraph should be removed.

General comment – There are other references to ammonia reductions in
various places in the tables and text of Chapters 1-6 of the RIA that
will likely also need to be updated to reflect the removal of ammonia
controls associated with animal operations from this analysis.

