1 Final Draft Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570

SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

REVISED PROPOSED AMENDMENTS TO 

RULE 4570 (CONFINED ANIMAL FACILITIES)

October 21, 2010 

Prepared by: Sandra Lowe-Leseth, Air Quality Engineer 

Nichole Corless, Air Quality Specialist 

Anna Myers, Air Quality Specialist 

Katy Linebach, Air Quality Specialist 

Glenn Ramming, Air Quality Inspector 

Ramon Norman, Air Quality Engineer 

Jonah Aiyabei, Air Quality Engineer 

Sheraz Gill, Supervising Air Quality Engineer 

Leland Villalvazo, Supervising Air Quality Specialist 

Tom Busenbark, Supervising Air Quality Inspector 

Ellyce Baldwin, Supervising Air Quality Inspector 

Reviewed by: Jessi Fierro, Senior Air Quality Specialist 

Stephanie Hitchman, Senior Air Quality Specialist 

James Sweet, Senior Air Quality Specialist 

Joven Nazareno, Senior Air Quality Engineer 

George Heinen, Supervising Air Quality Engineer 

Errol Villegas, Strategy and Incentives Program Manager 

Scott Nester, Senior Projects Manager 

Morgan Lambert, Director of Compliance 

Samir Sheikh, Director of Strategies and Incentives 

I. SUMMARY 

In June of 2006, the Governing Board of the San Joaquin Valley Air Pollution Control 

District (District) adopted the most stringent emissions regulation for confined animal 

facilities (CAF) in the nation, District Rule 4570. With Rule 4570, District staff 

established a comprehensive set of regulatory mitigation measures designed to reduce 

emissions from the various areas of CAFs, such as the housing and manure 

management systems. The 2006 rule applies to commercial operations such as larger 

dairies, beef feedlot, poultry, swine, and other cattle facilities. The significant 

commitment and investment from affected CAFs subject to Rule 4570 has resulting in 

emissions reductions exceeding the emissions reductions commitments for the rule 

included in the District’s 2004 Extreme Ozone Attainment Demonstration Plan (for the 

federal 1-hour ozone standard). 
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Revised Proposed Amendments to Rule 4570

The District is now seeking to amend Rule 4570, as committed in the District’s 2007 

Ozone Plan (for the federal 8-hour ozone standard). The proposed rule has undergone 

revision since the June 2010 draft, as staff has devoted extensive energy to evaluating 

and furthering science in the area of CAF-related emissions and potential mitigation 

measures. The District has worked closely with researchers and industry stakeholders, 

and this effort has yielded profound new information that has been incorporated into the 

revised amendments to the rule. In particular, scientific research has shed new light on 

dairy silage emissions and potential mitigation measures, and this research has been 

carefully considered in the Revised Proposed Rule 4570. 

The Revised Proposed Rule 4570 would lower the applicability threshold limits to bring 

in major poultry sources and additional dairy CAFs; tighten the mitigation measures; 

and improve rule enforceability by adding additional compliance language, including 

monitoring, testing, and recordkeeping. Revised Proposed Rule 4570 exceeds 

Reasonably Available Control Technology (RACT) requirements, even though the 

majority of the CAFs subject to the rule are not subject to RACT. The revised proposed 

rule also exceeds the emission reduction commitments contained in the District’s 2007 

Ozone Plan.

At the June 17, 2010 public hearing, the District Governing Board voted to continue the 

hearing to consider adoption of Rule 4570 until October, based on Environmental 

Protection Agency (EPA) testimony and request. The continuance was intended to 

allow more time for review and comment on the proposed rule. Since the June hearing, 

the District held multiple meetings with EPA, stakeholders, and scientists. The District 

has worked closely with EPA and stakeholders to address all concerns and comments. 

The resulting rule revisions include a refining of menu measures as well as an increase 

in feasible, mandatory measures. The Revised Proposed Amendments to Rule 4570 

and Final Staff Report has been brought before the District’s Governing Board for public 

hearing and adoption on October 21, 2010. 

A. REASONS FOR RULE DEVELOPMENT AND IMPLEMENTATION 

The San Joaquin Valley Air Basin is nonattainment for the National Ambient Air Quality 

Standard (NAAQS) for 8-hour ozone. The District’s 2007 Ozone Plan included a 

confined animal facilities control measure (S-AGR-2) to amend Rule 4570 to achieve 

additional volatile organic compound (VOC) reductions. The District’s analysis of the 

applicability, stringency, and enforceability of Revised Proposed Amendments to Rule 

4570 demonstrates that this proposed rule would exceed the minimum requirements for 

Reasonably Available Control Technology (RACT). Although VOC emissions contribute 

to ozone, VOC reductions are generally less important to the Valley’s long-term 

attainment goals as compared to reductions in oxides of nitrogen (NOx). Development 

of new Rule 4570 is intended to obtain as much VOC emissions reduction from the 

source category as is technologically and economically feasible, as determined by the 

District's Governing Board. 
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Since amending Rule 4570 is a control measure in the District’s 2007 Eight-Hour Ozone 

Plan, it is subject to Code of Federal Regulations (CFR), Clean Air Act (CAA), and 

California Health and Safety Code (CH&SC) requirements. It should be noted that 

unlike the previous version of the rule, this rule amendment project is not subject to the 

requirements of California Health and Safety Code (CH&SC) 40724.6. This rulemaking 

project is intended to support the attainment goals of the District’s 2007 Eight-Hour 

Ozone Plan. The proposed amendments to Rule 4570 (Confined Animal Facilities) will 

seek to obtain as much reduction of volatile organic compounds (VOCs) from confined 

animal facilities as is expeditiously practicable, technologically feasible, and 

economically reasonable, as determined by the District’s Governing Board. 

Furthermore, the rule is intended to satisfy the ozone plan commitments as identified in 

Table 1. 

Table 1 – Ozone Plan Commitments 

Subject Reference Requirement 

Timeline CAA Section 

172(c)(1) 

Ozone attainment plans shall implement 

control measures as expeditiously as 

practicable, and provide for attainment. 

RACT 

CAA Sections 

182(b)(2) and 

182(f) 

Ozone attainment plans shall assure that 

reasonably available control technology 

(RACT) for NOx and volatile organic 

compounds (VOC) is in use at sources and 

on source categories at or above the RACT 

threshold. 

BARCT CH&SC 

40919(a)(3) 

Ozone attainment plans should provide for 

best available retrofit technology (BARCT) 

for existing permitted sources. 

All Feasible 

Controls 

CH&SC 

40914(b)(2) 

Ozone attainment plans should include "all 

feasible control measures." 

Deadline 

District 2007 

Eight-Hour 

Ozone Plan 

Rule adoption by the second quarter of 

2010. 

Reductions 

District 2007 

Eight-Hour 

Ozone Plan 

The plan commits to 6.7 tons per day of 

VOC reductions in 2012 and 22.9 tons per 

day of VOC reductions in 2023. 

District Rule 4570 is a VOC rule, and therefore underwent a RACT analysis as a part of 

the 2009 RACT Demonstration for Ozone State Implementation Plan analysis. CAA 

Section 182(b) (2) states that ozone attainment plans shall assure that RACT for VOC is 

applied at certain sources. A RACT analysis requires an examination of three broad 

elements: applicability, stringency, and enforceability. These elements must be 
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examined against Federal rules, regulations, and technology guidelines, as well as 

comparing it against rules from other Districts in California. 

The District believes that this proposed rule exceeds RACT. A detailed RACT analysis 

will be provided to the District’s Governing Board before the October 21, 2010 Board 

hearing. 

The California Health and Safety Code (CH&SC) Section 40914(b) (2) requires the 

District to adopt ozone attainment plans that include “all feasible control measures”. 

The California Air Resource Board (ARB) interprets “all feasible control measures” to 

mean that, at a minimum, a district should consider regulations that have been 

successfully implemented elsewhere. They should also consider going beyond what 

has already been accomplished by evaluation of new technologies and innovative 

approaches that may offer potential emission reductions. Further, districts should 

consider not only technological factors, but also social, environmental, economic (e.g., 

cost effectiveness), and energy factors which prevail in the district, along with the 

resources realistically available to the district to adopt, implement, and enforce the 

measures.” Therefore, these amendments will consider other rules to address all 

feasible measures and RACT. 

B. RULE DEVELOPMENT PROCESS 

As part of the comprehensive rule development process, a public scoping meeting was 

held in March 2009. Comments received as a result of the scoping meeting were 

evaluated and, as appropriate, incorporated into proposed rule provisions. 

District staff conducted a public workshop to present the rule amendments and seek 

comments from the public. A socioeconomic focus group was held immediately after 

the workshop to outline the socioeconomic process and solicit economic information 

from stakeholders. Public comments and cost information received were incorporated 

into the Final Staff Report and proposed rule amendments. District staff also held 

multiple technical meetings as requested by stakeholders. 

The Revised Proposed Amendments to Rule 4570 and Final Draft Staff Report were 

brought before the District’s Governing Board for public hearing and adoption on June 

17, 2010. However, the District’s Governing Board decided to continue the hearing until 

the October Governing Board hearing based on testimony heard from the EPA to allow 

more time to review and comment on the rule. 

Since the June hearing, the District held weekly conference calls with EPA to discuss 

the rule in more detail and address outstanding concerns. The District also coordinated 

multiple meetings with EPA and dairy stakeholders, as well as environmental groups, 

stakeholders and silage experts. These meetings provided valuable information 

regarding current practices, new scientific information and concerns from all view points. 

The District also held additional meetings with stakeholders representing each type of 
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CAF to gain a better understanding of the different operations. The District has worked 

closely with the EPA and stakeholders to address all concerns and comments. The 

Revised Proposed Amendments to Rule 4570 and Final Draft Staff Report will be 

brought before the District’s Governing Board for public hearing and adoption on 

October 21, 2010.

II. CURRENT RULE 4570 

Current Rule 4570, as adopted in June 2009, limits VOC emissions from large CAFs 

through mitigation measures that target each major aspect of CAF operations, from feed 

to housing to manure management to land application. Operators must choose a 

specified number of limited, management practice menu measures for each operation. 

The current rule is available at <http://www.valleyair.org/rules/currntrules/r4570.pdf>. 

III. SUMMARY OF RULE AMENDMENTS 

Recently completed emissions studies at California dairies have indicated that dairy 

feed (primarily due to silage) is the most significant source of VOC emissions at dairy 

operations. These studies have shown that VOC emissions from open surfaces of 

silage piles and the silage-containing total mixed rations (TMR) placed as feed for cattle 

have significantly higher VOC flux rates than other sources and account for the majority 

of total VOC emissions measured at dairy facilities. These studies have also indicated 

that the feed VOC emissions are dominated by alcohols, primarily ethanol. The 

proposed rule amendments will strengthen the current mitigation measures included in 

the rule for feed sources and will include new additional requirements and management 

practices to reduce emissions of alcohols and total VOCs from this important source 

category. 

However, the opposite has been found to be true for CAF operations that feed a nonsilage based diet. A letter received from Dr. Mitloehener in regards to an emissions 

study on manure, enteric, and feed emissions, states that emissions from calf and 

feedlot cattle feed were not detected. Since all of the feedlot and calf operations feed 

dry grains and hay, which does not include silage, then it will be assumed that 

emissions from the feed from these facilities are negligible. The results from this study 

can also be transferred to all other facilities that feed a dry grain to their animals. A 

review of swine and poultry facilities found that the feed also consists of dry grain with 

very low moisture content. Therefore, all mitigation measures related to emissions 

directly from the feed have been removed from the rule for all CAFs except dairies. A 

silage category however either remains or has been added under most CAFs in case 

silage is fed to the animals at these CAFs. Where silage is fed, those facilities would 

have to comply with the applicable silage mitigation measures to ensure that emissions 

are being controlled. 
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The proposed rule amendments also go beyond the current rule in multiple aspects. 

Definitions and measure-specific testing and monitoring information have been added 

for clarification and increased enforceability. The threshold has been lowered for dairies 

and poultry in order to achieve additional emission reductions. 

For clarity, the requirements tables for each CAF have been split into Phase I and 

Phase II mitigation measures. Phase I mitigation measures are those applicable to 

facilities currently subject to Rule 4570. Phase II tables include mitigation measures 

applicable to facilities that would be subject to Rule 4570 under the proposed regulatory 

threshold. The table of mitigation measures would be amended to require more 

measures, as well as make current measures more stringent. Some mitigation 

measures have been refined to provide clarity. Mitigation measures from all categories 

of CAFs, which were determined not to be as effective as other measures, not 

technologically feasible or cost effective, were removed from rule language. Many of 

the tables have been revised and enhanced to specify mandated measures in high 

emission source categories such as feed, silage and housing while still maintaining 

flexibility to accommodate the variability of individual operators and facilities. 

The following is a summary of proposed amendments to each type of CAF mitigation 

measures: 

A. Dairies 

• The regulatory threshold has been changed from 1,000 milking cows to 500 milking 

cows. 

• Additional mitigation measures proposed, primarily for silage. The new mitigation 

measures would reduce VOC emissions through a combination of compaction 

standards, silage quality, and face and pile size management. 

• Current mitigation measures would be made more stringent by making some 

measures mandatory for feed and housing mitigation measures. 

• One requirement applied different frequency for medium dairies (greater than or 

equal to 500 milking cows), and large dairies (greater than or equal to 1,000 

milking cows) 

• The solid manure handling table would apply only to large dairy CAFs, as is 

required in the current rule.

B. Beef Feedlots and Other Cattle Operations 

• Additional mitigation measures proposed, primarily for silage. The new mitigation 

measures would reduce VOC emissions through a combination of compaction 

standards, silage quality, and face and pile size management. 

• Current control requirements would be made more stringent with multiple required 

measures as well as more frequent monitoring. 
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C. Swine 

• Mitigation measures would be adjusted from optional lists of potential measures to 

a mandatory list of required measures. 

D. Poultry 

• In order to clarify rule requirements and address EPA concerns regarding poultry 

mitigation measures, the poultry section would be divided into Layer operations, 

and Broiler/Duck/Turkey operations. 

• Mitigation measures would be adjusted from an optional list of potential measures 

to mandatory list of required measures. 

E. Monitoring Requirements 

Monitoring requirements would be added to Section 6.0 of the rule to enforce the 

proposed changes to the mitigation measures in the rule. 

F. Administrative Requirements 

Recordkeeping requirements would be added, amended, and expanded to detail the 

records for each mitigation measure, ensuring that mitigation measures are utilized on a 

regular basis. 

G. Compliance Schedule 

Owners/operators of facilities subject to the proposed amendments would be required to 

submit permit applications by April 21, 2011 and full compliance with Phase II would be 

required within one year after either the Authority to Construct or the Permit to Operate 

is issued, whichever is earlier. Owners/operators of new or modified facilities that 

become subject to the rule under the new proposed regulatory thresholds would be 

required to comply with Phase II requirements. 

IV. GLOBAL CLIMATE CHANGE AND GREENHOUSE GASES 

The California Global Warming Solutions Act of 2006 created a comprehensive, multiyear program to reduce green house gas (GHG) emissions in California, with the goal of 

restoring emissions to 1990 levels by 2020. In the coming years, the ARB and the 

Legislature will be developing policies and programs to implement Assembly Bill 32 (AB 

32). There are many win-win strategies that can reduce both GHG and criteria/toxic 

pollutant emissions. However, the District’s primary mission remains to achieve 

attainment with air quality standards to protect public health. Therefore, when situations 

that involve tradeoffs between GHG and criteria or toxic pollutants arise, the District will 

give precedence to reducing criteria or toxic pollutant emissions due to the more 
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immediate public health concerns associated with such pollutants. A detailed analysis is 

included in the CEQA Negative Declaration for this rule. 

V. SOURCE CATEGORY BACKGROUND 

Confined animal facilities (CAF) are used in the raising of livestock for the purpose of 

providing dairy products, meat, and eggs. Due to the different methods of confinement 

and associated manure management, there is no typical CAF. The design and 

operation of a CAF varies depending on animal type, regional climatic conditions, 

business practices, and preferences of the operators. 

The raising of livestock (livestock agriculture) has gone through significant changes 

since the 1990s. The size of all types of livestock agriculture farms continues to 

increase. Today, meat and dairy products typically originate on farms whose herds of 

cattle or hogs, or flocks of chickens are much larger than in the past. A big driver in the 

structural change in livestock agriculture is increased productivity and, through that, 

lower production costs to the farmer. These lower production costs are passed on to 

the consumer as lower prices for meat, dairy products, and eggs. However, to maintain 

competitiveness with similar facilities located in other non-regulated states, many of the 

additional regulatory costs are absorbed by the facilities without the cost being passed 

on to consumers. 

One example of the shift to large-scale production is the dairy industry. Nationally, only 

about 10% of all dairy cows were housed on farms with more than 1,000 head in 1992. 

By 2007, that ratio rose to 36% of all dairy cows. The shift to very-large dairies (1,000+ 

head) had its origin in California and other western states. Looking at California 

specifically, the state has become the largest producer of milk in the nation. The eight 

counties of the San Joaquin Valley are all in the top-ten California counties for milk 

production, with Tulare County heading the list. Tulare County alone produced almost 

as much milk as the entire state of Pennsylvania; the state ranked number five on the 

2007 list of top milk-producing states. Tulare County was also well ahead of Minnesota, 

the sixth largest milk producing state. 

For livestock agriculture, evidence to-date suggests that production costs fall as the 

farm size increases up to some threshold level. The largest dairy farms (1,000+ head) 

have production costs that are 15% lower than the next largest size class (500-999 

head). Production costs then level out, suggesting that there is no unique optimal dairy 

size above 1,000 cows. For example, dairies with 2,000 cows have average costs 

similar to dairies with 1,000 cows. 

Other types of livestock agriculture have also increased their average farm size. 

Production cost-saving for larger dairy operations is also true of layers (chickens raised 

to lay eggs), broilers (chickens raised for meat), pork and beef producers. Nationally, 

the median production of broilers (50% larger and 50% smaller) is 600,000 broilers per 
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year. In 2002, the median production was 520,000. Active District permits echo this 

national trend. 

A. Dairy Operations 

For this description, dairy operations are defined as those operations producing milk or 

animals for facilities that produce milk. In order to produce milk, the cows must be bred 

and give birth. Typically, the gestation period for dairy cattle is nine months and dairy 

cows are bred again approximately four months after calving. Milk production typically 

peaks shortly after calving and then declines. Commonly a cow will produce milk for ten 

to twelve months and then be dry approximately two months. Thus, a dairy operation 

may have several types of animal groups present including heifers, lactating cows, dry 

cows, calves, and bulls (for breeding purposes). Approximately 25% of a milking herd is 

replaced each year, but replacement levels can be as high as 40% for intensively 

managed herds (EPA 2001). 

Calves are typically housed in individual pens or hutches. Older animals are typically 

housed in freestall barns, dry lots, tie stalls/stanchions, or any combination of the 

aforementioned. The freestall barn is the predominant type of housing system used on 

dairy farms for lactating cows. In a freestall barn, cows are housed in large pens with 

free access to feed bunks, waterers, and stalls for resting. Standard freestall barns 

have a feed alley along the center, with one feed bunk on each side. The feed bunks 

are separated from the housing sections of the barn by stanchions. Animals stand on a 

feed lane directly behind the stanchions during feeding. Majority of the animal 

excretions are deposited on this feed lane. Animals stand on the corral side of the feed 

lane to eat; this is where the majority of the animal excretion occurs. In some cases, 

cows may be confined in or have access to corrals. Corrals are typically fenced in 

areas that may have shade. Corral confinements are similar to beef feedlots described 

later in this report. Tie stalls/stanchions are common on smaller dairy farms and older 

facilities. In this type of housing system, cows are confined in a stall for feeding, but 

have access to a dry lot or pasture for exercise. A mechanically or manually cleaned 

gutter is located behind each row of stalls for manure collection and removal. 

Feeding and watering practices vary for each animal type. In general, calves are 

nursed for four to five days after birth. Calves are then fed a milk replacement until 

weaning, which generally occurs at about eight weeks of age. During this period, a 

grain-based starter diet is introduced. This starter diet is fed to calves until they are 

approximately three months old. At approximately three months, calf rumen 

development allows a shift to a roughage-based diet. 

Older cattle and calves being raised for milk production are commonly fed a roughagebased diet. The principal constituents of these diets are corn or grain sorghum silage 

and legume or grass and legume hays with feed grains and byproduct foodstuff added 

in varying amounts to satisfy energy, protein, and other nutrient requirements. The 

manure tends to be generated in a semi-solid state (liquid to slurry). 
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Manure with a total solid content of 10% or less can be handled as a liquid. In slurry or 

liquid systems, the manure is flushed from alleys or pits to a storage facility. Typically, 

effluent from the solid separation system or supernatant from a pond or an anaerobic 

lagoon is used as flush water in animal housing. The supernatant is the clear liquid in 

the lagoon that is overlying the solids that settle below. Dairy manure that is handled 

and stored as a slurry or liquid may be mixed with dry manure. Liquid systems are 

common in large dairies due to their lower labor costs and ease of use with automatic 

flushing systems. Manure handled as solids can be removed by mechanized scraping 

systems, a tractor, or a chain scraper. Typically, the solid manure scraped is stock piled 

and dried for disposal through land application or used as bedding for the cows. 

B. Beef Cattle Feeding Operations 

This animal sector includes adult beef cattle (heifers and steers). Beef cattle may 

spend all, part, or none of their lives on a CAF. There are three types of operations in 

the beef industry: cow-calf operations, backgrounding operations, and finishing 

operations. These operations are typically conducted at separate locations that 

specialize in each phase of production, but may occur at a single location. 

Cow-calf operations are a source of heifers and steers fed for slaughter. These animals 

are fed primarily hay with some grain and other foodstuff. Backgrounding or stocker 

operations prepare weaned calves for finishing. The backgrounding process is highly 

dependent on feed prices. Typically the animals are fed the lowest priced feed at the 

time, which may be forages or crop residues, with the objective of building muscle and 

bone mass at a low cost. The duration of the backgrounding process may be from thirty 

(30) days to six (6) months old. Typically, high grain prices favor longer periods of 

backgrounding by reducing feed costs for finishing or fattening. After approximately 150 

to 180 days, animals in finishing operations will reach slaughter weights of 1,050 to 

1,250 pounds. However, some feedlots start with younger or older cattle and the 

finishing cycle may be less than 100 days or over 270 days. Accordingly, feedlots 

typically have between 1.5 to 3.5 cattle turnovers per year. 

In any case, animals are typically segregated by production stage in pens with feed 

truck access. The animals are typically fed two to three times per day using feed bunks 

located along feed alleys that separate the individual pens. 

For these types of operations, the manure is commonly handled as a solid. Solid 

manure is typically scraped or moved by tractors to stockpiles. Manure accumulates in 

areas around feed bunks and water troughs most rapidly, thus these areas may need to 

be cleaned during the finisher cycle. 
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C. Other Cattle Operations 

The phrase “other cattle operations” is a catch-all for cattle CAFs that are not dairies or 

beef feedlots. Types of cattle operations that fit in this category are heifer ranches and 

calf ranches. Dairy calf or heifer ranches are facilities that raise young female dairy 

animals to maturity. Details of animal ownership vary depending on the operation. 

When the cow is mature enough to breed, she is moved to a dairy, then either 

inseminated or put with a bull for breeding. After a calf is born, it is shipped to a dairy 

calf ranch or heifer ranch; the now-mature cow goes “into production” at the dairy and 

the cycle begins again. 

D. Swine Operations 

The production cycle for hogs has three phases: farrowing, nursing, and finishing. The 

first phase begins with breeding and gestation over a 114-day period followed by 

farrowing (giving birth). After farrowing, the newly born pigs or piglets normally are 

nursed for a period of three to four weeks until they reach a weight of approximately ten 

to fifteen pounds. Typically, there are from nine to eleven pigs per litter. Sows can be 

bred again within a week after a litter is weaned. Sows normally weigh 400 to 460 

pounds and produce five to six litters before they are sold for slaughter. 

Weaned pigs are fed a starter ration until they reach a weight of approximately 40 to 50 

pounds. At this point, they are typically eight to ten weeks of age. Then the animals are 

fed a growing and finally a finishing ration until they are approximately 240 to 280 

pounds at which point they are approximately 26 weeks of age and ready for slaughter. 

The diet varies, but it typically includes small grains such as wheat and barley, corn and 

soybean meal. 

The animals are typically housed in confinement buildings that are either totally 

enclosed or open-sided with curtains. Totally enclosed facilities are mechanically 

ventilated throughout the year. Open-sided buildings are naturally ventilated the 

majority of the year, but may be mechanically ventilated when the curtains are closed 

due to weather conditions. Manure may be flushed from the floor of the housing or fall 

through slats in the floor to a pit underneath the floor. 

E. Poultry Operations 

Poultry facilities operate either as layer ranches for egg production or as broiler ranches 

where birds are grown for the fresh meat market. Poultry facilities, called ranches in 

reference to their specialized operation, may consist of one or more farms on properties 

that may be several miles apart. Several barn-like houses may make up a farm. A 

chicken layer house may have over 100,000 layers; a typical chicken broiler house 

contains approximately 20,000-25,000 birds; and a typical turkey broiler house contains 

approximately 10,000 birds at any one time. 
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In the United States, approximately 61% of the chicken layer houses and a majority of 

the breeder and broiler houses use power ventilation instead of natural ventilation. The 

most common type of power ventilation is tunnel ventilation. In tunnel-ventilated 

houses, all the fans are clustered at one end of the house and the fans push the air to 

the other end of the house. Curtains on the houses may be used on a non-routine basis 

for ventilation, particularly during colder weather. 

Studies indicate that most chicken layer houses produce approximately two cubic yards 

of waste per week per five hundred chickens. Although a small amount of liquid manure 

may occur from egg washing operations located on the facility and a small amount of 

bedding may be collected as waste, poultry excretions account for a majority of the 

waste. Typically, hens are confined in a layer house that consists of many layer boxes 

positioned above the ground. Layer facilities remove manure, ranging from one to three 

times per year (every 17 to 52 weeks). 

In broiler facilities, complete litter removal from the house occurs one to two times per 

year. Litter removal generally occurs every third flock but can be as high as every 7 

flocks. Before introducing a new flock, the house is left empty, typically for five days. 

During this interlude, the operator adjusts the temperature and other ambient conditions 

in the house. In the broiler industry, the new flocks of birds are brought into the houses 

as chicks are raised for approximately 45 days, until they reach the desired weight. 

Shortly thereafter, the grown birds are removed and the house is again left empty for 

approximately five days to sanitize. This approximately 55-day cycle is the production 

period for one flock. Depending on management practices, litter production ranges from 

0.5 to 0.7 pounds per pound of live bird weight. 

 

Poultry excretions and bedding materials, such as rice hulls, are removed either by 

scraping or by flushing. In a scrape system, the litter is either swept or scraped from the 

house into a pile or piles outside the house. Typically, concerns about transmitting 

diseases among birds and flocks necessitate trucking the scraped litter offsite shortly 

after removal. The liquid handling system is similar to dairy flush systems. However, 

less than 15% of the poultry operations in the San Joaquin Valley use liquid manure 

handling systems. 

VI. EVALUATION OF THE LATEST SCIENTIFIC INFORMATION 

When Rule 4570 was originally adopted in 2006, the research available at the time of 

adoption pointed to handling of solid and liquid animal wastes as being the largest 

sources of VOC emissions at a dairy. District staff has made extensive efforts to review 

and advance dairy emission-related research. Recent dairy emission research studies 

performed under the District, other interested agencies, and stakeholders have 

significantly increased knowledge of dairy emissions and have also shed some light on 

potential strategies to reduce these emissions. The studies have been performed on 

California dairies and reflect current dairy practices. In contrast to the earlier focus on 
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other sources, the current research indicates that silage piles and placing feed in the 

feed bunkers are a larger portion of the total dairy emissions than solid/liquid manure 

handling. The District is in the process of finalizing a revised dairy emission factor to 

reflect the new information. The draft emission factor and supporting staff report is 

attached in Appendix H. 

Important findings of the latest dairy research studies include: 

• Manure storage ponds and lagoons, which were previously thought to be a major 

source of VOC emissions at dairies, now appear to emit a comparatively small 

fraction of the overall dairy VOC emissions; 

• Feed at dairies is a significant source of VOC emissions. The exposed faces of 

silage piles that are used to store and preserve silage to be fed to the cattle and 

the total mixed ration placed in lanes for cattle consumption emit significant 

amounts of VOCs, particularly alcohols. 

• Emissions of alcohols (primarily ethanol) from feed, fresh manure, and directly 

from cows appear to comprise a significant fraction of dairy VOC emissions; 

• Manure deposited in open corrals appears to be an important source of VOC 

emissions on some dairies; 

• Emissions of volatile fatty acids (VFAs) are important but not as significant as 

previously estimated during the District’s first revision of the dairy VOC emissions 

factor; 

• The practice of flushing freestall barns more frequently has the potential to 

reduce VOC emissions from cow housing areas. 

• Several of the compounds that have been identified as important components of 

dairy emissions, such as alcohols and volatile fatty acids, are highly soluble in 

aqueous solutions. This property may be important when developing potential 

mitigation strategies. 

• Land application of solid and liquid dairy manure contributes a relatively small 

amount to total VOC emissions at dairy. 

• Seasonal variation in emissions may be an important factor to consider when 

developing annual emission estimates. The seasonal variation in emission rates 

was observed to be more pronounced with ammonia emissions than VOC 

emissions. 

A VOC emission study was also conducted for California feedlot cattle and calves. This 

study is not as extensive as the VOC emission studies that have been conducted at 

dairies but will still provide important information on emissions from other cattle facilities. 

The study evaluated enteric (emissions directly from the cattle), fresh waste, and feed 

emissions from the various types and ages of cattle. Although the study was completed 

over a year ago, the results are currently undergoing peer review with the publishing 

journal’s peer review committee and the complete results have not yet been made 

available to the District. In order to provide a better understanding of the emissions 

from these facilities, Dr. Frank Mitloehner, the principle researcher for the study, 

submitted a letter (attached in Appendix I) sharing his overall findings. The results of 
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the emissions data for these animals were all below the detection limits of the 

instrumentation used to measure the emissions. Since the diet of these types of 

animals is completely different from dairy cows, consisting of dry grains, it is expected 

that the emissions from these animals and the feed would be far lower or negligible in 

the case of dry feed. Although this letter cannot be used to develop an emission factor 

for these sources, it does provide valuable information for use in tailoring mitigation 

measures to those facilities/sources that have a larger emissions profile, such as dairy 

and silage type feed. 

VII. EMISSION CONTROL TECHNOLOGY 

The majority of VOC emissions from confined animal operations are fugitive 

(evaporation of VOC from feed or waste, for example) or related to gaseous emissions 

generated directly from livestock (enteric). The fugitive nature of the emissions from 

agricultural sources including large amounts of land area imposes challenges and 

limitations on the types of controls that can be feasibly applied to reduce emissions. 

Unlike other stationary sources, where the majority of emissions are collected and 

released through a chimney, pipe, vent, or stack, emissions from agricultural sources 

are spread out over large areas and are very dilute at the point of release. These 

emissions cannot reasonably be captured at the point of release since capture of these 

emissions would entail monumental changes, which have not yet been developed and 

are likely infeasible, to the methods that are currently used for agricultural production. 

Rule 4570 groups CAF emission sources into five areas: feed/feed storage, animal 

housing, solid waste handling, liquid waste handling, and land application of animal 

wastes. In this way, all of the major emission sources within a given CAF are included 

in the control requirements. Within each area, rather than capture fugitive emissions at 

the point of release, Rule 4570 provides for management practices that minimize the 

formation of VOCs or control VOCs by moving the VOC-forming material to a controlled 

situation. Some examples of mitigation measures are feed manipulation, frequent 

scraping of animal housing, and covering of silage piles. 

Management practices are not the only way that VOC emissions can be controlled. 

Owner/operators may have installed control technology to meet water standards or to 

reduce nuisance complaints from neighbors. These controls are expensive, both in 

terms of capital outlay and in terms of on-going operating and maintenance costs. 

However, they provide a high level of VOC control. Rather than penalize an operator 

who installs these controls by requiring that the mitigation measure be implemented in 

addition to the costly control technology, Rule 4570 allows the owner/operator to 

replace a mitigation measure with the advanced control technology under Alternative 

Mitigation Measures. In this way the emissions from the facility are reduced beyond 

what is required in the rule. Select mitigation measures are discussed in more detail in 

Appendix E of this report. 
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VIII. PROPOSED AMENDMENTS TO RULE 4570 

District Rule 4570 generally limits VOC emissions from large CAFs through required 

implementation of various management practices. Each major aspect of CAF 

operations is covered – from food to housing to manure management to land 

application. Operators must choose a certain number of management practices from a 

limited table of measures for each operation. 

The following paragraphs detail the specific changes proposed by District staff to 

strengthen individual portions of the rule. 

A. Menu Approach 

As stated previously, the design and operation of a CAF varies depending on animal 

type, regional climatic conditions, business practices, and preferences of the 

owners/operators resulting in no typical CAF. As in the current rule, the proposed 

amendments to Rule 4570 generally provide a list of mitigation measures for affected 

owners/operators. This acknowledges that not all facilities can implement the same 

management practices due to infrastructure, conditional use permits, water board 

permits, soil types, production contracts, and other limitations. It also enables the 

owners and operators, who understand their particular operation best, to choose the 

mitigation measures that make the best environmental and economic sense for their 

facility. 

A menu approach provided much needed flexibility for the variability of Valley 

operations. Each measure has now been reevaluated to minimize measures 

addressing the same source and clarify any exclusive mitigation measures or those that 

address the same source. Many mitigation measures have also been mandated for the 

various CAFs. Any additional mitigation measures that remain to be chosen from have 

been justified by technological infeasibility, discuss below, or a quantitative analysis in 

Appendix C. Allowing for some additional measures rather than specifically mandating 

all requirements allows the flexibility for producers to select measures that will work best 

for their facility based on their own type of housing, manure management practices, and 

feed storage and management while minimizing their compliance costs and achieving 

the same emission reductions. The measures listed in the additional categories are all 

considered to be equally effective at reducing emissions from the specific source 

category, but cannot be mandated at every facility. Also, in some cases, the choices 

would be mutually exclusive, meaning that selecting one measure would eliminate 

implementing the other management practices in that section. For example, lagoons 

can be either phototropic or anaerobic, but not both. 

Based on the revised cost estimate in Appendix C, dairies will spend $61,312,210 

annually, at $6,695 per ton of reduction, to comply with the proposed rule revisions. 

This is a significant cost to bear to implement the rule. The emission reductions 

achieved by the measures included in the proposed rule are already projected to 
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exceed the reductions required from this rule in the District’s attainment plan. 

Mandating additional requirements would result in increased compliance costs which 

will have a detrimental economic impact on the industry and go far beyond RACT and 

BARCT requirements. Appendix C has a more detailed discussion about each individual 

additional measure. 

For clarity, the tables for each CAF have been split into Phase I and Phase II mitigation 

measures. Phase I mitigation measures are those applicable to facilities currently 

subject to Rule 4570. Phase II tables includes increased requirements for some 

facilities currently subject to Rule 4570, as well as mitigation measures applicable to 

facilities that would be subject to Rule 4570 under the proposed regulatory threshold. 

Stakeholders have provided information to support specified control management 

practices that are feasible but not yet implemented by all facilities. 

B. Section 3.0 – Definitions 

In this section, 20 definitions would be added. The new definitions are: 

Biofilter Mature Cow Processed Cereal Grain or 

Processed Corn 

Cereal Grains Medium Dairy Rain Event 

Composting Nursery Pig Split-Sex Feeding Program 

Dry Rolled Corn Oxygen Barrier Film Steam Flaked Cereal Grains 

Feedlanes Phase Feeding Steam Flaked Corn 

High Moisture Corn Poultry Molt Swine 

Large CAF Poultry Litter 

Biofilters can be used to reduce VOC emissions in certain situations. The definition for 

large CAF is taken from the California Code of Regulations Title 17, Section 86500. 

The purpose of the definition is to improve reader clarity, especially with respect to 

CAFs that would be new to control requirements. The purpose for adding the medium 

dairy CAFs definition to the rule is to reduce the wordiness of certain rule provisions. 

Definitions for the remaining items were added to provide clarity and more specification 

in the control requirement tables. 

Several definitions have been modified. Wording has been added to the definitions for 

standards from the Natural Resource Conservation Service California Field Office to 

make clear which specific document is being referenced. Animal waste has been 

changed to litter or manure throughout the rule language as requested by a commenter 

at the workshop and for a more appropriate characterization. 

The definitions for aerated static pile and emission mitigation plan have had language 

removed. The removed language in these definitions was actually requirements for 

these items. Section 5 is the appropriate place for requirements; however, the 

language removed from the two definitions is redundant to Section 5 requirements. 
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C. Section 4.0 – Exemptions 

The regulatory threshold, meaning the minimum number of animals that trigger the 

control requirements of the rule (mitigation measures) are listed in Table 2 below. 

Stated another way, if the number of animals at the facility is, at all times, below the 

number of animals listed in Table 2, the facility would not be required to implement 

applicable mitigation measures. The operator would, however, be required to show that 

the facility continues to qualify for the exemption by keeping adequate records of the 

number of animals at the facility. 

The regulatory threshold is being lowered for dairy, chicken, and duck operations. 

These changes will subject additional facilities to the rule and therefore, provide 

additional emission reductions. Beef feedlots, other cattle, swine and other categories 

will remain at the same threshold given a minimal number of additional facilities that 

would be added, if any at all. 

Table 2 – Proposed Regulatory Thresholds 

Livestock Category Current 

Regulatory Threshold 

Proposed 

Regulatory Threshold 

Dairy 1,000 milking cows 500 milking cows 

Beef Feedlots 3,500 beef cattle 3,500 beef cattle 

Other Cattle Facility 7,500 calves, heifers, or 

other cattle 

7,500 calves, heifers, or other 

cattle 

Poultry Facilities 

Chicken 650,000 head 400,000 head 

Duck 650,000 head 400,000 head 

Turkey 100,000 head 100,000 head 

Swine Facility 3,000 head 3,000 head 

Horses Facility 3,000 head 3,000 head 

Sheep and Goat 

Facilities 

15,000 head of sheep, 

goats, or any combination 

of the two 

15,000 head of sheep, goats, 

or any combination of the two 

Any livestock facility 

not listed above 30,000 head 30,000 head 

D. Class Two Mitigation Measures 

The current rule contains options for facilities to implement certain “Class Two” 

mitigation measures that may have the potential to achieve increased emission 

reductions when compared to the required “Class One” mitigation measures. The Class 

Two mitigation measures are practices that are beyond the requirements of RACT and 
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BARCT. These measures were included in the rule to give credit to operators who have 

made substantial investments in facilities and equipment that result in air quality 

benefits equivalent to or greater than those achieved by one of the Class One mitigation 

measures and to encourage operators to go beyond the basic rule requirements and 

implement innovative practices to further reduce emissions. However, these measures 

cannot be reasonably mandated because of a variety of concerns including animal 

health, technological factors, environmental factors, and economic feasibility. The 

technological and economic feasibility of various selected Class Two mitigation 

measures are analyzed to more clearly illustrate that it is not currently feasible to require 

facilities to implement these measures. A detailed analysis of Class Two measures is 

included in Appendix E. 

E. Section 5.0 Requirements 

In the current rule, some of the requirements related to facility mitigation plans and 

permits are located later in the rule. District staff is proposing that all of the 

requirements be located at the beginning of Section 5.0 and grouped by subject matter. 

District operating permits would be required for all facilities that are at or above the 

regulatory threshold. All CAFs that are at or above the regulatory threshold would also 

be required to have a facility emission mitigation plan and to submit enough information 

to allow District staff to estimate the emissions from the CAF. Previously, the rule 

stated facilities may demonstrate 30% reductions in lieu of a mitigation plan. District 

staff proposes that facilities should demonstrate equivalent facility-wide reductions in 

place of a mitigation plan. This ensures that projected emission reductions would occur 

regardless of the emission control approach. 

The sub-sections for temporary suspension of mitigation measures and the sub-section 

for induced poultry molt have been combined into one. Since the reporting and records 

requirements were essentially the same, having two different sections for the 

suspension of mitigation measures was redundant. 

District staff is proposing to retain that an operator would be required to implement all of 

the mitigation measures within 365 days of receiving an Authority-to-Construct or 

Permit-to-Operate, whichever is sooner. An implementation time of one year would 

allow the District adequate time to provide much needed compliance assistance through 

new operator outreach, seminars, and multi-language informational materials to new 

regulated CAF operators. In addition, it would allow operators to make the necessary 

changes to their facilities to comply with the rule. The 365-day allotment was also 

originally required during the previous rule. 
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F. Dairy CAF Mitigation Measures 

Dairy operations can be divided into six functional processes: feed/feed storage, silage, 

milk parlor, animal housing (freestalls and corrals), solid/liquid waste handling, and land 

application. Rule 4570 echoes these divisions and requires operators to implement a 

certain number of management practices (mitigation measures) for each functional 

process to control VOC emissions. 

Due to a larger variability in operations with medium size dairies, some distinctions have 

been made between the number and frequency of mitigation measures to be 

implemented for medium and large dairy CAFs. Medium size dairies will have to 

implement all of the mitigation measures listed for the large dairies except for the 

frequency for removing manure from freestall beds. Medium dairies would be required 

to clean the freestall beds at the current level of once every 14 days, whereas the large 

dairies would be required to clean once each week. Also, only large dairy CAFs would 

be subject to the solid manure section due to feasibility and potential cost, as described 

in further detail below. 

1. Dairy Feed Mitigation Measures

As discussed earlier, recent research studies about the operational source of dairy 

VOCs have demonstrated that the total mixed rations are a significant source of VOCs. 

Therefore, four measures will be mandated for all dairy CAFS and operators will choose 

one additional mitigation measure from three measures: 

a) Mandatory mitigation measures

(1) Feed according to NRC guidelines.

The NRC guidelines are geared to supply the exact blend and quantity of nutrients 

needed by the animals with the minimum being excreted and lost to the environment. 

One significant group of compounds that can be excreted is starch. Starch, in the 

presence of oxygen and certain aerobic bacteria, will be food for the bacteria, which 

then break down starch molecules to simpler compounds, most of which are VOCs. 

Strategies which minimize starch in the manure, therefore, will help minimize the 

emission of VOCs. This mitigation measure is required for all dairy CAFs because the 

guidelines have been recently updated to reflect the latest scientific information about 

the efficient conversion of feed to milk without endangering the health of the cow. By 

feeding only the nutrients necessary, the excretion of material that could serve as a 

substrate for VOC-producing reactions is minimized and the potential for VOC 

emissions in manure-handling operations after feeding would also be reduced. 

 
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(2) Push feed within 3 feet of feedlane fence.

This is a new measure added to the rule. The measure reduces emissions by 

minimizing the surface area of the feed bunker. 

(3) Begin feeding TMR within 2 hours of grinding and mixing.

The timeframe for feeding TMR was reduced from 48 hours to 2 hours to reflect recent 

information that shows that feed emissions occur within the first 12-24 hours after the 

feed is put into the feed lane. 

(4) Store grain in a weatherproof structure or covering, October through May.

Although dry grains are not expected to have any emissions associated, there is a 

potential for secondary emissions to occur from the decomposition of wet grain due to 

heavy rain events. Therefore, this measure requires that dry grain be covered with a 

weatherproof structure during the Valley’s wet season. 

b) Additional mitigation measures

In addition to requiring the above four measures, dairies will have to select one of the 

three additional mitigation measures: 

As stated earlier, allowing for some additional measures rather than specifically 

mandating all requirements allows the flexibility for producers to select measures that 

will work best for their facility. Mandating additional requirements would result in 

increased compliance costs which will have a detrimental impact to the health of the 

industry. Refer to Appendix C for a more detailed discussion about each individual 

mitigation measure. 

(1) Feed steam-flaked, dry rolled, cracked or ground corn or other steam-flaked, 

dry rolled, cracked or ground cereal grains.

Recent studies have shown that fermented feed can be a large source of VOC 

emissions at agricultural facilities. Using dry feeds eliminates potential emissions from 

fermentation. Additionally, processing these dry feeds increases the digestibility of the 

feed. This reduces excretion of starch and other nutrients in the manure reducing the 

potential for VOC emissions. Language has been changed to more accurately capture 

the feed types specified by the measure to feed steam-flaked corn or other cereal 

grains. 
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(2) Remove uneaten wet feed from feed bunks within twenty-four (24) hours after 

the end of a rain event.

Feed that gets wet after a rain event will have a greater potential for secondary 

emissions to occur from decomposition. This measure requires that this feed be 

removed within 24 hours after the end of a rain event. 

(3) For total mixed rations that contain at least 30% by weight of silage, feed 

animals total mixed rations that contain at least 45% moisture.

As noted above, recent research has indicated that silage emits more VOCs than 

previously thought, more specifically, ethanol. Ethanol is also known to be highly 

soluble in water. Since silage is a large part of TMR, then increasing the moisture 

content of the TMR would decrease the amount of VOCs emitted because the water in 

the TMR would absorb the VOCs that would otherwise escape into the air. 

California dairies in the San Joaquin Valley have access to an amazing variety of food 

processing residuals that also happen to be appropriate for dairy feed. The measure 

remains an additional mitigation measure due to stakeholder concerns of the possible 

detriment to the health of cows. The moisture of the TMR can be influenced by both the 

NRC guidelines and the available commodity. In addition, adding excessive moisture to 

a TMR that contains a high percentage of fermented forage may decrease cows’ intake 

of feed dry matter and reduce their consumption of neutral detergent fiber. Decreased 

intake of dry matter and fiber may decrease milk production. Reduced fiber intake can 

also adversely affect the health of cows by increasing the risk of ruminal acidosis and 

other ailments; therefore, making the moisture content a required element would limit 

the operator’s flexibility in providing appropriate nutrition for the health and productivity 

of the animals. 

c) Retired mitigation measures

The following measures will be retired from the rule: 

(1) Remove feed where animals stand to eat every 14 days.

(2) Remove spilled feed around the feed bunk every 14 days.

New information from industry stakeholders has stated the amount of feed left behind or 

spilled is minimal. In addition, based on the recent studies, the emissions from the feed 

are generated within the course of the first day and removing the feed within 14 days 

would result in only minimal emission reductions. A reduced cleaning timeframe to 

capture the potential emissions would be unachievable in practice due to the labor 

intensity and hours needed to perform this task resulting in a high cost to the industry. 
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2. Dairy Silage Mitigation Measures

Crop harvest occurs only a few times per year, but animals need to be fed every day. 

Cattle operations have learned how to preserve crops grown on-site so that they can 

reduce costs associated with purchasing feed. Silage is plant material (usually wheat, 

alfalfa, or corn) preserved through a fermentation process. The shredded plant material 

is stacked into a pile with a certain amount of compaction and then allowed to ferment. 

Fermentation is an anaerobic process, therefore, silage piles are formed in a way to 

exclude as much oxygen as possible. Quality silage is achieved when lactic acid is the 

predominant acid produced during the fermentation stage. Speed of fermentation is 

also important because the faster the fermentation is completed, the more nutrients will 

be retained in the silage. Since lactic acid is non-volatile, increasing the production of 

lactic acid during the silage fermentation process has the double benefit of increasing 

the quality of the silage and reducing emissions from organic compounds that are more 

volatile. The emission reductions from changing the chemical makeup of fermentation 

by-products are realized at three points: 

• during the fermentation process, 

• while removing the silage from the pile and 

• when the combined silage and other feed components (called total mixed rations 

or TMR) are laid out for the animals to eat. 

Recent emission studies at California dairies indicate that emissions from silage are a 

significant portion of the total dairy VOC emissions. In order to control as much of these 

emissions as possible, District staff proposes that individual dairies implement one 

mitigation measure from a list of two choices. 

a) Mandatory mitigation measures

There are no mandatory measures for this section. 

b) Additional mitigation measures

As stated earlier, allowing for some additional measures rather than specifically 

mandating all requirements allows the flexibility for producers to select measures that 

will work best for their facility. Mandating additional requirements would result in 

increased compliance costs which will have a detrimental impact to the health of the 

industry. Refer to Appendix C for a more detailed discussion about each individual 

mitigation measure. 

(1) Management practices for silage pile formation and pile management 

This management practice requires that a total of four out of five mitigation measures 

are selected to maximize the emissions reductions. These selection choices are 

detailed below: 
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District staff used information from industry representatives to establish a baseline of 

current silage practices and to develop the requirements to reduce the exposed surface 

area of silage piles to less than the current baseline. Reducing the exposed area from 

the current baseline will reduce emissions. District staff reviewed scientific and 

technical literature concerning the process of making silage to develop the mitigation 

measures that will ensure the production of quality silage while also minimizing 

emissions from the silage. 

(a) Cover the surface of silage piles, except for the area where feed is being 

removed from the pile, with a plastic tarp that is at least 5 mils thick (0.005 

inches), multiple plastic tarps with a cumulative thickness of at least 5 mils 

(0.005 inches), or an oxygen barrier film covered with a UV resistant material, 

within 72 hours of last delivery of material to the pile.

This measure is mandatory and all silage piles must be covered within 72 hours of the 

last delivery of material to pile. This will not only preserve the silage material but will 

reduce the emissions that would have been released from an uncovered pile. 

(b) Create silage piles in a manner to achieve a minimum packing density.

This measure is mandatory. Dr. Charles Krauter of California State University, Fresno 

has indicated that preliminary information from dairy emissions research that he has 

completed has shown that silage with higher density resulted in less total VOC 

emissions from both the silage piles and the total mixed ration (TMR) prepared from the 

silage and placed as feed for animals. Packing density is important when making silage 

because it enables the ensiled plant forage to quickly move from an aerobic phase to an 

anaerobic phase and achieve a rapid drop in pH that will hinder further microbial 

decomposition. The rapid drop in pH is primarily caused by conversion of soluble 

carbohydrates to nonvolatile lactic acid. Sufficient packing creates the conditions that 

allow lactic acid bacteria to dominate the fermentation rather than other organisms that 

will produce greater amounts of VOCs. Sufficient packing followed by covering of piles 

also reduces yeast counts in the silage. Because yeasts are primarily responsible for 

the production of ethanol during fermentation of silage, reducing the number of colony 

forming units of yeast will reduce the amount of ethanol generated and the 

concentration of ethanol in the silage. Ethanol is one of the most volatile compounds 

found in silage; therefore, reducing ethanol concentrations will reduce emissions. 

Increased density in silage piles reduces porosity, which will reduce transport of 

emissions to the atmosphere. Reduced porosity also limits the amount of air that 

penetrates the silage piles that causes aerobic decomposition and heating of the piles. 

 

Within silage formation, dairy operators can meet silage pile standards in one of three 

ways: by measuring the bulk density; by manipulating silage pile formation parameters 

to meet a calculated bulk density; or by implementing specific work practices during 

silage pile formation that would lead to good silage compaction and formation. 
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Additionally, this management practice requires that dairy operators choose two more 

work practices from a list of three selections. The three management practices include 

minimizing the pile’s exposed surface area; and using a silage facer or maintaining a 

smooth vertical face; and inoculation of silage during pile formation or application of 

additives to reduce yeast counts. The following paragraphs describe these work 

practices. 

(c) Minimizing the pile’s exposed surface area and/ using a silage facer or 

maintaining a smooth vertical face

This stringent set of requirements, in addition to the packing density and coverage 

requirements, accommodate the variability in harvesting and silage management 

practices found in the numerous dairies located in the San Joaquin Valley. The first two 

practices both deal with managing the exposed area of silage piles by reducing the 

open area or maintaining a smooth vertical surface. These practices will reduce the 

exposed area and porosity at the working face of the silage piles, which will reduce 

emissions from the working face. These practices will also reduce infiltration by 

spoilage organisms that can produce VOCs and heating caused by aerobic 

decomposition. Many dairies will not be able to choose both of these measures without 

significant changes to their current feed handling operations. In order to store the 

amount of silage needed for the large dairies in the San Joaquin Valley, silage piles 

must have a very large volume. Because of limited space on the ground and the need 

to increase the size of silage pads, silage piles often must be built very high. The height 

of typical silage piles will often be beyond the reach of equipment that must be used to 

maintain a completely smooth surface. Because the equipment used at many dairy 

operations cannot reach the highest portion of the piles, the surface of the piles will 

often not be smooth but rather will have bulges and overhangs that will be gathered and 

fed when they collapse and fall to the ground. 

(d) Inoculation of silage during pile formation or application of additives to 

reduce yeast counts

Silage additives, such as inoculants and additives to reduce yeast counts, are another 

mitigation measure that has shown promise to reduce emissions. Due to the variability 

and costs associated with effective use of these additives, this practice will be included 

as an additional mitigation measure. The least costly measure would involve 

inoculating the ensiled material with homolactic bacteria. The purpose of inoculation 

with homolactic bacteria is to shift the fermentation such that greater amounts of lactic 

acid are generated rather than volatile compounds, such as ethanol. Because the 

bacteria in inoculants are living organisms, there will be inherent variability in the 

effectiveness of the various products available. The inoculants must provide sufficient 

bacteria to outcompete the naturally occurring microorganisms in the ensiled forage and 

must be applied in a fairly uniform manner to achieve optimum benefit. The successful 

application of the inoculants is related to several factors including, the type of crop 

harvested, the stage the crop is harvested, the moisture content of the forage, the 
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buffering capacity of the forage, the density of the piles, etc. Because properly 

harvested and ensiled corn will generally have higher counts of naturally-occurring 

homolactic bacteria, inoculating corn silage with homolactic bacteria will often not cause 

great changes in fermentation when compared to other crops. In some instances 

inoculation of corn with homolactic bacteria can cause greater aerobic losses when the 

silage is fed because the inoculants will shift the fermentation away from the production 

of acetic acid and other organic acids that inhibit aerobic growth of yeast when the 

silage is fed. With corn silage, inoculating with homolactic bacteria is probably most 

effective when something else in the process has not been optimal. For other crops, 

inoculating with homolactic bacteria is probably more likely to provide a benefit but a 

great deal of variability will still remain. As stated above, the other additives and 

preservatives are much more expensive than inoculants. The greater expense of these 

additives often results in farmers applying minimal amounts to the forage rather than the 

optimal rate. Additionally, these additive practices will have issues similar to those 

associated with the use of inoculants. For example, the organic acids used are 

corrosive, must be handled with care, and may require specialized application 

equipment and the quality and characteristics of the specific crop being ensiled will still 

be very important factors in the success of these additives. Therefore, because of the 

dairy-to-dairy, crop-to-crop, and even season-to-season variability, it is more reasonable 

to allow individual producers to assess their operations to determine if this measure 

would be beneficial for their particular operation. Because conservation of the feed 

value of silage will also reduce the amount of dry matter lost as VOC emissions, the 

choices of producers based on the assessment of their operation will lead to efficient 

reductions of VOC emissions without being excessively costly or impractical because of 

the variability at different operations. 

(2) Use a sealed feed storage system 

The second control measure for silage is for dairy operators to utilize a sealed feed 

storage system like an AG-BagTM. Sealed systems for silage have been around for 

several years. The principle for these systems is to limit oxygen contact with the plant 

material being ensiled. Ensiling is an anaerobic process and having significant amounts 

of oxygen available promotes the growth of aerobic organisms rather than the desired 

anaerobic organisms. Closing off the materials from air also keeps VOCs that would be 

created as part of the ensiling process from being emitted into the air. Also, by keeping 

the VOCs close to the bacteria, the bacteria would have to potential to further convert 

the VOCs into carbon dioxide and water. 

With a very small working face compared to traditional silage piles and being totally 

enclosed, sealed feed storage systems alone have inherently fewer emissions. The 

emissions from AG-BagsTM would be comparable to facilities selecting all the required 

controls from the first table of controls. Although there are advantages of using this 

system, there are also limitations for the quantity of ensiled material handled at some 

dairies. The sealed system bags have limited diameters, so an operator would need to 

set aside a significantly larger area for silage storage compared to piling material 
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vertically as is currently done for silage piles. Sealed systems are already in use at 

some dairies for certain crops; however, since sealed systems take up more space per 

volume of silage they are not feasible for every dairy. A non-trivial portion of the 

Valley’s dairies have limited area available for storage of feed and silage due to owned 

property restraints, neighboring farms, right of ways, etc. There is a huge cost 

associated with the purchase of land to be able to accommodate such a measure and in 

some instances that option may not even be available to some facilities. Therefore, this 

measure will be included as one of the two additional measures. 

c) Retired mitigation measures

The following measures are being retired from the rule: 

(1) Enclose silage in a bag or weatherproof structure and vent to VOC control 

device with greater than 80% VOC capture and control

Any active venting of silage to a control device would ruin its feed value because silage 

must remain anaerobic. Further analysis of this Class Two mitigation measure is 

included in Appendix E. 

(2) Eliminate silage from animal diet

Based on the information currently available, this management practice is not feasible 

for most dairies in the San Joaquin Valley and would potentially cause adverse 

environmental impacts if implemented on a large scale. Growing of silage crops is 

currently required in the nutrient management plans for most dairies to reduce the 

leaching of nutrients into groundwater. For dairies to switch from growing silage crops 

to growing crops that require fewer nutrients would generally require approval of the 

Regional Water Quality Control Board. In addition, the change would require dairies to 

acquire more land and/or export a much larger portion of manure offsite. Reducing the 

amount of silage used would also require dairies to substitute other types of feed. This 

feed would need to be purchased resulting in increased costs to the dairy operators. It 

is also likely that the purchased feed would need to be trucked in to the dairies. The 

need to transport more feed to the dairy would increase fuel usage and trucking 

emissions. Additional details on the potential impacts of eliminating silage are 

discussed in a letter provided by Deanne Meyer, Ph.D., UC Davis Livestock Waste 

Management Specialist and Peter Robinson, PhD., UC Department of Animal Science 

Cooperative Extension Specialist (see Appendix I). 
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3. Dairy Milking Parlor Mitigation Measures

The recent research indicates that the frequent flushing required for dairy health 

standards results in very low emissions from this dairy operation. For this reason, no 

change is proposed for mitigating VOC emissions from milking parlors. Further analyses 

of Class Two mitigation measures are included in Appendix E. 

4. Dairy Freestall Barn Mitigation Measures

Dairy cows spend most of their time in freestall barns or corrals. Mitigation measures 

include work practices to minimize the accumulation of solid or liquid animal waste. Two 

freestall mitigation measures would be required by all dairy CAFs: pave feedlanes; and 

flush, vacuum, or scrape freestall flush lanes. Operators would have a choice of three 

additional mitigation measures from which they would need to choose one to 

implement. 

a) Mandatory mitigation measures

(1) Pave feedlanes, where present, for a width of at least 8 feet along the corral 

side of the feedlane fence for milk and dry cows and at least 6 feet along the 

corral side of the feedlane for heifers.

A new specified mitigation measure has been added to the freestall list to pave feed 

lanes at least either six or eight feet on the corral side of the feedlane fence depending 

on animal size and type. Heifers are smaller animals that produce much less manure 

than milk cows so six feet feedlanes are sufficient to allow cleaning of the manure 

deposited in this area. The South Coast Air Quality Management District’s Rule 1127 

(Emission Reductions from Livestock Waste) requires that the facilities subject to the 

rule pave their feedlanes. The purpose of the requirement is to remove manure more 

completely from the areas where it is most likely to be deposited without digging up the 

floor of the freestall barn or corral. The paving also facilitates flushing or scraping of 

manure from freestall barns and corrals. 

(2) Flush, scrape, or vacuum freestall flush lanes immediately prior to, 

immediately after, or during each milking or at least three times per day

This measure will remove manure more completely from the freestall flush lanes, 

thereby reducing emissions. 
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b) Additional mitigation measures

As stated earlier, allowing for some additional measures rather than specifically 

mandating all requirements allows the flexibility for producers to select measures that 

will work best for their facility. Mandating additional requirements would result in 

increased compliance costs which will have a detrimental impact to the health of the 

industry. Refer to Appendix C for a more detailed discussion about each individual 

additional measure. 

The following measures are not mandated to allow for flexibility in different operating 

practices. 

(1) Use non-manure-based or separated solids-based bedding for at least 90% of 

the bedding material.

This measure would reduce the amount of manure sitting around and releasing 

emissions. 

(2) Remove manure that is not dry from individual cow freestall beds or rake, 

harrow, scrape, or grade freestall bedding

Of the freestall mitigation measures, there are certain measures which have been 

combined as they address the same source. These include cleaning freestall flush lanes 

and freestall bedding. The measures combined to clean freestall bedding are also 

performed more frequently in South Coast AQMD Rule 223 for large dairy CAFs, which 

is the rule that corresponds to District Rule 4570. Large dairies would be required to 

rake, harrow or scrape freestall beds at least once every seven days. Operators of 

medium dairy CAFs who elect this particular mitigation measures would perform the 

mitigation measure at least once every 14 days. 

(3) Have no animals in exercise pens or corrals. 

This requirement has remained in the freestall table because of animal welfare 

concerns. This measure would reduce emissions by reducing the area in which the 

animals have to excrete. Restricting access to exercise pens by enclosing the barn 

may exacerbate animal welfare and animal health concerns, as access to open exercise 

pens is important for good breeding and pregnancy rates and hoof health. This measure 

could affect animal health and therefore should remain as an operator choice. 

c) Retired mitigation measures

Four mitigation measures are being removed from this control table. 
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(1) Inspect water pipes and troughs.

Recent studies have shown that the vast majority of VOCs such as alcohols and volatile 

fatty acids are highly soluble in the liquid form. Since freestall barns are generally a wet 

system, consisting of at least two flushes per day and a naturally high moisture content 

of the manure, emissions will prefer to stay in the aqueous form. Therefore, inspecting 

water troughs and pipes for leaks will not provide any additional benefit and this 

measure will be removed. 

(2) Install floats or other devices in water troughs to prevent spills.

This measure is considered standard practice and therefore will be removed from the 

rule. A constant supply of cool clean water is an essential requirement for all livestock. 

For large operations such as dairies and feedlots in the Valley, this requirement is met 

by the use of numerous water troughs at various locations around the cattle housing 

areas. Because of the large number of troughs required, the only practical way to 

ensure a constant supply of water in the troughs is to use an automated filling system. 

This is accomplished by plumbing each trough into the piped water system and using a 

float valve to control the water level at the trough. The float valve automatically shuts of 

the water when the trough is full. As cattle drink and the water level begins to go down, 

the float valves automatically turns on the water supply to replenish the trough. The float 

valves are therefore not optional, but are rather integral and essential components of 

the automatic water supply system. 

(3) Using a dry waste handling system to remove animal waste. 

As stated above, recent studies have shown that the vast majority of VOCs such as 

alcohols and volatile fatty acids are highly soluble in the liquid form. Since freestall 

barns are generally a wet system, consisting of at least two flushes per day and a 

naturally high moisture content of the manure, emissions will prefer to stay in the 

aqueous form. Due to the emission reduction benefits achieved from liquid manure 

handling, the District will not prefer one manure management practice to the other. 

(4) Vacuum manure and apply to land through injection or incorporation 

This measure would be removed since it is not applicable to freestalls. This measure is 

covered under land application. 

5. Dairy Corrals Mitigation Measures

Staff proposes that dairies shall implement six specified mitigation measures in addition 

to selecting one out of the three remaining additional measures. 
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a) Mandatory mitigation measures

Operators would be required to implement six specific mitigation measures: 

(1) Pave feedlanes, where present, for a width of at least 8 feet along the corral 

side of the feedlane fence for milk and dry cows and at least 6 feet along the 

corral side of the feedlane for heifers

This measure is further described above in the freestall section. 

(2) Clean corrals four times per year; or at least once between April and July and 

at least once between September and December.

This measure would reduce manure build-up in the corrals, thereby reducing emissions. 

(3) Manage manure depth in concreted areas to less than 12 inches; or 

scrape/flush feed concrete lanes daily for mature cows and every seven days for 

support stock.

This measure would reduce manure build-up in the concreted feed lanes. The 

frequency for this measure has been increased from once every 7 days for mature cows 

to once every day. There is also another mitigation measure of keeping manure below 

12 inches, which serves the same purpose. 

(4) Inspect and repair leaks every 7 days.

The District has re-evaluated this measure and has reduced the frequency of inspecting 

and repairing pipes by 50%, from 14 days to 7 days. The District believes that this is a 

proper frequency that leaks do not cause moist conditions in open corrals. In open 

corrals, moist conditions lead to anaerobic decomposition of manure. Emissions of 

gaseous compounds can be reduced by faster drying of manure and minimization of 

moisture. Minimizing the moisture in the manure reduces the moisture needed by the 

microbes that decompose the manure to form VOC. 

(5) Slope corrals; ensure proper drainage; or maintain a dry surface.

As stated earlier, VOC emissions are formed when manure undergoes anaerobic 

decomposition. An increase in moisture will increase anaerobic decomposition and in 

return will increase VOC emissions. Proper management of the corrals can reduce or 

eliminate excess moisture in the corrals. Sloping corrals and/or providing proper 

drainage allows the corrals to dry more quickly and effectively. Emissions are 

significantly decreased when manure is dried out quickly. 

These measures would reduce moisture in the corrals and allow for proper drying of 

manure. The slopes given in this measure are recommended from the California Code 
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of Regulations, Title 3, Division 2, to allow corrals to dry more quickly and effectively. 

Depending on the severity of a rain event, it may take several days before water in the 

corrals can naturally be cleared out. There have been times where weather has 

rendered corrals inoperable and uninviting. There are mechanical means that can be 

used (i.e., pumps) to remove the water out more rapidly. However, this process takes 

time, money and resources, all of which are limited at a CAF, especially when there can 

be anywhere from a dozen corrals up to hundreds of corrals at a facility. It is in the best 

interest of CAF operators to clear out the excess water from the corrals as quickly as 

possible primarily for animal health purposes. Even though more time may be needed, 

the District believes that if the proper steps are taken in a timely fashion, 48 hours 

should be just enough time to remove excess water from the corrals. By adhering to 

these measures, puddles in the corrals can be eliminated and liquid manure can drain 

where it can be potentially stored or treated in lagoons or ponds.

(6) If the facility has shade structures, use light permeable material; install on an 

uphill slope; install in a North/South orientation; or clean under corral shades.

Two mitigation measures have been added - to clean under corral shades once every 

14 days and to install shade structures in a North/South orientation. Since cows will 

tend to congregate and spend long periods in shaded areas, a large portion of the 

manure will be deposited in these areas; therefore, the purpose of all the shade 

measures is to ensure that the manure under the shades are dried out or removed 

frequently if the manure is not dry. Installing shades in the north/south orientation 

allows the manure to dry out more rapidly due to the changing of the sun’s direction 

throughout the day. With the north-south orientation, the sun will strike every part of the 

floor area at some time during the day. This will help to keep the floored area dry. 

b) Additional mitigation measures

As stated earlier, allowing for some additional measures rather than specifically 

mandating all requirements allows the flexibility for producers to select measures that 

will work best for their facility. Mandating additional requirements would result in 

increased compliance costs which will have a detrimental impact to the health of the 

industry. Refer to Appendix C for a more detailed discussion about each individual 

additional measure. 

In addition to the mandatory mitigation measures outlined above, dairy operators are 

expected to implement one additional mitigation measure out of three management 

practices. 
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(1) Manage corrals such that the manure depth in the corral does not exceed 

twelve (12) inches at any time or point, except for in-corral mounding. 

(2) Knockdown fence line manure build-up prior to it exceeding a height of twelve 

(12) inches at any time or point.

These two measures will remain choices to provide for operator flexibility. Both 

measures would require many labor hours and are dependent on the current practices 

employed at the dairy. These measures could also be affected by weather not allowing 

equipment into the corrals at certain times of the year. Flexibility is necessary because 

of the variability within the affected emissions category. Dairy housing corrals vary by 

geographical location, age of the facility and standard practices at the time of 

construction, size and financial resources of the facility, as well as the operator’s 

preferences. Dairy size and financial capability also determine design features at the 

time of construction. Large or more financially capable dairies may be able to invest 

significant amounts of money for engineered grading and proper sloping of corrals, as 

well as paving over more extensive corrals areas. Smaller dairies, on the other hand, 

may have more difficulty complying with these requirements. 

Further information is included in Appendix C. 

(3) Use lime or a similar absorbent material or thymol in the corrals according to 

the manufacturer's recommendation to minimize moisture in the corrals.

This measure has been retained from the Class Two mitigation measures due to its 

potential to reduce VOC emissions, however, the cost to implement this measure 

makes it infeasible to be required of everyone (refer to Appendix C). Lime has been 

used at several livestock facilities to reduce moisture. Reducing the moisture content of 

manure minimizes biological activity, which reduces the potential for VOC emissions. 

Thymol is an aromatic essential oil found in thyme and oregano. Thymol has strong 

antibacterial properties, which reduces microbial activity that can produce VOC 

emissions. Several studies have indicated plant oils with antibacterial properties can be 

used to control pathogens and emissions of volatile fatty acids (VFA) from manure. 

Thymol also causes the pH of manure to drop, further inhibiting microbial activity and air 

emissions. Studies by Vincent Varel of the United States Department of Agriculture, 

Agricultural Research Service have shown that thymol inhibited microbial activity and 

reduced emissions of odors and VFAs from cattle and swine manure. 

c) Retired mitigation measures

Three corral measures will be retired from the rule: 
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(1) Install floats or other devices in water troughs to prevent spills.

This measure is considered standard practice and therefore will be removed from the 

rule. Further information is described above in the dairy freestall control section. 

(2) Install no shade structures. 

This measure is removed because a clarification has been added that the measure only 

applies to facilities with shade structures and is now mandatory. Since the new measure 

was added to clean manure out from under the shade structures, the earlier concerns of 

additional piled up manure will be alleviated. Additionally, prohibiting shade structures 

is in conflict with a different District rule – Rule 4550 (Conservation Management 

Practices). 

(3) House animals in an enclosure vented to a VOC control device with a 

combined VOC capture and VOC control efficiency of at least 80%.

The detailed analysis for removing this measure is included in Appendix E. 

6. Dairy Solid Manure Handling Mitigation Measures

Most recent emissions research indicates that the handling and storage of solid manure 

is a very small emission source at California dairies. District staff is proposing to 

combine the two manure measures and the two separated solids measures leaving two 

measures overall. The number of required measures would also be reduced from two to 

one to reflect this change. This allows the measures to be slightly more stringent while 

still allowing for operational flexibility. Medium size dairies would not be required to 

comply with this section, due to the potential difficulties and cost of compliance. 

a) Mandatory mitigation measures

There are not mandatory mitigation measures for this menu. 

b) Additional mitigation measures

The measures in this category have been retained as additional because they are 

mutually exclusive. An operator making the required investment (covering materials and 

labor) to cover animal waste/separated solids piles would not logically be planning to 

remove the waste/separated solids from the facility within 72 hours of removal from 

corrals/separation areas since the investment would not make any sense for such shortterm storage, on top of hauling or tipping fees. Likewise, the operator choosing removal 

within 72 hours would not logically choose covering piles since there will be no manure 

to be stored in piles at the facility. 
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c) Retired mitigation measures

The following two measures have been removed from the rule: 

(1) Store no separated solids

The mitigation measure to store no separated solids outside of anaerobic digesters or 

aerobic digesters will be removed due to the practicality of the measure. Anaerobic and 

aerobic digesters require that the content in those systems consist of very low solids 

generally below 2%. At the worst-case, for a plug flow digester, a 13% solids content 

could be desirable; however this percentage of solids falls under the category of slurry. 

Therefore, this measure is not applicable to the solid manure and has been removed. 

(2) Solid manure handling Class Two mitigation measures

The Class Two Mitigation Measures in solid manure handling will be removed due to 

lack of feasibility, either economically or technologically, as described in Appendix E. 

The proposed rule would remove: 

• Composing manure in an aerated static pile vented to a VOC control device. 

• Store removed manure in an enclosure vented to a VOC control device. 

• Send at least 51% of the manure in a digested vented to a VOC control device. 

7. Dairy Liquid Manure Handling Mitigation Measures

For liquid animal waste handling, the proposed rule has no changes to the measures, 

which are work practices that assure viable bacteria colonies in lagoons to treat the 

animal manure. 

All of the other measures in this section have all been retained as additional because 

they are all independent of each other. Again, each measure listed is expected to 

achieve its own reductions, and no two measures can reasonably be classified as two 

ways of doing the same thing. The number of measures provided in the category will 

accommodate the variability within the dairy industry as far as treatment of liquid waste 

manure is concerned. Variability is expected due to various factors such as age, size, 

and financial capability of the facility. For instance, due to BACT requirements, newer 

facilities are designed with enough lagoon capacity to comply with NRCS guidelines for 

anaerobic treatment, whereas older facilities that were not subject to BACT often do not 

have sufficient lagoon capacity for NRCS guidelines but can instead potentially use a 

phototropic treatment lagoon. Smaller facilities that cannot afford the expenses 

associated with phototropic treatment, which requires a large number of aerators, may 

still achieve sizeable reductions by using an efficient solids separation system. 

a) Mandatory mitigation measures

No mitigation measures are mandatory for the dairy liquid manure controls. 
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b) Additional mitigation measures

(1) Use a phototropic lagoon.

Phototrophic or red water treatment lagoons are easily identified by their characteristic 

purple, pink or rose color. Purple sulfur bacteria utilize hydrogen sulfide and volatile 

organic acids as an electron source for anoxygenic photosynthesis and utilize volatile 

organic acids and alcohols as a carbon source for growth. This reduces the 

concentration of these compounds at the surface of the lagoons and reduces the rate of 

volatilization of these compounds to the atmosphere. A number of studies have found 

reduced odors and emissions of volatile organic acids from lagoons with higher 

concentrations of phototropic bacteria. 

This technology seeks to take advantage of a naturally occurring phenomenon where 

municipal and animal waste lagoons as well as natural lagoons and estuaries, strata in 

lakes etc have turned either purple, pink, or rose in color. This phenomenon is caused 

by assemblages of phototrophic bacteria known as the purple sulfur and purple nonsulfur bacteria. Blooms of these bacteria occur opportunistically when conditions 

provide the appropriate dilute nutrient loading in combination with the right 

temperatures, lighting conditions and limited oxygen availability that are required for 

these bacteria to become dominant. In nature these blooms (as the name suggests) are 

transitory. In order for these types of blooms to be maintained in a municipal wastewater treatment or dairy lagoon context, the conditions must be continuously and 

properly maintained. 

In order to encourage and maintain the development of these bacterial species 

assemblages in farm lagoons year-round, sequential pond systems (i.e. up to 3 ponds: 

for processing, sequestration, and polishing), in combination with mechanical 

circulation/aeration, and mixing/dilution with fresh water. Continuous mechanical mixing 

of the lagoon liquids and solids ensures that the phototrophs are exposed to sufficient 

sunlight. Addition of fresh water (irrigation water) provides the necessary dilute 

conditions and translucency. As in any treatment lagoon, this system also includes 

mechanical solids/liquids separation to remove excess solids prior to treatment. For 

phototrophic lagoons, solids removal has two advantages: 1) it removes the excess 

carbon found in the solids and which can inhibit the desired beneficial nitrification/ 

denitrification process that occurs in these lagoons, and 2) excess solids contributes to 

turbidity and thus would inhibit the phototrophs. 

The agricultural community has met with some success in taking advantage of these 

purple-pink-rose bacterial communities in treating the waste-water from swine and dairy 

operations in order to reduce the odors produced by the lagoon water associated with 

their operations. Research indicates that these microbes and their associated syntrophs 

metabolize sulfur and nitrogen containing compounds as well as various long chain 

organic compounds, many of which could be a potential source of problematic VOCs of 
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concern with regards to air quality. Indeed there is some research which indicates that 

these systems can reduce VOC emissions, at least at swine operations. 

(2) Use an anaerobic treatment lagoon designed in accordance with NRCS 

Guideline No. 359.

The measure to use an anaerobic treatment lagoon will be clarified to be designed in 

accordance with NRCS Guideline 359. The current rule allows the use of an anaerobic 

treatment lagoon that is not mechanically aerated. While the mitigation measure 

seemed to contain enough information at the time of rule adoption, the measure did not 

describe the lagoon in sufficient detail to be certain that the lagoon is designed 

adequately to control emissions from the manure degradation process. To address this 

issue, District staff proposes that the mitigation measure specify that the lagoon be 

designed in accordance with the NRCS Conservation Practice Standard 359. Within 

this standard, there are guidelines that help the operator design the lagoon to handle 

the level of liquid waste generated on-site. 

An anaerobic treatment lagoon is a waste treatment lagoon that is designed to facilitate 

the decomposition of manure by microbes in the absence of oxygen. This process of 

anaerobic decomposition results in the preferential conversion of organic compounds in 

the manure into methane, carbon dioxide, and water rather than intermediate 

metabolites (VOCs). The National Resource Conservation Service (NRCS) California 

Field Office Technical Guide Code 359 - Waste Treatment Lagoon specifies the 

following criteria for anaerobic treatment lagoons: 

1) Minimum treatment volume - The minimum design volume must account for 

all potential sludge, treatment, precipitation, and runoff volumes; 

2) Minimum hydraulic retention time – The retention time of the material in the 

lagoon must be adequate to provide environmentally safe utilization of waste; 

3) Maximum Volatile Solids (VS) loading rate – The VS loading rate shall be 

based on maximum daily loading considering all waste sources that will be 

treated by the lagoon. The suggested loading rate for the San Joaquin Valley 

is 6.5-11 lb-VS/1000 ft3/day depending on the type of system and solids 

separation; and 

4) Minimum operating depth of at least 12 feet - Maximizing the depth of the 

lagoon has the following advantages: 1) The surface area in contact with the 

atmosphere is minimized, which will reduce volatilization of air pollutants; 2) 

The smaller surface area reduces the effects of the environment on the 

lagoon, which provides a more stable and favorable environment for 

anaerobic bacteria; 3) There is better mixing of lagoon due to rising gas 

bubbles; 4) and A deeper lagoon requires less land for the required treatment 

volume. 

The anaerobic treatment lagoon system generally consists of two stages, a treatment 

lagoon (primary lagoon) and a storage pond (secondary lagoon) but can be designed as 
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a single stage. The effluent from the treatment lagoon generally overflows into a storage 

pond/secondary lagoon which is designed for liquid storage. 

(3) Remove solids from the waste system with a solid separator system, prior to 

the waste entering the lagoon.

Removal of solids prior to lagoons reduces the organic loading rate. This reduces the 

amount of organic material in the lagoon that can be degraded to VOCs. Reducing the 

concentration of dissolved VOCs in the lagoon will reduce the rate of volatilization to the 

atmosphere. Additionally, reducing the organic rate loading prevents conditions that are 

inhibitory to methane-forming bacteria and facilitates more efficient conversion of 

dissolved organic compounds to methane rather than being emitted as VOCs. 

(4) Maintain lagoon pH between 6.5 and 7.5.

Maintaining proper lagoon pH reduces the potential for VOC emissions because 

anaerobic methane-forming bacteria thrive best at a pH that is near neutral. Methaneforming bacteria convert the volatile fatty acids (and some alcohols) in the lagoon to 

methane. If the methane reducing bacteria do not thrive, there would be increased 

concentrations of volatile fatty acids which would lead to higher emissions of these 

compounds. Low lagoon pH is also indicative of excessive lagoon loading, which 

increases the potential for emissions. 

c) Retired mitigation measures

(1) Use no lagoons

Eliminating lagoons is not a viable choice for dairies in California. The state’s Water 

Quality Board requires nearly all dairies to treat their wastes before releasing any 

process water back to the environment. 
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(2) Liquid manure Class Two mitigation measures

The following Class Two liquid manure handling measures would be removed from the 

table: 

• Use an aerobic lagoon or use a mechanically aerated lagoon. 

• Maintain organic loading in the lagoon below a certain amount. 

• Use additional non-standard equipment or chemicals on the solid separator 

system. 

• Cover the lagoon or storage pond and vent to a VOC control device. 

The Class Two Mitigation Measures in liquid manure handling will be removed due to 

lack of feasibility, either economically or technologically. Further information is included 

in Appendix E. 

8. Dairy Land Application of Solid/Liquid Manure Mitigation Measures

Mitigation measures for land application of manure, whether solid or liquid, are a single 

table in the current rule. For clarity, the proposed rule would split the current table into 

separate parts for solid manure and liquid manure to make explicit that the operator is to 

select separate measures for each type of manure. 

Language to incorporate solid manure has been changed to more accurately reflect 

industry practice. Application of liquid/slurry manure via injection with drag hose or 

similar apparatus has been added as an additional mitigation measure. The measures 

to apply no solid and apply no liquid will be removed since the table has been 

restructured and would not apply. 

a) Mandatory mitigation measures

None of the mitigation measures are mandatory. 

b) Additional mitigation measures

All of the measures in this section will be retained as additional under each category 

because they are all independent of each other. Each measure listed is expected to 

achieve its own reductions, and no two measures can reasonably be classified as two 

ways of doing the same thing. The number of measures provided in the category will 

accommodate the variability within the dairy industry as far as application of solid and 

liquid/slurry manure to land is concerned. Variability is expected due to various factors 

such as available cropland, manure management practices, and financial capabilities of 

the different facilities. For instances, some facilities may not have enough cropland to 

apply both solid and liquid manure, or some may be using only dry manure 

management methods that do not generate any liquid/slurry waste that need to be 

applied to land. Facilities with limited financial capabilities may not be able to use such 

methods as pre-treatment of waste in digester, or direct injection into land but can 
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achieve fairly similar reduction using more cost effective methods such as discing 

manure into the soil after spreading, or proper preparation of fields prior to irrigation with 

liquid manure in order to avoid standing puddles. 

c) Retired mitigation measures

The measures to “Apply no solid manure” and “Apply no liquid manure” would be 

removed from the table. If an operator is not land-applying a given type of manure, the 

mitigation measure does not need to be implemented. 

9. Summary of All Dairy Mitigation Measures

Summary of the Minimum Number of VOC Mitigation Measures 

Compared to Total Number of Management practices 

Area New Rule Medium and Large Dairy 

Feed (TMR) 4 mandatory + 1 additional = 5 of 7 total

Silage 1 additional of 2 total 

Measure 1 contains four required measures 

Milk Parlor 1 required of 1 total 

Freestalls 2 mandatory + 1 additional = 3 of 5 total 

Corrals 6 mandatory + 1 additional = 7 of 9 total 

Solid Manure 1 additional of 2 total for large dairies only 

Liquid Manure 1 additional of 4 total 

Land Application 2 additional of 6 total 

TOTAL 22 of 35 

10. Dairy CAF Compliance Schedule

Dairies currently subject to the control requirements, i.e., large dairies, as well as 

medium dairies, which would be new to rule requirements, would be required to submit 

an Authority-to-Construct application by April 21, 2011 and be in full compliance with the 

Phase II requirements within one year after either the Authority-to-Construct or the 

Permit-to-Operate are issued, whichever is earlier. 

G. Beef Feedlot CAF Mitigation Measures 

The beef feedlot controls have been significantly improved and streamlined. Many of the 

measures have been mandated, grouped where measures are tackling similar sources 

and removed where necessary. 

1. Beef Feedlot Feed Mitigation Measures

As discussed earlier, emissions from dry grain are expected to be negligible from 

facilities that feed a dry grain diet, as supported by the letter provided in Appendix I. 
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Since emissions from feed are negligible, only feed measures that have the likelihood to 

increase the efficiency of the animals will be evaluated. All other feed measures will be 

removed (see the retired measures section below). District staff is proposing to make 

changes to the tables to accurately reflect the more recent information. The feed table 

would have three measures and be required to select two to implement. 

a) Mandatory mitigation measures

To allow flexibility based on the different feed practices at feedlot operations, no 

measures were mandated. 

b) Additional mitigation measures

Out of three specific mitigation measures, operators would need to implement two 

measures. 

(1) Feed according to National Research Council (NRC) guidelines

A letter submitted by beef feedlot stakeholders state that cattle may require supplement 

feed outside of the NRC guidelines. Each business is different, and the NRC guidelines 

provide a great foundation to build nutrient requirements from. But, there is a 

considerable amount of other factors that require livestock producers to seek the 

services and consult with nutritionists to potentially go beyond what is suggested in the 

NRC guidelines. These changes are important to the health of the animal, including 

feeding the animal efficiently, which at times requires feeding outside of the NRC 

guidelines. Therefore, operators who do feed to NRC guidelines would be allowed 

select it as one of their mitigation measures. 

(2) Feed steam-flaked corn or other steam-flaked cereal grains.

As described above, this measure reduces excretion of starch and other nutrients in the 

manure reducing the potential for VOC emissions. The feed management practices for 

beef feedlots can vary greatly depending on feed prices and other factors, therefore this 

measure has been retained as additional. 

(3) Remove uneaten wet feed from feed bunks within twenty-four (24) hours after 

the end of a rain event.

This measure would reduce spoilage from wet feed occurring after a rain event. Please 

refer to the dairy section for more information. 

c) Retired mitigation measures

As stated earlier, emissions directly from feed are expected to be negligible, therefore, 

the following measures will be retired from the rule: 
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• Remove feed where animals stand to eat. 

• Remove spilled feed from around the feed bunk. 

• Feed or dispose of rations within 48 hours of grinding and mixing. 

New information from industry stakeholders has stated the amount of feed left 

behind or spilled is minimal. As described above, the emissions from these 

sources would be negligible. A reduced cleaning timeframe or feeding time 

schedule to capture the potential emissions would be unachievable in practice 

due to the labor intensity and hours needed to perform this task resulting in a 

high cost to the industry. 

• Store grain in a weatherproof structure or covering, October through May. 

This measure would be very costly especially when compared to the minimal 

emission reductions achieved by the practice. Details of the cost analysis are 

outlined in Appendix C 

2. Beef Feedlot Silage Mitigation Measures

The proposed rule will require that all operations that store and feed animals from silage 

piles create the piles based on a combination of compaction standards, silage quality, 

and face and pile size management. These measures are consistent with those 

described above in the dairy section as beef feedlots may feed silage as well. 

3. Beef Feedlot Housing Mitigation Measures

Staff proposes that beef feedlot implement four specified mitigation measures in 

addition to selecting one out of the three remaining additional measures. 

a) Mandatory mitigation measures

The following measures are specified: 

(1) Clean corrals twice per year with 90 days between cleanings.

For animal housing, clarification has been made to clean corrals twice per year with 90 

days between cleanings. In discussions with stakeholders, the previous first mitigation 

measure in the beef feedlot housing table was problematic to implement. Since the 

cattle are housed in open pens, the rainy season makes the corrals extremely muddy 

which makes it very difficult if not impossible to get scraping equipment into the pens. 

In place of specific times to scrape the pens, District staff proposes that the pens be 

cleaned twice during the year with at least 90 days between cleanings. In making this 

change, the pens would be cleaned just as often as the option in the current rule, but 

operators would have the flexibility to clean at times when the equipment can safely be 

used. 
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(2) Inspect water pipes and troughs and repair leaks at least once every seven 

days.

This measure is further described above in the dairy corrals section. 

(3) Slope corrals; ensure proper drainage; or maintain a dry surface.

Clarification has been made to the measure of maintaining pens so that there are no 

puddles preventing water from standing more than forty-eight (48) hours or to harrow, 

rake, or scrape pens sufficiently to maintain a dry surface. These two measures have 

been combined with the measure to slope the surface of the corrals since they address 

the same source. More information is discussed in the dairy section above. 

(4) If the facility has shade structures, use light permeable material; install on an 

uphill slope; or install in a North/South orientation.

This measure is includes a new management practice to orient the shade North to 

South and will be required if a facility has shade structures. It is similar to the measures 

required for the dairy facilities and is described further above. 

b) Additional mitigation measures

(1) Manage corrals and concrete lanes such that the manure depth in the corral 

does not exceed twelve (12) inches at any time or point, except for in-corral 

mounding. 

Two similar mitigation measures would be combined and rewritten to reduce the amount 

of manure that would be allowed in individual housing floors and concrete lanes. A 

more detailed discussion is shown under the dairy section, above. 

(2) Knockdown fence line manure build-up prior to it exceeding a height of twelve 

inches at any time or point.

The standard for the two measures would be moved from 18 inches to 12 inches (not 

including in-corral mounding) to increase manure management and emission 

reductions. Language has also been added to clarify depth when corrals are 

inaccessible due to rain events. These measures are described in more detail under the 

dairy section, above. 
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c) Retired mitigation measures

The following measures will be retired from the rule: 

(1) Installing floats of other devices in water troughs to prevent spills.

This measure is standard practice and is more fully described in the dairy section 

above. 

(2) Use a dry animal waste manure handling system. 

As stated in the dairy section above, recent studies have shown that the vast majority of 

VOCs such as alcohols and volatile fatty acids are highly soluble in the liquid form. Due 

to the emission reduction benefits achieved from liquid manure handling, the District will 

not prefer one manure management practice to the other. 

(3) Scrape or smooth pen floors where puddles may form prior to placing cattle in 

pens. 

This measure is not entirely feasible since the cattle’s behavior causes indentions when 

they move dirt and manure around the corrals. However the mandatory measures listed 

above to slope, harrow or maintain a dry surface, serve the same purpose as this 

measure but in a more feasible manner, while still allowing the operator the flexibility to 

manage the corrals in a way that is consistent with their corral management practices. 

(4) Install no shade structures. 

This measure will be removed as a clarification has been added that the measure only 

applies to facilities with shade structures and is now mandatory. 

(5) Class Two Mitigation Measure to apply lime or thymol. 

These measures were removed for beef cattle because they are infeasible. Due to the 

cattle being active throughout the day, corral surface is continuously being disturbed. 

Therefore, any application of this material would quickly be removed through the active 

hoof action or would get buried under a fresh layer of manure. This would require 

periodic reapplication of lime or thymol to corral surfaces in order to continue to be 

effective. This would also lead to frequent disturbance of the animals, which is 

undesirable for feedlot cattle. Additionally, the application rates needed to reduce VOC 

emissions lead to high costs for feedlot cattle facilities. Due to all these factors, this 

measure will not be effective and therefore has been deemed infeasible for this 

category. 
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4. Beef Feedlot Solid Manure Handling Mitigation Measures

a) Mandatory mitigation measures

(1) Remove or cover dry manure or manage moisture content of manure to less 

than 50%.

The measures in this table have been combined into one measure. Operators have the 

choice to remove or cover dry manure, or comply with a new measure that has been 

added to manage the moisture content of the manure to less than 50%. Reducing the 

moisture content of manure minimizes biological activity, which reduces the potential for 

VOC emissions.

b) Additional mitigation measures

There are no additional measures in this table.

c) Retired mitigation measures

(1) Solid manure Class Two mitigation measures

The Class Two Mitigation Measures in solid manure handling will be removed due to 

lack of feasibility, either economically or technologically. Further information is included 

in Appendix E. 

5. Beef Feedlot Liquid Manure Handling Mitigation Measures

All of the other measures in this section have all been retained as additional because 

they are all independent of each other. Again, each measure listed is expected to 

achieve its own reductions, and no two measures can reasonably be classified as two 

ways of doing the same thing. The number of measures provided in the category will 

accommodate the variability within the dairy industry as far as treatment of liquid waste 

manure is concerned. Variability is expected due to various factors such as age, size, 

and financial capability of the facility and is further described above in the dairy section. 

a) Mandatory mitigation measures

The Phase II mitigation measures for liquid manure handling do not have required 

mitigation measures. Operators would have the choice to select one mitigation measure 

from four control management practices. It is District staff’s belief that any of the listed 

management practices has equivalent ability to reduce VOC emissions. 
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b) Additional mitigation measures

These measures are consistent with the dairy section and have been described more 

fully in that section above. 

(1) Use a phototropic lagoon

(2) Use an anaerobic treatment lagoon designed in accordance with NRCS 

Guideline No. 359.

The measure to use an anaerobic treatment lagoon will be clarified to be designed in 

accordance with NRCS Guideline 359 and is further described in the dairy section. 

(3) Remove solids from the waste system with a solid separator system, prior to 

the waste entering the lagoon.

(4) Maintain lagoon pH between 6.5 and 7.5.

c) Retired mitigation measures

(1) Use no lagoons

(2) Liquid manure handling Class Two mitigation measures

The following Class Two liquid manure handling measures would be removed from the 

table: 

• Use an aerobic lagoon or use a mechanically aerated lagoon 

• Maintain organic loading in the lagoon below a certain amount 

• Use additional non-standard equipment or chemicals on the solid separator 

system 

• Cover the lagoon or storage pond and vent to a VOC control device 

The Class Two Mitigation Measures in liquid manure handling will be removed due to 

lack of feasibility, either economically or technologically. Further information is included 

in Appendix E. 

6. Beef Feedlot Land Application Mitigation Measures

As with the dairy land application section, the beef feedlot land application table was 

split into two: a section for land application of solid manure and a section for land 

application of liquid manure. For a detailed explanation, see the narrative for the dairy 

land application controls above. 
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a) Mandatory mitigation measures

None of the mitigation measures are mandatory. 

b) Additional mitigation measures

All of the measures in this section will be retained as additional under each category 

because they are all independent of each other. This is further described in the dairy 

section above. 

c) Retired mitigation measures

The measures to “Apply no solid manure” and “Apply no liquid manure” would be 

removed from the table. If an operator does not land-apply a given type of manure, the 

mitigation measure does not need to be implemented. 

7. Summary of Feedlot Mitigation Measures

Summary of the Minimum Number of VOC Mitigation Measure 

Management practices Compared to Total Number of Management 

practices 

Area New Rule Beef Feedlot 

Feed (TMR) 2 additional of 3 total 

Silage 1 additional of 2 total 

Measure 1 contains four required practices 

Housing 4 mandatory + 1 additional = 5 of 6 total 

Solid Manure 1 required of 1 total 

Liquid Manure 1 additional of 4 total 

Land Application 2 additional of 6 total 

TOTAL 13 of 22 

8. Beef Feedlot Compliance Schedule

Existing beef feedlots that would become subject to control requirements would be 

required to submit an Authority to Construct application by April 21, 2011 and be in full 

compliance with the Phase II requirements within one year after either the Authority to 

Construct or the Permit to Operate are issued, whichever is earlier. 

H. Other Cattle CAF Mitigation Measures 

“Other cattle operations” is the collective name for operations that are not dairies and 

are not beef feedlots, but may raise animals for both those types of operations. Dairy 

animals at calf ranches or heifer ranches are usually younger and smaller than mature 

animals with a lower emission factor associated with activities at that type of ranch. 
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1. Other Cattle Feed Mitigation Measures

As discussed earlier, emissions from dry grain are expected to be negligible from 

facilities that feed a dry grain diet. Since emissions from feed are negligible, only feed 

measures that have the likelihood to increase the efficiency of the animals will be 

evaluated. All other feed measures will be removed (see the retired measures section 

below) District staff is proposing to make changes to feed/feed storage tables that 

accurately reflect the more recent information. The feed table would have three 

measures with specific actions from which to choose, and be required to select two to 

implement. 

a) Mandatory mitigation measures

To allow flexibility based on the different feed practices at other cattle operations, no 

measures were mandated. 

b) Additional mitigation measures

Out of three specific mitigation measures, operators would need to implement two 

measures. The measures are consistent with those of the beef feedlot feed section and 

have been further described above. 

(1) Feed according to National Research Council (NRC) guidelines

This measure is additional due to the flexibility needed for these types of facilities. 

Please refer to the beef feedlot section for more information. 

(2) Feed steam-flaked corn or other steam-flaked cereal grains.

As described above, this measure reduces excretion of starch and other nutrients in the 

manure reducing the potential for VOC emissions. The feed management practices can 

vary greatly depending on feed prices and other factors, therefore this measure has 

been retained as additional. 

(3) Remove uneaten wet feed from feed bunks within twenty-four (24) hours after 

the end of a rain event.

This measure would reduce spoilage from wet feed occurring after a rain event and is 

further described above in the dairy section. 

c) Retired mitigation measures

As stated earlier, emissions directly from feed are expected to be negligible, therefore, 

the following measures will be retired from the rule: 
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• Remove feed where animals stand to eat. 

• Remove spilled feed from around the feed bunk. 

• Feed or dispose of rations within 48 hours of grinding and mixing. 

• Store grain in a weatherproof structure or covering, October through May. 

These measures have been more fully described in the beef feedlot section above. 

2. Other Cattle Silage Mitigation Measures

The proposed rule will require that all operations that store and feed animals from silage 

piles create the piles based on a combination of compaction standards, silage quality, 

and face and pile size management. These measures are consistent with those 

described above in the dairy section. 

3. Other Cattle Freestall Barn Mitigation Measures

In order to tailor mitigation measures to the housing type, the housing table has been 

separated into two separate tables to cover Freestalls and Corrals. Three measures are 

now required in the Freestalls table. The first two measures would be specified and then 

facilities would need to choose one additional measure. The following summarizes the 

freestalls mitigation measures. 

a) Mandatory mitigation measures

These measures are similar to those required for dairies and the potential to reduce 

emissions has been further described above. 

(1) Vacuum, scrape or flush freestalls at least once every seven days.

(2) Pave feedlanes, where present, for a width of at least 6 feet along the corral 

side of the feedlane. (new measure)

b) Additional mitigation measures

The following measures will remain as additional mitigation measures to allow for 

flexibility in different operating practices. These measures are further described in the 

dairy section above. 

(1) Use non-manure-based or separated solids-based bedding for at least 90% of 

the bedding material.

(2) Remove manure that is not dry from individual cow freestall beds or rake, 

harrow, scrape, or grade freestall bedding.
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The measures to remove manure from bedding or rake, harrow, scrape, or grade 

bedding has been combined since they address the same source. The frequency has 

also been changed to seven days. 

c) Retired mitigation measures

See the following corral discussion which will describe the retired measures. 

4. Other Cattle Corrals Mitigation Measures

Eight mitigation measures have been included in the new corrals table. 

a) Mandatory mitigation measures

Five measures would be mandated. The following measures are similar to those in the 

dairy section and more detailed descriptions can be found in that section above. 

(1) Scrape corrals twice a year with at least 90 days between cleanings, 

excluding in-corral mounds.

Clarification has been made to clean corrals twice per year. Nearly all other cattle CAFs 

keep at least some animals in corrals. As with the beef feedlots, it can be impractical to 

scrape corrals at certain times of the year due to the amount of rain that falls in that time 

period. For this reason, District staff proposes changes to the mitigation measure to 

make it more flexible. 

(2) Scrape or flush concrete lanes at least once every seven days; or clean the 

concrete aprons such that the depth of manure does not exceed 12 inches.

This measure is a combination of two measures that address the same source. The 

frequency to scrape or flush concrete lanes is now once every seven days. 

(3) Inspect water pipes and troughs and repair leaks at least once every seven 

days.

The frequency to inspect water pipes has decreased from 14 to 7 days. 

(4) Slope corrals; ensure proper drainage; or maintain a dry surface.

This measure is a combination of three measures designed to address the same 

source. 
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(5) If the facility has shade structures, use light permeable material; install on an 

uphill slope; install in a North/South orientation.

This measure is includes a new management practice to orient the shade North to 

South and will be required if a facility has shade structures. 

b) Additional mitigation measures

Facilities would need to choose one additional mitigation measure from the three 

measures remaining. All three of these measures are more fully described in the dairy 

section above. 

(1) Manage dry manure depth so that it does not exceed twelve inches.

(2) Knockdown fence line manure build-up prior to it exceeding a height of twelve 

inches.

(3) Apply lime or thymol.

c) Retired mitigation measures

The following housing measures will be retired from the rule: 

(1) Installing floats of other devices in water troughs to prevent spills. 

This measure is standard practice and is more fully described in the dairy section 

above. 

(2) Use a dry animal waste manure handling system. 

As stated in the dairy section above, recent studies have shown that the vast majority of 

VOCs such as alcohols and volatile fatty acids are highly soluble in the liquid form. Due 

to the emission reduction benefits achieved from liquid manure handling, the District will 

not prefer one manure management practice to the other. 

(3) Have no animals in exercise pens, corrals, or drylots at any time.

This requirement was removed from the housing tables because of animal welfare 

concerns. Restricting access to exercise pens by enclosing the barn may exacerbate 

animal welfare and animal health concerns, as access to open exercise pens is 

important for good breeding and pregnancy rates and hoof health. For further 

information, see dairy freestall narrative for a more detailed explanation. 
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5. Other Cattle Solid Manure Handling, Liquid Manure Handling, and Land 

Application Mitigation Measures

Changes proposed for the solid and liquid manure handling, and land application tables 

are consistent with those made to the dairy tables as described above. 

6. Summary of Other Cattle Mitigation Measures

Summary of the Minimum Number of VOC Mitigation Measure 

Management practices Compared to Total Number of Management 

practices 

Area New Rule Other Cattle 

Feed (TMR) 2 additional of 3 total 

Silage 1 additional of 2 total 

Measure 1 contains four required practices 

Freestalls 2 mandatory + 1 additional = 3 of 4 total 

Corrals 5 mandatory + 1 additional = 6 of 8 total 

Solid Manure 1 additional of 2 total 

Liquid Manure 1 additional of 4 total 

Land Application 2 additional of 6 total 

TOTAL 16 of 29 

7. Other Cattle Compliance Schedule

Other cattle operations that would become subject to control requirements of the rule 

would be required to submit an Authority-to-Construct application by April 21, 2011 and 

be in full compliance with the Phase II requirements within one year after either the 

Authority-to-Construct or the Permit-to-Operate are issued, whichever is earlier. 

I. Swine CAF Mitigation Measures 

District staff proposes to revise the swine CAF menu and make all the proposed 

measures mandatory. All other measures will be retired. Since there is only one facility 

currently subject to Rule 4570, with no new foreseen facilities coming under the rule, 

there is no need for variability as in other CAFs and the measures have been tailored 

for the single facility subject to the rule. 

1. Swine Feed Mitigation Measures

The Feed control table would require both of two measures; use grain with a certain 

particle size and utilize phase feeding and split-sex seeding programs, which are both 

new measures. 
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a) Mandatory mitigation measures

(1) Use grain with an average particle size diameter between 300-800 microns. 

This measure requires a specific range for the average particle of grains fed to swine. 

Reducing the particle size of grain in swine diets increases the digestibility of the feed. 

This reduces excretion of starch and other nutrients in the manure reducing the 

potential for VOC emissions. 

(2) Utilize phase feeding and Split-Sex Feeding programs to more closely match 

the nutrient requirements of animals. 

This measure requires animals be placed in different categories and fed diets that are 

formulated to more closely match the nutrient requirements of each category. This will 

reduce overfeeding of nutrients, which will reduce excretion of excess nutrients that can 

be a source of VOCs. 

b) Additional mitigation measures

All measures in the Phase II feed table are required; therefore, there are no additional 

swine feed mitigation measures. 

c) Retired mitigation measures

The following measures will be retired from the rule: 

(1) Feed according to NRC guidelines.

The NRC guidelines for swine have been out for some years and do not reflect current 

knowledge of feeding practices. 

 

(2) Feed animals at least 5% cellulose.

 

This measure has been found to reduce ammonia but not VOCs. It is also not widely 

used in Valley facilities and therefore will be removed. 

(3) Feed animals a casein based diet.

Casein is one of the proteins found in milk. Casein-based diets are diets in which the 

majority of protein fed is casein. Although nursery pigs will receive some casein in the 

milk that they receive as part of their ration, casein-based diets are not fed at 

commercial swine facilities because of the high cost of feeding large amounts of casein 

that must be extracted from milk. Therefore, this measure is not feasible for commercial 

swine facilities. 
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(4) Feed animals an amino acid-supplemented diet with 2% sucrose thermal 

oligosaccharide caramel. 

(5) Feed animals a diet with no more than 10% crude protein with supplemented 

lysine, threonine, tryptophan, and methionine. 

(6) Feed animals 10 ppm anthraquinone.

These three mitigation measures were based on limited information from scientific 

studies. Stakeholders have expressed concerns regarding the practicality of 

implementing these measures at commercial swine facilities. Also, anthraquinone has 

recently been listed as a toxic carcinogen by the Office of Environmental Health Hazard 

Assessment (OEHHA). In light of these issues, these measures have been removed 

from the table.

(7) Remove spilled from the facility every 14 days. 

(8) Feed or dispose of rations within 48 hour of grinding and mixing rations. 

As stated earlier, emissions from facilities that feed a dry grain are expected to have 

negligible emissions. Since swine facilities feed a dry grain diet to their animals, the 

measures to remove spilled feed and to feed or dispose will be deleted from the swine 

feed table. 

(9) Remove uneaten wet feed from the housing within 24 hours of a rain event. 

Animals in swine facilities are housed in enclosed buildings. Therefore, the feed is not 

expected to get wet and this measure will not be included in the Phase II table. 

(10) Store grain in a weatherproof storage structure from October through May. 

All grain at a swine facility is stored in weatherproof structures, therefore this measure is 

not needed and has been removed. 

2. Swine Housing Mitigation Measures

In the swine housing control tables, operators would be required to implement three 

mitigation measures. 

a) Mandatory mitigation measures

(1) Use a slatted floor system with daily manure removal for shallow flush alleys 

and weekly removal from deep pits.

This measure has been clarified based on the manure management of the single 

regulated facility to ensure appropriate emission reductions. 
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As stated earlier, recent studies have shown that the vast majority of VOCs such as 

alcohols and volatile fatty acids are highly soluble in water. Since the manure 

management system for swine is similar to a freestall barn consisting of manure 

removal through a flush system, emissions will tend to remain in the aqueous mixture of 

water and manure and will be sent to a lagoon or storage pond to be further treated. 

(2) Manage pens such that the manure depth in the pen does not exceed 12

inches.

As stated earlier, VOCs are emitted when manure undergoes anaerobic decomposition. 

The depth has been lowered from 18 inches to 12 inches. Limiting the depth of manure 

in pens will reduce the anaerobic decomposition in the manure pack that causes VOC 

emissions. 

(3) Inspect pipes and troughs and repair leaks at least once every 7 days.

The frequency has been lowered from 14 days to 7 days. This measure is described in 

more detail in the dairy section, above. 

b) Additional mitigation measures

All measures in the Phase II housing table are required; therefore, there are no 

additional swine housing mitigation measures. 

c) Retired mitigation measures

Six Phase I mitigation measures have been retired in the Phase II swine housing table: 

(1) Clean manure from the housing at least twice every 14 days. 

This measure is similar or equivalent to using the slatted floor system and therefore, not 

necessary. 

(2) Slope the surface of the pens. 

The animals housed on swine facilities in the Valley are housed indoors; therefore, this 

measure is not applicable to these operations. 

(3) Install floats on the troughs.

This measure is standard practice and since the housing floors are slatted there is not a 

concern for spilled water. This measure is further described above in the dairy section.
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(4) Use lime in the pens. 

This measure does not apply to the swine housing system since the facility does not 

have any pens. Any lime applied to the swine housing would fall directly to the pits 

through the slatted floors. Therefore, this measure has been removed. 

(5) House animals in an enclosure vented to a VOC control device with a 

combined VOC capture and VOC control efficiency of at least 80%

The effectiveness of this measure is related to maintaining dry conditions in animal 

housing and rapidly reducing the moisture of manure. Because of this, this measure is 

not applicable to swine facilities, which handle manure as a liquid. Therefore, this 

measure has been removed. 

(6) House animals in a tunnel ventilated house with mechanical ventilation

The detailed analysis for this measure is included in Appendix E. 

3. Swine Solid Manure Handling Mitigation Measures

The mitigation measures associated with the Phase I swine solid manure table will be 

removed entirely from the Phase II swine section because the facility does not handle or 

store solid manure. 

4. Swine Liquid Manure Handling Mitigation Measures

a) Mandatory mitigation measures

There are no mandatory mitigation measures for this table. 

b) Additional mitigation measures

For the liquid manure controls, the facility will need to choose one of three mitigation 

measures to comply with the rule. 

(1) Use a phototropic lagoon.

(2) Use an anaerobic treatment lagoon.

(3) Maintain lagoon pH between 6.5 and 7.5

The reasons for keeping these mitigation measures in the swine liquid manure table are 

the same as those outlined in the dairy liquid manure control table narrative. 
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c) Retired mitigation measures

The following Phase I mitigation measures would not be included in the swine Phase II 

liquid manure handling table: 

(1) Have no lagoons. 

This measure will be removed for the reason explained in the dairy liquid manure 

handling section. 

(2) Remove solids from the waste system with a solid separator system. 

Swine manure does not consist of non-digestible fibrous compounds that are prevalent 

in dairy manure. Therefore, there is no need to separate manure since all of the 

manure excreted is digestible and can be treated in a lagoon without separation. 

(3) Liquid manure handling Class Two mitigation measures

The following Class Two liquid manure handling measures would be removed from the 

control table: 

• Use an aerobic lagoon or use a mechanically aerated lagoon. 

• Maintain organic loading in the lagoon below a certain amount. 

• Use additional non-standard equipment or chemicals on the solid separator 

system. 

• Cover the lagoon or storage pond and vent to a VOC control device. 

The Class Two Mitigation Measures in liquid manure handling will be removed due to 

lack of feasibility, either economically or technologically, or substantial similarity to a 

Class One mitigation measure . Further information is included in Appendix E. 

5. Swine Land Application Mitigation Measures

Operators would have one required mitigation measure in the Phase II swine land 

application table. 

a) Mandatory mitigation measures

(1) Allow liquid manure to stand in the fields for no more than twenty-four (24) 

hours after irrigation.

This mitigation measure would be the only Phase I mitigation measure that would 

remain on the Phase II land application table because the facility does not land apply 

solid manure. 
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b) Additional mitigation measures

There are no additional mitigation measures in this table. 

c) Retired mitigation measures

Three Phase I mitigation measures applicable to solid manure in the land application 

table will be removed entirely from the Phase II table because the facility subject to the 

rule does not handle or store solid manure. These mitigation measures are: 

(1) Land incorporate all solid manure shortly after removal from animal housing.

(2) Apply no solid manure with a moisture content of more than 50%.

(3) Apply no solid manure.

The following two Phase I mitigation measures will not be part of the Phase II swine 

land application table because they are either not applicable or the equivalent to the 

required Phase II mitigation measure retained in this section. 

(4) Only apply manure that has been treated with an anaerobic or aerobic lagoon 

or digester system.

These systems were also found to not be cost effective based on the analysis in 

Appendix E. 

(5) Apply no liquid manure.

6. Summary of Swine Mitigation Measures

Summary of the Minimum Number of VOC Mitigation Measures Compared 

to Total Number of Management practices 

Area New Rule Swine 

Feed (TMR) 2 required of 2 total 

Housing 3 required of 3 total 

Liquid Manure 1 additional of 3 total 

Land Application 1 required of 1 total 

TOTAL 7 of 9 

7. Swine CAF Compliance Schedule

The existing swine operation that is subject to the control requirements of the rule would 

be required to submit an Authority-to-Construct application by April 21, 2011 and be in 

full compliance with the Phase II requirements within one year after either the Authorityto-Construct or the Permit-to-Operate is issued, whichever is earlier. 
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J. Poultry CAF Mitigation Measures 

As with other CAFs, the management practices for reducing VOC emissions are divided 

between the various operations. In the case of poultry, the operations are: feed/feed 

storage, housing, and solid/liquid waste handling. Poultry operations vary by 

geographical location, age of the facility and standard practices at the time of 

construction, size and financial resources of the facility, as well as the operator’s 

manure management preferences. There is also a large degree of variability in the 

manure management practices, housing techniques, and potential feeding practices for 

the different types of poultry operations in the valley. These differences are explained in 

the poultry description in Section II. B. Due to these differences, the requirements in the 

rule for poultry operations do not apply to all the various types of poultry facilities. The 

measures, as presented in the current rule, give the false impression that there are a 

dozen or so mitigation measures available as management practices for a particular 

poultry facility when in fact, only a handful are feasible. Therefore, the poultry category 

will be broken down into the following two categories so that the mitigation measures 

can be tailored to the appropriate operation: 1) layers, 2) broilers, ducks and turkeys. 

1. Layer Feed Mitigation Measures

a) Mandatory mitigation measures

All of the feed measures affecting animal diet have been combined into one measure as 

all are intended to improve efficiency in the animals. Operators have the following 

management practices within the single feed mitigation measure: 

• Feed according to NRC guidelines 

• Feed probiotics 

• Feed certain amino acids 

• Feed certain enzymes 

The NRC guidelines are geared to supply the exact blend and quantity of nutrients 

needed by the animals with the minimum being excreted and lost to the environment. 

However this is not the only way to reduce nutrient loading in the manure for poultry. 

Including probiotics, amino acids, or certain enzymes in the diet are other ways to 

promote more complete digestion. The NRC guidelines do not include the use of these 

materials, so an operator who chooses to add one or more of these substances to the 

birds’ diet would not be feeding according to NRC guidelines, but the potential for VOC 

reductions would be similar. For this reason, District staff is proposing that poultry 

operators have the flexibility to choose one of the four management practices as a feed 

mitigation measure. 
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b) Additional mitigation measures

All specific-action mitigation measures for layer feed are mandatory; therefore there are 

no additional measures. 

c) Retired mitigation measures

Five Phase I mitigation measures would not be brought into the Phase II feed table. 

Emissions from dry feed are described in more detail above in Section VIII. 

(1) Remove spilled feed every 7 days.

The feed for poultry is generally less than 20 percent moisture which makes it too dry 

for decomposition by microbes, which would generate the secondary formation of 

VOCs. Since the feed is dry, it is not expected that spilled feed would have enough 

moisture to support microbial decomposition. 

(2) Enclose grain in a weatherproof storage structure from October through May. 

Operators already store grain in weatherproof structures year-round for two reasons. 

One reason is that the grain needs to stay dry in order for the automatic feeding system 

to work appropriately. The second reason for the storage structure is that the structures 

serve as a deterrent to rodents and other pests who would compete for the grain. 

(3) Feed or dispose of feed within 48 hours of grinding and mixing. 

Unlike some other types of CAFs, poultry CAFs generally buy ready-to-use feed from 

outside sources, i.e., feed mills, and, therefore, grinding and mixing of feed components 

to make a final ration does not take place at the facility. For this reason, the measure is 

not applicable to poultry CAFs and will not be included in the Phase II feed table. 

(4) Use feed additives designed to reduce feed decomposition or oxidization. 

District staff has removed this Phase I mitigation measure because poultry feed is a 

low-moisture product, is stored in weatherproof structures and is fed to the animals 

within a short amount of time, therefore, the potential for secondary emissions from feed 

decomposition is minimal. 

(5) Remove uneaten wet feed from the housing within 24 hours of a rain event.

District staff is removing this mitigation measure because layers are housed in buildings 

and, during a rain event, it is not expected that the rain would come into the building. 

Because the rain would not drip onto the feed, there would be no wet feed to undergo 

decomposition and emit VOCs. 
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2. Layer Housing Mitigation Measures

Operators would be required to implement two mitigation measures from this table. 

a) Mandatory mitigation measures

(1) Use drinkers that do not drip continuously.

The purpose of this mitigation measure is to prevent drinkers from dripping water onto 

the floor so that the moisture in the manure and litter is not increased. Increased 

moisture in the manure and litter increase the potential for anaerobic decomposition, 

resulting in an increase in VOC emissions. 

(2) Inspect water pipes and drinkers and repair leaks daily.

As with the drinker mitigation measure, this mitigation measure would minimize the 

water available for microbial decomposition and the resulting VOC emissions. 

b) Additional mitigation measures

There are no additional mitigation measures, since all provisions are required mitigation 

measures. 

c) Retired mitigation measures

Several Phase I poultry mitigation measures will be not be included in the Phase II layer 

housing table. 

(1) Use a dry housing cleaning method. 

This Phase I measure would not be included in the Phase II measures for housing. The 

floors of layer houses are clear of any material that would enhance microbial 

decomposition if the floor got wet from a wet cleaning method. As stated earlier, recent 

studies have shown that the vast majority of VOCs such as alcohols and volatile fatty 

acids are highly soluble in the liquid form. Liquid manure handling systems will therefore 

also result in emission reduction due to the affinity of the pollutants to the wet handling 

system. Although there is benefit in maintaining a completely dry manure handling 

system, equivalent benefits can also be achieved by a liquid manure handling system. 

Therefore, the District will not prefer one manure management practice to the other and 

has removed this mitigation measure. 
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(2) Adjust the drinkers every 14 days. 

The birds are all grown and will not increase in size to warrant a change in the drinker 

configuration. This measure would be retired since it is not applicable to layer facilities. 

(3) Remove caked animal waste every 14 days. 

Emissions from poultry houses are generally created from the high moisture in manure. 

Once manure is caked, the manure is essentially dry and will no longer have potential 

emissions. Therefore, this mitigation measure will be removed as it will result in minimal 

emission reductions. 

(4) Clean under poultry cages every 14 days. 

Industry standard for layers currently consists of removing manure underneath the 

cages once per year and in some instances twice per year. The manure is generally 

handled when the layers are no longer in the houses. Therefore, removing manure on a 

biweekly basis will be highly cost prohibitive and have a huge impact on animal welfare. 

(5) Use poultry litter additives designed to reduce air emissions or moisture 

content in litter. 

Layers do not use litter (i.e., rice hulls, saw dust, etc.) at their facilities since the hens 

are housed in cages. The manure simply drops to the bottom of the ground as is, 

therefore, this measure does not apply. 

(6) Use no foggers in the house. 

Foggers can be used in poultry housing to provide cooling during the Valley’s hot 

summer months. However, operators have found other means that are more 

economically feasible for cooling, therefore, this mitigation measure is being removed 

from the housing table. 

(7) Only use a fogger system designed to provide water droplets of a specified 

size. 

District staff proposes removing this mitigation measure because the technology is not 

available. The main reason that this mitigation measure is in the current rule is that 

droplets that are no more than 50 microns when released would be small enough to 

evaporate before the water can fall to the floor of the poultry housing and wet the 

manure. However, poultry operators have contacted the manufacturers of fogging 

systems and the manufacturers will not guarantee the size of the water droplets 

released, meaning that there are no fogging systems available that would meet the 

mitigation measure standard. 
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(8) Slope the floor of the house to 3% 

(9) Install mounds or berms up gradient to prevent the runoff of stormwater into 

pens.

These measures do not apply to layer housing because the hens are housed in cages. 

(10) Maintain the roof structure and manage roof runoff.

This measure requires that all of the houses install gutter systems on the roof. The rain 

water will not have any contact with the manure in the housing whether the water falls 

down from the side of the roof to the ground or through a gutter system. This measure 

will not result in any real reductions and is an unnecessary capital expense. Therefore, 

this measure has been removed. 

(11) Layer housing Class Two housing mitigation measures

The following Class Two housing mitigation measures would be removed from the table: 

• Vent housing to a VOC emission control device 

• Use a belt litter removal system to dry manure/litter 

• House animals in a tunnel-ventilated house with mechanical ventilation 

• Use a litter drying system 

The Phase I Class Two mitigation measures in poultry housing will be removed due to 

lack of feasibility, either economically or technologically. Further information is included 

in Appendix E. 

3. Layer Solid Manure Handling Mitigation Measures

Operators of layer CAFs would be required to implement one mitigation measure. 

a) Mandatory mitigation measures

The following mitigation measure is required of all layer CAFs which handle solid 

manure: 

(1) Within 72 hours of removal from poultry housing, either cover poultry 

litter/manure or send the poultry litter/manure off-site

District staff is proposing to combine two Phase I solid manure handling mitigation 

measures. This allows the measures to be slightly more stringent while still allowing for 

operational flexibility. 

b) Additional mitigation measures

There are no additional mitigation measures in this table. 
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c) Retired mitigation measures

Two Phase I Class One mitigation measures and all of the Phase I Class Two mitigation 

measures will be retired from the rule. 

(1) Send manure to a lagoon 

This Phase I mitigation measure is being retired as it is not applicable to poultry 

operations in the Valley. 

(2) Use a solid litter/ manure handling system in housing. 

As discussed in earlier sections, the District is not recommending one manure 

management technique (solid manure management or liquid manure management) 

over the other. Each management technique has its own merits and if used properly 

can result in similar emission reductions. Therefore, this measure will be deleted to 

allow operators the flexibility to utilize a manure management system that works best for 

their facilities. 

(3) Poultry Phase I Class Two solid manure handling mitigation measures

The following Class Two solid manure handling measures would be removed from the 

rule: 

• Send at least 51% of the litter/manure to a digester system vented to a VOC 

emission control device 

• Compost poultry litter/manure using an aerated static pile vented to a VOC 

emission control device 

The Class Two Mitigation Measures from the Phase I solid manure handling table will 

be removed due to lack of feasibility, either economically or technologically. Further 

information is included in Appendix E. 

4. Layer Liquid Manure Handling Mitigation Measures

All of the mitigation measures are considered to have equivalent reductions. 

a) Mandatory mitigation measures

There are no mandatory mitigation measures for this table. 

b) Additional mitigation measures

There are three specific-action mitigation measures included in this table. 
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(1) Use a phototropic lagoon.

(2) Use an anaerobic treatment lagoon.

(3) Maintain lagoon pH between 6.5 and 7.5

These measures have been included in the additional measures for the same reasons 

outlined in the dairy liquid manure section above. 

c) Retired mitigation measures

The following mitigation measures will not be in the Phase II liquid manure table: 

(1) Manage the facility such that there are no lagoons. 

(2) Remove solids from the waste system with a solid separator system, prior to 

the waste entering the lagoon. 

(3) Poultry Phase I Class Two liquid manure mitigation measures

These mitigation measures will not be included in the layer Phase II liquid manure 

handling table for the same reasons outlined in the dairy liquid manure section. 

5. Broiler/Duck/Turkey Feed Mitigation Measures

The broiler/duck/turkey feed table would be modified to be the same as the layer feed 

table for the same reasons outline in the later feed section above. 

6. Broiler/Duck/Turkey Housing Mitigation Measures

Operators are required to implement four mitigation measures for broiler/duck 

operations, five for turkey operations. 

a) Mandatory mitigation measures

All of the mitigation measures with specific actions are mandatory. 

(1) Use a dry housing cleaning method

A wet cleaning method would put water, manure, and litter in proximity to one another 

which are ideal conditions for microbial decomposition of the litter and manure. Broilers 

are housed directly on the ground; they require a bedding of some sort, generally a 

fibrous type material. This bedding provides for a cleaner environment for the birds, 

while maintaining dry housing conditions. Since birds are housed directly on 

the ground, a flush system by nature cannot be used because it would simply flush the 

birds away. Untarnished manure, droppings from layers directly to the ground without 

bedding material, can be flushed without worrying about animal welfare. But more 

importantly, manure that contains a majority of bedding material (saw dust, rice hulls, 

hay, etc) cannot be flushed because it would not make sense to do so. This type of 
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material is more properly handled as a solid assuming that it is maintained in dry 

conditions. 

(2) Use drinkers that do not drip continuously.

The reason for including this mitigation measure is the same as for the layer operations 

outlined above. 

(3) Adjust drinkers every seven days. 

Broiler, duck and turkey CAFs generally raise animals from chicks until they reach 

market weight. The size of the birds changes significantly in that time period. If the 

drinker is not set at the right height or the flow is not set correctly, water will be knocked 

out of the drinker by the birds as they attempt to drink water. The water would then mix 

with the litter and manure on the floor, leading to conditions that are good for microbial 

degradation. Since the process of microbial decomposition emits VOCs (specifically 

volatile fatty acids), adjusting the drinkers for flow and height is needed and will reduce 

the likelihood of water spilling. 

(4) Inspect water pipes and drinkers and repair leaks daily.

The reason for including this mitigation measure is the same as for the layer operations 

outlined above. 

(5) Install mounds or berms up gradient to prevent the runoff of storm water into 

pens. 

This measure will only be required for turkey operations since turkeys are the only type 

of poultry that are housed in outside pens. This measure will allow the turkeys to move 

to higher grounds during wet weather, reducing the manure content in the wet pens, 

which in turn will reduce excess anaerobic conditions. 

b) Additional mitigation measures

All applicable measures are required in the Phase II broiler housing table. There are no 

additional mitigation measures. 

c) Retired mitigation measures

The following Phase I poultry housing mitigation measures will not be included in the 

Phase II broiler/duck/turkey housing table for the same reasons outlined in the layers 

housing section narrative above. 
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(1) Remove caked animal waste every 14 days. 

(2) Use poultry litter additives designed to reduce air emissions or moisture 

content in litter. 

(3) Use no foggers in the house. 

(4) Only use a fogger system designed to provide water droplets of a specified 

size 

(5) Slope the house at 3%

(6) Maintain the roof structure and manage roof runoff.

(7) Phase I poultry housing Class Two mitigation measures

All the above measures have been discussed in the broiler layer section above. 

The following Phase I poultry housing measure is not applicable and will not appear in 

the Phase II broiler/duck/turkey housing table: 

(8) Clean under poultry cages every 14 days. 

Operators do not cage broilers, ducks, or turkeys; therefore this measure does not apply 

to these operations and removed from the Phase II broiler housing table. 

7. Broiler/Duck/Turkey Solid Manure Handling Mitigation Measures

The broiler/duck/turkey solid manure handling table has the same management 

practices as the corresponding menu for layer solid manure. See the dairy solid 

manure handling section narrative for detailed descriptions of individual mitigation 

measures. 

8. Broiler/Duck/Turkey Liquid Manure Handling Mitigation Measures

The broiler/duck/turkey liquid manure handling table has the same management 

practices as the corresponding table for layer liquid manure. See the dairy liquid 

manure handling section narrative for detailed descriptions of individual mitigation 

measures. 
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9. Summary of Poultry Mitigation Measures

Summary of the Minimum Number of VOC Mitigation Measures 

Compared to Total Number of Management practices 

Area New Rule Layer 

Feed (TMR) 1 required of 1 total 

Housing 2 required of 2 total 

Solid Manure/ 

Separated Solids 1 required of 1 total 

Liquid Manure 1 additional of 3 total 

TOTAL 5 of 7 

Summary of the Minimum Number of VOC Mitigation Measures 

Compared to Total Number of Management practices 

Area New Rule Broiler, Duck, and Turkey 

Feed (TMR) 1 required of 1 total 

Housing For Chicken Broiler and Ducks: 4 required of 4 total 

For Turkeys: 5 required of 5 total 

Solid Manure/ 

Separated Solids 1 required of 1 total 

Liquid Manure 1 additional of 3 total 

TOTAL 7 of 9 (Turkey 8 of 10) 

10. Poultry Operations Compliance Schedule

Poultry operations that become subject to the Phase II control requirements would be 

required to submit an Authority-to-Construct application by April 21, 2011 and be in full 

compliance with the Phase II requirements within one year after either the Authority-toConstruct or the Permit-to-Operate are issued, whichever is earlier. 

K. Other Proposed Changes 

The requirements for a permit and the emission mitigation plan from Section 5.0 and 

Section 6.0 would be consolidated and moved to the beginning of Section 5.0 to 

improve reader understanding. The requirements for a mitigation plan would be 

consolidated to Section 5.1 for reader clarity. The Sections 5.0 and 6.0 would be 

renumbered as needed. Section 5.2 has been altered to reflect related SB 700 

language about permit renewal. Recordkeeping has been added to Section 5.4.1.1 to 

retain a signed written copy of a determination that a measure is suspended because it 

is detrimental to animal health. 
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The provisions covering temporary suspension of mitigation measures when inducing 

poultry to molt have been combined with the section covering the general requirements 

for temporary suspension of mitigation measures. 

Monitoring requirements for lagoons have been added to the rule. This is in response 

to EPA concerns that certain mitigation measures need to be monitored more often than 

annually in order to verify compliance. 

The required records in Section 7.0 have been expanded to detail the records and 

testing needed for each mitigation measure. The proposed change will help 

owners/operators and compliance inspectors with making sure that mitigation measures 

are utilized on a regular basis. The following record requirements have been added: 

• Feed Moisture Content 

• Silage Density 

• Silage Pile Formation 

• Exposed Silage 

• Silage Inoculation 

• Housing Bedding Material 

In light of the fact that Rule 4570 will apply to more operations and that those operations 

will be smaller than those currently regulated, the District is committed to providing 

multiple resources and tools to minimize costs and administrative burden associated 

with the implementation of this rule. District staff plans to review required records to 

minimize paperwork burden and provide outreach to the medium-sized CAFs 

throughout the Valley. 

L. Revisions from the June 17, 2010 Proposed Rule 

Modifications to the June 17, 2010 version are reflected in the Revised Proposed Rule 

4570. Changes have been made based on new information and further discussions with 

EPA and various stakeholders, and are discussed earlier in this staff report. The 

following summarizes the overarching revisions to the rule since the June hearing: 

• Control requirement tables have been tightened and streamlined, requiring more 

mandatory measures that are feasible, and eliminating infeasible measures, such 

as enclosing and controlling dairy freestall barns with prohibitively expensive 

controls. Also, some existing measures have been removed or combined, based 

on new science and understanding of operations. 

• The silage measures have been reevaluated and refined but are essentially the 

same requirements as in the June version. Silage requirements aggressively 

reduce emissions from this category and are based on the latest science. 

• The current regulatory thresholds for feedlots, other cattle, swine and horses, 

have been amended to reiterate the current rule’s thresholds, given that a 

minimal number of facilities, if any, that would be brought into the rule. 

• Language has been polished to more clearly reflect the practices at CAFs. 
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XI. EMISSIONS AND EMISSION REDUCTION ANALYSIS

The estimated current baseline emissions inventory for CAFs is summarized in Table 4. 

Table 4 – Estimated Baseline Emission Inventory 

VOC Emission Inventory in tons per day 

Type of CAF 2008 

current rule 

2012 

without rule reductions

2023 

without rule reductions

Dairy 95.82 105.82 137.38 

Layers 0.26 0.26 0.26 

Broilers 7.35 7.35 7.35 

Total CAF Emissions 112.4 122.4 153.96 

The estimated emission reductions associated with implementation of the proposed 

amendments are summarized in Table 5. Details of the emission reduction analysis are 

found in Appendix B of this staff report. 

Table 5 – Estimated Emission Reductions 

Estimated Emission Reductions in tons per 

day Type of CAF 2012 

(1st full year of compliance)

2023 

(projected reductions) 

Dairy 25.09 31.62 

Layers 0.012 0.012 

Broilers 0.132 0.132 

Total Estimated Reductions 25.234 31.764 

XII. COSTS AND COST EFFECTIVENESS ANALYSIS 

District staff estimated added compliance costs for the amendments to the rule 

provisions. For dairy CAFs, it is estimated that the changes to the rule will affect 

operations at individual dairies by requiring the operator to use certain emission 

reduction practices. Overall, the implementation cost for dairy CAFs is estimated to be 

$61 million per year. District staff estimates that the additional cost to poultry CAF 

owner/operators, and more specifically to chicken meat and egg producers, is $274,000 

annually. Compliance costs for beef feedlots, other cattle, and swine operations are 

estimated to be minimal and likely absorbed into current practices. 

Cost effectiveness is a measure of the cost required to achieve the emissions 

reductions associated with the proposed rule, found by dividing the compliance cost by 

the estimated emission reductions. For the two main CAF categories impacted by the 

proposed amendments, dairy and poultry CAFs, the cost effectiveness is estimated to 

be $6,695 per ton of VOC reduced, and $5,362 per ton of VOC reduced, respectively. A 
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Revised Proposed Amendments to Rule 4570

detailed cost effectiveness analysis for the proposed Rule 4570 amendments is 

included as Appendix C of this staff report. 

XIII. SOCIOECONOMIC IMPACT ANALYSIS 

Pursuant to state law, District staff is required to perform a socioeconomic impact 

analysis prior to adoption, amendment, or repeal of a rule that has significant air quality 

benefits or that will strengthen emission limitations. As part of the District’s 

socioeconomic analysis process, owners, operators, and other interested parties were 

invited to submit economic information to aid District staff with the socioeconomic 

impact analysis. This information and supporting data was provided to an outside 

consultant who identified and analyzed the socioeconomic impacts of the proposed 

amendments to Rule 4570 on the regional economy. The results of the socioeconomic 

analysis are available as Appendix D of this staff report. 

XIV. ENVIRONMENTAL IMPACT ANALYSIS 

The proposed project is a continuation of the June 17, 2010, proposed amendment to 

Rule 4570. Pursuant to California Environmental Quality Act (CEQA) Guidelines 

§15063, staff conducted an Initial Study, incorporated herein by reference, to determine 

if the proposed project may have a significant effect on the environment. Staff 

determined that there was no substantial evidence before the District that any aspect of 

the project may cause a significant environmental impact. On April 14, 2010, staff 

published a Notice of Intent to Adopt a Negative Declaration (CCR §15072). The draft 

Negative Declaration was available for public comment from April, 14, 2010 to May 14, 

2010. 

Comments were received from the California Regional Water Quality Control Board 

(RWQCB) regarding management practices that may increase water usage, as 

summarized in Appendix A. The Hydrology and Water Quality section of the Negative 

Declaration was revised to reflect RWQCB comments; however the revision did not alter 

the initial determination that the proposed project would not have a significant 

environmental impact. 

Since publication in June, 2010, the proposed rule amendments have undergone minor 

revision. A summary of the proposed revisions is presented in Section X.L of this staff 

report. Staff concludes that the proposed revisions do not constitute a “substantial 

revision” as defined in CEQA Guidelines section 15073.5(b) and recirculation of the 

Negative Declaration is not required (CCR §15073.5(c). Thus, upon approval of the 

proposed amendments by the District’s Governing Board, District staff will file a Notice 

of Determination with each County Clerk within the boundaries of the District (CCR 

§15075(d). 
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Revised Proposed Amendments to Rule 4570

XV. RULE CONSISTENCY ANALYSIS 

Pursuant to CH&SC 40727.2, District staff has prepared a rule consistency analysis that 

compares the elements of the amendments with the corresponding elements of other 

District rules, federal regulations and guidelines that apply to the same source category 

or type of equipment. District staff found that the proposed amendments and 

requirements of this rule would not conflict with federal rules, regulations, or policies 

covering similar sources. The rule consistency analysis is presented in Appendix F of 

this report. 

XVI. REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) ANALYSIS 

CAA Section 182(b) (2) states that ozone attainment plans shall assure that RACT for 

volatile organic compounds (VOC) is applied at certain sources. 

A RACT analysis requires an examination of three broad elements, applicability, 

stringency, and enforceability, against federal rules, regulations, and technology 

guidelines, as well as comparing it against rules from other air districts in California 

The District believes that this proposed rule exceeds RACT. A detailed RACT analysis 

has been provided to the District’s Governing Board as a separate document. 

XVII. HEALTH BENEFIT ANALYSIS 

The District adopted its first confined animal facility rule, Rule 4570, at a public hearing 

held on June 15, 2006. Prior to and during the rule adoption hearing, the District 

considered (1) the feasibility of the control measures contained in Rule 4570, (2) the 

economic impacts associated with the rule, (3) reductions in ozone pre-cursors that 

would result from compliance with the rule, and (4) the public health impacts of ozone 

and ozone precursors. As is normally the case under CAA rulemaking, the District did 

not consolidate this information into a specific discussion of the rule’s impact on public 

health in 2006. However, because Rule 4570 was triggered by the enactment in 2003 

of Senate Bill 700 (codified under CH&SC Section 40724.6(e)), the California Fifth 

Appellate District ruled that rulemaking under this statute must explicitly consider the 

public health impacts of control measures on CAFs. These benefits were to be 

balanced against the economic impacts of the proposed rule and its feasibility. 

In response to this ruling, the District, in conjunction with a temporary suspension and 

re-adoption of Rule 4570, conducted a health benefit analysis of the 2007 Ozone Plan 

in 2009 that included (1) the contribution of the CAF sector to ozone concentrations in 

the San Joaquin Valley, (2) Rule 4570’s contribution to regional ozone reductions in 

2012 and 2020, and (3) a quantification of cumulative health benefits in 2020 resulting 
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Revised Proposed Amendments to Rule 4570

from the 2007 Ozone Plan. Of particular relevance to the current proposed amendment 

of Rule 4570, that 2009 health benefit analysis quantified the distinct contribution to 

VOC reductions made by previously adopted Rule 4570 as well as the additional 

reductions accruing from the current proposed amendments. This prior health benefit 

analysis satisfied the requirements of the CH&SC Section 40724.6(e). 

This rule project is not subject to CH&SC Section 40724, et seq. (SB 700) and an 

explicit analysis of health benefits from the proposed amendment is not required. The 

purpose of this rule project is to meet a control strategy commitment in the District’s 

2007 Ozone Plan (Control Measure S-AGR-2). However, because of the relevance to 

the rule project of the previous health benefit analysis and the similarity in the VOC 

reductions estimated in the 2009 analysis to the reduction estimate from the proposed 

amendments of 31.8 tons per day of VOC, an abbreviated reiteration of the health 

benefit analysis is included in Appendix G. 

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30. Mitloehner, Dr. Frank. Correspondence regarding “Production efficiencies as 

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