SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

APPENDIX B 

BASELINE EMISSION INVENTORY 

AND EMISSION REDUCTION ANALYSIS 

FOR REVISED PROPOSED RULE 4570 

(CONFINED ANIMAL FACILITIES) 

October 21, 2010 

B-1 Final Staff Report with Appendices For 

 Revised Proposed Amendments to Rule 4570 
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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

APPENDIX B 

BASELINE EMISSION INVENTORY AND ESTIMATED EMISSION REDUCTIONS 

I. SUMMARY 

The purpose of this appendix is to detail the emission inventory and emission reduction 

analyses associated with the proposed amendments to Rule 4570 (Confined Animal 

Facilities) (CAF). The rule applicability threshold has been lowered for dairies and 

poultry (laying and broiling chickens) operations. The lowering of the threshold will make 

many previously exempted facilities subject to the requirements of the rule. Additional 

mitigation measures are also required for dairy operations. Although many measures 

have now been mandated in the proposed rule for all of the CAF categories, no 

additional emission reductions are expected from feedlot cattle, other cattle, swine, 

turkeys, goats, sheep, horses and other smaller CAFs. Therefore, no analysis will be 

performed for these categories and this analysis will only calculate the emissions 

reductions from dairy, layer and broiler CAF categories. 

A. Baseline Emission Inventory for Affected CAFs 

The baseline emission inventory for CAF types affected by the amendments to this rule 

is summarized in Table 1. 

Table 1 - 2012 Population Estimate 

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 

Poultry 

Laying Chickens 0.26 0.26 0.26 

Broiler Chickens 7.35 7.35 7.35 

Total CAF Emissions 112.4 122.4 153.96 

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Revised Proposed Amendments to Rule 4570 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

B. Estimated Emission Reductions 

Table 2 summarizes the estimated emission reductions from each type of CAF. 

Table 2 - Estimated Emission Reductions by CAF Type 

Estimated Emission Reductions in tons per day 

Type of CAF 2012 

(1st full year of compliance)

2023 

(projected reductions) 

Dairy 25.09 31.62 

Poultry 

Laying Chickens 0.01 0.01 

Broiler Chickens 0.13 0.13 

Total Estimated Reductions 25.23 31.76 

II. EMISSION INVENTORY METHODOLOGY 

Emission inventories are calculated using an Emission Factor (EF) multiplied by a 

process rate. For CAFs, the EF is generally calculated on a per-animal basis, meaning 

that the EF is generally in pounds of emissions per head per year (lbs/hd-yr). The 

Emission Inventory can then be calculated by multiplying the EF by the number of 

animals at the facility. For dairies, recent studies have found feed (primarily from silage) 

to be a significant source of emissions. Since emissions from feed sources are based 

on an exposed surface area, the emissions are calculated by multiplying the area of the 

exposed feed surface and the EF in unit/area emitted. In order to calculate the 

emissions reductions, the emission inventory is multiplied by the control efficiency of 

each mitigation measure. 

As a note, the reductions are only assessed from the facilities that exceed the Rule 

applicability levels. The remaining animals for each source are included in the inventory 

as uncontrolled emissions. 

A. Dairy Inventory 

1) Dairy Population Estimation Method 

The United States Department of Agriculture (USDA) National Agriculture Statistics 

Service (NASS) is one data source used to determine the number of animals within 

the District. NASS projects animal counts and livestock facility size distribution 

based a survey of a limited number of facilities. The most recent NASS information 

on CAF numbers is the 2007 Agriculture Census. The number of animals at dairies 

is reported in number of mature cows – which means milking (lactating) cows plus 

dry adult cows. District staff disaggregated the number of mature cows into the 

number of milking cows and the number of dry cows by using the District’s Permit 

 B-4 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

Services database of Permits to Operate. The permits list the maximum number of 

milking cows, dry cows, large, medium, and small heifers and the number of calves 

for each facility. Using the overall ratios, the number of milking cows can be 

estimated by applying the ratio of milking cows to the total of [milk cows plus dry 

cows] from the permits database to the number of dairy mature cows in the 2007 

Agricultural Census. 

Information from the Regional Water Board was also used to estimate the number of 

milking cows on dairies and determine the various sizes. 

The 2008 population estimate is shown in Table 3. 

Table 3 - 2008 Population Estimate 

County 

Population 

Estimate Fresno Kern Kings Madera Merced 

San 

Joaquin Stanislaus Tulare Totals 

Milk Cows 94,889 140,181 144,106 60,184 211,644 91,183 150,721 384,772 1,277,678

Dry Cows 23,711 29,319 31,394 15,116 46,556 17,817 32,679 87,928 284,522 

Large Heifers 33,444 50,621 43,877 20,338 45,920 19,660 42,579 113,806 370,246 

Medium Heifers 31,385 36,263 32,336 18,445 38,986 18,241 35,759 97,262 308,677 

Small Heifers 15,388 20,345 18,863 12,203 26,348 12,454 26,353 65,835 197,789 

Calves 10,967 17,636 14,673 18,178 42,015 11,051 17,755 67,526 199,802 

Totals 209,785 294,365 285,249 144,464 411,469 170,406 305,846 817,129 2,638,714

The rule only looks to control emissions from dairy operations with ≥500 milk cows, 

however, the population estimates provided in Table 2 were disaggregated into the 

following categories: <300, ≥300<500, ≥500<1,000, and ≥1000 milk cows since the EFs 

for each of these categories vary, specifically for the silage piles. Silage piles sizes vary 

with the size of the dairy. The smaller dairies will generally have smaller piles than the 

larger dairies. The categories suggested here allow for a more accurate emissions 

inventory and emission reduction calculations. 

Using the herd information from the Regional Water Board, the dairy population 

breakdown by category type is shown in Table 4. 

 B-5 Final Staff Report with Appendices For 

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

Table 4 - 2008 Dairy Cow Population Summary by Category

Category Milk Cows Dry Cows 

Large 

Heifers 

Medium 

Heifers 

Small 

Heifers Calves Totals 

< 300 34,303 7,517 8,926 7,679 5,594 5,240 69,260 

>= 300 88,602 19,433 23,807 20,184 12,410 13,107 177,542 

>= 500 260,158 57,618 72,327 61,081 38,644 39,142 528,968 

>= 1000 894,616 199,954 265,187 219,734 141,141 142,313 1,862,945

Totals 1,277,678 284,522 370,246 308,677 197,789 199,802 2,638,714

In order to determine the emissions reduction effect of the rule in 2012 and 2023, 

population estimates for those years were also created. Data provided by the California 

Department of Food and Agriculture (CDFA) indicates that the average milk cow 

population in the last 7 years has grown approximately 3% per year. The District used 

this information to grow the 2008 estimate by 3% percent each year to derive the 

population estimate in Table 5 and 7. The same methodology noted for Table 4 above 

was used to speciate the data into each category and animal type. The results are 

shown in Tables 6 and 8. 

Table 5 - 2012 Dairy Cow Population Estimate 

County 

Population 

Estimate Fresno Kern Kings Madera Merced 

San 

Joaquin Stanislaus Tulare Totals 

Milk Cows 106,798 157,775 162,192 67,737 238,207 102,627 169,638 433,064 1,438,038 

Dry Cows 26,687 32,999 35,334 17,013 52,399 20,053 36,781 98,964 320,232 

Large Heifers 37,642 56,974 49,384 22,891 51,684 22,128 47,923 128,089 416,715 

Medium 

Heifers 35,325 40,815 36,394 20,760 43,879 20,530 40,247 109,469 347,419 

Small Heifers 17,319 22,899 21,231 13,734 29,655 14,017 29,661 74,098 222,613 

Calves 12,344 19,850 16,515 20,459 47,288 12,438 19,983 76,001 224,879 

Totals 236,115 331,311 321,050 162,596 463,112 191,794 344,232 919,686 2,969,896 

Table 6 - 2012 Dairy Cow Population Summary by Category

Category Milk Cows Dry Cows 

Large 

Heifers 

Medium 

Heifers 

Small 

Heifers Calves Totals 

< 300 38,609 8,460 10,046 8,643 6,296 5,898 77,952 

>= 300 99,722 21,872 26,795 22,717 13,968 14,752 199,825 

>= 500 292,810 64,849 81,404 68,747 43,494 44,054 595,358 

>= 1000 1,006,898 225,050 298,470 247,312 158,856 160,175 2,096,761

Totals 1,438,038 320,232 416,715 347,419 222,613 224,879 2,969,896

 B-6 Final Staff Report with Appendices For 

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

Table 7 - 2023 Dairy Cow Population Estimate 

County 

Population 

Estimate Fresno Kern Kings Madera Merced 

San 

Joaquin Stanislaus Tulare Totals 

Milk Cows 147,834 218,397 224,512 93,764 329,734 142,060 234,818 599,462 1,990,581 

Dry Cows 36,941 45,679 48,911 23,551 72,533 27,759 50,913 136,989 443,276 

Large Heifers 52,105 78,866 68,359 31,687 71,542 30,630 66,337 177,306 576,832 

Medium 

Heifers 48,897 56,497 50,378 28,737 60,739 28,419 55,711 151,531 480,909 

Small Heifers 23,974 31,697 29,388 19,011 41,050 19,403 41,058 102,569 308,149 

Calves 17,087 27,477 22,861 28,320 65,458 17,218 27,662 105,203 311,285 

Totals 326,838 458,612 444,409 225,071 641,056 265,488 476,498 1,273,060 4,111,031 

Table 8 - 2023 Dairy Cow Population Summary by Category

Category Milk Cows Dry Cows 

Large 

Heifers 

Medium 

Heifers 

Small 

Heifers Calves Totals 

< 300 53,444 11,711 13,906 11,964 8,715 8,164 107,904 

>= 300 138,038 30,275 37,091 31,446 19,334 20,420 276,605 

>= 500 405,317 89,766 112,682 95,162 60,206 60,981 824,115 

>= 1000 1,393,782 311,523 413,152 342,338 219,894 221,719 2,902,407

Totals 1,990,581 443,276 576,832 480,909 308,149 311,285 4,111,031

2) Number of Dairies in the Valley 

It has been estimated that there are approximately 1,331 dairies in the San Joaquin 

Valley. In order to calculate the silage emissions appropriately, the total dairies in 

the valley must be speciated into the following categories (<300, >= 300, >=500, and 

>=1000 milk cows) as discussed above. The data provided by the Regional Water 

Board was used to develop the percent of dairies and the number of dairy facilities 

for each category, as shown in Table 9. 

Table 9 - Estimated Dairies By Category 

Category 

< 300 

(SCAF) 

>= 300 

(SCAF) 

>= 500 

(CAF) 

>= 1000 

(LCAF) Total

# Dairies 180 242 419 490 1331 

 B-7 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

3) Silage Surface Area Estimation 

The emission factors for total mixed rations (TMR) and for silage are based on the 

total amount of surface area exposed. In meetings with dairy industry 

representatives, stakeholders provided an average exposed area for both TMR and 

silage piles at dairies of various sizes. The following surface area, in square meters 

(m2), will be used to calculate the emissions from TMR and silage on a per-dairy 

basis. 

Table 10 - Estimated Size of Pile (m2) Based on Size of Dairy 

Size of Dairy >1,000 Milk Cows 300 to 999 Milk Cows <300 Milk Cows 

Size of Pile (m2) 225 102 44.59 

Size of Pile (m2) 24 24 0 

Size of Pile (m2) 225 102 0 

B. Layer and Broiler Inventory 

The population of animals in this category was estimated based on information from the 

USDA Agricultural Census and the District’s Permit/CMP database. 

District staff is expecting that these sectors will not change significantly between now 

and 2023. 

Table 11 - Laying and Broiler Chicken Inventory 

Animal Type Number of Animals # of birds subject 

to Current Rule 

Additional birds brought 

into proposed Rule1

Laying Chickens 9,565,825 5,548,179 1,050,000 

Broiler Chickens 287,565,325 178,290,502 9,450,000 

III. EMISSION FACTORS 

A. Dairy Emission Factors 

The current uncontrolled Emission Factor (EF) being used by the District in the 

permitting of dairies is 19.3 lbs/hd-yr which was based on a report released by the 

District on August 1, 2005, entitled “Air Pollution Control Officer’s (APCO) Determination 

of VOC Emission Factors for Dairies”

2

. The report was based on the best available 

science at the time and also outlined areas and sources which needed further studying. 

The District and other stakeholders developed multiple studies which were tailored to fill 

 

1

 Based on information provided by industry, due to the lowering of the applicability threshold for layers 

and broiler, 2 additional layer operations and 18 additional broiler operations will now be brought into the 

Rule. It will be estimated that each of these operations has an average of 525,000 birds each 2

http://www.valleyair.org/busind/pto/dpag/APCO%20Determination%20of%20EF_August%201_.pdf

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

in the information gaps identified in the previous work. These studies were performed in 

California to capture the conditions found on local dairies. Upon completion of these 

studies, the District undertook a very detailed analysis to revise the dairy VOC Emission 

Factor. This new analysis includes updates to the existing dairy emission sources that 

were documented in the 2005 report for the following sources: enteric emissions, milk 

parlor, freestall barns, corrals, lagoon/storage, and separated solid piles. The revised 

analysis also includes a great deal of data that strengthens the emission quantification 

for other sources at dairies. These sources are as follows: liquid and solid land 

application, manure piles, silage piles, and Total Mixed Ration (TMR). The revised 

analysis was released as a draft report (which can be found in Appendix I) for comment 

to the public on January 21, 2010, with the commenting date expiring on February 22, 

2010.The District has reviewed all comments received, and does not expect any 

significant changes to the emission factor. 

Summary of Dairy Emissions3 

In summary, the table below shows the APCO’s recommended revised EF for each 

source or constituent: 

Table 12 - Per Cow Dairy Emissions Factor 

Process or Constituent Emissions (lb/hd-yr) 

1. Enteric Emissions from Cows 4.1 

2. Milking Parlor(s) 0.03 

3. Freestall Barns 1.8 

4. Corrals/Pens 6.6 

5. Liquid Manure Handling 

(Lagoons, Storage Ponds, Basins) 1.3 

6. Liquid Manure Land Application 1.4 

7. Solid Manure Land Application 0.33 

8. Separated Solids Piles 0.06 

9. Solid Manure Storage 0.15 

12. Composting & Manure 

Disturbance TBD, >0

 

3

 All milk cow Emission Factors discussed in this report have been adjusted for all of the other support 

stock at a dairy which includes dry cows, heifers, and calves. The adjustment is made by taking the ratio 

between the milk cow manure output to the other support stock and multiplying by the milk cow EF. 

 B-9 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

Table 12 - Per Cow Dairy Emissions Factor 

Process or Constituent Emissions (lb/hd-yr) 

Total not including Feed 15.8

Table 12a - Silage Pile VOC Emissions Flux 

10. Silage Piles Emissions Flux (μg/m2

-min) 

1. Corn Silage 34,681

2. Alfalfa Silage 17,458

3. Wheat silage 43,844

Table 12b - Average TMR VOC Emissions Flux 

11. TMR Emissions Flux (μg/m2

-min) 

Average 13,056 

The above emission factors have been determined to include the mitigation measures 

from the current version of Rule 4570 (adopted in 2006) based on the mitigation 

measures that were in place on the dairies when the studies were performed. 

Therefore, the above emission factors will be used to calculate the baseline emissions 

inventory for dairies with greater than 1,000 milk cows (the current regulatory threshold 

for Rule 4570). 

Dairies with less than 1,000 milk cows are expected to have no control as those 

facilities were not required to have any mitigation measures in place. In order to 

determine the uncontrolled emission factor, the mitigation measures that were in place 

when the studies were performed need to be adjusted. The controlled EF of 15.8 

lbs/hd-yr and the associated silage and TMR EFs will therefore be adjusted accordingly 

to consider the control measures that were in place at the time the emission 

measurements took place. The following control measures were determined to be in 

place at the dairies where the emission measurements were taken: 

• Feed according to the NRC guidelines4

• Feed or dispose of rations within 48 hours of grinding and mixing rations 

• Cover the horizontal surface of silage piles, except for the area where feed is 

removed from the pile. 

 

4

 5% control efficiency will be used for this measure since one of the two dairies that were sampled did 

not include this measure when the testing was performed. Therefore, the average for the two dairies was 

taken (10%/2=5%). 

 B-10 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 
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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

• Flush or hose milk parlor immediately prior to, after, or during each milking 

• Clean corrals at least once between April and July and at least once between 

October and December 

• Manage corrals such that the depth of animal waste in the corral does not 

exceed 12” at any point or time, except for in-corral mounding4

• Maintain corrals to ensure proper drainage 

• Inspect water pipes and troughs and repair leaks at least once every 14 days4

• Install shades uphill of the corrals4

• Remove solids from the waste system with a solids separator system, prior to the 

waste entering the lagoon 

• Land incorporate all solid manure within 72 hours of applying to land 

• Do not allow liquid manure to stand in fields for more than 24 hours 

Dairy emissions research indicates that the proposed mitigation measures will achieve 

significant emissions reductions. Based on this science, and in an effort to be 

conservative, the District has assessed a 10% minimum control efficiency to the 

majority of mitigation measures, which the District believes may underestimate the 

emissions benefits of the proposed rule. The majority of the VOC emission reductions 

achieved by the proposed rule are expected to come from the measures for silage and 

the total mixed ration (TMR) prepared from the silage. These practices are likely to 

exceed the District conservative control efficiency estimates as discussed below.5

Increased Density & Proper Management of Silage Piles

The proposed rule requires best management practices that will reduce dry matter loss 

and emissions of VOCs. Chapter 40, “Silage Production”, of Forages - The Science of 

Grassland Agriculture6 indicates that dry matter loss in silage piles can be as high as 

35% but proper management of the silage can reduce this loss to 15% or less, a 57% 

reduction in dry matter loss. While some of the dry matter loss is the result of reduced 

CO2 production; a large reduction in weight loss is also attributable to a large reduction 

in VOC emissions. 

Additionally, Dr. Charles Krauter of California State University, Fresno measured VOC 

emissions from silage and feed while performing a study on dairy emissions. 

Information from his completed study has shown that silage with higher density emits 

significantly less total VOC emissions from both the silage piles and the TMR. This 

information indicates that ethanol emissions from two silage piles with the lowest 

 

5

 Section XVIII “References” of the Staff Report, Appendix A of the Dairy Emission Factor Report, and the 

previous Rule 4570 staff report identifies additional studies that support the District’s analysis. 6 "Silage Production" (Forages - The Science of Grassland Agriculture, Chapter 40, December 2006) by 

Richard E. Muck, Agricultural Engineer, US Dairy Forage Research Center, Agricultural Research 

Service, USDA, Madison, WI and Limin Kung, Jr., Professor of Animal and Food Sciences, University of 

Delaware, Newark, DE http://ddr.nal.usda.gov/bitstream/10113/9224/1/IND43941281.pdf

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

densities were more than twice as great as the average ethanol emissions from all other 

remaining piles. 

Although the expected reduction in dry matter loss from proper management of silage 

piles can be as high as 57% and information from Dr. Krauter’s study showed that 

adequate density could potentially reduce ethanol emissions by as much as 50%, the 

District conservatively applied a 25% control efficiency for this measure. 

Inoculation with Homolactic Bacteria

In a study by Filya7, inoculation with homolactic lactic acid bacteria (L. plantarum) 

resulted in an average reduction in ethanol concentration of 12.1% in the corn silages 

that were studied compared to the control with no inoculation. The study also found that 

inoculation with homolactic lactic acid bacteria reduced weight loss in corn silage by an 

average of 43.2% compared to the control with no inoculation. Similar to the study 

above, a large reduction in weight loss is also attributable to a large reduction in VOC 

emissions. Although this study found an average reduction in ethanol concentration 

greater than 10% and an average reduction in weight loss much greater than 10%, the 

District conservatively applied a 10% control efficiency for this measure. 

Antifungal Chemical Additives 

Another study showed that the addition of sodium benzoate and a potassium sorbate 

additive reduced ethanol concentrations in corn silage by 73.2% and 79.7%, 

respectively compared to the control. The study also found that these additives reduced 

dry matter loss by more than 85.7%.8 While this study found reductions in ethanol 

concentration and dry matter loss much greater than 10% the District conservatively 

applied a 10% control efficiency for this measure. 

Although the District believes that the VOC emission reductions achieved by several 

measures included in the proposed rule may be underestimated, the District will 

continue to seek out and support research that further enhances its understanding of 

CAF emissions and potential mitigation measures. 

Applying the above assumptions to the proposed EF of 15.8 lbs/hd-yr and the 

associated silage and TMR EFs results in a corrected uncontrolled EF of 20 lbs/hd-yr. 

The 20 lbs/hd-yr is consistent with the uncontrolled EF of 19.3 lbs/hd-yr that was 

established in the 2005 APCO VOC report2. The 20 lbs/hd-yr EF and the associated 

 

7

 Filya, I., 2003. The effect of Lactobacillus buchneri and Lactobacillus plantarum on the fermentation, 

aerobic stability and ruminal degradability of low dry matter corn and sorghum silages. J. Dairy Sci., 86: 

3575-3581. 

8

 Kleinschmit, D. H., Schmidt, R. J., and L. Kung, Jr. 2005. The effects of various antifungal additives on 

the fermentation and aerobic stability of corn silage. J. Dairy Sci. 88:2130-2139.

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Revised Proposed Amendments to Rule 4570 
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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

 B-13 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

adjusted silage and TMR EFs will therefore be used as the uncontrolled baseline EF for 

dairies with less than 1,000 milk cows. 

Table 13 shows the breakdown of the emission calculations. A sample calculation for 

Enteric Emissions demonstrates how the calculations were conducted: 

 Enteric Emissions = 4.1 lbs/hd-yr ÷ (1 - Control Efficiency Feed to NRC Guideline) 

= 4.1 lbs/hd-yr ÷ (1 - 0.05) 

= 4.32 lbs/hd-yr 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions 

B-14 Final Staff Report wit

 Revised Proposed Amendm

Table 13 - Correcting Dairy Emission Baseline Summary 

Feed Silage Parlor Corrals Liquid L

Source 

Proposed 

Revised Draft 

EF 

Feed to NRC 

Guidelines 

feed/dispose 

rations 48 hrs 

Silage pile 

cover 

flush parlor after 

each milking 

remove manure 

April to July 

depth of waste 

not exceed 12 " 

in corral 

ensure drainage

- slope surface - 

harrow/rake 

Inspect Water 

pipes 

Install Shades 

uphill 

remove solids 

w/ separator 

1. Enteric Emissions 4.1 5% 2. Milking Parlor(s) 0.03 5% 10% 3. Freestalls (lanes) 0.8 5% 

Freestall beds 1.0 5% 

4. Corrals/Pens 6.6 5% 10% 5% 10% 5% 5% 5. Liquid Manure Handling (Lagoons, Storage Ponds) 1.3 5% 10% 6. Liquid Manure Land Application 1.4 5% 7. Solid Manure Land Application 0.33 5% 108. Separated Solids Piles 0.06 5% 9. Solid Manure Storage 0.15 5% Total not including Feed 15.8 10. Silage Piles (μg/m2-min) 

Corn Silage 34,681 10% 

Alfalfa Silage 17,458 10% 

Wheat silage 43,844 10% 

11. TMR 13,056 10% 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

Emission Factors for Dairies with greater than 1,000 milk cows (large dairies) with 

proposed Rule 4570 mitigation measures in place

As indicated above, the baseline emission factor for dairies with milk cows greater than 

1,000 milk cows is 15.8 lbs/hd-yr. The proposed rule includes many mandated 

measures in addition to requiring additional mitigation measures. The control 

efficiencies of the additional mitigation measures will be applied to the baseline EF of 

15.8 lbs/hd-yr which will result in a further controlled EF. 

All of the mitigation measures and assumptions are listed below for an example dairy: 

Example dairy with the proposed rule mitigation measures: 

• Feed according to the NRC guidelines 

• Feed steam-flaked, dry rolled, cracked or ground corn or other steam-flaked, dry 

rolled, cracked or ground cereal grains 

• Begin feeding or disposing of total mixed rations within two (2) hours of grinding 

and mixing rations. 

• Store grain in a weatherproof storage structure from October to May 

• Push feed to within three (3) feet of feed bunk fenceline 

• Cover the surface of silage piles, except for the area where feed is removed from 

the pile. 

• Silage Inoculation 

• Manage multiple silage piles such that the total exposed surface area of all silage 

piles is less than 4,300 square feet 

• Incorporate the following practices when creating a silage pile:9

o Harvest silage crop at: ≥65% moisture for corn; and ≥60% moisture for 

alfalfa/wheat/grass using TM BBB. 

o Set chop particle length to 1/2 inch or less for unprocessed silage 

material. 

o Manage silage material delivery such that no more than six (6) inches of 

material are uncompacted on top of the pile. 

o Cover silage pile within 72 hours of last delivery of material to the pile. 

• Flush or hose milk parlor immediately prior to, after, or during each milking 

• Flush, scrape, or vacuum freestall flush lanes immediately prior to, immediately 

after, or during each milking 

• Rake, harrow, scrape, or grade bedding in freestalls at least once every 14 days 

• Clean corrals at least once between April and July and at least once between 

September and December. 

 

9

 All these practices result in reduced porosity, which in turn reduces ethanol production. A significant 

amount of emission reductions can be achieved through this practice, however to be conservative, a 25% 

control efficiency will be applied. These management practices will also have a reduction in emissions 

from the TMR. To be conservative, only a 10% control efficiency will be applied at this time, although 

emissions reductions could be significantly greater. 

B-15 Final Staff Report with Appendices For 

 Revised Proposed Amendments to Rule 4570 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

B-16 Final Staff Report with Appendices For 

 Revised Proposed Amendments to Rule 4570 

• Scrape, vacuum, or flush concrete lanes in corrals at least once every day for 

mature cows and every seven (7) days for support stock 

• Inspect water pipes and troughs and repair leaks at least once every seven (7) 

days. 

• Maintain corrals to ensure drainage and prevent water from standing more than 

48 hours after a storm 

• Install shade structures such that they are constructed with a light permeable 

roofing material 

• Manage corrals such that the depth of animal waste in the corral does not 

exceed 12” at any point or time, except for in-corral mounding. Manure depth 

may exceed 12 inches when corrals become inaccessible due to rain events. 

The facility must resume management of the manure depth of 12 inches or lower 

immediately upon the corral becoming accessible. 

• Cover dry animal waste piles outside the pens with a weatherproof covering from 

October to May, except for times, not to exceed 24 hours per event, when wind 

events remove the covering 

• Remove solids with a solids separator system, prior to the manure entering the 

lagoon 

• Apply no solid manure with a moisture content of greater than 50% 

• Allow liquid animal waste to stand in the fields no more than 24 hours after 

irrigation 

Applying the above mitigation measures and the associated control efficiency to the 

15.8 lbs/hd-yr and the associated silage and TMR baseline EFs results in an Revised 

Proposed Rule 4570 control EF of 13.5 lbs/hd-yr for the manure and a significant 

change (decrease) for the silage and TMR EFs. These EFs will be used towards 

developing the Revised Proposed Rule 4570 emissions inventory and will serve as the 

basis for the reductions for this proposed rule for the greater than 1,000 milk cow 

category. 

Table 14 summarizes the calculations of the emission factors. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

 Appendix B: Baseline Emission Inventory and Emission Reductions 

Table 14 - Dairy Emission Factor after applying current R4570 requirements 

Feed Mitigation Silage Parlor Freestalls Corrals S

Source 

Baseline EF 

Feed to NRC Guidelines** 

Push feed within 3 feet 

feed/dispose rations 2 hrs* 

feed high moisture corn 

store grain weatherproof cover 

silage pile cover* 

Density 

Smooth Face 

Inoculation 

flush parlor after milking* 

Rake, harrow scrape or grade 

flush more frequently 

Remove manure from corrals** 

clean lanes not exceed 12" - 

clean lanes 1-7 days 

Inspect water troughs for leaks** 

slope surface/ensure 

drainage/harrow-scrape* 

Shades*** 

depth in corral less than 12** 

1. Enteric Emissions 4.1 5% 2. Milking Parlor(s) 0.03 5% 3a. Freestall Lanes 0.8 5% 10% 3b. Freestall Beds 1.0 5% 10% 4. Corrals/Pens 6.6 5% 10% 5% 2.3% 5% 5. Lagoons, Storage Ponds 1.3 5% 6. Liquid Manure Land Application 1.4 5% 7. Solid Manure Land Application 0.3 5% 8. Separated Solids Piles 0.06 5% 9. Solid Manure Storage 0.15 5% Total not including Feed 15.8 

B-17 Final Staff Repo

 Revised Proposed Ame
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions 

B-18 Final Staff Repo

 Revised Proposed Ame

Table 14 - Dairy Emission Factor after applying current R4570 requirements 

Feed Mitigation Silage Parlor Freestalls Corrals S

Source 

Baseline EF 

Feed to NRC Guidelines** 

Push feed within 3 feet 

feed/dispose rations 2 hrs* 

feed high moisture corn 

store grain weatherproof cover 

silage pile cover* 

Density 

Smooth Face 

Inoculation 

flush parlor after milking* 

Rake, harrow scrape or grade 

flush more frequently 

Remove manure from corrals** 

clean lanes not exceed 12" - 

clean lanes 1-7 days 

Inspect water troughs for leaks** 

slope surface/ensure 

drainage/harrow-scrape* 

Shades*** 

depth in corral less than 12** 

10. Silage Piles (μg/m2-min) 

Corn Silage 34,681 25% 10% 10% 

Alfalfa Silage 17,458 25% 10% 10% 

Wheat silage 43,844 25% 10% 10% 

11. TMR 13,056 10% 10% - 10% *Estimated to be included in the revised EF of 15.8 lbs/hd-yr and the associated silage and feed EF. **Estimated to be partially included in the revised EF of 15.8 lbs/hd-yr and the associated silage and feed EF. ***Estimated to be partially included in the revised EF of 15.8 lbs/hd-yr and expecting 50% of dairies will select the measure.-Emission reductions not quantified from this measure since no EF is available for this measure 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

Emission Factors for Dairies between 500 to 999 milk cows (Medium dairies)

This source category was previously not required to perform any of the mitigation 

measures from the current rule (adopted 2006). The proposed rule now requires these 

facilities to adopt mitigation measures consistent with dairies with > 1,000 milk cows. 

The number of measures required for the medium size dairies are the same as those for 

large dairies, with the exception of one less measure from the solid manure category. 

The emissions from the solid manure category is extremely low, adjustments to the 

calculation will not change any of the above numbers, therefore, the resulting controlled 

EF will be the same as calculated for the large dairies in the above table. Therefore, the 

13.5 lbs/hd-yr and the associated silage and TMR EFs will be used as the controlled 

EFs for this category as well. 

These EFs will be used towards developing the emissions inventory and will serve as 

the basis for the reductions for this proposed rule for the 500-999 milk cow category. 

B. Layer and Broiler Emission Factors 

The layer and broiler Emission Factors are summarized in the table below. 

Table 15 - Layer and Broiler Emission Factors 

Animal Type10 VOC Uncontrolled Emission 

Factor Manure (lb/hd-yr)

VOC Controlled Emission 

Factor Manure (lb/hd-yr)11

Laying Chickens 0.025 0.0164 

Broiler Chickens 0.025 0.0148 

 

10 Based on the 2005 California Department of Food and Agriculture source test of a chicken broiler 

facility, results have been transferred over to layer operations – EFs are also approved the California Air 

Resources Board (CARB) 

11 Applying the 10% control efficiency for mitigation measures, the overall control efficiency for layer and 

broiler ranches is 34% and 41%, respectively, resulting in controlled EFs of 0.0164 lbs/hd-yr and 0.0148 

lbs/hd-yr respectively. 

B-19 Final Staff Report with Appendices For 

 Revised Proposed Amendments to Rule 4570 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

IV. BASELINE EMISSION INVENTORY 

A. Dairy 

The dairy baseline emissions inventory for 2008 and the project 2012 and 2023 is 

summarized in the table below. 

Table 16 - Dairy Baseline Emission Inventory 

Source 

2008 

Emissions 

(tons/day)

2012 

Emissions 

(tons/day)

2023 

Emissions 

(tons/day) 

Cows 43.38 48.82 67.58 

Silage <300 0.49 0.49 0.49 

Silage >300<500 3.44 3.44 3.44 

Silage >500<1000 5.96 5.96 5.96 

Silage >1000 13.78 13.78 13.78 

TMR 28.77 33.33 46.13 

Total 95.82 105.82 137.38 

B. Broiler and Layer Baseline Emission Inventory 

The broiler and layer baseline emissions inventory is summarized in the table below. 

Table 17 - Boiler and Layer Baseline Emission 

Inventory 

Type Inventory (tons/day) 

Layers 0.26 

Broilers 7.35 

Total 7.61 

B-20 Final Staff Report with Appendices For 

 Revised Proposed Amendments to Rule 4570 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

V. EMISSION REDUCTIONS FROM PROPOSED RULE 

A. Reductions from Dairy CAFs 

Based on the estimated population, the EFs stated above and the controls proposed by 

the proposed rule, the District estimates that by 2012 and 2023 the overall emissions 

reduction from the proposed rule will be 25.09 tons/day and 31.62 tons/day, 

respectively, as shown in Tables 18 and 19, below: 

Table 18 - Dairy 2012 Emission Reductions

Type W/out proposed 

Rule (tons/day) 

With Proposed 

Rule 

(tons/day) 

Emission 

Reductions 

(tons/day) 

Cows 48.82 40.46 8.36 

Silage 

>500<1000 5.96 3.26 2.70 

Silage >1000 13.78 8.39 5.39 

TMR 33.33 24.68 8.64 

Total 105.82 80.73 25.09 

Table 19 - Dairy 2023 Emission Reductions

Type W/out proposed 

Rule (tons/day) 

With Proposed 

Rule 

(tons/day) 

Emission 

Reductions 

(tons/day) 

Cows 67.58 56.01 11.57 

Silage 

>500<1000 5.96 3.26 2.70 

Silage >1000 13.78 8.39 5.39 

TMR 46.13 34.17 11.96 

Total 137.38 105.76 31.62 

B. Reductions from Poultry CAFs 

As shown in the inventory section above, because the regulatory threshold for broiler 

CAFs and layer CAFs is being lowered, additional poultry CAFs will be subject to the 

control measures in the revised rule. The emission reductions are calculated in the 

following table: 

B-21 Final Staff Report with Appendices For 

 Revised Proposed Amendments to Rule 4570 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010 

B-22 Final Staff Report with Appendices For 

Table 20 - Poultry Emission Reductions

Type Additional 

birds 

Uncontrolled 

EF (lbs/hd-yr)

Controlled EF 

(lbs/hd-yr) 

Total Reductions 

(tons/day) 

Laying Chickens 1,050,000 0.025 0.0164 0.012 

Broiler Chickens 9,450,000 0.025 0.0148 0.132 

Total Emission Reductions 0.144 

Sample Calculation 

Total Reduction = (1,050,000 birds x (0.025 lbs/hd-yr-0.0164 lbs/hd-yr))/(2,000tons x 365 days/yr ) 

 = 0.012 tons/day 

C. CAFs with No Emission Reductions from Proposed Amendments 

There are certain CAFs that will not be affected by the revised proposed amendments 

to the rule. The main reason is that there are no facilities that would become newly 

subject to the rule. District staff has examined information about the number of animals 

at these CAFs and has determined that there are no existing facilities that are large 

enough to become subject to the rule. These categories are: 

• Beef Feedlots 

• Other Cattle 

• Swine 

• Sheep/Goats 

• Horses 

• Other CAFs not elsewhere listed. 

 Revised Proposed Amendments to Rule 4570