Air Regulations in California--the good, the bad and the ugly
Deanne Meyer
dmeyer@ucdavis.edu
Department of Animal Science
University of California, Davis
Attention to the increased impact of animal facilities to atmospheric conditions has already caught the
attention of local and State regulatory agencies. California is located in US EPA Region 9. The
California Air Resources Board (CARB) oversees implementation of the Clean Air Act and California
Air Quality Regulations. There are 15 independent Air Management Districts (AMD) that provide
more local restrictions, enforcement actions, etc. Local AMD are responsible for submitting a State
Implementation Plan (SIP) when Ambient Air Quality Standards are not met.
The Good:
As with many things in life, the good old days WERE. Attention to ammonia emissions has been a
key focus in one or more parts of California since the mid 1980s.
The Bad
Citizen lawsuits began the need for the State to develop a SIPs to address air quality in the South Coast
Air Quality Management District (SCAQMD) and the Sacramento Metropolitan Air District. The
SCAQMD is obligated to reduce Particulate Matter (PM) and Volatile Organic Compounds. The
major contributor to PM during much of the year is particulate nitrate; hence the focus on ammonia
emissions. More recently, Environmental Impact Reports (EIR) written as a component of the
California Environmental Quality Act (CEQA) have described that significant negative impact on the
environment from planned dairy facilities include ammonia emissions and volatile organic compounds.
The Ugly
In California, dairy operators in the Chino basin have braced for new regulations (implementation
anticipated in 2004) to reduce ammonia emissions. The previously developed plans to reduce
ammonia emissions relied heavily on relocation of animals from the basin. If sufficient relocation of
dairy cows and other animals does not occur before January 1, 2004 and ammonia emissions are
identified as greater than the carrying capacity of the basin then ammonia control measures will be
imposed. The level of control will be set by the emission reductions still required to meet the ammonia
“carrying” capacity, after crediting emission reductions due to relocation. Control measures to reduce
ammonia emissions were identified in 1996 as: Dietary manipulation, reduced volume of wet/moist
manure, composting and/or removal of manure to composting facilities, enhanced biodegradation
(enzymatic and microbial applications), optimize pH for standing manure, improve aeration of
stockpiled manure, and other control methods. More recently, a new study has re-emphasized almost
all of the previous list of management practices to reduce ammonia emissions. Also included in the
new list was use of rBST and three times a day milking in lieu of twice a day milking. The consultant
who prepared the report assumed that if the goal of dairy production was a specified volume of milk,
then if each cow produced more, fewer cows would be needed to produce the equivalent milk. And the
assumption continued that there would be less manure (and ammonia) produced. Due to unforeseen
problems associated with relocation, many of the dairy animals remain in the basin. As such, the
South Coast Air Quality Management District will need to promulgate and enforce regulations in late
2002 to reduce ammonia emissions from dairy animals by 50% of the estimated 1995 values. The
District will need to re-evaluate emission factors used for dairy animals, and support research to
quantify anticipated ammonia emission reductions depending on management practice implemented.
They currently hope to be able to certify technologies for ammonia emissions reduction.
A Hearing was held in September, 2000 to address the contribution of dairy animals to the San Joaquin
Air Pollution Control District air emissions. The preliminary report indicated that ammonia emissions
from dairy cattle in each of the counties in the basin ranged from less than 40% to greater than 60%.
Clearly, one of the key issues is the actual values used for emissions per animal and animal
inventories.
The CEQA process requires that CEQA be addressed when a discretionary land use permit is issued by
a government agency. Currently, the permit process for animal feeding operations is being modified
(most operations in the State are regulated through a Waiver of Waste Discharge Requirements). The
Waiver policy sunsets in December as a result of legislation passed previously. For a new Waiver
policy to be developed, or actual Waste Discharge Requirements to be written, CEQA will need to be
completed. This is an expensive (one facility has spent more than $750,000) and time consuming
process and requires public input. There are numerous Counties interested in developing their
Programmatic Environmental Impact Report. Two key issues resulting from these reports are normal
and cumulative impacts to air. Counties are finding themselves faced with reports that will arbitrarily
cap herd size based on assumed values for gaseous emissions. If a facility owner (existing or
proposed) would like to increase their herd size, they will need to provide sufficient mitigation
measures to reduce impact to air quality below significant levels. The County has the right to accept
environmental impacts. However, this will inevitably result litigation from concern citizen groups.
(Litigation that began in 1999 has not been resolved and has almost completely halted the permitting
process for dairy facilities).
Further Reading
Baseline Consulting. 1999. Screen administrative draft #2 environmental impact report for Borba
Farms Dairy. Kern County. July 12. Emeryville, CA.
Dickson, R.J. and S.R. Tate. 1988. Evaluation of emissions from selected uninventoried sources in
the State of California. Final Report. AR Contract No. A5-147-32.
Halberg, E.D. 1984. South Coast Air Quality Management District Engineering Division Report on
area source emissions for c/v 1983 from agricultural livestock waste CES. No. 66605. October 6.
Diamond Bar.
KVB, Inc. 1978. Control of hydrocarbon emissions from stationary sources in the California South
Coast Air Basin. Final Report, Volume I (Volume II Appendix). Tustin, CA. Contract ARB 5-1323.
South Coast Air Quality Management District. 1996. Draft appendix IV-A. Stationary and mobile
source control measures. CM#97WST-01. August. Diamond Bar, CA.