USDA Agricultural Air Quality Task Force
USDA Agricultural Air Quality Task Force
USDA Agricultural Air Quality Task
May 1, 2002
Jamie L. Whitten
Building, Williamsburg Room
Avant Kevin Rogers
Coleman John Sweeten
Cunha Michael Unsworth
Green Stephanie Whalen
Gary Margheim, Acting Chair
Other NRCS Support Staff:
Beth Sauerhaft (Designated
Beyer Jeff Schmidt
Brenner Ray Sinclair
Graves Roel Vining
Other EPA Support Staff:
Penny Lassiter, Linda Metcalf,
Other Federal Personnel:
Jim Moseley, Deputy Secretary of
Mack Gray, Deputy Under Secretary for Natural Resources and Environment
Nancy Bryson, OGC, NHQ Deb Atwood, Confidential Asst. to Mr.
Dick Amerman, ARS, NHQ
David Mobley, EPA
Ray Knighton, CSREES, NHQ
Jean-Mari Peltier, EPA, NHQ
Ed Knipling, ARS
Dan Kugler, CSREES
Mavis Bermudez, Sierra Club
Jamie Jonker, National Academy of
Michele Merkel, Environmental
Martha Noble, Sustainable Air
John Walke, Natural Resources
The Agricultural Air Quality Task Force meeting was
called to order by Beth Sauerhaft, the Designated Federal Official. Acting
Chair Gary Margheim welcomed everyone to Washington, D.C., made a few
announcements, and informed the group that because the Ag conferees would be
releasing the new Farm Bill sometime that morning, the Task Force could have
access to the bill that afternoon.
Dr. Margheim announced that Clinton Reeder had resigned
from the Task Force, and he read a few paragraphs from Mr. Reeder’s letter of
resignation. The Task Force accepted the resignation.
Deputy Undersecretary Mack Gray shared a few words of
greeting and praise with the Task Force directing them to continue their good
work as it will be vital to agriculture over the coming years, and then Dr.
Margheim asked Beth Sauerhaft to present the minutes from the last meeting on
January 16 and 17, 2002. Dr. Sauerhaft mentioned that she had made a few changes
to the minutes since sending them out the members before the meeting, so Dr.
Wakelyn suggested that the Task Force wait until the following day to approve
the minutes; at the prerogative of the Chairman, Dr. Margheim so ordered.
Dr. Margheim recognized Ray Knighton, Dick Amerman, and
Beth Sauerhaft for their work on the previous day’s tour of NASA’s Goddard Space
Flight Center, and the other facilities, and then he turned the meeting over to
Sally Shaver for the EPA update. Ms. Shaver introduced David Mobley, Division
Director for EPA’s Missions Measurement and Analysis Division, who presented
information on the particulate matter (PM) monitoring and speciation work being
conducted across the country and some of the data that have been collected. He
shared the initial results from their mass monitoring network and the analysis
of its first three years of data. Mr. Mobley said they are beginning to
understand what they will need to do for control approaches, and they are aware
of the agriculture issues and are trying to address them as they proceed.
Manuel Cunha exhorted Mr. Mobley and his staff to
remember that farming is very much controlled by the market and the consumer for
trade issues. Farms can change their farming practices within three months from
what they normally grow to something different because of the market demand.” He
urged Mr. Mobley’s department to seriously consider these fluctuations in
agriculture practices when they recommend control measures that can cost farmers
a great deal of money.
Viney Aneja asked Mr. Mobley what percentage of the
monitoring sites are in rural agricultural environments. Mr. Mobley replied that
out of the 1100 monitors in the country, only 33 are in counties with more than
75% agriculture practice, and no super sites are located in a true rural
Calvin Parnell shared that research at A&M demonstrated
that when sampling with the PM2.5 FRM sampler in an environment such as
[unclear] is larger than 2.5 then we get a bias. Although the goal of EPA is to
do ambient sampling, states don’t necessarily support that concept. They want to
put the sampler at a property line or near agricultural sources and then address
that saying, they have an exceedence of PM2.5 24-hour standards, so therefore we
have a problem. The impression from a standpoint of states is that that’s an
EPA-approved sampler, and therefore that must be PM2.5. And that sampler we know
is actually over-sampling the concentration. How do we address that issue?
Mobley replied saying EPA hopes that most states follow
EPA guidance and are locating their monitors in an area that would not be
influenced by a single source or source category. EPA has done a number of
studies to determine the penetration rates of particles greater than 2.5 and
found that while the situation described can occur, EPA hasn’t seen significant
problems with that. The penetration rates over time for monitors and zones with
particles known to be, or thought to be, greater than PM2.5, have still come out
with a cut point that represents the PM2.5 category.
Wayne Robarge asked that, assuming EPA’s database will be
available to the public, is it conceivable that states will make one
interpretation of the database, and you will make another interpretation based
on your quality assurance review of the data.
Mobley responded that the data are currently available to
the public on the AIRS computer system. As the regulatory process proceeds,
there will be a give-and-take round between EPA and the states, and Dr. Wakelyn
suggested that states would view the data a little bit differently than does the
AAQTF. The discussions of designations between states and EPA will be in the
public domain as that proceeds.
Kevin Rogers raised questions about the placement of
monitors for specific measurements (for example, near a feed yard). He was
concerned that such specific data could later be reported to county or state
monitoring networks and then pooled with the more general data. Mr. Mobley
agreed that everyone needs to be aware of such specialized applications that
could end up with a different application in the end.
Calvin Parnell also expressed some serious concerns that
state agencies and regulators could set up monitors near agriculture sites, take
PM10 and PM2.5 samples, get multiple exceedences of
24-hour concentration because the farmers are out disking or such, and then use
that data to “cause difficulties for farmers in this country.” Dr. Parnell
understood that collecting these kinds of samples could be valuable to EPA’s
work, but he believed that the use of this particular monitoring methodology
could cause difficulties for specific agricultural operations (for example,
setting a sampler adjacent to a farmer’s property to demonstrate exceedences and
then force him to change his operation). Mr. Mobley replied, “In the sense that
ambient air is defined as any area that the public has access to, and the
ambient air quality standard would apply to that zone, no, I can’t say it’s an
Viney Aneja asked if EPA is considering the creation of a
super site for rural/agricultural-related issues, as well as a model for rural
areas. Mr. Mobley answered that the existing super site programs will be
shutting down when the funding (a one-time appropriation from Congress) is
expended, so EPA does not anticipate even continuing those sites, much less
expanding to new sites. However, if the Task Force wished to recommend a super
site in a rural area, they should make the recommendation to the appropriation
committee so the monies can come with it.
Stephanie Whalen shared more concerns about the
monitoring technique being used for PM2.5 and the increased
possibility of having more errors in rural areas than in urban areas because the
rural sampling zones tend to be more likely to be dominated by particles greater
than PM2.5 that will penetrate the samplers. Mr. Mobley concurred
that this was theoretically possible, but he said they had analyzed samples in
all areas to ensure that they were not getting unusual penetration of large
particles; he mentioned an Arizona road dust study as one such test. Ms. Whalen
requested copies of the Arizona study for all Task Force members.
Deputy Secretary of Agriculture, Jim Moseley, arrived and
introductions were made. The Deputy Secretary expressed his appreciation of the
work the Task Force had done, and he said it was “very clear” that the Task
Force would be reauthorized to continue. The Deputy Secretary formally
recognized Chairman Reed for his leadership and guidance of the Task Force.
Mr. Moseley asked the Task Force to help him understand
what the major air quality issues are, what needs to be done, and specifically,
what role USDA can play to ensure the development of reasonable solutions to the
challenges our country faces. Annette Sharp shared with the Deputy Secretary the
urgency of developing scientifically-based emissions factors for agricultural
processes, particularly animal issues and burning, because the states must
submit SIPs in the year 2004.
Manuel Cunha focused on the desperate need for
agricultural air quality research, especially in those areas prioritized in the
Task Force’s research document. He called for increased funding for air quality
research, particularly through USDA’s ARS and CSREES, to provide the good
science needed to support American farmers.
Bob Avant repeated the importance of getting USDA to
shift gears on some of their research priorities to make sure they have good
science to use to intervene in the rulemaking process. Once the research is
done, there needs to be an extension component so that the farmers are advised
of the best management practices to comply with the law. Mr. Avant also stressed
the need for USDA to be an advocate for agriculture in communicating the
concerns of air quality work to EPA and the other regulatory entities, and for
USDA to intervene in some of the most important rulemaking activities and
litigation when they affect the viability of American agriculture.
Roger Isom stated that the Task Force’s top concern is
getting more air quality research and more funding for that work. John Sweeten
added that the livestock feeding industry needs answers in the form of best
management practices that are borne of sound science, and that will solve both
water quality and air quality issues.
Dr. Sweeten suggested that an interagency program be
created for air quality—something analogous to that established for water
quality by the 1990 Farm Bill. The program could unite a number of agencies to
work together to conduct the research, education, and technology transfer
directly to producers, and to stay out ahead of the regulatory agencies. Wayne
Robarge agreed with this suggestion, adding that dealing with air quality issues
such as odor and pathogen dispersal will require a long-term commitment to
proper science and proper funding. Phyllis Woodford concurred.
Kevin Rogers stated that because of a lawsuit, farmers
and ranchers in Maricopa County, Arizona, are now living under strict guidelines
that are not science-based. However, because they have something in place that
is now legal, whether based on science or not, Arizona’s regulations threaten to
be repeated all across the agriculture belt in a sort of domino effect—“because
it’s easy to promulgate rules and it’s difficult to have the science to do it.”
The Deputy Secretary requested a background briefing on the situation in
Stephanie Whalen declared that farmers are calling for
best management practices that have scientifically-proven results and that can
demonstrate clear environmental benefits. Mark Boese and Calvin Parnell
reiterated the need for appropriate science to ensure that agriculture is fairly
Deputy Secretary Moseley wrapped up the discussion,
saying, “I’ve heard your message very loud and clear, and you have my commitment
to work through the process” of funding research. He then called for further
information on the situation in Arizona and on the highest priorities for
research. He also asked for a very clear and rational accounting of the
resources needed for that research.
Before the Deputy Secretary left, Gary Margheim and the
Task Force recognized Mr. Pearlie Reed in absentia for his outstanding
contributions to the Agricultural Air Quality Task Force.
After a break, Bob Flocchini introduced Jamie Jonker from
the National Academy of Sciences (NAS) who briefed the Task Force on the
progress of the NAS scientific assessment of emissions from animal feeding
operations. The National Academy Committee has submitted an interim report
through the National Research Council (NRC) for a detailed review. Once the NRC
coordinator and monitor approve the report, it will be available for the
public. Copies will be made available to Task Force members. The committee
anticipates issuing its final report in October of 2002. The interim report
responds to a specific set of questions that EPA requested the study to address;
the final report will focus on some of the broader issues beyond those specific
Bob Flocchini, who serves on the National Academy
Committee, explained the general process the committee has followed for their
report, but he could not disclose any specific information.
Next, Gary Margheim asked Jean-Mari Peltier to give her
EPA update. Ms. Peltier began by complimenting the committee on the
presentations that they made to Deputy Secretary Moseley that morning. Just as
the Deputy Secretary had done, Ms. Peltier committed to the Task Force to work
with Sally Shaver to carry the message back to EPA about the need for heightened
coordination, especially on the research fund. She reported that currently there
is “an unprecedented level of coordination” between the Department of
Agriculture and EPA. Secretary Veneman and Administrator Whitman meet monthly,
and they have sent the message down through the agencies that everyone is to
coordinate and work very closely together. That very afternoon, USDA and EPA
would be starting to create an interagency work group for implementation of the
new Farm Bill.
Mark Boese inquired about the progress being made with
the reformulation of pesticides, specifically as it relates to reducing or
eliminating petroleum-based carriers. Ms. Peltier replied that volatile organic
compounds (VOC) emissions associated with pesticide use were definitely an issue
“that we need to get on the federal radar screen.”
Dan Kugler, Deputy Administrator for Natural Resources in
the Environment, at the Cooperative State Research, Education, and Extension
Service (CSREES) expressed his eagerness to learn more about air quality issues,
and appreciated hearing the comments the Task Force shared with Deputy Secretary
Moseley. CSREES has requested doubling the National Research Initiative (NRI),
raising its funding to $240 million, and they are considering creating a
subprogram on air quality. When CSREES has its budget for 2003, they will
prepare a call for proposals that recognizes the air quality research identified
by the Task Force.
He also mentioned that the Farm Bill includes a program
called the Initiative for the Future of Agricultural and Food Systems (IFAFS),
and a good portion of the CSREES money that has been dedicated to air quality
has come through the IFAFS program. The Farm Bill calls for IFAFS funding to go
from $120 to $200 million, which could mean more money for air quality research.
Stephanie Whalen asked what the possibility would be of
creating a stand-alone program on air quality that is directed by the
recommendations of this Task Force should CSREES secure these increases in
funding. Mr. Kugler responded that with the National Research Initiative, there
is a period of time during which the request for applications is prepared and
input is sought concerning the priority needs within the country. Those issues
are then factored into and explicitly listed in the call for proposals.
Bob Avant expressed his frustration with not seeing some
fairly significant amount of money reprogrammed for air quality research when it
is “a priority area that could bring agriculture to its knees.” He informed the
Acting Chair that he intends to introduce a resolution reiterating the
importance of air quality being made a stand-alone research program and being
granted adequate funds to do the job.
Beth Sauerhaft opened up the public comment period for
the morning session, and John Brenner introduced the first speaker, Michele
Merkel from the Environmental Integrity Project. Ms. Merkel expressed concern
that the Task Force seemed to be going beyond its mission of coordinating
research on agricultural air quality issues and was trying to influence EPA’s
decisions on the permitting of concentrated animal feeding operations (CAFOs)
and on regulation and enforcement. She was particularly upset about the Task
Force’s recommendations to defer the reporting of ammonia emissions under CERCLA
until EPA defined the application of Clean Air Act requirements for CAFO
Annette Sharp thanked Ms. Merkel for sharing her opinion,
but Ms. Sharp refuted Ms. Merkel’s presentation of the enforcement action
against PSF. Ms. Sharp also stated that 40CFR part 70 grants any industry group,
including groups like the Task Force, the right to go before the Administrator
of EPA and request that a particular industry be put aside or not regulated
until such time as emission factors are developed.
The next speaker was Mavis Bermudez from the Sierra Club;
she said she was submitting comments on behalf of a colleague of hers who could
not attend the meeting at the last minute. Ms. Bermudez illustrated the
detrimental effects of CAFOs on air quality and explained why the Sierra Club
feels it is necessary to regulate these air emissions.
John Walke, the Director of Clean Air Programs with the
Natural Resources Defense Council, was the third speaker. Mr. Walke formally
requested that the Task Force expand the composition of its body to include
environmental group representatives and thereby provide better balance to the
He also said he concurred with Michele Merkel’s
conclusions with respect to the Task Force’s past policy directions, and
believed those policy directions reflected the interest of the industry
representatives to a greater extent than what he thought sound policy would
dictate in the name of air quality and public health protection.
The last public speaker was Martha Noble from the
Sustainable Air Culture Coalition, a Washington, D.C.-based group representing
13 organizations from the Midwest. Since about 1989, Ms. Noble has worked on
CAFO air quality issues, and she has noticed that most of the action taken
against CAFOs has been initiated by the operations’ rural neighbors “who are
watching an industrialization occur in agricultural zones with none of the
protections that were provided in industrial zones.” Ms. Noble also suggested
that a few representatives of public health authorities be added to the Task
Force to give the committee greater credibility with rural grass roots
The afternoon session began with Ms. Annette Sharp
presenting an update on the Regional Planning Organizations (RPOs), which are
charged with addressing regional haze and related issues. She described the
make-up of the different RPOs and their current work on major and minor
pollutant sources, including mobile sources and area sources and their work to
develop long-term strategies for controlling 26 categories of sources, primarily
With respect to agriculture, Regional Planning
Organizations will be identifying emissions from dust and smoke and including
them in state emissions inventories. Ms. Sharp stated that if there are no
studies from which to draw better emissions factors based on science, the states
will use AP-42. The RPOs will also be working very closely with the federal
agencies that are in charge of prescribed burns to develop smoke management
Bob Flocchini related that the IMPROVE data set is better
than AP-42, and he suggested the RPOs consider using that data.
Manuel Cunha mentioned that the WRAP is starting some
research on PM10 and PM2.5, and he asked if they are
making a very concerted effort to coordinate with those states that already have
such information. David Mobley replied that EPA communicates frequently with the
WRAP, and they are all coordinating their efforts as they move forward. Mr.
Cunha requested that Mr. Mobley prepare a report on this coordination effort for
the next Task Force meeting; Mr. Mobley agreed.
Ed Knipling from the Agricultural Research Service (ARS)
gave a quick overview of the Air Quality Research Program. Dr. Knipling said
that air quality is one of ARS’s 22 designated national programs, and there are
elements of air quality in many of the other national programs, such as manure
and byproduct utilization, and methyl bromide alternatives. ARS has about $8.5
million in their base program related to air quality, and it is allocated to 15
laboratory locations across the country, comprising the work of 27 scientists
(in FTEs). The current base program has five program components: particulate
emissions, ammonia and ammonium emissions, malodorous compounds, ozone, and
pesticide and other synthetic organic compounds.
Dr. Knipling then addressed the Task Force’s proposed $20
million increase within USDA for air quality research, and the additional $10
million that the increase would designate for the ARS program. ARS is proposing
to allocate about 50 percent of the funding increase to particulates and ammonia
emissions, wind erosion, agricultural burning, agriculture operations,
processing industry, transport of emissions, nitrogens, and measurement and
monitoring. Thirty percent, or $3 million, would go to ozone research, and 20
percent to odorous compounds. He added that the Administration’s 2003 budget
proposal for ARS includes another $5 million increase tied to air quality and
the broad area of waste management. If this increase is approved by Congress, it
would be allocated to work on particulate emissions and odorous compounds.
Dr. Knipling suggested that the Task Force must be sure
that all the groups at all stages of the budget process hear the same message.
Several Task Force members asserted that enough work has
already been done on wind erosion, so that money should be spent on other more
demanding issues. They encouraged Dr. Knipling and his staff to meet with Jim
Trotter and the Task Force Research Priorities Subcommittee to go over the areas
the Task Force has determined are the highest priorities for air quality
research. They strongly suggested that the research efforts be focused on
finding ways to reduce VOC emissions, determining proper control mechanisms and
strategies for PM10 in areas where it is a problem, and development
of Best Management Practices (BMPs).
With respect to wind erosion, Dr. Knipling mentioned that
each of the bulleted items on his list are really part of a spectrum, not
discreet program components, and wind is certainly still one of the principal
transport mechanisms for particulates. However, he did take note of the Task
Stephanie Whalen stated, “We’re going to be getting Best
Management Practices out of litigation or consensus decrees rather than by
research because the research is just responding too slowly. . . . We need Best
Management Practices as soon as possible, not just for major agriculture . . .
but to keep the small farmers in operation.”
Dr. Knipling accepted Ms. Whalen’s constructive comments
and responded that over the last ten years, ARS programs have focused on quality
issues and not so much production and yield issues, but to the producers, yield
is still very important. The agency has to address all of the issues and respond
to all customers in some sort of balanced way.
Kevin Rogers stated that what is going to put his small
farm out of business is not going to be wind erosion but the increasing
regulation. As it is now, in order to till his soil, he has to fill out a form
describing how he will do it and how he will reduce his PM10
emissions, but neither he nor his state agencies know how much he is emitting.
Mr. Rogers stressed the urgent need for emission factors for tillage practices,
cultivation practices, and planting practices, and he said the research agencies
need to recognize and address that need. He also suggested that it would be more
helpful for ARS to spend some of their money on evaluating the BMPs that states
like Arizona have in place and determining if they are really doing any good.
Sally Shaver updated the committee on several current EPA
issues. While Title V had been on the original agenda, Ms. Shaver felt it was
not appropriate to discuss that issue because it is under litigation in
California, and they were holding settlement discussions at the time.
With respect to CERCLA/EPCRA, Ms. Shaver reminded the
group that when Lynn Beasley addressed the group about a year ago, Jim Trotter
had some concerns about fertilizer application. Since that meeting, Ms. Beasley
had looked into the issue and found that farmers are not required to report
releases from the normal application of fertilizer.
On the issue of hydrogen sulfide being listed as a
hazardous air pollutant (HAP) under the Clean Air Act, Ms. Shaver said EPA’s
Office of Research and Development is still working on it and she had no
preliminary indications of how the issue might be resolved.
Ms. Shaver reported that EPA does have some options for
addressing the CERCLA issue. Since the quantities for reporting are based on
numbers from the Clean Water Act, not from the Clean Air Act and the numbers are
much lower than the emission limits of concern, EPA could approve an
administrative reporting exemption, or they can adjust the reportable quantities
based on air quality. Their offices are investigating these options further.
Calvin Parnell interjected that CERCLA/EPCRA requires
producers to report any time they emit more than a certain number of pounds of a
chemical, but the reporting limits are based on Clean Water Act requirements,
not Clean Air Act requirements. There are a number of agricultural operations
that are likely to exceed the 100-pound per day reporting limit for ammonia, for
example, but they are not reporting. Dr. Parnell explained that those
agricultural producers are not purposely failing to report these emissions;
rather, they are not reporting because they do not know they are emitting 100
pounds, and they do not realize they fall under the Clean Water Act. Dr. Wakelyn
indicated that the reportable quantity for NOx is 10 lbs/day and a 10
hp engine running about 12 hrs will reach that, which could affect agriculture.
Ms. Shaver promised to take that message back to EPA. Phil Wakelyn also
informed the task force that EPA published revised final guidance clarifying
permitted releases under CERCLA/EPCRA on April 17 (67 FR 18899) and April 23
(67 FR 19750; Definition of “Grandfathered” Sources) and passed out copies of
the notices. Wakelyn was not sure how this applied to agriculture where there
are few if any federal permits but thought if the clean air act levels were not
exceeded agriculture would not have to report.
Ms. Shaver addressed the progress on the National Ambient
Air Quality Standards (NAAQS) for PM and ozone. On March 26, 2002, the DC
Circuit Court of Appeals found PM2.5 and ozone standards to be
neither arbitrary nor capricious, and they denied all the remaining challenges
to the standards. Therefore, EPA now feels free to move forward with
implementation of the standards. Over the next year, the agency plans to propose
implementation rules for the eight-hour ozone standard, and to address the
sub-part one, sub-part two issue concerning how to classify areas. They will
determine which requirements are mandatory requirements and which can have more
flexibility on an area-by-area basis. Dr. Wakelyn indicated that several issues
still remain to be resolved on ozone before the standard can be implemented,
including EPA has to reconsider its implementation plan for ozone.
For the PM2.5 standards, EPA will analyze the
1999-2001 air quality data and determine the attainment status of each county.
Working closely with the states and the RPOs, EPA will draft guidance on
determining the geographic scope of non-attainment areas for PM2.5,
and begin modeling analyses to characterize regional transport. The states will
be able to make recommendations to EPA regarding designations, and then EPA will
propose final designations, probably in 2003.
Randy Waite (EPA) passed out a detailed schedule of
anticipated deadlines. He said EPA would probably finalize the implementation
rule for the eight-hour ozone NAAQS in FY 2003. They plan to propose the
implementation rule for PM2.5 sometime in 2003, and then finalize it
in 2004. Given this timeline, he suggested that the Task Force’s Implementation
Subcommittee continue to work on the NAAQS issues that concern the full
committee, and to pay special attention to the ozone issues as well as the PM2.5.
Ms. Shaver mentioned that EPA has called for NOx
state implementation plans (SIPs) to try to address some of the ozone issues,
and these SIPs will have beneficial effects for the eight-hour standard as well.
In addition, the Administration has gone forward with its Clear Skies
Initiative, which should result in both SO2 and NOx
reductions, and which should help in non-attainment issues, particularly in the
With respect to the criteria pollutant standards, EPA is
on a five-year review cycle, and currently both the PM2.5 standard
and the PM10 standard are undergoing review. Around May 8, 2002, the
Office of Research and Development will release a third draft of the criteria
document for the Clean Air Science Advisory Committee (CASAC) and public review
at a meeting on July 18-19, 2002; a final criteria document should be out by the
end of this calendar year. Ms. Shaver said the next draft staff paper for
particulates should be released in early July for CASAC and public review, and
the meeting for that staff paper has been scheduled for September 18-19, 2002.
The final staff paper will probably be out sometime in 2003. For ozone, the
criteria document preparation is planned from 2003-2004, and the earliest
anticipated date for a decision would be late 2005.
Roger Isom asked what impact the 8-hour standard would
have on existing non-attainment standards under the one-hour standard, and Ms.
Shaver answered that they would have no effect.
Ms. Shaver then displayed various maps of non-attainment
areas by county for the ozone and PM2.5 standards. The information on
these standards has given EPA reason to consider them together and try to
determine how best to proceed towards implementation, especially in the areas
that have non-attainment for both standards.
The subcommittee reports began with the Follow-Up
Subcommittee. Co-Chair Bob Avant distributed a table that he compiled from the
meeting minutes of all of the outstanding action items from the July 2001 and
January 2002 Task Force meetings. He went through the list and asked the person
named for each action item to briefly report on the item’s status and say
whether it still needs to be on the list or not.
Sally Shaver was asked to comment on Item 1, the EPA
Regional Administration meeting with the State Departments of Agriculture. She
said most of those meetings had already occurred, and the rest are scheduled;
once they are complete, Ms. Shaver would give the Task Force a report.
Item 8 was a qualification statement in AP-42 to indicate
that the data included there was intended for general guidance and not for
regulatory compliance. Calvin Parnell stated that such a statement was included
in the older, 1987 AP-42, but it was taken out of the new version; he clarified
that the issue is whether that qualification statement should be added to the
AP-42 web page and the new AP-42. Ms. Shaver said she would have to look into
Ms. Shaver’s name was also listed for Item 9, EPA staff
working on agriculture. She said that EPA and USDA staff members have a higher
level of communication on research policy issues and regulations than at any
time in the past, though it can still improve. Mr. Avant added that there had
been a request at the July 2001 meeting for a list of the key USDA and EPA
people who are working on Ag air quality issues. Gary Margheim said he and Beth
Sauerhaft would compile the list of USDA staff, and Ms. Shaver would share the
names for EPA.
Phyllis Woodford also asked to know the names of those
participating in the monthly USDA/EPA meetings with Jean-Mari Peltier and Mack
Gray. Mr. Avant suggested that Dr. Sauerhaft include those names with the other
Emmett Barker spoke about Item 2, foundations funding
research. He distributed a list of 25 to 30 foundations and the types of work
they sponsor. Mr. Barker will continue to expand the list.
Item 3 on the action list was conferences and association
meetings related to air quality. Calvin Parnell recalled that the intent of this
action item was to generate a list of the various conferences and meetings going
on throughout the country that Task Force members may want to attend. Mr. Avant
asked Dr. Sauerhaft to compile this list as well and distribute it to the Task
The next action item was the status of the NRCS list of
14 research needs with priority for air quality. Gary Margheim responded that
each year NRCS submits to the research agencies its priority list of research
needs as a user agency. Both Dick Amerman of ARS and Ray Knighton of CSREES say
they use that information to help put together their plans for the year. Dr.
Margheim stated that this year, NCRS’s number one research priority was air
quality, or more specifically, “the role and effectiveness of conservation
practices for particulate matter and odor control.” Mr. Avant requested that Dr.
Margheim pass out his list of other priority areas the following morning.
Item 5, the status of air quality funding priorities in
CSREES, had already been addressed by earlier presentations, and the Task Force
was still waiting to hear about the status of the research title of the Farm
Bill, which was Item 6.
Item 7 was the cross-cutting budget status for air
quality research in the 2003 budget. Dr. Margheim explained that USDA had
completed the 2003 budget process. Through the Office of Budget Planning and
Analysis, ARS and CSREES participated in a cross-cutting process to avoid
duplication of efforts and to ensure that the agencies are coordinating their
work. Since this item had been completed, Dr. Margheim said it could be removed
from the list.
Mr. Avant said there had been a question about the
Carnegie Mellon University ammonia study and database. Randy Waite replied that
some EPA emission factors staff were involved in reviewing the output of the
study. The database is on the web.
The Ag Regulatory Status under the Clean Air Act was Item
10; Sally Shaver already addressed it in her presentation, so Mr. Avant removed
it from the action list.
Item 11 was the definition of agriculture for regulatory
processes; in some states, different agencies have different definitions for
agriculture. Mr. Avant asked Ms. Shaver for her input, and she said that the EPA
regions are working on being consistent with their definitions. With respect to
CAFOs, she added that when the NAS report is complete, EPA will plan to define
facilities, farms, major sources, and fugitive emissions, to name a few. Ms.
Shaver suggested that the Implementation Subcommittee should also address the
definition issue and prepare something for the Task Force’s review if the group
wants to make a recommendation.
John Sweeten described the status of Item 12, EPA
standards on issues for CAFOs. Dr. Sweeten said the intent is to increase
research and development, education, and technology transfer relative to the
standardization and enforcement efforts so as to bring those back into balance.
Item 13 was Air Quality as a priority in the Research
Title of the Farm Bill, on which the committee was awaiting news, and Item 14
was Climate Change, which was on the agenda for the following day
Next, Kelley Green gave a brief report on the Research
Priorities and Oversight Committee. Mr. Green reminded the Task Force that at
the last meeting they had revised and approved a shortened list of research
priorities. Since then, the subcommittee had made a minor change to Priority 3
based on comments from Bob Flocchini; Mr. Green read the change aloud. Gary
Margheim requested new copies of the revised priority list for the following
Manuel Cunha suggested the priority list be brought to
Deputy Secretary Moseley and Secretary Veneman so that they understand that the
Task Force’s recommendations have not yet been addressed.
Mike Unsworth recalled that earlier that day, Deputy
Secretary Moseley had requested both a list of research priorities and some
details about the necessary resources and activities associated with those
priorities. He wondered whether the Task Force planned to follow up the short
list with an expanded version. Gary Margheim interjected that this short summary
document was already supported by a longer, more thorough report. Mr. Green
added that the intent of the shorter list was to focus clearly on the Task
Force’s highest priorities, and to keep the document as simple and as pointed as
possible. Dr. Margheim suggested that there is a need for both documents: those
involved with budgeting want more details than the Secretary or Deputy
Mr. Avant asked whether the longer detailed report is
consistent with the revised summary document. Calvin Parnell responded that the
detailed, 60-page report was created by the first AAQTF in 1996, and it may be
time to revisit that document. He suggested holding a special brainstorming
meeting for the long report to determine how best to modify it. Mr. Green added
that there once were three research priority documents: a one-pager, a
three-pager, and a 60-pager. Now there is one single updated two-pager, which is
what will be distributed. Mr. Green recalled that at the January 2002 meeting,
the Task Force had decided to clearly communicate the two-pager and then work on
the details. He agreed that the long document needs to be revised before it is
Stephanie Whalen also supported revisiting the long
document. She believed that since the Deputy Secretary has committed to doing
work in air quality and has said he heard the group’s message loud and clear,
the Task Force should present the information to him in a spirit of
collaboration. Mr. Cunha added that there was widespread frustration over USDA’s
inertia on air quality research.
For the report from the Agricultural Burning
Subcommittee, Stephanie Whalen handed out copies of the memo that was sent to
the Fire Emissions Joint Forum of WRAP concerning burning. Calvin Parnell
complimented both Ms. Whalen and Phyllis Woodford on their “yeoman effort”
regarding the memo.
As Title V was discussed earlier by Sally Shaver, this
subcommittee waved their time for a presentation.
John Sweeten said that the CAFO Subcommittee would be
presenting the full Task Force with a draft report the next day, so he would
save the discussion for that time. He did mention, however, that since the
January meeting, the subcommittee had been closely following the progress of the
NAS panel on the CAFO rules and effluent limitation guidelines.
To end the day’s session, Beth Sauerhaft began the public
comment period. The only speaker was Dick Amerman of the Agricultural Research
Service. He apologized for the confusion caused earlier over the meaning of the
words “wind erosion.” He stated that several years ago, the three stations in
ARS’s Wind Erosion Program shifted substantially into PM10 research.
The group at Pullman, Washington, shifted its research entirely to PM10,
the work at Lubbock, Texas, is almost entirely PM10, and the work in
Manhattan, Kansas, is concerned with developing a conservation planning tool
that has a PM10 element in it. This tool, which will be used by the
Natural Resources Conservation Service (NRCS), will evaluate alternative methods
of controlling wind erosion plus PM10. He explained that ARS does
know many things about the practices that need to be put on the landscape to
control the emission of dust from wind. He also stated that for PM2.5,
ARS has shifted heavily into the ammonia area because it is a precursor to the
Tom Coleman asked about ARS’s timetable for releasing its
new information on practices and technologies and getting it out where it can be
used. Dr. Amerman replied that much of it is already out, but the issue is
bringing it together. He said that NRCS and ARS have discussed many times how
they might take information out of the published literature and put it into a
form that goes into recommendations to the field.
Roger Isom recommended that at the next Task Force
meeting, a significant amount of time be set aside for ARS to present some of
their ongoing research, especially on ammonia and PM10.
Bob Flocchini requested copies of the 2001 final reports
on wind erosion from the research stations in Washington, Texas, and Kansas.
Dick Amerman would get these to Dr. Sauerhaft for distribution to the Task
Calvin Parnell briefly expressed some concerns about ARS
using terminology like “dust” instead of “PM10” or “PM2.5,”
and “contaminants” instead of “hazardous air pollutants” or “toxics.” Dr.
Parnell stressed that USDA should be using the same terminology as EPA and the
Stephanie Whalen observed that based on Dr. Amerman’s
comments about ARS having many solutions to PM issues, the problem seems to be
that the system is failing to deliver the solutions to the people who need them.
Phil Wakelyn asked about what constitutes PM10
research at the Pullman and Lubbock laboratories. Dr. Amerman said they work
with wind erosion as an emitter of PM10, as suspension, into the
atmosphere. They are also looking at emission data and factors that they will
ultimately be able to enter into the conservation planning tool. Dr. Wakelyn
inquired whether they were looking at tillage, cultivation, and planting and
what is emitted with different types of equipment under different conditions.
Dr. Amerman answered that the research stations are not working on those things
at the present time, but they would be added to the program with the new
funding. Finally, Dr. Wakelyn requested copies of the ARS reports that deal with
agriculture air quality.
Dr. Sweeten requested a transcript of Ed Knipling’s
presentation. He commented that ARS is in an excellent position to address
ammonia emissions with its large group of experts. He added that as progress is
made on ammonia, they should not lose sight of effluent limitation guidelines.
Dr. Sweeten noted too that only a casual effort had been made in the past to
relate the trade-offs between water and air quality considerations vis-à-vis
nutrient balances. He asked Dr. Amerman if ARS would be focusing on these
important areas. Dr. Amerman stated that ARS is definitely working on both of
these areas. They held a meeting in the spring with representatives from 16
units across the country who are working on ammonia emissions. With respect to
the integration of air and water, the National Program Staff and other
scientists are discussing these issues from a watershed perspective, since they
do not yet know how to define an air shed.
Gary Margheim adjourned the meeting until the following
USDA Agricultural Air
Quality Task Force
May 2, 2002
Hall of States, Room 333
444 North Capitol Street
Washington, D.C. 20001
Viney Aneja Wayne Robarge
Bob Avant Kevin Rogers
Emmett Barker Annette Sharp
Mark Boese Sally Shaver
Tom Coleman John Sweeten
Manuel Cunha Michael Unsworth
Bob Flocchini Phil Wakelyn
Kelley Green Stephanie Whalen
Roger Isom Phyllis Woodford
Gary Margheim, Acting Chair
Other NRCS Support Staff:
Beth Sauerhaft (Designated Federal Official)
John Beyer Liz Rogers
John Brenner Ray Sinclair
Schmidt Roel Vining
Other EPA Support Staff:
Randy Waite Charlene Spells
Penny Lassiter Linda Metcalf
Other Federal Personnel:
Dick Amerman, ARS, NHQ
Ray Knighton, CSREES, NHQ
Bill Hohenstein, USDA, OCE
Gary Baise, Baise & Miller Associates
Michelle Merkel, Environmental Integrity Project
Martha Noble, Sustainable Air Culture Coalition
Bryan Shaw, Texas A&M University
The minutes from the
Meeting in Phoenix were approved.
John Sweeten and Mike Unsworth,
Co-Chairs of the Subcommittee on Air Quality for Animal Feeding Operations (CAFOs),
presented an overview of recent developments. This included: service of three
Subcommittee members on the National Academy of Sciences Ad-Hoc Committee on Air
Emissions from Animal Feeding Operations that has lead to an interim report (Flocchini,
Robarge, Parnell); numerous conference proceedings that involved Subcommittee
members as authors; production of white papers on odor, particulate and ammonia
for the 14-state National Center for Manure and Animal Waste Management, with
public access electronically via the Midwest Plan Service (Sweeten, Parnell,
Robarge); Chairmanship of the recent USDA-ARS external review committee for an
agricultural air quality national research program (Coleman); new significant
grants from USDA-CSREES that will help fulfill elements of the AAQTF’s
recommended research priorities, including the IFAFS (Initiative for Future
Agricultural & Food Systems) and state-specific research grants (Texas,
California, etc.). Then, Sweeten presented major findings of the new report
“Iowa Concentrated Animal Feeding Operations Air Quality Study”, Final Report,
February 2002. This report is receiving a lot of attention nationally in that
it recommended new odor and odorant–based regulatory approaches. Literature
was distributed regarding this and other specific CAFO-related air quality
studies or conferences. Finally, future areas of potential CAFO-subcommittee
inquiry were identified, including possible development of future white paper
topics such as ammonia loss and prevention, PM-fine from CAFOs, and health or
Annette Sharp gave the
Emission Factors Subcommittee report. A summary of survey results from 43
states was presented. Conclusions from participants indicate that top emission
factor development priorities are PM10
for livestock, agricultural burning, and cropland activity. Wayne Robarge
explained the plans of the Subcommittee for Phase II. North Carolina State
University, again, will host a web site for a one-stop listing of agricultural
research that is pertinent to agricultural emission factor development
regarding the date and location of the next meeting. Acting Chair Gary Margheim
announced that the next session would be held in Iowa sometime before August 6,
2002, the date the current Task Force charter expires, and that Beth would work
with Emmett Barker to schedule it.
Next on the agenda was
the discussion of emission reduction credits (ERCs) for agricultural operations.
Roger Isom reminded the group that the Task Force adopted the policy and
background document on emission reduction credits as part of the voluntary
incentive-based compliance plan at the last meeting in Phoenix. Since then the
Implementation Subcommittee held several conference calls and meetings on the
issue, and prepared a more formal proposal for presentation to EPA for a pilot
program for ERCs for agricultural operations. They are drawing from existing ERC
programs in California that have been successful in encouraging stationary
sources to update controls through a voluntary program and a way to recover some
of their cost. The existing programs have also allowed ARS to spend more money
on additional research on finding new controls, because people want to find
controls in order to generate further reductions. Mr. Isom then summarized some
of the emission reduction successes of the different ERC programs. For example,
in Imperial County they have an emission reduction credit for eliminating
burning. It’s regulated by their Rule 214, which is their standard ERC’s. I’m
going to use the term ERC, that’s the acronym for emission reduction credits.
And what they’ve been able to gain by that is a reduction of 50% in agricultural
burning in a little over six years. So it’s been a very successful program down
In the Feather
River Air Quality Management District they allow emission reduction credits for
reductions in rye straw burning beyond what they have already mandated. They’ve
mandated that burning be reduced to 25% of the level five years ago. Credits
are given only if the producer goes beyond established baseline levels.
In the San Joaquin
Valley, ERC’s are obtained from converting from a diesel-fired internal
combustion engine to an electric motor to drive irrigation pumps. And where you
get the reductions in air quality there, the air district takes 10% right off
the top. And when those credits are used, there is a distance offset ratio where
an additional 20-50% of emission reductions is provided.
Based on the results they
have studied, the Implementation Subcommittee feels there is a need for a
standardized nationwide agricultural ERC program. Mr. Isom said the biggest
concern for EPA and the air districts has to do with new source review criteria,
or how ERCs are determined acceptable. The five main criteria an ERC would have
to meet are that it be real, permanent, quantifiable, enforceable, and surplus.
To fit with the voluntary incentive-based compliance program, the ERCs would
also need to be voluntary and not require a permit to operate.
Subcommittee then proposed that the Task Force recommend that EPA consider
creating a one-year pilot program for ERCs for agricultural operations, and that
they limit the program to irrigation pump engines and agricultural burning,
sources for which there are already adequate emissions data. The Implementation
Subcommittee has drafted a conceptual outline for the program, but they would
ask EPA to help develop a more specific protocol for how to handle these types
Manuel Cunha expressed
his support for the pilot program. Emmett Barker agreed that the program is an
excellent idea, and he encouraged the subcommittee to consider offering credits
for the use of new clean-burning diesel engines and low-sulfur fuels, which he
said would provide more fuel flexibility nationwide than the use of electricity.
Kelley Green remarked
that if the pilot program starts with just a few industries, and a dollar figure
is put on those emission reductions, it could give a great deal of incentive to
the other industries that do not have such good emission factors to start trying
to help the efforts to develop those good emission factors.
Annette Sharp reminded
the committee that the Regional Haze Rule specifically instructs states to look
at ERCs as a possible way to provide offsets or some other mechanism to
establishing controls on what they identify as the 26 BART sources. Therefore,
the proposed pilot program is in keeping with existing EPA programs, and it will
assist states as they have to examine ERCs.
Michael Unsworth thought
the ERC proposal was a great way of expanding the voluntary incentive programs,
and he believed the idea of focusing on engines was a strong one because those
emissions are so well determined. He asked about agricultural burning and how
well those emissions are qualified. Stephanie Whalen replied that it is very
difficult to get particulate matter emission factors for agricultural burning,
but two specific studies have been done by Dr. Darley of UC Riverside and by Dr.
Brian Jenkins of UC Davis that arrived at roughly the same emission factors.
Dr. Unsworth then asked
if in practice the pilot program would be monitored by identifying the area
burned, the residue being burned, and an emission factor, and then the credit
would be calculated. Both Stephanie Whalen and Roger Isom answered yes, and Mr.
Isom added that Dr. Jenkins’s work is very crop-specific, so whatever protocol
EPA develops would limit that to those specific crops.
Phyllis Woodford stated
that the timing is excellent for a program like this because if the program
works, it will provide an idea of how to make real, quantifiable, certifiable
types of reductions. She said she is already encouraged by the agricultural
burning reductions that have occurred in a proactive manner in advance of
regulation, and she believes that if an ERC program can promote those
voluntary-type reductions, it is worth developing in cooperation with EPA.
Viney Aneja asked why
such diverse sources as irrigation pumps and agricultural burning are being
considered for emission reduction credits, especially when ag. burning is not
nearly as well-quantifiable in terms of emission factors. Sally Shaver responded
that those were areas that were brought to EPA by the agricultural community
because of California’s situation and the need for emission reductions there.
She admitted that there may be some aspects to these pilots that are not good,
or they may all be good; for the pumps, it may work very well, but they may
decide they never want to do it again for agricultural burning. This is why EPA
is interested in trying some of these new ideas for a short period of time, and
then evaluating the outcomes. Mr. Isom added that these are areas for which air
districts are already issuing credits, but all in different ways. The pilot
program will attempt to determine a uniform way of administering such programs.
Bob Flocchini declared
that he is quite comfortable supporting a pilot program with respect to the
engines because they have well-documented emission factors, but he questioned
the idea for agricultural burning. Based on his experience measuring rye straw
burning, he said it is “nearly impossible” to measure burning with emission
factors because the controlling factor for emissions from burning is
Mark Boese explained the
importance of ERC programs to California, and he remarked that the enforcement
part will be the most complicated issue.
With respect to Ag
burning, Stephanie Whalen stated that there will always be uncertainty in trying
to get exact emission factors for burning; no one will ever get exact
quantitative results that apply to every fire. However, if there is not a move
into some kind of incentive program, agricultural burning emissions will either
be legislated on poor data or based on speculation, and those industries without
economically viable alternatives will just go out of business. For the last
three decades, the rice industry has been looking for economical alternatives to
burning, and so far some of the best Ag universities in the US have not been
able to find any. The rice industry is still moving towards legislated
reduction, but if there is an incentive based on the best science to date to
move beyond the mandated reduction, then Ms. Whalen thinks it is well worth
Manuel Cunha made a
motion to accept the Implementation Subcommittee’s presentation and to recommend
to the Secretary of Agriculture that a one-year pilot program for emissions
reduction credits be implemented for agricultural internal combustion engines
and agricultural burning. The motion was seconded.
Kelley Green reiterated
that it is critical that the Task Force continue to move forward with projects
like this on a much expedited basis. The ERC pilot program is a perfect
opportunity to “put some economic power behind the science,” and projects like
this can really drive the development of the new emissions factors.
suggested that Michael Unsworth’s recommendation to consider meteorology in the
ag. burning program be included. Stephanie Whalen declared, however, that
meteorology is not a factor in a program that provides credits to eliminate
burning. Meteorology is an important factor in determining burn/no-burn days
which postpones burning; it does not eliminate it.
Kevin Rogers called for
the question; the motion passed.
After a break, Bill
Hohenstein, Director of USDA’s Global Change Program Office, gave a presentation
on the Global Climate Change Initiative. He offered a broad overview of climate
change and agriculture, USDA’s Global Change Program, and the Administration’s
initiatives on climate change.
Mr. Hohenstein explained
that the Administration’s plan links emissions to economic activity, therefore
allowing some flexibility to account for the uncertainties in economic growth.
Given economic projections, it is anticipated that the goal will be to reduce
carbon by 100,000,000 tons from 2000 levels. To help achieve this, the President
is establishing a system of transferable credits, and the Department of Energy
(DOE) will take the lead in developing this system. DOE maintains an existing
voluntary reporting system under Section 1605B of the Energy Policy Act; they
are now in the process of improving the quality of that reporting system, and
they have been directed to consult with USDA. Mr. Hohenstein said that the new
voluntary system will be reviewed in 2012 to see how responsible industry is and
how well they manage the potential risks of future regulation.
In addition, the
President directed the Secretary of Energy to identify some targeted incentives
that could be implemented by USDA, and to develop rules and guidelines for how
forestry and agricultural practices could be included in the Section 1605B
Mr. Hohenstein stated
that the final component of the Administration plan is to improve both the
science and technology, and invest in the types of technologies that are going
to reduce emissions in the long-term. He went over some of the changes the
President is recommending to the current interagency mechanism that coordinates
the work of the 14 agencies that are part of the U.S. Global Change Research
Program. The Department of Commerce will take the lead in coordinating the
science program, and the Department of Energy will be in charge of coordinating
the technology program.
For their FY 2003 budget,
the Global Change Research Program is proposing a 20% increase in their global
change research, primarily targeted at technology development and practice
development that can sequester carbon and offset emissions in the Ag and
forestry sectors to improve the measurement and understanding of the emission
sources and sinks, and to improve high-priority basic science. According to Mr.
Hohenstein, USDA will be a key player in the global change research. On February
14, 2002, the President directed the Secretary of Agriculture to provide
recommendations on targeted incentives and on additional steps and incentives
that could be taken to reduce greenhouse gas emissions and increase carbon
sequestration. In addition, USDA has been given the lead in developing the
technical methods that will be used for reporting carbon offset projects under
the 1605B program, and potentially other future programs as well. USDA is
working on developing guidelines that farmers can use to estimate the benefits
of projects such as increasing the use of conservation tillage or converting
marginal lands to trees.
Roger Isom asked how Mr.
Hohenstein’s office was engaging the agricultural community in feedback and in
outreach. Mr. Hohenstein said the program plans to recreate and revitalize the
Climate Change Ag Dialog, a group of representatives from all the major farm
organizations that was originally formed in preparation for the last negotiating
session at The Hague in December of 2000. Dr. Wakelyn said he was part of the
“Climate Change Ag Dialog” and in the meeting summary report of those meetings
it was stated that it was generally felt by the group that C-sequestration
should be framed as a good conservation measure for soil quality and nutrient
management but that C-sequestration is a separate issue from the Greenhouse Gas
(GHG) issue. The Ag dialog group also noted that soil C-sequestration is
influenced by a number of factors and one of the challenges will be to determine
what the best policy for agriculture is and is there really anything in it for
Manuel Cunha stressed that the Global Change Program needs to seriously
consider the economic impacts of these carbon sequestration practices on U.S.
farmers. He also suggested that the program work closely with the Task Force as
well as national agriculture groups and grass roots organizations on the
Stephanie Whalen commented that this program offers an opportunity not
only for some policy decision but also to look at food security and to help
maintain U.S. farmers as viable producers by granting them payments or other
incentives for providing environmental benefits to the entire community.
Emmett Barker asked Mr. Hohenstein if he could provide the Task Force with
a chart that shows the usage of fossil fuels per unit of food and fiber produced
in the U.S., and Mr. Hohenstein said he would try, but their data for some fuel
types were limited.
Next, Beth Sauerhaft opened up the public comment period, and John Brenner
introduced Martha Noble from the Sustainable Air Culture Coalition. Ms. Noble
talked about the Iowa Concentrated Animal Feeding Operation Air Quality Study
done by the University of Iowa and Iowa State, and about research on antibiotic
emissions and emissions of antibiotic resistant bacteria from confined hog
houses being conducted by Dr. James Zahn with the Agricultural Research Service
in Iowa. Ms. Noble strongly suggested that the Task Force look into these
studies and these issues, which she said are important to the public.
Dr. Sweeten responded that during the CAFO Subcommittee report, he had
indeed given a very brief synopsis of the executive summary of the Iowa study.
He also said that the Task Force would consider inviting Dr. Zahn to the next
meeting in the Midwest.
The second speaker, Michelle Merkel from the Environmental Integrity
Project, merely thanked Beth Sauerhaft and Gary Margheim for sharing with her
the materials that were distributed to the Task Force.
After lunch, Calvin Parnell led a discussion of modeled concentrations
versus measured concentrations. He also explained the problems that can arise
for farmers if ambient samplers are placed too close to agricultural operations,
especially since they tend to over sample under such conditions.
Phil Wakelyn reiterated that the Task Force is not saying that
agriculture should be exempt from measurement or regulation; rather, the
committee is advocating that any requirements placed on agricultural operations
be based on good science and implemented fairly and measured correctly.
Bob Flocchini suggested that a question concerning the siting criteria for
ambient air samplers be added to the list of questions for David Mobley He also
mentioned that the IMPROVE data set for PM2.5 will soon be coming out
of U.C. Davis and will be posted on the IMPROVE website.
Dr. Wakelyn said another question to add to this list would be, what are
the confidence limits, that EPA puts on their samplers when they are making
measurements and that they use to determine whether an area is in
non-attainment. Dr. Flocchini responded that the IMPROVE data set lists the
error in each of the individual concentration identifications.
Bob Avant asked if EPA has issued guidance on the appropriate protocol for
the placement of samplers for particulate matter exceeding a mass medium
diameter of ten microns, and he suggested the question be added to the list. Dr.
Wakelyn said he would be sending all of the questions to David Mobley by e-mail,
for Mr. Mobley had promised to answer them.
Wayne Robarge offered another question for the list: is the 15 micrograms
per cubic meter on an average basis over a year a tolerance limit or a
Dr. Wakelyn then invited Calvin Parnell to talk about dispersion modeling.
Dr. Parnell explained that there are two different applications of dispersion
modeling: air shed modeling, which looks at long-range impacts of pollutants,
and the modeling used for permitting purposes, which uses an emission rate to
predict a concentration at some point downwind. The primary application/use of
this latter type of modeling is the Industrial Source Complex (ISC), which is
the EPA-approved model that is used in most states. However, the ISC model
predicts downwind concentration several times higher than the measured
concentration for most agricultural operations, including cotton gins, feed
mills, and all of the ground-level area sources like cattle feed yards, dairies,
farming operations, and field operations. For example, the ISC model
overestimates downwind PM10 concentrations for a cotton gin to be 150
milligrams per cubic meter when samplers measure only 50--one third of the model
Dr. Parnell explained that there are other, better models, such as AERMOD
and ADMS, and David Mobley has said that EPA is considering switching from ISC
to AERMOD. Dr. Parnell stressed again that the Task Force wants agriculture to
be appropriately regulated, so if the states want to use modeling for permitting
purposes, then the model must accurately predict concentration, not give an
estimate that is several times the measured concentration.
Michael Unsworth shared that he has been talking with David Caruthers, who
led the development of the European ADMS model, and Dr. Caruthers has indicated
that there are a number of data sets available and some significant differences
between the various models. Dr. Unsworth added that Gaussian models do not work
particularly well for sources that are especially close to the ground, but some
of the more sophisticated models, such as AERMOD and ADMS, handle low-level
sources better than others. He strongly suggested that somebody conduct
inter-comparisons of these models for some specified agricultural situations;
“until we’ve done that, I don’t think we really can quantify some of the
arguments that we’re putting forward.”
Wayne Robarge commented that accurate models are needed in order to begin
to make a realistic appraisal of health issues. He then asked if a range of
models is needed to be able to handle the dispersion of various gases and PM, or
can one particular model be adapted to predict exposure a set distance from the
boundary line. Dr. Parnell responded that he did not believe it will ever be
acceptable to use a range of models. The issue is that now some states and EPA
are considering replacing the standard model, which is ISC, with AERMOD, so we
are looking at AERMOD to determine whether it will help or hurt agricultural
Stephanie Whalen asked if there were a mechanism by which to present, in a
form acceptable to EPA, a study that would compare these models and then
recommend an official alternative model for low-level sources. She also wondered
whether it would be appropriate for EPA to put out a RFP to do that comparison
with some of their new research funds. Sally Shaver said they could look into
Ms. Shaver then asked Calvin Parnell if other models already existed, or
if they are into model development; Dr. Parnell invited Bryan Shaw from Texas
A&M University to respond. Dr. Shaw said that Texas A&M is not developing a new
model from scratch, but is instead looking at the existing model and trying to
make some adjustments to make it more appropriately applicable. He explained
some of the differences in the way dispersion parameters account for variations
in wind speed, wind direction, and atmospheric conditions, for example.
Viney Aneja remarked that modeling dispersion diffusion for a source near
the surface is very difficult to test. He concurred with Dr. Unsworth that
before the group jumps to too many conclusions about how a model is being used
for regulatory purposes, it would be prudent to do a modeling experiment to see
how two models compare to each other. Dr. Parnell replied that his team at Texas
A&M has been involved in modeling for more than ten years and they have run
various modeling experiments. Their research has convinced them that the current
model used by ISC is overestimating the emissions downwind.
Tom Coleman asked if the ISC model had been validated against actual
measurements, especially since it is being used for permitting. Dr. Parnell
explained briefly how the model was developed and that the only validation they
did was to assume that the dispersion parameters developed by Pascal Gifford
were correct. He added that this model does not pose a problem for croplands,
but it is a great concern for small point sources like cotton gins and dairies.
After a short break, Gary Margheim reported that at that moment, the Farm
Bill was still on the House floor pending a vote, and the Senate vote was
scheduled for the next Tuesday. He passed out copies of the language of the
House and Senate provisions of the Research Title and Conservation Title of the
bill. He also asked Dr. Parnell if he could prepare a one-page summary of the
models he had discussed, since several people had requested such a synopsis.
Next, Sally Shaver briefly explained the President’s Clear Skies
Initiative and presented maps showing the predicted effect of the initiative on
ozone and PM2.5 non-attainment areas. Ms. Shaver stated that the
Clear Skies Initiative is the most aggressive action that has ever been proposed
by a president to reduce emissions from power plants. It provides for mandatory
emission caps, separate trading programs in the east and the west, and improved
environmental performance, all at a lower cost than would occur through the
standard implementation of the Clean Air Act.
Calvin Parnell complimented EPA and the Administration on the initiative;
Bob Flocchini encouraged everybody to take a look at the Clear Skies website in
detail, for it is very impressive.
Gary Margheim quickly reminded the Task Force that they would soon need to
prepare their report, summarizing the committee’s accomplishments over the past
two years; this report will be submitted to the Secretary of Agriculture as she
considers reauthorizing the Task Force charter for another two years. Dr.
Margheim directed each of the subcommittees to provide Beth Sauerhaft with a
one-paragraph summary of the subcommittee’s most significant accomplishment over
the past two years. Dr. Sauerhaft will compile the paragraphs and create a draft
report for the Task Force to review at the next meeting and then provide it to
the Secretary as we move forward with our next charter.
Next, Dr. Margheim introduced Gary Baise from Baise and Miller Associates,
to talk about regulatory choices at the state level. Mr. Baise presented a
history of the work on air pollution problems in the U.S. and a summary of
current PM emissions across the country.
Mr. Baise touched on a number of court cases that will inevitably impact
U.S. agriculture, including EPA’s current CAFO settlement agreement with Premium
Standard Farms; a spray drift case in Puerto Rico, which indicates that the
farmers violated FIFRA and Resource Conservation Recovery Act (RCRA) when
spraying pesticides; and the case Save our Summers versus the Washington State
Department of Ecology concerning the burning of wheat stubble and grass residue.
Mr. Baise asserted, “My point here is the courts are going to drive the
decision-making in the area impacting agriculture. And the research you are
trying to do today should have been done ten years ago. The train has left the
station, and the research that is in place now is what will be put before the
courts and the courts will make a decision.”
With respect to agricultural burning, Mr. Baise informed the group that
the RCRA includes a provision that says agricultural waste can be considered a
solid waste. Residue from crops and timber can be considered discarded material,
and therefore, it is a solid waste. Mr. Baise ended his presentation by
stating, “Agriculture does not have a lot of data that defense lawyers like me
can use in a courtroom. . . . USDA, bless your heart, you are a great
institution, but you’re behind. I know you are looking at priorities, but these
are some of the things we’re going to be fighting in the courts immediately.”
Since no one wished to make public comments, Beth Sauerhaft officially
adjourned the meeting.